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

The defendant formed a company in 2005 that solicited funds from clients through financial agreements promising fixed returns, with the stated purpose of developing various businesses. Clients entered into these agreements, called "Productive Development Contracts," by making monetary contributions in exchange for promised earnings. The company failed to fulfill its obligations, and the government alleged that the defendant operated a Ponzi scheme, using funds from later clients to pay earlier ones, without generating legitimate profits. The indictment listed specific transactions involving eight clients, and at trial, both these and additional clients testified about their experiences and losses.The case was tried in the United States District Court for the District of Puerto Rico. The government presented evidence including client testimony, bank records, and summary exhibits prepared by a forensic accountant. The defendant objected to the admission of certain summary exhibits under Federal Rule of Evidence 1006, arguing they contained hearsay and improper conclusions. The district court overruled these objections, and the jury convicted the defendant on all counts. At sentencing, the court calculated loss and restitution amounts based on both testifying and non-testifying victims, resulting in a sentence of 135 months’ imprisonment and a restitution order exceeding $2.1 million. The defendant appealed, challenging the evidentiary rulings, sufficiency of the evidence, sentencing calculations, and restitution order.The United States Court of Appeals for the First Circuit affirmed the securities fraud conviction, sentence, and restitution order, but vacated the bank fraud convictions at the government’s request. The court held that any error in admitting the summary exhibits was harmless given the overwhelming unchallenged evidence. It found sufficient evidence supported the jury’s finding that the contracts were securities under the law. The court also upheld the district court’s loss and restitution calculations, concluding they were supported by reliable evidence and not plainly erroneous. View "United States v. Maldonado-Vargas" on Justia Law

In 2018, the plaintiff contacted police to help resolve a dispute at her home involving her adult children. After officers arrived and de-escalated the situation, a third officer arrived, and a disagreement between the plaintiff and this officer led to her arrest. She was charged with resisting arrest, disorderly conduct, and assault and battery on a police officer. Rather than pleading guilty or going to trial, the plaintiff entered into an agreement under Massachusetts law for three months of pretrial probation, with the understanding that the charges would be dismissed upon successful completion. She did not admit to any wrongdoing or facts, and after completing probation, the charges were dismissed.The plaintiff later filed a lawsuit in state court against the City of Springfield and several police officers, alleging civil rights violations under 42 U.S.C. § 1983, including excessive force during her arrest. The defendants removed the case to the United States District Court for the District of Massachusetts and moved for summary judgment, arguing that the plaintiff’s claims were barred by the doctrine established in Heck v. Humphrey, which prevents § 1983 claims that would impugn a valid criminal judgment. The district court denied summary judgment on this ground for two officers, holding that the Heck bar did not apply because the plaintiff was not convicted.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s decision. The court held that the Heck bar does not apply when there is no underlying criminal conviction or sentence. Because the plaintiff’s charges were dismissed after pretrial probation without any admission of guilt or factual findings, her § 1983 claims could proceed. The case was remanded for further proceedings. View "Aprileo v. Clapprood" on Justia Law

During a government shutdown that began on October 1, 2025, the United States Department of Agriculture (USDA) announced it would not provide November Supplemental Nutrition Assistance Program (SNAP) benefits, affecting millions of Americans who rely on these funds for food. Despite having approximately $6 billion in contingency funds appropriated by Congress for emergencies, USDA stated it would not use these funds, arguing they were unavailable once regular appropriations lapsed. Plaintiffs, including nonprofits, local governments, a union, and a food retailer, filed suit, alleging that USDA’s suspension of benefits was arbitrary, capricious, and contrary to law under the Administrative Procedure Act (APA).The United States District Court for the District of Rhode Island granted a temporary restraining order (TRO) requiring USDA to provide either full or partial November SNAP payments by specified dates. The government chose to provide partial payments but failed to do so in a timely manner, as many recipients would not receive benefits by the court’s deadline. The district court found the government had not complied with its order, both by failing to resolve administrative burdens and by not ensuring timely disbursement. As a result, the court ordered USDA to make full November SNAP payments, including by using funds from the Section 32 fund in combination with contingency funds. The government appealed and sought a stay of the district court’s order.The United States Court of Appeals for the First Circuit reviewed the government’s request for a stay pending appeal. The court held that the government had not met its burden to justify a stay, finding it had failed to show a likelihood of success on the merits or that irreparable harm would result from compliance. The court emphasized the immediate and substantial harm to SNAP recipients if benefits were withheld and denied the government’s motion for a stay. View "Rhode Island State Council of Churches v. Rollins" on Justia Law

