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

Ángel Forteza-García appealed the denial of his 28 U.S.C. § 2255 petition for post-conviction relief from his conviction under 18 U.S.C. § 924(j), which criminalizes causing death through the use of a firearm during a crime of violence. Forteza based his petition on United States v. Davis, which held part of the definition of a "crime of violence" in § 924(c) unconstitutionally vague. He argued that his predicate conviction under § 2114(a) did not qualify as a "crime of violence" post-Davis, rendering his § 924(j) conviction unconstitutional.The District Court for the District of Puerto Rico denied Forteza's petition, ruling that his § 2114(a) offense did have the use of force as an element, thus qualifying as a "crime of violence" under § 924(c)(3)(A). The court also noted that any argument about Forteza being an accomplice rather than a principal was foreclosed by precedent. The court denied Forteza a certificate of appealability (COA) on his claim.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the District Court's decision, holding that Forteza's predicate § 2114(a) offense, which involved wounding the victim and placing his life in jeopardy by the use of a dangerous weapon, qualified as a "crime of violence" under § 924(c)(3)(A). The court rejected Forteza's argument that his conviction as an aider and abettor did not meet the force clause requirement, citing binding precedent. The court concluded that the aggravated form of the § 2114(a) offense, as charged, supported Forteza's § 924(j) conviction. View "Forteza-Garcia v. United States" on Justia Law

In this case, José M. Rojas-Tapia appealed the denial of his 28 U.S.C. § 2255 petitions for post-conviction relief, which he filed in the District of Puerto Rico. Rojas's convictions and sentences stem from his October 2000 guilty pleas to charges related to two separate post office robberies. The first indictment involved the Levittown Post Office, and the second involved the Sabana Seca Post Office. Both indictments included charges under 18 U.S.C. § 2114(a) for assaulting postal employees with intent to rob, and under 18 U.S.C. § 924(c) for using a firearm during a crime of violence. Additionally, Rojas was charged under 18 U.S.C. § 922(g) for being a felon in possession of a firearm.Rojas did not challenge his convictions or sentences on direct appeal. However, in 2017, he filed two habeas petitions challenging his § 924(c) convictions and the application of the Armed Career Criminal Act (ACCA) to his § 922(g) convictions. He argued that his § 924(c) convictions could not stand under Johnson v. United States (2015) and United States v. Davis (2019), as his underlying offenses did not qualify as crimes of violence. He also contended that his ACCA-enhanced sentences were improper because his prior convictions did not qualify as violent felonies or serious drug offenses.The United States District Court for the District of Puerto Rico denied both petitions. The court concluded that Rojas's federal mail robbery convictions under § 2114(a) qualified as crimes of violence under the force clause of § 924(c). Additionally, the court found that Rojas's prior convictions for attempted murder, second-degree murder, and armed carjacking under Puerto Rico law qualified as violent felonies under the ACCA.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court held that Rojas's convictions for aggravated mail robbery under § 2114(a) qualified as crimes of violence under § 924(c)'s force clause. The court also rejected Rojas's argument that his aiding and abetting convictions did not qualify as crimes of violence, reaffirming that aiding and abetting liability under 18 U.S.C. § 2 does not alter the application of the categorical approach. The court did not address Rojas's ACCA-related arguments, as his request for a Certificate of Appealability on those claims had been denied. View "Rojas-Tapia v. United States" on Justia Law

The case involves a business venture between W.R. Cobb Company (Cobb) and V.J. Designs LLC (VJ Designs) to sell diamond products under the Forevermark brand. Cobb, unable to secure a license directly from Forevermark, entered into an agreement with VJ Designs, an existing Forevermark licensee, to form a new company, WR Cobb/VJ LLC (the Joint Entity). The agreement stipulated that the Joint Entity would operate under the Forevermark license. However, VJ Designs could not transfer its Forevermark rights without Forevermark's written consent. The venture quickly fell apart, and Cobb sued VJ Designs and its owner, Benjamin Galili, to recover funds paid under the agreement, alleging breach of contract and misrepresentation.The United States District Court for the District of Rhode Island held a two-day bench trial and ruled in favor of VJ Designs and Galili on all claims. The court found that VJ Designs did not breach the contract or misrepresent any material facts. Cobb appealed, arguing that the district court erred by not rescinding the agreement and not holding Galili personally liable for fraud and misrepresentation.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's judgment, holding that VJ Designs did not breach the contract by failing to assign the Forevermark license to the Joint Entity upon execution of the agreement. The court found no provision in the agreement requiring immediate transfer of the license and noted that the parties understood Forevermark's consent was necessary. The court also rejected Cobb's claims of fraud and misrepresentation, finding no evidence of material misrepresentation by VJ Designs or Galili. Additionally, the court dismissed Cobb's mutual mistake theory as it was not pled in the complaint and was raised too late in the proceedings. View "W.R. Cobb Company v. VJ Designs, LLC" on Justia Law

