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

A package was shipped from a FedEx location in Eureka, California to an address in Plymouth, Massachusetts. The printed address label inadvertently showed an incorrect address, that address being Plaintiff’s address. When the package was delivered, Plaintiff and her eleven-year-old daughter opened the package to find two bags of marijuana. Plaintiff alerted the police. That same day, a man came to Plaintiff’s door asking whether Plaintiff had received a package. As a result of these events, Plaintiff and her minor daughters suffered fear and anxiety. Plaintiff, on her own behalf and on behalf of her minor children, sued FedEx, alleging invasion of privacy, infliction of emotional distress, and negligence. Specifically, Plaintiff claimed that FedEx mislabeled and misdelivered the package and that FedEx disclosed Plaintiff’s address to third parties. The case was removed to federal district court. The court granted summary judgment for FedEx, concluding that Plaintiff’s claims were preempted by the Airline Deregulation Act (ADA). The First Circuit affirmed, holding that Plaintiff’s three common-law claims were barred by the preemption provision of the ADA. View "Tobin v. Fedex Corp." on Justia Law

When Appellant, a resident of the Pondview Condominiums, did not pay his condominium fees on time, the condominium trustees hired law firm Marcus, Errico, Emmer and Brooks, P.C. (“MEEB”) to collect Appellant’s debt. MEEB filed nine collection actions in Massachusetts state court against Appellant and prevailed in two of them. Displeased with MEEB’s collection activities, Appellant sued MEEB in federal district court, alleging violations of federal and state law. The magistrate judge concluded that MEEB committed numerous violations of the Fair Debt Collection Practices Act (FDCPA) and that the FDCPA violations constituted “per se” violations of Mass. Gen. Laws ch. 93A. Upon reconsideration, the magistrate judge reversed in part, finding MEEB not liable under Chapter 93A. The First Circuit reversed the magistrate judge’s determination that MEEB was not liable under Chapter 93A, holding that MEEB’s violations of the FDCPA constituted per se Chapter 93A violations by virtue of the unambiguous statutory language in the FDCPA and the Federal Trade Commission Act. View "McDermott v. Marcus, Errico, Emmer & Brooks" on Justia Law

Defendant, a Colombian national, was convicted of participating in a conspiracy to import cocaine to the United States. Prior to trial, Defendant moved to suppress an identification that he argued had been obtained by a highly suggestive means. The district court denied the motion, finding that the means used to obtain the identification was unduly suggestive but that the identification was still reliable enough to put to the jury. Defendant appealed, arguing, among other things, that the government’s use of the identification at trial violated his constitutional right to due process. The First Circuit affirmed, holding (1) the district court did not err in finding that the method of obtaining the identification was problematic but that there was reason enough to credit the identification to permit a jury to decide its worth; and (2) Defendant’s remaining allegations of error were without merit. View "United States v. Castro-Caicedo" on Justia Law

Defendant, a coconspirator in a 2010 murder in Rhode Island, pleaded guilty to conspiracy to commit robbery affecting commerce, robbery affecting commerce, and possessing and discharging a gun in relation to a crime of violence with death resulting. Defendant sought to vacate his plea on grounds that, at the change-of-plea hearing, the district court omitted sufficient notice of the possible sentence accompanying the third charge. The government agreed that the omission was a violation of Fed. R. Crim. P. 11(b)(1)(I). The First Circuit affirmed, holding that Defendant’s substantial rights were not affected by this error. View "United States v. Santiago" on Justia Law

In 2011, a tornado ripped through the downtown area of the City of Springfield, Massachusetts and caused significant damage. City officials quickly determined that the South Commons Condominiums were among the properties that suffered substantial damage. The City hired a private company to demolish most of those buildings the next evening. The owners of the condos brought suit against the City, its officials, and the demolition company that took down the buildings, claiming violations of the owners’ procedural and substantive due process rights under 42 U.S.C. 1983, as well as various violations of Massachusetts state law. The district court dismissed the federal claims for failure to state a claim and dismissed the state claims without prejudice as an exercise of its discretion to deal with pendent claims. The Supreme Court affirmed, holding that when a city decides buildings are so damaged that they must be immediately demolished, and when the city does so pursuant to a state law that authorizes the use of summary procedure to respond to such an emergency, the remedy for any wrong, absent behavior that objectively “shocks the conscience,” must come from the remedies the state itself supplies rather than from a federal suit premised on the U.S. Constitution’s due process clause. View "South Commons Condo. Ass’n v. Charlie Arment Trucking, Inc." on Justia Law

