Justia U.S. 1st Circuit Court of Appeals Opinion Summaries

Pruco Life Insurance Company sought rescission of a life insurance policy, owned by the Paul E. L'Archevesque Special Revocable Trust on the life of Paul L'Archevesque, after it discovered that the policy application contained material misrepresentations about the health of Paul. Pruco tendered to Wilmington Trust Company, a co-trustee of the trust, a check in the amount of the policy premiums paid along with a letter stating Pruco was rescinding the policy. Wilmington cashed the check. Pruco subsequently filed a complaint seeking a rescission of the policy and a declaration that the policy was void ab initio. The district court granted summary judgment to Pruco, concluding that, under the circumstances, a mutual rescission had taken place as a matter of law. The First Circuit Court of Appeals affirmed, holding (1) the district court properly interpreted Rhode Island law regarding the standard for mutual rescission; (2) there were no genuine issues of material fact concerning whether Pruco made material misrepresentations in its rescission letter that could have prevented summary judgment; and (3) the district court did not err in finding that the issue of whether Pruco acted in bad faith was irrelevant to the rescission analysis. View "Pruco Life Ins. Co. v. Wilmington Trust Co." on Justia Law

Defendants in this case were a Puerto Rico legislator and a Commonwealth businessman who were charged with unlawfully exchanging favorable action on legislation for a trip to Las Vegas to attend a prize fight. After a jury trial, Defendants were convicted of, inter alia, federal program bribery in violation of 18 U.S.C. 666. Defendants appealed, contending, among other issues, that the district court erred in instructing the jury to find guilt on the section 666 counts based on a gratuity theory rather than a bribery theory. The First Circuit Court of appeals (1) vacated Defendants' section 666 convictions, holding that because section 666 does not criminalize gratuities in addition to bribes, the district court erred in its instructions; and (2) directed the district court to enter a judgment of acquittal on Defendants' conspiracy charges, holding that the Double Jeopardy Clause entitled both men to acquittal on their respective conspiracy charges. View "United States v. Bravo-Fernandez" on Justia Law

From 1999 to at least 2007, Defendant illegally downloaded and distributed copyrighted music without authorization. In 2007, a group of recording companies (collectively, "Sony") filed this action against Defendant under the Copyright Act, seeking damages and injunctive relief. Sony pursued claims for thirty copyrighted works, although Defendant allegedly distributed far more than that amount. After a trial, the jury awarded $675,000 in damages, which represented $22,500 for each of thirty songs whose copyright Defendant violated. Defendant appealed, arguing that the award was so large that it violated his constitutional due process rights. The First Circuit Court of Appeals affirmed, holding that the jury's award did not violate Defendant's right to due process. View "Sony BMG Music Entm't v. Tenenbaum" on Justia Law

After a jury trial, Appellant was convicted of seventeen counts of mail fraud, wire fraud, bank fraud, and aggravated identity theft. Appellant appealed, arguing (1) the trial court violated his Sixth Amendment right to confront the witnesses against him by admitting testimony of a forensic examiner about another examiner's prior examination; and (2) the evidence was insufficient to support his aggravated identity theft convictions. The First Circuit Court of Appeals upheld Appellant's convictions on all counts, holding (1) the evidence was sufficient to allow a reasonable jury to conclude beyond a reasonable doubt that Appellant was guilty of aggravated identity theft; and (2) the district court did not plainly err in admitting the testimony of the forensic examiner about the conclusions in another examiner's report, as the statements did not affect Appellant's substantial rights. View "United States v. Soto" on Justia Law

Petitioners, Lebanese citizens, were raised Muslim. While visiting the United States in 2005, Petitioners converted to Christianity. When they returned to the Ivory Coast, where they were living at the time, Petitioners received a number of threats, which they attributed to the Muslim population's reaction to their conversion to Christianity. Petitioners subsequently began living in the United States on expired visas, and the United States began removal proceedings against them. Petitioners filed challenged the proceedings, asserting that they had a well-founded fear of future persecution in Lebanon, based on their belief that Lebanon's majority Muslim population would carry out the threats made in the Ivory Coast. The immigration judge (IJ) rejected petitioners' claims, and the Board of Immigration Appeals (BIA) affirmed. The First Circuit Court of Appeals affirmed, holding (1) substantial evidence supported the BIA's finding that Petitioners failed to prove they had a well-founded fear of future persecution in Lebanon in order to qualify for asylum; (2) the BIA did not err in rejecting Plaintiffs' claim for withholding of removal; and (3) the Convention Against Torture did not require the BIA to forestall Petitioners' return to Lebanon. View "Darwich v. Holder" on Justia Law

