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

In September 2022, police received a tip that the defendant was armed on the roof of a public housing building. When officers arrived and announced themselves, the defendant jumped off the roof and was found injured. He informed police that he had three firearms on the roof, where officers subsequently recovered two Glock pistols modified to fire automatically, a tactical rifle, a micro conversion kit, multiple magazines—including high-capacity ones—and 279 rounds of ammunition. At the time, the defendant was on supervised release for a prior firearm-possession conviction.The defendant pled guilty in the United States District Court for the District of Puerto Rico to possessing machine guns and being a felon in possession of firearms and ammunition. The district court calculated an advisory guidelines range of sixty-three to seventy-eight months based on the total offense level and criminal history. The defendant requested a sentence at the bottom of the range, citing improved mental health and questioning the evidence, while the government requested a sentence at the top of the range due to the defendant’s criminal history and the quantity and type of weapons and ammunition possessed. The district court imposed a ninety-six-month sentence, an eighteen-month upward variance, citing the dangerousness of the weapons, the large cache of ammunition, the defendant’s prior conviction, his commission of the offense while on supervised release, and his active surveillance of the rooftop.On appeal to the United States Court of Appeals for the First Circuit, the defendant argued his sentence was procedurally and substantively unreasonable and that the government breached the plea agreement by defending the upward variance. The First Circuit held that the district court adequately explained its reasons for the upward variance, properly considered aggravating factors not captured by the guidelines, and did not abuse its discretion. The court also found no breach of the plea agreement. The judgment was affirmed. View "United States v. Maldonado-Velazquez" on Justia Law

The plaintiffs in this case are the sons of Roberto Clemente, a renowned Puerto Rican baseball player, and two corporations they control. The dispute centers on the Commonwealth of Puerto Rico’s use of Clemente’s name and image on commemorative license plates and vehicle registration tags. Proceeds from these items were designated to fund a new “Roberto Clemente Sports District,” a public project that would replace an earlier initiative, Ciudad Deportiva, originally founded by Clemente. The plaintiffs allege that they hold trademark rights in Clemente’s name and that the Commonwealth’s actions were unauthorized and caused public confusion, with many mistakenly believing the Clemente family benefited financially from the program.The plaintiffs brought suit in the United States District Court for the District of Puerto Rico against the Commonwealth, several high-ranking officials, and the Puerto Rico Convention Center District Authority. Their claims included trademark infringement, false association, false advertising, and trademark dilution under the Lanham Act, as well as a takings claim under the Fifth and Fourteenth Amendments. The Commonwealth and the Authority moved to dismiss, arguing sovereign and qualified immunity and failure to state a claim. The district court granted both motions, dismissing all federal claims on immunity and merits grounds, and declined to exercise jurisdiction over non-federal claims.On appeal, the United States Court of Appeals for the First Circuit reviewed the dismissal de novo. The court affirmed the dismissal of all claims against the Authority and all claims against the Commonwealth and its officials in their official capacities. It also affirmed dismissal of the false advertising and takings claims. However, the court vacated the dismissal of the Lanham Act claims for trademark infringement, false endorsement, and dilution against the Commonwealth officials in their personal capacities, holding those claims were plausibly alleged and not barred by qualified immunity at this stage, and remanded for further proceedings. View "Clemente Properties, Inc. v. Pierluisi-Urrutia" on Justia Law

