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

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

Plaintiffs Jodi Bourgeois and Pamela Smith filed separate lawsuits against The TJX Companies, Inc., Home Depot U.S.A., Inc., and The Gap, Inc., alleging violations of the New Hampshire Driver Privacy Act (NH DPA). The plaintiffs claimed that the retailers required them to present their driver's licenses for non-receipted returns and subsequently disclosed their driver's license information to a third party, The Retail Equation (TRE), without their consent. The plaintiffs argued that this disclosure violated sections IX(a) and IX(b) of the NH DPA.The United States District Court for the District of New Hampshire dismissed the complaints in all three cases. The court held that the plaintiffs failed to state a claim under the NH DPA because a driver's license in the possession of the person to whom it pertains is not considered a "motor vehicle record" under the statute. The court also found that the information disclosed to TRE was not from a "department record" as defined by the NH DPA.The United States Court of Appeals for the First Circuit reviewed the consolidated appeals. The court affirmed the district court's dismissals, agreeing that the plaintiffs' driver's licenses, in their own possession, are not "motor vehicle records" under the NH DPA. The court also held that the term "department record" refers to authentic copies of documents deposited and kept with the New Hampshire Department of Safety, and the information disclosed to TRE did not fall within this definition. Therefore, the plaintiffs' claims under sections IX(a) and IX(b) of the NH DPA were not supported by the facts alleged. View "Bourgeois v. The TJX Companies, Inc." on Justia Law

The case involves a civil enforcement action by the Securities and Exchange Commission (SEC) against Henry B. Sargent for allegedly violating registration and antifraud provisions of federal securities laws. The district court granted partial summary judgment to the SEC, finding that Sargent violated section 5 of the Securities Act of 1933 by directing unregistered public offerings of penny stocks. The court ordered equitable remedies, including disgorgement and a ten-year ban on trading penny stocks, but dismissed the SEC's fraud claims and denied an additional civil penalty.Sargent appealed the partial summary judgment, arguing that his transactions were exempt from registration and that the district court abused its discretion in imposing the ten-year ban and calculating the disgorgement amount. The SEC cross-appealed, contending that the district court erred in not imposing a civil penalty and in dismissing its fraud claims.The United States Court of Appeals for the First Circuit affirmed the district court's grant of partial summary judgment, the disgorgement amount, and the dismissal of the SEC's fraud claims. However, it found that the district court erred in imposing equitable remedies and in concluding that it lacked the power to issue a civil penalty. The appellate court vacated the injunction against Sargent and remanded the case for further proceedings to assess the appropriateness of injunctive relief and civil penalties for Sargent's section 5 violation. View "Securities and Exchange Commission v. Sargent" on Justia Law

Franciele dos Reis Olimpio Alves, a native and citizen of Brazil, along with her husband and child, arrived in the United States in 2021 and were placed in removal proceedings. They conceded removability, and Olimpio filed an application for asylum, withholding of removal, and protection under the Convention Against Torture, citing abuse by her ex-partner in Brazil. The Immigration Judge (IJ) denied her request for relief, concluding that even if the abuse amounted to persecution, it was not on account of a protected ground.Olimpio appealed the IJ's denial of her asylum claim to the Board of Immigration Appeals (BIA). The BIA affirmed the IJ's decision, agreeing that Olimpio's ex-partner's motivation to harm her was based on personal issues regarding their relationship, not on account of her membership in a particular social group. Olimpio, her husband, and child then petitioned for review of the BIA's decision.The United States Court of Appeals for the First Circuit reviewed the case. The court noted that it reviews both the IJ's and the BIA's decisions as a unit when the BIA adopts portions of the IJ's findings while adding its own analysis. The court upheld the agency's factual findings under the substantial-evidence standard, which requires upholding the findings unless any reasonable adjudicator would be compelled to conclude otherwise.The court held that Olimpio did not demonstrate the requisite nexus between her claimed persecution and a protected ground. The agency reasonably concluded that her ex-partner's actions were motivated by personal issues rather than her membership in the proposed social group of "Brazilian women who are victims of domestic violence." Consequently, the petition for review was denied. View "Sanches Alves v. Bondi" on Justia Law

Sine Phimmady, a Laotian refugee admitted to the U.S. in 1979, was convicted of multiple assault-related crimes in 1992 and 1993. He served five years in prison and was subsequently placed in removal proceedings by the Immigration and Naturalization Services (INS). An Immigration Judge (IJ) found him deportable based on his convictions, and the Board of Immigration Appeals (BIA) dismissed his appeal. After being released from INS custody in 2000, Phimmady rebuilt his life, maintaining steady employment and starting a family. In 2022, he successfully vacated his 1993 convictions due to a lack of proper immigration warnings during his plea hearings.Phimmady requested the BIA to reopen his removal proceedings sua sponte, citing the vacatur of his convictions. The BIA denied his motion, stating that he had not demonstrated an exceptional situation warranting reopening, particularly noting his delay in seeking post-conviction relief. Phimmady filed a motion for reconsideration, arguing that the BIA had a settled practice of granting reopening in cases where convictions were vacated due to defects in the criminal proceedings. The BIA denied the reconsideration, emphasizing the need to consider the specific facts and circumstances of each case, including Phimmady's delay and the nature of his convictions.The United States Court of Appeals for the First Circuit reviewed the case. The court concluded that the BIA does not have a settled practice of granting sua sponte reopening solely based on the vacatur of convictions. The court found that the BIA's decisions often consider the totality of circumstances, including the noncitizen's diligence in seeking post-conviction relief. Therefore, the court denied Phimmady's petition for review, upholding the BIA's decision. View "Phimmady v. Bondi" on Justia Law

In this case, Jesús Abdiel Feliciano-Candelario was indicted on five federal counts related to three separate armed robberies. Feliciano pled guilty to four counts under a plea agreement, which included a joint recommendation for a 130-month sentence, below the calculated Guidelines range of 157 to 181 months. The district court, however, sentenced him to 181 months. Feliciano appealed, challenging the sentence on several grounds.The United States District Court for the District of Puerto Rico initially reviewed the case. Feliciano moved to sever the charges into three separate trials, which the court granted. During a status conference, the court discussed the possibility of sequential sentencing if Feliciano were convicted in separate trials. Eventually, Feliciano and the government reached a plea agreement, and Feliciano pled guilty to four counts, with the fifth count dismissed. The district court sentenced him to 181 months, applying a four-level enhancement for "otherwise using" a knife during a carjacking, among other considerations.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed with Feliciano that the district court improperly applied the four-level enhancement for "otherwise using" a knife instead of the three-level enhancement for "brandishing" it. The court vacated the sentence on the carjacking count and remanded for further proceedings regarding that enhancement. On other grounds, including the government's alleged breach of the plea agreement and the district court's consideration of community factors, the court affirmed the district court's decisions. The court found no plain error in the government's actions or the district court's consideration of community-based factors and rejected Feliciano's argument about the district court's supposed belief in a hypothetical, piecemeal sentencing process. View "United States v. Feliciano-Candelario" on Justia Law