Disaster Solutions LLC v. City of Santa Isabel, No. 20-1841 (1st Cir. 2021)
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The First Circuit affirmed the decision of the district court dismissing Plaintiff's breach of contract lawsuit against the City of Santa Isabel, a Puerto Rico municipality, holding that the district court did not abuse its discretion.
This case arose from services that Plaintiff provided to the City of Santa Isabel following Hurricane Maria. When the City failed to pay Plaintiff for its services, Plaintiff brought this breach of contract action seeking almost $368,880. The district court granted the City's motion to dismiss, concluding that Plaintiff failed to show that it met the requirements for forming an enforceable contract with a Puerto Rico municipality such as the City. The First Circuit affirmed, holding that the district court (1) correctly found that the documents Plaintiff filed did not constitute a written contract; and (2) did not err by denying Plaintiff's motion for reconsideration.
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