The plaintiff, Carmen Quintana-Dieppa, a 62-year-old Puerto Rican woman, worked for the Department of the Army since 1988 and served as a Child Youth and School Services Coordinator at Fort Buchanan, Puerto Rico, since 2009. In 2014, she filed a complaint with the EEOC alleging national origin discrimination. While her complaint was pending, the Army conducted two investigations into her management style, finding that she fostered a toxic work environment. Consequently, she was reassigned to a nonsupervisory role in 2017. Quintana claimed this reassignment was discriminatory and retaliatory.The United States District Court for the District of Puerto Rico granted summary judgment in favor of the Army, finding no genuine issues of material fact. The court determined that Quintana failed to properly contest the Army's Statement of Facts according to Local Rule 56, and thus, the Army's facts were deemed admitted. The court concluded that Quintana did not establish a prima facie case of discrimination or retaliation and, even if she had, she failed to show that the Army's reasons for her reassignment were pretextual.The United States Court of Appeals for the First Circuit reviewed the case de novo. The court affirmed the district court's judgment, agreeing that Quintana did not meet her burden of showing that the Army's stated reasons for her reassignment were a pretext for discrimination or retaliation. The court noted that the Army's investigations provided legitimate, nondiscriminatory reasons for the reassignment, and Quintana's arguments, including claims of hearsay and fabrication, were unsupported by the record. The court also found that the temporal proximity between her EEOC complaint and reassignment was insufficient to establish a causal link for retaliation. View "Quintana-Dieppa v. Department of the Army" on Justia Law

Rosemary Morgan-Lee, a former employee of Therapy Resources Management, LLC (TRM), alleged that she was discharged in violation of the whistleblower protections under the False Claims Act (FCA) and the Rhode Island Whistleblowers' Protection Act (RIWPA). Morgan-Lee claimed that her termination was due to her efforts to report fraudulent activities by TRM. The district court found that while she had engaged in some protected activity and TRM had general corporate knowledge of this, she failed to prove that her protected conduct was the but-for cause of her termination.The case was initially tried before a jury in 2017, resulting in a mistrial. The district court then conducted a four-day bench trial, during which it heard testimony from ten witnesses. The court ultimately ruled against Morgan-Lee, finding that her termination was due to unapproved absences and her refusal to provide specifics about the alleged fraudulent activities, rather than any retaliatory animus from TRM.The United States Court of Appeals for the First Circuit reviewed the case. Morgan-Lee argued that the district court committed legal errors and that its factual findings were clearly erroneous. However, the appellate court found that many of her arguments were waived, unpreserved, or without merit. The court affirmed the district court's decision, holding that the district court properly applied the law and that its findings, including the lack of but-for causation, were well-supported by the record. The appellate court also rejected Morgan-Lee's arguments regarding the application of the McDonnell Douglas burden-shifting framework and the causation standard, affirming the district court's use of the but-for causation standard as consistent with precedent. View "United States ex rel. Morgan-Lee v. Therapy Resources Management, LLC" on Justia Law

An environmental group, Conservation Law Foundation (CLF), sued Academy Express, LLC (Academy), a transportation company, alleging that Academy violated the Clean Air Act (CAA) by idling its buses beyond state limits in Massachusetts and Connecticut. CLF claimed that its members were harmed by breathing polluted air from Academy's buses. Academy moved for summary judgment, arguing that CLF lacked associational standing. The district court agreed and granted Academy's motion, holding that CLF could not demonstrate that its members suffered a concrete injury traceable to Academy's conduct.The United States District Court for the District of Massachusetts found that only two of CLF's members, Wagner and Morelli, had alleged injuries-in-fact, but their injuries were not traceable to Academy's idling due to the presence of other potential pollution sources in the urban environment. The court did not address the standing of additional members disclosed by CLF after the close of fact discovery or the expert testimony submitted by CLF.The United States Court of Appeals for the First Circuit reviewed the case and disagreed with the district court's narrow interpretation of injury-in-fact. The appellate court held that breathing polluted air and reasonable fear of health effects from pollution are cognizable injuries. It also found that recreational harms do not require a change in behavior to be considered injuries-in-fact. The court emphasized that traceability does not require a conclusive link but can be established through geographic proximity and expert testimony.The First Circuit vacated the district court's grant of summary judgment and remanded the case for further proceedings. The district court was instructed to determine the scope of the record, make necessary factual findings, and apply the correct legal standards for injury-in-fact and traceability. The appellate court did not address redressability, leaving it for the district court to consider if necessary. View "Conservation Law Foundation, Inc. v. Academy Express, LLC" on Justia Law

The defendant, Guillermo Vasquez-Landaver, was sentenced in 2016 to 120 months of imprisonment followed by 60 months of supervised release for crimes committed as a member of the MS-13 gang. Conditions of his supervised release included abstaining from drugs and alcohol, not committing another crime, reporting to his probation officer, and remaining in the District of Maine unless permitted to travel. After his release in February 2020, he violated these conditions by leaving Maine without permission, using illegal drugs and alcohol, failing to report to his probation officer, and operating a motor vehicle while intoxicated. Additionally, on October 20, 2021, he allegedly propositioned a woman and asked if she liked cocaine while in possession of the drug.The United States District Court for the District of Maine held a hearing on December 18, 2023, where the defendant admitted to all violations except the one from October 20, 2021. The government presented evidence from law enforcement officers who testified about the defendant's possession of cocaine packaged in a manner indicative of distribution. The district court found that the defendant possessed more than two grams of cocaine, which under Maine law, allowed an inference of intent to distribute. Consequently, the court revoked his supervised release and imposed a 60-month imprisonment term.The United States Court of Appeals for the First Circuit reviewed the case and upheld the district court's findings. The appellate court found no clear error in the district court's determination that the defendant possessed more than two grams of cocaine and intended to distribute it. The court affirmed the district court's decision to revoke the defendant's supervised release and impose a 60-month imprisonment term. View "United States v. Vasquez-Landaver" on Justia Law