After serving time for a federal drug trafficking conviction, the defendant entered a residential re-entry program as ordered by the court. On November 2, 2023, while returning from an approved work pass, a drive-by shooting occurred near the facility. The defendant fled and later told staff he would return, but did not. Nearly two months later, U.S. Marshals arrested him at a residence where they found a Glock pistol modified to function as a machine gun, seven magazines (five high capacity), and 152 rounds of nine-millimeter ammunition. The defendant pled guilty to escaping from the re-entry program and to being a felon in possession of a firearm and ammunition.The United States District Court for the District of Puerto Rico calculated a guideline range of 33 to 41 months’ imprisonment. The defendant requested a sentence at the low end of the range, citing compliance prior to escape and his acceptance of responsibility. The government sought the high end, emphasizing the escape and the significant quantity and nature of the firearm and ammunition found. The court determined that the guideline range did not adequately reflect the seriousness of the offenses, or promote respect for the law and deterrence, and imposed two concurrent sentences of 60 months—an upward variance of 19 months above the guideline range.On appeal, the United States Court of Appeals for the First Circuit reviewed the procedural and substantive reasonableness of the sentence. Applying plain error review to the procedural challenge, the court found that the district court adequately justified the upward variance based on the specific facts: the modified pistol and large amount of ammunition and magazines. For substantive reasonableness, reviewed for abuse of discretion, the appellate court held that these aggravating factors legitimately distinguished the case from typical guideline cases. The First Circuit affirmed the district court’s judgment and sentence. View "United States v. Del-Valle-Camacho" on Justia Law

G.H. was a child with serious, complex medical issues requiring extensive treatment. In 2011, his older sister died from a mitochondrial disorder. Afterward, G.H. began showing symptoms believed to be similar, and his mother, J.S.H., sought care for him at Boston Children's Hospital. Dr. Alice Newton, head of the hospital’s child protection team and a mandated reporter, filed a report with the Massachusetts Department of Children and Families (DCF) alleging medical child abuse by J.S.H., based on perceived inconsistencies in reported symptoms. The report was unsubstantiated, and subsequent similar reports from other sources were also unsubstantiated. In 2013, Dr. Newton moved to Massachusetts General Hospital (MGH). In 2018, after learning J.S.H. was identified as a witness in an unrelated trial, Dr. Newton reviewed G.H.’s medical records at MGH and again raised concerns of medical child abuse, documenting her findings and filing another report with DCF, which was also deemed unsubstantiated.J.S.H. filed suit in the United States District Court for the District of Massachusetts against Dr. Newton and MGH, asserting state-law emotional distress claims and a federal disability discrimination claim under Section 504 of the Rehabilitation Act. The district court granted summary judgment in favor of the defendants, finding insufficient evidence to proceed to trial. The court declined to consider an affidavit submitted by J.S.H. on the grounds of untimeliness.The United States Court of Appeals for the First Circuit reviewed the district court’s summary judgment de novo. The appellate court held that expert testimony was required to establish negligence for the emotional distress claims but was not provided. The court further found no evidence that Dr. Newton’s actions constituted extreme and outrageous conduct or caused harm to G.H., nor evidence that MGH denied or limited services to G.H. based on disability. The First Circuit affirmed the district court’s grant of summary judgment to both defendants. View "J.S.H. v. Newton" on Justia Law

A group of eleven current and former employees of the Woods Hole, Martha’s Vineyard and Nantucket Steamship Authority challenged the Authority’s COVID-19 vaccine mandate, which required all employees to be fully vaccinated unless they qualified for a medical or religious exemption. The policy allowed for exemptions if an employee provided sufficient medical documentation or demonstrated a sincerely held religious belief, provided that reasonable accommodations could be made without undue burden to the Authority. Thirteen employees applied for religious exemptions, but only the request of one fully remote employee was granted. One employee received a temporary medical exemption but was ultimately terminated after refusing vaccination once that exemption expired. Four appellants later became vaccinated and remained employed; the remaining seven were fired for noncompliance.After the Authority enacted its policy, the plaintiffs filed suit, alleging violations of their rights under the Massachusetts Declaration of Rights, the First and Fourteenth Amendments, and Massachusetts anti-discrimination law. The state court initially granted a temporary restraining order, but after removal to the United States District Court for the District of Massachusetts, the district court denied their preliminary injunction request. On a prior appeal, the United States Court of Appeals for the First Circuit affirmed the denial as to most claims but remanded for further consideration of the First Amendment claim, instructing the district court to address the relevance of the granted medical exemption and to determine the appropriate level of scrutiny.On remand, the district court again denied a preliminary injunction, finding the policy to be generally applicable and thus subject to rational basis review, which it held the policy satisfied. The United States Court of Appeals for the First Circuit affirmed, holding that the policy’s medical and religious exemptions were not comparable for Free Exercise purposes, the policy was generally applicable, and the Authority’s interests justified the mandate under rational basis review. View "Brox v. Woods Hole, Martha's Vineyard & Nantucket Steamship Authority" on Justia Law