Gerardo Martinez was convicted of first-degree murder in Rhode Island for the 2005 killing of Lindsay Ann Burke, with evidence at trial showing a troubled relationship and a violent altercation that ended in Lindsay’s death by stabbing. Martinez’s defense attorney, Mark Smith, obtained a PTSD diagnosis from a forensic psychiatrist but chose not to present this expert testimony at trial. Instead, Smith argued that Martinez lacked premeditation and should be convicted of second-degree murder. The jury found Martinez guilty of first-degree murder, and he was sentenced to life without parole. On direct appeal, the Rhode Island Supreme Court affirmed the conviction and sentence.Martinez then sought post-conviction relief in the Rhode Island Superior Court, claiming ineffective assistance of counsel for Smith’s decision not to present the PTSD-based diminished capacity defense at trial. After a three-day evidentiary hearing, the Superior Court found that Smith’s choices were strategic and not constitutionally deficient, and therefore did not address the issue of prejudice. The Rhode Island Supreme Court denied Martinez’s petition for writ of certiorari. Martinez subsequently filed a federal habeas petition in the United States District Court for the District of Rhode Island, which was dismissed, but a certificate of appealability was granted.The United States Court of Appeals for the First Circuit reviewed whether the Rhode Island court’s denial of post-conviction relief was an “unreasonable application” of Strickland v. Washington under 28 U.S.C. § 2254(d). The First Circuit held that the state court’s decision was reasonable, emphasizing the strategic nature of Smith’s choices and the deference required under federal habeas review. The court affirmed the district court’s dismissal of Martinez’s habeas petition, finding no constitutional deficiency in counsel’s performance. View "Martinez v. Salisbury" on Justia Law

Rebecca Blakesley, a nurse, ended her marriage with Andrew Blakesley in early 2021 after a tumultuous relationship marked by alleged abuse. Shortly after she obtained a protective order and filed for divorce, Andrew’s mother, Colleen Marcus, and his sister-in-law, Jennifer Marcus, reported Rebecca to various public and private organizations. They accused her of violating patient confidentiality, fraudulent billing, academic dishonesty, and faking a COVID test. These reports led to investigations, the loss of Rebecca’s employment, and the suspension of her application for a professional license.Rebecca filed a lawsuit in the United States District Court for the District of Massachusetts, alleging defamation and intentional interference with business relations. She claimed the Marcuses’ actions were motivated by retaliation for her divorce. The Marcuses responded with a special motion to dismiss under the Massachusetts anti-SLAPP statute, which is designed to protect individuals from lawsuits intended to chill their right to petition the government. The district court denied the motion, finding that Rebecca’s claims were not based solely on petitioning activity because the Marcuses’ reports to private employers and a nursing school did not qualify as protected petitioning under the statute.On appeal, the United States Court of Appeals for the First Circuit reviewed whether the anti-SLAPP statute applied. The court held that the Marcuses failed to show their conduct was solely petitioning activity, as required by the Massachusetts Supreme Judicial Court’s recent clarification in Bristol Asphalt, Co. v. Rochester Bituminous Prods., Inc. The First Circuit affirmed the district court’s denial of the anti-SLAPP motion, holding that mixed claims involving both petitioning and non-petitioning conduct are not subject to dismissal under the statute, and remanded the case for further proceedings. View "Blakesley v. Marcus" on Justia Law

