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

After a jury trial, Defendant was convicted of possession of a controlled substance with intent to distribute and possession of a firearm in furtherance of a drug trafficking offense. Defendant appealed, arguing that the evidence was insufficient to convict him of either crime. The First Circuit Court of Appeals affirmed Defendant’s conviction as to both counts, holding that, although another jury may have concluded otherwise, (1) the evidence plausibly supported the jury’s conclusion that Defendant possessed the marijuana with the requisite intent to distribute; and (2) a reasonable jury could have found that Defendant possessed the firearm “in furtherance of” a drug trafficking offense. View "United States v. Bobadilla-Pagan" on Justia Law

Plaintiff filed a charge of gender discrimination with the Equal Employment Opportunity Commission (EEOC) alleging that the Municipality of Carolina discriminated against her because of her gender by refusing to hire her as a firefighter. The EEOC concluded that Carolina had discriminated against Plaintiff in its hiring process. Carolina subsequently hired Plaintiff as a firefighter. Thereafter, Plaintiff sued the Municipality and Mayor of Carolina, asserting claims for sex discrimination and retaliation under Title VII of the Civil Rights Act of 1964, as well as pendent state law claims, based on Defendants’ pre- and post-hire conduct. The district court dismissed Plaintiff’s complaint for failure to state a claim. The First Circuit Court of Appeals reversed in part and dismissed in part, holding (1) Plaintiff waived her right to the review of her claims against the Mayor and her post-hire discrimination claims; and (2) the district court erred in dismissing Plaintiff’s pre-hire discrimination claims and post-hire retaliation claims against Carolina, as the claims asserted met the plausibility standard. View "Garayalde-Rijos v. Municipality of Carolina" on Justia Law

Plaintiffs filed a complaint against their bank and others, asserting a cause of action under the Racketeer Influenced and Corrupt Organizations Act (“RICO”), among other claims, asserting that Defendants engaged in an unlawful scheme to lend Plaintiffs money in violation of federal margin requirements limiting the extent to which securities can be used as collateral for funds loaned to purchase the securities. The district court (1) dismissed the complaint as to two defendants for failure of service, and (2) dismissed the remainder of the suit for failure to state a claim upon which relief could be granted, finding that the alleged misconduct was not actionable under RICO, which does not encompass private claims that would have been actionable as securities fraud. The First Circuit Court of Appeals affirmed, holding that the district court (1) correctly concluded that Plaintiffs failed to state a claim for relief under RICO; and (2) did not abuse its discretion in dismissing the complaint as to two defendants for failure of service. View "Calderon-Serra v. Banco Santander P.R." on Justia Law

After a jury trial, Defendant was convicted of one count of the crime of possession of a firearm by a felon. Defendant appealed the district court’s denial of his motion to suppress the evidence of a pistol found in his possession by state law enforcement authorities because it was obtained pursuant to an invalidated arrest warrant and in violation of his Miranda rights. The First Circuit Court of Appeals affirmed, holding that, pursuant to the good faith exception to the exclusionary rule articulated most recently in Herring v. United States, the evidence did not warrant exclusion because the officers acted in good faith and relied on a warrant that was facially valid at the time they detained Defendant. View "United States v. Echevarria-Rios" on Justia Law

Appellant acted as counsel in district court for a criminal defendant (“Defendant”) who pleaded guilty to several charges arising out of a carjacking. The day before a disposition hearing was scheduled to take place, Appellant moved for a continuance, stating that she could not attend the scheduled sentencing because it conflicted with the commencement of a trial in another criminal case. The district court denied the motion. The court subsequently fined Appellant a monetary sanction, stating that Appellant had not been “candid with the Court” because she entered her appearance in the second case subsequent to requesting the continuance of Defendant’s sentencing. Appellant sought a vacation of the monetary sanction, asserting that she had been a key participant in the second case for several months. The district court denied relief. The First Circuit Court of Appeals vacated the sanctions order and expunged the sanction, holding that the district court abused its discretion in sanctioning Appellant, as there was no appropriate basis for a finding that Appellant had not been candid with the court. View "In re Plaza-Martinez" on Justia Law

David Efron and his former wife, Madeleine Candelario-Del-Moral, were engaged in long-running litigation related to their high-stakes divorce. In 2006, a Puerto Rico court in which the divorce proceedings were pending issued an order attaching the funds held in Efron’s UBS Financial Services Inc. accounts. The court subsequently made a ruling that may or may not have vacated the attachment. UBS treated the attachment as void and dispersed the bulk of the funds. Candelario sued UBS in federal district court for negligently releasing the attached funds. Ultimately, at the district court’s suggestion, UBS and Candelario opted to undertake mediation. Thereafter, Efron moved to intervene as of right in the Candelario-UBS litigation. The district court denied the motion. The First Circuit Court of Appeals affirmed the denial of the motion and denied Candelario’s motion for appellate sanctions, holding (1) the Court had jurisdiction to hear and determine Efron’s interlocutory appeal; (2) the district court did not abuse its discretion in deeming Efron’s motion to intervene untimely and in refusing to grant it; and (3) although Efron’s case for intervention was weak, it was not frivolous. View "Candelario-Del-Moral v. Efron" on Justia Law

