Dec 11 2025
1st Cir. Nos. 24-1532, 24-1614, 24-1734 Panel Decision

Orkin v. Albert

The First Circuit vacated a district court judgment that had found siblings liable for defamation and conversion in a dispute over a family business operated without formal corporate structure. The appellate court held that the lower court erred by failing to recognize an implied contract for compensation and by issuing an injunction that exceeded its authority to resolve ownership disputes.

Dec 11 2025
1st Cir. 24-1734 Panel Decision

Orkin v. Albert

The First Circuit vacated and remanded a district court judgment that failed to recognize an implied contract entitling a sibling to compensation for his decade-long management of a family business. The court also reversed a finding that the sibling's email accusing him of fraud was not defamatory, holding that the statement unambiguously imputed criminal conduct.