U.S. Court of Appeals for the First Circuit
Galakatos v. Marsh & McLennan Companies, Inc.
August 21, 2026
Summary
The court affirmed dismissal of Galakatos's claims against Marsh for breach of contract, negligence, and breach of fiduciary duty. The complaint did not identify a definite contractual promise, an intelligible request for the insurance coverage allegedly missing, or facts establishing the special circumstances necessary for an expanded fiduciary relationship. The court also affirmed denial without prejudice of Galakatos's motion to strike because the challenged materials did not affect the dismissal.