A high school student, Adrianna Wadsworth, filed a lawsuit against her principal, Andrew Cavanaugh, a school social worker, Chuck Nguyen, and the school district, MSAD 40/RSU 40, alleging constitutional violations and a Title IX claim. Wadsworth claimed that Cavanaugh sexually harassed her, Nguyen failed to protect her, and the school district was indifferent to the harassment.The United States District Court for the District of Maine dismissed some of Wadsworth's claims and granted summary judgment in favor of the defendants on others. The court dismissed the supervisor-liability claim against Nguyen, finding no control over Cavanaugh. It also granted summary judgment to Cavanaugh on the substantive due process claim, concluding that non-physical harassment did not violate Wadsworth's right to bodily integrity. The court found that Wadsworth's equal protection claim against Cavanaugh was valid but granted him qualified immunity. Nguyen was granted summary judgment on the state-created-danger claim, as his conduct did not shock the conscience. The court also granted summary judgment to MSAD on the § 1983 municipal liability claim, finding no deliberate indifference, and on the Title IX claim, concluding that the assistant principals did not have actual knowledge of the harassment.The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court's decision on the substantive due process claim against Cavanaugh but reversed the summary judgment on the equal protection claim, finding that a reasonable jury could conclude that Cavanaugh's conduct was severe and pervasive enough to constitute sexual harassment. The court also affirmed the dismissal of the supervisor-liability claim against Nguyen and the summary judgment on the state-created-danger claim. However, it reversed the summary judgment on the Title IX claim against MSAD, concluding that a reasonable jury could find that the assistant principals had actual knowledge of the harassment. The case was remanded for further proceedings consistent with the opinion. View "Wadsworth v. MSAD 40/RSU 40" on Justia Law

The case involves the United States government alleging that Regeneron Pharmaceuticals violated the Anti-Kickback Statute (AKS) by covering copayments for patients prescribed Eylea, a drug used to treat wet age-related macular degeneration. The government contends that this action induced doctors to prescribe Eylea, leading to Medicare claims that were "false or fraudulent" under the False Claims Act (FCA) because they "resulted from" the AKS violation.The United States District Court for the District of Massachusetts reviewed the case and agreed with Regeneron's interpretation that the phrase "resulting from" in the 2010 amendment to the AKS requires a but-for causation standard. This means that the government must prove that the AKS violation was the actual cause of the Medicare claims. The district court noted the conflict in case law and sought interlocutory review, which was granted.The United States Court of Appeals for the First Circuit affirmed the district court's ruling. The court held that the phrase "resulting from" in the 2010 amendment to the AKS imposes a but-for causation requirement. The court reasoned that the ordinary meaning of "resulting from" requires actual causality, typically in the form of but-for causation, unless there are textual or contextual indications to the contrary. The court found no such indications in the 2010 amendment or its legislative history. Therefore, to establish falsity under the FCA based on an AKS violation, the government must prove that the kickback was a but-for cause of the submitted claim. View "United States v. Regeneron Pharmaceuticals, Inc." on Justia Law

The case involves parents (the "Parents") of a student at Baird Middle School in Ludlow, Massachusetts, who challenged the school's protocol regarding the use of a student's requested name and gender pronouns without notifying the parents unless the student consents. The Parents argued that this practice interfered with their parental rights under the U.S. Constitution. The school, represented by the Ludlow School Committee and various school officials, defended the protocol as necessary to ensure a safe and inclusive environment for students.In the United States District Court for the District of Massachusetts, the Parents' complaint was dismissed. The court held that the Parents failed to state a plausible claim that the school's protocol violated their fundamental right to direct the upbringing of their child. Specifically, the court found that the Parents did not adequately allege that the school's actions constituted medical treatment or that the conduct was so egregious as to shock the conscience, which is required to establish a substantive due process violation.The United States Court of Appeals for the First Circuit reviewed the case. The court concluded that the protocol is a form of legislative conduct, not executive conduct, and thus did not require the shock-the-conscience test. The court determined that the Parents had identified a fundamental right but failed to plausibly allege that the school's conduct restricted that right. The court found that the school's actions, including the use of the student's chosen name and pronouns, did not constitute medical treatment and that the protocol did not restrict the Parents' rights to direct their child's upbringing.The First Circuit held that the protocol was rationally related to the legitimate state interest of creating a safe and inclusive educational environment for students. Therefore, the court affirmed the district court's dismissal of the Parents' complaint. View "Foote v. Ludlow School Committee" on Justia Law