The case concerns multiple petitions for review challenging a Federal Communications Commission (FCC) order that established new rate caps for communications services provided to incarcerated individuals. The FCC’s order, issued pursuant to the Martha Wright-Reed Just and Reasonable Communications Act of 2022, also dismissed as moot certain petitions for clarification and waiver filed by Securus Technologies, LLC, a provider of these services. After the FCC published portions of the order in the Federal Register, several parties—including service providers, advocacy organizations, and state governments—filed petitions for review in various federal appellate courts, contesting different aspects of the order.Following the filing of these petitions, the FCC notified the United States Judicial Panel on Multidistrict Litigation (JPML) under 28 U.S.C. § 2112(a)(3), which randomly selected the United States Court of Appeals for the First Circuit to hear the consolidated petitions. The administrative record was filed in the First Circuit, and subsequent petitions filed in other circuits were transferred there pursuant to statute. Some petitioners, notably Securus and Pay Tel Communications, Inc., argued that the petitions should be transferred to the Fifth Circuit, asserting that it was the proper venue based on the timing and nature of the initial filings. The First Circuit denied these transfer motions, and a request for mandamus to the Supreme Court was also denied.The United States Court of Appeals for the First Circuit held that the petitions for review are properly before it, as the administrative record was filed there pursuant to the JPML’s direction. The court rejected arguments for mandatory transfer to the Fifth Circuit, finding no legal basis to override the JPML’s selection or to collaterally attack its determination. The court also declined to exercise its discretion to transfer the petitions elsewhere. View "Direct Action for Rights and Equality v. Federal Communications Commission" on Justia Law

A 68-year-old man experiencing abdominal pain was brought to a hospital emergency room in Bayamón, Puerto Rico, in January 2016. After a delayed CT scan revealed a perforated intestine, he underwent surgery and remained in intensive care until his death in February 2016. His son, a physician residing in Florida, later learned of the seriousness of his father’s condition during a visit. The son filed a lawsuit against several doctors, the hospital, and related entities, alleging that negligent medical care led to his father’s death.The United States District Court for the District of Puerto Rico reviewed the case after a contentious discovery period. The court granted summary judgment in favor of five defendants: three doctors, a corporate entity managing the emergency room, and the emergency room’s medical director. The court found that the claims against the doctors and the corporate entity were time-barred under Puerto Rico’s one-year statute of limitations for tort claims, and that Puerto Rico law did not provide a basis for liability against the medical director, as he had not directly treated the patient. The court also disregarded certain evidence submitted by the plaintiff and denied his motion for reconsideration.On appeal, the United States Court of Appeals for the First Circuit found that the district court erred in converting two doctors’ motions to dismiss into motions for summary judgment without giving the plaintiff adequate notice or an opportunity to present evidence. The appellate court also held that the district court abused its discretion in disregarding the plaintiff’s declaration regarding when he learned of one doctor’s involvement. The court vacated and remanded the summary judgments for the three doctors and the medical director on the first cause of action, but affirmed summary judgment for the corporate entity and the medical director on the second cause of action. Each party was ordered to bear its own costs. View "Calderon-Amezquita v. Rivera-Cruz" on Justia Law

While awaiting resentencing on federal charges, an individual was detained at the Donald W. Wyatt Detention Facility in Rhode Island. During his approximately seventeen-month confinement, he, a Sunni Muslim, communicated with facility officials about his religious needs, including requests to hold congregational prayer and access religious programming and property. He alleges that officials responded with harassment, denied his requests for religious services, and ultimately transferred him to another facility in retaliation for his complaints.He filed a pro se complaint in the United States District Court for the District of Rhode Island against the facility’s warden and three unknown officials, seeking damages under 42 U.S.C. § 1983 for alleged violations of his First and Fourteenth Amendment rights. The defendants moved to dismiss, arguing they were not acting under color of state law but rather federal law, and thus were not subject to suit under § 1983. The district court granted the motion, relying on a prior district court decision that held officials at Wyatt act under color of federal law.On appeal, the United States Court of Appeals for the First Circuit reviewed the facility’s statutory creation and governance, noting that the Central Falls Detention Facility Corporation, a municipal entity, owns and operates Wyatt. The court found that, although the facility houses federal detainees under contract, it remains a municipal institution and its employees are municipal actors. The First Circuit held that the complaint plausibly alleged action under color of state law, making the defendants potentially liable under § 1983. The court reversed the district court’s dismissal and remanded for further proceedings. View "Wright v. Martin" on Justia Law