Marcus Mello was charged with multiple offenses in connection with drug trafficking activities in Maine, including distributing pills purported to be oxycodone but containing fentanyl, possession with intent to distribute fentanyl, possession of a firearm in furtherance of drug trafficking, and later, failing to appear for his scheduled jury trial. The investigation linked Mello to a supplier named "Chop" and documented several large shipments of pills, some of which were sold to individuals, one of whom subsequently died from fentanyl toxicity. Law enforcement seized thousands of pills, a firearm, and cash during Mello’s arrest, and communications confirmed ongoing drug transactions over several months.Following his indictment in the United States District Court for the District of Maine, Mello pleaded guilty to all charges. At sentencing, the district court calculated a Guidelines range of 228-270 months, based on drug quantity, criminal history (including juvenile adjudications), and enhancements for obstruction of justice due to his failure to appear. The court denied Mello’s requests for downward departures related to age, mental health, and overrepresentation of criminal history, and also denied a reduction for acceptance of responsibility. After considering the factors under 18 U.S.C. § 3553(a), the court varied downward and sentenced Mello to a total of 181 months’ imprisonment.On appeal to the United States Court of Appeals for the First Circuit, Mello challenged his sentence on both procedural and substantive grounds. The First Circuit reviewed the district court’s factual findings and legal conclusions for clear error and abuse of discretion, and procedural rulings de novo. The appellate court held that the district court had not erred in its drug quantity calculation, consideration of juvenile adjudications, application of enhancements and denials of reductions, or its refusal to depart further from the Guidelines. The First Circuit concluded that the sentence was both procedurally and substantively reasonable and affirmed the district court’s judgment. View "United States v. Mello" on Justia Law

Marilyn Besosa-Noceda moved from Puerto Rico to Texas with her daughter, whose biological father, Emmanuel Santiago-Melendez, objected to the relocation and subsequently filed criminal charges against Besosa, alleging she deprived him of access to his child. Santiago’s complaint led to Besosa’s arrest in Texas and extradition to Puerto Rico. Ultimately, the criminal charges were dismissed after Besosa demonstrated a lack of probable cause.After the dismissal, Besosa filed suit in the United States District Court for the District of Puerto Rico against the police officer who received Santiago’s complaint, the prosecutor who authorized the criminal charges, and the prosecutor’s supervisor. She alleged malicious prosecution under 42 U.S.C. § 1983 and Commonwealth law, claiming her constitutional rights were violated by the initiation of legal process unsupported by probable cause. The defendants moved for summary judgment, which the district court granted. The court found the arrest warrant was issued by a judge based on probable cause and was not obtained through false statements or omissions. The district court also rejected Besosa’s claim that her absence from the probable cause hearings violated her rights, finding no entitlement under Commonwealth law to be present at such hearings.On appeal, the United States Court of Appeals for the First Circuit reviewed Besosa’s arguments, including a challenge to an unresolved discovery dispute and the merits of the summary judgment ruling. The First Circuit held that Besosa failed to invoke the proper procedural mechanism to delay summary judgment pending discovery and that she did not present evidence showing the defendants knowingly provided false information or recklessly disregarded the truth when seeking the arrest warrant. The First Circuit affirmed the district court’s grant of summary judgment for the defendants. View "Besosa-Noceda v. Capo-Rivera" on Justia Law