In 1999, Redondo Construction Corporation pled guilty to aiding and abetting the making of false statements during its work on a federal highway project. The Puerto Rico Highway and Transportation Authority (“PRHTA”) and the Puerto Rico Public Guildings Authority (“PBA”) subsequently revoked the bids it had awarded Redondo before the plea and suspended Redondo from bidding on new contracts. Redondo challenged both decisions, which resulted in settlement agreements with both agencies allowing Redondo to resume bidding for contracts. After Puerto Rico passed Law 458, which prohibited Puerto Rico agencies from awarding contracts corporations convicted of offenses involving public funds, the PBA cancelled several of Redondo’s bids and the contract it had executed with Redondo, and the PRHTA withdrew from its settlement with Redondo. Redondo sued PRHTA, PBA, and several officials at both agencies, alleging that Defendants were in breach of the settlement agreements, that this caused Redondo’s bankruptcy, and that Defendants were liable in damages. The district court granted the PRHTA’s and the individual defendants’ motions for summary judgment and sua sponte dismissed Redondo’s claims against the PBA. The First Circuit Court of Appeals (1) affirmed the entry of summary judgment as to the PRHTA and the individual defendants, as Redondo had no record of evidence of damages against these defendants; but (2) vacated the dismissal of the claim against the PBA, as the court did not meet the necessary conditions for entering judgment sua sponte. View "Redondo Constr. Corp. v. Izquierdo" on Justia Law

Appellant pled guilty to two counts of possession of a firearm and ammunition by a convicted felon. The district court sentenced Appellant to 180 months’ imprisonment, the mandatory minimum for an individual deemed an armed career criminal under the Armed Career Criminal Act (“ACCA”). On appeal, Appellant argued that the district court erred in concluding that one of his prior convictions - a 2006 conviction for assault and battery on a court officer - qualified as a “violent felony” as that term is defined in the ACCA’s residual clause. The First Circuit Court of Appeals affirmed Appellant’s sentence, holding (1) the ACCA is not void for vagueness; and (2) assault and battery on a court officer qualifies as a violent felony under the ACCA. View "United States v. Anderson" on Justia Law

In 2002, Grand Wireless, Inc. (“Grand”) and Verizon Wireless, Inc. (“Verizon”) entered into an agreement authorizing Grand to act as a Verizon sales agent. The agreement contained an arbitration provision. In 2011, Verizon notified Grand of its intent to terminate the relationship. According to Grand’s complaint, Verizon subsequently mailed a postcard to Grand’s customers proclaiming that certain Grand stores had “closed." Erin McCahill, a Verizon employee, had allegedly authorized the mailing knowing it to be false. Grand brought this action in Massachusetts state court against Verizon and McCahill, alleging a violation of RICO against McCahill and several state law claims against McCahill and Verizon. The case was removed to the federal district court, where Defendants moved for an order compelling arbitration of Grand’s claims. Grand opposed the motion, arguing that because McCahill was not a signatory to the contract containing the arbitration clause, the claim against her could not be arbitrated. The district court denied Defendants’ motions. The First Circuit Court of Appeals reversed, holding (1) Grand’s claims were within the scope of the parties’ arbitration agreement; and (2) arbitration of the claims against McCahill was not barred despite her status as a non-signatory of the arbitration agreement. View "Grand Wireless, Inc. v. Verizon Wireless, Inc." on Justia Law

Petitioner, a citizen of Argentina, and Respondent, a United States citizen from Puerto Rico, had a child together in 2008. The child (“LAD”) was a citizen of both the United States and Argentina. In 2011, the family traveled to the United States, first stopping in Florida and then moving on to Puerto Rico. It was there that Respondent announced that she and LAD would not be returning to Argentina. After Petitioner returned to Argentina, Respondent filed for legal custody of LAD in Puerto Rico state court. Petitioner subsequently filed the instant action with the federal district court in Puerto Rico, alleging that Respondent’s actions amounted to a wrongful retention of his son. The district court denied the petition. The First Circuit Court of Appeals reversed and remanded, holding (1) because Petitioner had custody rights over LAD and was exercising those rights at the time of the retention, Petitioner established wrongful retention by a preponderance of the evidence; and (2) Respondent did not introduce sufficient evidence to establish Petitioner’s consent or acquiescence to this retention. View "Darin v. Olivero-Huffman" on Justia Law