Patton v. Johnson, No. 18-1750 (1st Cir. 2019)Annotate this Case
The First Circuit affirmed the judgment of the district court determining that Appellant was barred from relitigating his argument that Plaintiffs should be compelled to arbitrate various tort claims, holding that the district court did not err in denying Appellant’s motion to compel arbitration.
At issue in this procedurally complicated case was whether Appellant’s association with a certain law firm required that Plaintiffs’ various tort claims, including their claims of legal malpractice, be submitted to arbitration. After adopting a magistrate judge’s report and recommendation and applying principles of collateral estoppel derived from Rhode Island law, the district court denied Appellant’s motion to compel. The First Circuit affirmed, holding that Appellant waived any claim of error regarding the magistrate judge’s analysis under Rhode Island collateral estoppel law.