In early 2025, the National Institutes of Health (NIH), an agency within the Department of Health and Human Services (HHS), issued a Supplemental Guidance that implemented a uniform 15% cap on indirect cost reimbursement for all NIH-funded research grants, effective almost immediately. Indirect costs, which include necessary administrative and facility expenses not attributable to a single research project, had previously been negotiated individually with grant recipients according to established regulations and memorialized in negotiated indirect cost rate agreements (NICRAs). The new policy would substantially reduce the reimbursement many recipients, such as universities and hospitals, could receive under existing and future grants.Shortly after the guidance was issued, a coalition of states, medical associations, and higher education organizations challenged the NIH’s action in the United States District Court for the District of Massachusetts. The district court first granted temporary restraining orders to prevent implementation of the guidance, then issued a nationwide preliminary injunction. After further proceedings, the district court converted this into a permanent injunction and vacated the Supplemental Guidance, concluding that the NIH’s action likely violated a congressional appropriations rider and HHS regulations, and finding the action arbitrary, capricious, and procedurally improper.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s decision. The court held that the district court had jurisdiction because the plaintiffs challenged an agency-wide policy rather than seeking contract damages, which would fall under the exclusive jurisdiction of the Court of Federal Claims. The appellate court further held that the NIH’s Supplemental Guidance violated the statutory appropriations rider and HHS regulations governing indirect cost reimbursement, including the requirements for deviations from negotiated rates. The First Circuit affirmed the permanent injunction and vacatur of the Supplemental Guidance. View "Commonwealth of Massachusetts v. National Institutes of Health" on Justia Law

In this case, the petitioner was convicted of first-degree murder and robbery for an offense committed at age 17, resulting in a mandatory sentence of life imprisonment without parole under Massachusetts law. Decades later, following developments in constitutional law, the Massachusetts Supreme Judicial Court held that life-without-parole sentences for juveniles were unconstitutional and ordered that such sentences be modified to life with the possibility of parole. As a result, the petitioner’s sentence was changed; he became parole eligible, was granted parole, and was released.After this modification, the petitioner sought to file a second habeas corpus petition in federal court under 28 U.S.C. § 2254. The United States District Court for the District of Massachusetts ruled that this petition was “second or successive” under 28 U.S.C. § 2244(b) and thus subject to its “gatekeeping” requirements, concluding that the addition of parole eligibility did not constitute a new judgment for purposes of federal habeas law.On appeal, the United States Court of Appeals for the First Circuit reviewed de novo whether the sentence modification constituted a new judgment. The court held that the change from life without parole to life with parole eligibility was a material change, making the sentence a new judgment under federal law. The court reasoned that, because the petitioner’s current custody was authorized by this new judgment, his second-in-time habeas petition did not trigger the restrictions of § 2244(b).Therefore, the First Circuit reversed the district court’s decision, holding that the petitioner need not obtain pre-authorization to file his habeas petition, and remanded for further proceedings. View "Donovan v. Massachusetts Parole Board" on Justia Law

Two long-time residents of Nashua, New Hampshire, sought to fly various flags on a designated "Citizen Flag Pole" located at City Hall Plaza. The City had previously allowed private citizens and groups to fly flags representing diverse causes and cultural events on this pole, with minimal oversight and no substantive review of flag content. After one of the plaintiffs flew a "Save Women's Sports" flag, the City received complaints, revoked permission, and removed the flag, stating that it was discriminatory toward the transgender community. Subsequently, the City adopted a written policy in 2022 asserting that the flagpole’s use constituted government speech and reserving the right to deny flags not aligned with City policies.The plaintiffs filed suit in the United States District Court for the District of New Hampshire, alleging violations of the First and Fourteenth Amendments and seeking a preliminary injunction to prevent viewpoint-based denials of flag applications. Before the City filed its opposition, it enacted a new policy to exercise exclusive government control over the flagpoles. The magistrate judge recommended denying the injunction, finding the flag program to be government speech, and the district court adopted that recommendation and denied relief. The plaintiffs then appealed to the United States Court of Appeals for the First Circuit.The First Circuit reviewed the district court’s denial for abuse of discretion and legal conclusions de novo. Applying the government speech test from Shurtleff v. City of Boston, the court held that Nashua’s Citizen Flag Pole program was not government speech, but rather operated as a forum for private expression. Because Nashua conceded that, absent a government speech determination, its actions constituted impermissible viewpoint discrimination, the First Circuit reversed the district court. The case was remanded with instructions to enter interim declaratory relief in favor of the plaintiffs. View "Scaer v. City of Nashua" on Justia Law