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

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In 2010, Ángel M. Ayala-Vázquez was indicted and convicted on multiple drug-related charges, including conspiring to possess with intent to distribute and aiding and abetting the possession of with intent to distribute over 280 grams of cocaine base. He was sentenced in 2011 to life imprisonment. In 2021, Ayala filed a motion to reduce his sentence under the First Step Act and for compassionate release due to his hypertension and obesity making him vulnerable to COVID-19.The District Court denied Ayala's motion, concluding that he was ineligible for a sentence reduction under the First Step Act because his sentences were imposed "in accordance with" the amendments made by the Fair Sentencing Act. The court also rejected his request for compassionate release, finding that Ayala failed to demonstrate extraordinary and compelling reasons to warrant such relief. Moreover, the court determined that Ayala posed a danger to other persons and the community.On appeal to the United States Court of Appeals for the First Circuit, the court affirmed the District Court's decision. It concluded that Ayala was indeed convicted of offenses involving 280 grams or more of cocaine base, and his life sentences were in accordance with the Fair Sentencing Act. Therefore, he was not eligible for a sentence reduction under the First Step Act. As for the compassionate release, the court found no abuse of discretion in the District Court's evaluation of Ayala's health conditions and perceived danger to the community. View "United States v. Ayala-Vazquez" on Justia Law

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The case involves Joseph A. Jakuttis, a former officer and detective in the Dracut Police Department, who also served as a Task Force Officer for the federal Drug Enforcement Administration's Cross Borders Initiative. Jakuttis brought multiple federal and state claims against the Town of Dracut, certain Dracut police officers, and members of the federal law-enforcement task force. He alleged that he was demoted and faced retaliation after reporting serious criminal activities implicating two Dracut police officers, which he learned from a confidential drug informant.The United States Court of Appeals for the First Circuit affirmed the dismissal of Jakuttis's Bivens claims against Michael V. O'Hanlon and Richard P. Poirier, Jr., and his §1983 claim against the Town of Dracut, David J. Chartrand Jr., and Demetri Mellonakos. The court ruled that the defendants are entitled to qualified immunity, as they could have reasonably thought that Jakuttis was speaking as part of his official duties rather than as a private citizen when he reported the misconduct, thus not clearly violating his First Amendment rights.The court also affirmed the dismissal of Jakuttis's state-law tort claims against Poirier, as Poirier was deemed to be acting within the scope of his federal employment during the relevant times. However, the court remanded the Massachusetts Whistleblower Act claim against the Town of Dracut and the Intentional Interference with Advantageous Economic Relationship claim against Chartrand and Mellonakos to the District Court. The court reasoned that these state-law claims should be resolved by a state court due to reasons of comity. View "Jakuttis v. Town of Dracut" on Justia Law

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In this case, the United States Court of Appeals for the First Circuit examined an appeal against a district court's refusal to issue a preliminary injunction against the enforcement of a Rhode Island law banning certain large-capacity ammunition magazines. The plaintiffs, a group of gun owners and a registered firearms dealer, argued that the law infringed upon their Second Amendment rights, as well as their rights under the Fifth and Fourteenth Amendments.The Court of Appeals, however, upheld the district court's decision. It noted that the law did not impose a significant burden on the right of armed self-defense, as it did not prevent gun owners from owning other forms of weaponry or ammunition, and the banned magazines were rarely used in self-defense situations. Furthermore, the court found that the law was consistent with a longstanding tradition of regulating firearms in the interest of public safety.The court also rejected the plaintiffs' arguments that the law was retroactive and vague, violating their Fourteenth Amendment rights. It concluded that the law was not retroactive as it did not impose new liability on past actions, and it was not unconstitutionally vague as individuals of ordinary intelligence could understand what it prohibited. The court also found that the plaintiffs were unlikely to succeed on their Fifth Amendment claims, as the law did not effect a physical or regulatory taking of their property. View "Ocean State Tactical, LLC v. Rhode Island" on Justia Law