Giovanni Irizarry Sierra worked as an Attorney Advisor for the Social Security Administration (SSA) in Puerto Rico and was terminated in March 2019 for unsatisfactory performance. He subsequently filed a complaint with the SSA’s Office of Civil Rights and Equal Opportunity (OCREO), alleging that his termination was the result of discrimination and retaliation. The OCREO reorganized his allegations, dismissing one as untimely and bifurcating the remainder into pre-termination and termination discrimination claims. The termination claim was treated as a “mixed case” because it involved both discrimination and an adverse personnel action.After receiving a report of investigation, Irizarry requested a hearing before an Equal Employment Opportunity Commission (EEOC) Administrative Judge (AJ). The AJ dismissed the termination claim for lack of jurisdiction, explaining that mixed cases must proceed through the Merit Systems Protection Board (MSPB), not the EEOC. Irizarry then appealed his termination claim to the MSPB, which sustained his removal and notified him that he had thirty days from the final decision to seek judicial review in federal district court. Irizarry did not file within that period. Later, the OCREO erroneously issued a Final Agency Decision (FAD) on the termination claim, which was subsequently rescinded.Irizarry filed suit in the United States District Court for the District of Puerto Rico, relying on the rescinded FAD. The SSA moved to dismiss, arguing the complaint was untimely and the FAD was issued in error. The district court granted the motion, finding the claims time-barred and rejecting Irizarry’s arguments for equitable tolling and estoppel.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The court held that Irizarry’s claim was untimely because he failed to file within thirty days of the MSPB’s final decision, and equitable relief was not warranted. View "Irizarry Sierra v. Bisignano" on Justia Law

In this case, the defendant was involved in a Boston-based drug trafficking organization that distributed fentanyl from March 2020 to March 2021. He played a leadership role, coordinating large drug sales and organizing the movement of proceeds to Mexico, where he resided for much of the relevant period. The organization operated out of a specific apartment, used vehicles with hidden compartments to transport drugs and cash, and relied on encrypted communications. Law enforcement conducted extensive surveillance, culminating in searches and seizures of drugs, cash, and related paraphernalia. The defendant was arrested in the Dominican Republic and extradited to the United States.A federal grand jury in the District of Massachusetts indicted the defendant and several co-defendants for conspiracy to distribute fentanyl and conspiracy to commit money laundering. The defendant moved to dismiss the indictment, arguing that his arrest abroad constituted outrageous government conduct, but the United States District Court for the District of Massachusetts denied the motion. At trial, the defendant challenged various evidentiary rulings, alleged prosecutorial misconduct, and objected to aspects of the jury instructions and sentencing. The jury found him guilty on both counts, and he was sentenced to 25 years in prison. His co-defendant, who cooperated with the government, later received a significantly shorter sentence.On appeal, the United States Court of Appeals for the First Circuit reviewed the defendant’s claims, including the denial of his motion to dismiss, evidentiary objections, allegations of prosecutorial misconduct, jury instruction issues, and sentencing challenges. The court held that the arrest did not constitute outrageous government conduct, the evidentiary rulings and jury instructions were not reversible error, and there was no plain error or prosecutorial misconduct warranting a new trial. The court also found the sentence procedurally and substantively reasonable. Accordingly, the First Circuit affirmed the conviction and sentence. View "United States v. Castillo" on Justia Law