Under current Transportation Security Administration (TSA) security protocols, some passengers cannot pass through some security checkpoints in U.S. airports without submitting to a standard pat-down, which includes security officials touching areas around the groin and breasts to look for concealed metallic and nonmetallic weapons. Plaintiff, whose job requires her to fly frequently, has had at least one metallic joint replacement and is often subject to the standard pat-down. After Plaintiff petitioned the TSA to change its protocols, without success, Plaintiff filed this action challenging the TSA’s security procedures, claiming that the standard pat-downs constitute an unreasonable search under the Fourth Amendment and violate federal disability discrimination law. The First Circuit denied Plaintiff’s petition asking that the Court set aside the decision of the TSA, holding (1) the TSA’s screening procedures do not violate the Fourth Amendment; and (2) the TSA’s refusal to implement the changes suggested by Plaintiff did not violate the Rehabilitation Act of 1973. View "Ruskai v. Pistole" on Justia Law

After T G Plastics Trading Co., Inc. (“National Plastics”) allegedly fell behind on payments owed to Toray Plastics (America), Inc., Toray filed suit. The parties settled the lawsuit, and the terms of the settlement were memorialized in a Settlement Agreement. The Settlement Agreement provided that Toray would sell certain materials exclusively through National Plastics and pay National Plastics a twelve percent commission on all sales generated by National Plastics. When the parties began to dispute several aspects of the application of the Settlement Agreement, National Plastics sued Toray. The original complaint did not contain a jury demand. After two years of settlement negotiations, National Plastics amended its complaint to request a jury trial. A jury found Toray liable for breach of the Settlement Agreement and awarded National Plastics more than $2 million in damages. The First Circuit affirmed, holding (1) the district court did not err in allowing National Plastics to amend its complaint to add a jury demand, as National Plastics did not waive its right to a jury trial by a belated demand; and (2) the evidence was sufficient to support the jury’s finding of liability and its calculation of damages. View "T G Plastics Trading Co., Inc. v. Toray Plastics (America), Inc." on Justia Law

After a jury trial, Appellant was found guilty of conspiracy to distribute five kilograms or more of cocaine. Appellant was sentenced to 144 months’ imprisonment, a sentence below that suggested by the United States Sentencing Guidelines. The First Circuit affirmed, holding (1) the jury instructions, assessed in their totality, were not in error and correctly guided the jury in its determination; (2) the jury necessarily made an individualized drug-weight determination, and therefore, the district court did not err in its sentencing decision; and (3) the district court did not abuse its discretion by refusing to grant Appellant a two-level reduction for acceptance of responsibility. View "United States v. Melendez" on Justia Law

Rosana Claudio-de Leon (Claudio) and the University of the East of the Ana G. Mendez University System (SUAGM) entered into an employment contract that contained a forum selection clause precluding adjudication in federal court. Claudio, Luis F. Carrasquillo-Rivera, and the conjugal partnership Carrasquillo-Claudio (collectively, Appellants) filed suit against SUAGM in the district court, alleging, among other claims, pregnancy and gender discrimination. The district court dismissed Appellants’ Title VII pregnancy and gender discrimination claim and supplemental state law claims due to the forum selection clause. The First Circuit affirmed as modified, holding (1) the forum selection clause was applicable and enforceable; but (2) the district court should have dismissed the case without prejudice to permit Appellants to refile in the appropriate forum. Remanded. View "Claudio de-Leon v. Ayala" on Justia Law

Pamela Manning, who suffers from type I diabetes, resigned from her employment at Kohl’s Department Stores, Inc. after Kohl’s refused to grant her request for a steady work schedule. The Equal Employment Opportunity Commission brought this suit on Manning’s behalf, alleging that Kohl’s refused to provide Manning with reasonable accommodations in violation of the Americans with Disabilities Act (ADA) and constructive discharge. The district court entered summary judgment for Kohl’s. The First Circuit affirmed, holding that because Kohl’s made multiple offers to Manning after her resignation to discuss alternative reasonable accommodations, Manning had neither a claim for ADA discrimination nor a claim for constructive discharge. View "Equal Employment Opportunity Comm’n v. Kohl's Dep’t Stores, Inc." on Justia Law