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In 1990, Mac Hudson and Charles Hughes were tried for charges relating to a shooting incident which resulted in the death of one person and injury of another. After being convicted, their verdict was reversed by the Massachusetts Appeals Court for unrelated reasons and a retrial was ordered.During the second trial in 1997, issues arose regarding the jury selection process and the admission of certain witness testimonies. The judge reduced the number of jurors from sixteen to fifteen, which Hudson claimed prejudiced his use of peremptory challenges. Furthermore, key witness Kimbrough, who recanted his testimony from the first trial, was deemed unavailable to testify. His previous testimony was, however, read into the record. Hudson argued that his right to due process was violated by these actions. Despite these objections, Hudson was again convicted and sentenced to life imprisonment for second-degree murder, among other charges.Following unsuccessful appeals in state court, Hudson petitioned for a writ of habeas corpus in federal court, arguing that his right to due process was violated during his trial. The United States Court of Appeals for the First Circuit affirmed the District Court's denial of Hudson's petition. The court found that the Massachusetts Appeals Court's rulings on Hudson's claims were not contrary to, nor involved an unreasonable application of, clearly established Federal law as determined by the Supreme Court of the United States. View "Hudson v. Kelly" on Justia Law

Posted in: Criminal Law
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This case involves an appeal from plaintiffs Sara Halsey and Susan Kiralis-Vernon against Fedcap Rehabilitation Services, Inc. The plaintiffs were participants in a state program, Additional Support for People in Retraining and Employment - Temporary Assistance for Needy Families (ASPIRE-TANF), for which Fedcap was a contract agency. The plaintiffs allege that Fedcap failed to correctly administer the program and fulfill its obligations, including informing them of available services and support, processing their requests for benefits, and engaging in an interactive process to evaluate their requests for reasonable accommodations. Kiralis-Vernon also alleges that a Fedcap employee verbally assaulted her due, in part, to her race.The U.S. District Court for the District of Maine dismissed the case, reasoning that the plaintiffs were required to first pursue an administrative remedy before the Department of Health and Human Services as required by Maine law. On appeal, the United States Court of Appeals for the First Circuit affirmed the dismissal of the claims related to Fedcap’s administration of the ASPIRE-TANF program, agreeing that under Maine law, the plaintiffs had to first seek administrative review before bringing these claims to court.However, the appellate court vacated the dismissal of Kiralis-Vernon's claim of racial discrimination, ruling that this claim did not fall within the same jurisdiction and expertise of the Department, and thus, was not subject to the same requirement for administrative review. The case was remanded for further proceedings on this claim. View "Halsey v. Fedcap Rehabilitation Services, Inc." on Justia Law

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Sara Esteban-Garcia, a native and citizen of Guatemala and an indigenous woman of Mam descent, petitioned for review of a decision by the Board of Immigration Appeals (BIA) which affirmed an immigration judge's order denying her application for asylum and claim for withholding of removal under sections 208 and 241(b)(3)(A) of the Immigration and Nationality Act. Esteban-Garcia had fled Guatemala after a man she had been romantically involved with, along with his friends, demanded she become a prostitute or sell drugs to earn money for them. The immigration judge and the BIA found that Esteban-Garcia had failed to establish a nexus between the harm she experienced and a statutorily protected ground. On appeal, the United States Court of Appeals for the First Circuit held that the record did not compel a contrary conclusion. It noted that the petitioner consistently stated the reason why her alleged persecutors wanted her to become a prostitute and drug seller was so that they could benefit financially, which is not a protected ground. Therefore, the court denied the petition for review. View "Esteban-Garcia v. Garland" on Justia Law

Posted in: Immigration Law
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The case involved a dispute between two Brazilian nationals, Heitor Ferreira da Costa and Jessica Camila Albefaro de Lima, who were previously married and had a child together. Following their divorce in Brazil, de Lima moved with the child to the United States without da Costa's knowledge. Once da Costa discovered his ex-wife and child's location, he filed a petition under the Hague Convention on the Civil Aspects of International Child Abduction (the Convention) to have the child returned to Brazil. The United States District Court for the District of Massachusetts denied da Costa's petition, concluding that the child was now settled in his new environment and it would not exercise its discretion to order the child's return. The United States Court of Appeals for the First Circuit affirmed the decision, agreeing with the lower court's conclusion based on the totality of the circumstances, including the child's age, stability and duration of residence in the new environment, relationships with family members in the United States, and his progress in learning English. The appellate court noted that returning the child to Brazil would be disruptive given the child's strong connections in the United States and his limited connections to Brazil. View "Ferreira da Costa v. Albefaro de Lima" on Justia Law