Plaintiff was a Jordanian national who entered the United States illegally. Once Plaintiff was placed in removal proceedings, he married his first cousin, a marriage that lasted one year. Plaintiff subsequently married his second wife. Both marriages were to United States citizens. Plaintiff's second wife filed an I-130 petition on Plaintiff's behalf. The United States Citizenship and Immigration Services (USCIS) denied the petition, concluding that Plaintiff previously entered into his first marriage for the purpose of evading the immigration laws. The Board of Immigration Appeals (BIA) affirmed. Plaintiff and his wife filed an amended complaint in the district court seeking to set aside the BIA's decision. The district court dismissed the action for failure to state a claim. The First Circuit Court of Appeals vacated the judgment of the district court without reaching the merits of the appeal, holding (1) the district court erred in invoking the plausibility standard in deciding that this case did not warrant either discovery or trial, as the plausibility standard does not apply to a complaint for judicial review of a final agency action; and (2) the methodologic error was not harmless where the parties failed to file the administrative record with the court. View "Atieh v. Riordan" on Justia Law

Plaintiff filed a second amended complaint against polystyrene food service packaging manufacturers and two trade associations, claiming that Defendants refused in concert to deal with Plaintiff in a recycling business method for polystyrene food service products. In its complaint, Plaintiff alleged violations of section 1 of the Sherman Act and the Massachusetts Fair Business Practices Act (Mass. Gen. Laws ch. 93A). The district court granted Defendants' motions to dismiss and entered judgment in their favor, finding that, as in Bell Atlantic Corp. v. Twombly, there were legitimate business reasons that could explain Defendants' refusal to deal with Plaintiff or to compete with each other for market share. The First Circuit Court of Appeals vacated and remanded, holding (1) Plaintiff alleged sufficient facts to adequately plead its Sherman Act claim; and (2) because the district court summarily dismissed Plaintiff's chapter 93 claim because it failed for the same reasons that its Sherman Act claim failed, the issue needed to be reconsidered. View "Evergreen Partnering Group, Inc. v. Pactiv Corp." on Justia Law

Defendants, Baldwin and Gladys Ihenacho, were the owners and operators of a neighborhood pharmacy. Defendants were convicted of dispensing and shipping drugs to customers pursuant to invalid online prescriptions for Internet pharmacy operations headquartered in the Dominican Republic. Baldwin pled guilty to almost all of the charges. Gladys went to trial, and a jury convicted of her eight counts. The First Circuit Court of Appeals affirmed Baldwin's sentence and Gladys's convictions, holding (1) the district court did not err in applying the fraud sentencing guideline to Baldwin and in calculating the loss caused by Baldwin's offenses for purposes of the fraud guideline; and (2) the evidence was sufficient to support Gladys's convictions for distributing controlled substances, conspiracy, and money laundering. View "United States v. Ihenacho" on Justia Law

While fleeing from the United States Coast Guard, Claimant and his crew tossed more than $8 million into the Caribbean Sea. The Coast Guard subsequently recovered the currency. The government filed this action seeking to have the $8 million, along with additional money found on the crew members' persons, forfeited to the United States. Claimant, who was convicted of knowingly failing to obey a federal law enforcement officer's order to slow down or stop, filed a claim of ownership for the currency. The district court granted summary judgment for the government, holding that Claimant had not shown a colorable interest in the seized currency, and therefore, Claimant failed to establish standing to challenge the forfeiture. The First Circuit Court of Appeals affirmed in part and reversed in part, holding (1) the district court had jurisdiction over a portion of the currency; (2) Claimant did not have constitutional standing the contest the forfeiture of the $8 million; but (3) Claimant did have standing to contest the forfeiture of the $10,000 found on his person. View "United States v. Duyzing" on Justia Law

Plaintiff, a female, brought federal and state claims alleging gender discrimination against the Town of Dennis, Massachusetts, the Town golf course, and several individuals after the golf course refused to let Plaintiff participate in a men's golf tournament. The district court granted summary judgment for Plaintiff and held a trial on damages. The court ruled (1) awarded Plaintiff $34,600 in attorney's fees and costs, (2) rejected Plaintiff's request that the jury be instructed on punitive damages, (3) denied Plaintiff's request for an injunction ordering Defendants to adopt a policy barring gender-based discrimination. Both parties appealed, challenging the nature and extent of Plaintiff's remedy. The First Circuit Court of Appeals (1) affirmed the district court's treatment of punitive damages; (2) vacated the denial of injunctive relief where the district court failed to explain its decision to grant or refuse such relief; and (3) vacated the award of attorney's fees, holding that the district court erred in reducing Plaintiff's requested award based on, inter alia, Plaintiff's rejection of a settlement offer. View "Joyce v. Town of Dennis" on Justia Law