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In this case, the plaintiffs, Susan Johnson and Jocelyne Welch, brought an action against the City of Biddeford, Chief of Police Roger P. Beapure, and Officer Edward Dexter of the Biddeford Police Department, alleging a violation of substantive due process rights under the state-created danger test. Johnson and Welch's action stems from a violent incident involving their landlord, James Pak. Pak became agitated about the number of cars parked in the driveway of the property he rented to Johnson and her son, Thompson. During a confrontation, Pak made gun-shaped hand gestures and said "bang." Thompson called the police and Officer Dexter responded.Officer Dexter spoke with both parties separately. During his conversation with Pak, Pak expressed his anger and frustration, making various threatening remarks. Despite these threats, Officer Dexter did not arrest, detain, or initiate a mental health intervention for Pak. After speaking with Pak, Officer Dexter returned to Johnson and Thompson's apartment, informing them that Pak was "obviously extremely upset" but did not relay the specific threats made by Pak. A few minutes after Officer Dexter left, Pak entered Johnson and Thompson's apartment and shot Johnson, Thompson, and Welch.On appeal, the United States Court of Appeals for the First Circuit held that Officer Dexter was entitled to qualified immunity against the plaintiffs' claim of violation of substantive due process rights under the enhancement-of-danger prong of the state-created danger test. The court found that a reasonable officer in Dexter's position would not have understood, based on the facts of the case, that he was violating any such rights by his actions and inactions. View "Johnson v. City of Biddeford" on Justia Law

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This case revolves around the dismissal of a case due to the plaintiff's counsel's unexcused absence from the final pretrial conference. The United States Court of Appeals for the First Circuit raised the question of whether a district court may dismiss a case for such a reason, especially when it's the first and only instance of non-compliance and the court did not consider a lesser sanction. In this case, the plaintiff had filed a complaint alleging RICO violations and related state-law claims. However, the plaintiff's counsel failed to appear at the final pretrial conference, leading to the dismissal of the case by the district court.Upon review, the Court of Appeals held that while a district court has inherent power to manage its docket and may dismiss a case sua sponte for reasons prescribed in Rule 41(b), such dismissal should only occur when a plaintiff's misconduct has been extreme or contumacious. The dismissal should not be viewed as a sanction of first resort or an automatic penalty for every failure to abide by a court order. Thus, the Court of Appeals found that the district court had erred in dismissing the case without first considering a lesser sanction or warning the disruptive party. The court vacated the district court's dismissal order and remanded the case for further proceedings. View "Vivaldi Servicios de Seguridad, Inc. v. Maiso Group, Corp." on Justia Law

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A group of individuals filed a lawsuit against Genzyme Corporation, a drug manufacturer, for injuries allegedly caused by the company's mishandling of a prescription drug shortage between 2009 and 2012. The lawsuit was filed several years after the events in question occurred and would typically have been considered too late under the applicable statutory limitations periods. However, the plaintiffs argued that previous class actions, a savings statute, and a tolling agreement between the parties allowed the lawsuit to proceed. The district court partially agreed and rejected Genzyme's argument that the delay in filing required dismissal of the lawsuit. However, it dismissed the claims of all but four plaintiffs for lack of standing, and dismissed the remaining claims on the merits.On appeal, the United States Court of Appeals for the First Circuit found that all plaintiffs have standing and the court has jurisdiction to proceed with the case, at least with respect to the plaintiffs' individual claims. However, it concluded that four plaintiffs waited too long before filing this lawsuit, and their claims are time-barred. For the remaining plaintiffs, the court vacated the judgment dismissing their claims and remanded the case to the district court for further proceedings. View "Wilkins v. Genzyme Corporation" on Justia Law