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

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The First Circuit reversed the order of the district court dismissing this appeal, holding that the district court erred both in refusing to enforce the contested agreement and in dismissing the case after effectively declaring the agreement null and void.The Commonwealth School, Inc. brought suit against Commonwealth Academy Holdings, LLC under the Lanham Act, 15 U.S.C. 1114(A) and 1125(a), alleging that the School had trademarked the name "Commonwealth School" and that the Academy's name, "Commonwealth Academy," infringed that trademark. The parties achieved a settlement agreement, and the district court conditionally dismissed the case. When the parties failed to memorialize the agreement the School moved to reopen the case. The Academy, in response, moved for enforcement of the settlement agreement. The district court refused to enforce the settlement, finding that there had not been a meeting of the minds, and then dismissed the case. The First Circuit reversed, holding (1) this Court had jurisdiction to hear and determine this appeal; (2) enforcement of the settlement agreement was within the district court's jurisdictional orbit; and (3) the settlement agreement was valid and enforceable, and therefore, the district court erred in refusing to enforce the agreement and in dismissing the case. View "Commonwealth School, Inc. v. Commonwealth Academy Holdings LLC" on Justia Law

Posted in: Trademark
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The First Circuit affirmed the judgment of the district court revoking Defendant's supervised release on the underlying conviction of failing to register as a sex offender, in violation of federal law, holding that Defendant's challenges on appeal were unavailing.In revoking Defendant's supervised release, the district court found that Defendant, upon his release from prison, once again failed to register as a sex offender, thus violating the conditions of his release, as well as state and federal law. On appeal, Defendant argued that the district court abused its discretion by not excusing his failure to register and that his sentence was unreasonable. The First Circuit affirmed, holding (1) the district court did not abuse its discretion in finding that Defendant violated the terms of his supervised release; and (2) Defendant's sentence was procedurally and substantively reasonable. View "United States v. Picard" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed the judgment of the district court sentencing Defendant to eighty-seven months for engaging in firearms trafficking without a license and conspiring to commit an offense against the United States, holding that the sentence was not unreasonable.Defendant's crimes violated the terms of two supervised release sentences, leading to the revocation of both and two consecutive sentences of imprisonment. For his crimes, Defendant was sentenced to eighty-seven months in prison, to be served consecutively to the revocation sentences. On appeal, Defendant argued that the district court erred by viewing the Sentencing Guidelines as mandatory. The First Circuit affirmed, holding that Defendant's claims on appeal were without merit. View "United States v. Zayas-Burgos" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed Defendant's sentence of sixty months imprisonment for being a felon in possession of a firearm, holding that the district court did not abuse its discretion in sentencing Defendant.Defendant's Guidelines Sentencing Range was thirty-seven to forty-six months in prison. The district court, however, sentenced Defendant to sixty months. The First Circuit affirmed the sentence, holding (1) the district court did not base his sentence on unreliable information in the form of a description in the presentence report of a juvenile burglary conviction in Puerto Rico court; (2) the judge imposed a variance, rather than a departure; and (3) Defendant was not entitled to relief on his remaining claims of error. View "United States v. Ayala-Landor" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed Defendant's conviction of unlawful reentry into the United States, in violation of 8 U.S.C. 1326(a), holding that Defendant's claims of error were without merit.On appeal, Defendant challenged the government's introduction into evidence under Fed. R. Evid. 803(8) of a so-called I-296 form. The First Circuit affirmed, holding (1) Defendant failed to demonstrate that the district court committed plain error in admitting the I-296 document into evidence; and (2) the record adequately supported a finding that the "previously removed" element of the statute of conviction was met, and therefore, Defendant's motion for judgment of acquittal was properly denied. View "United States v. Fuentes-Lopez" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Marvic d/b/a Brady-Built Sunrooms (Marvic) and dismissing Cynthia Foss's state law claims, holding that the district court did not err.Foss, a graphic designer, created a brochure for Marvic to use in marketing its sunrooms. Twelve years later, Foss brought a complaint alleging a federal claim for copyright infringement and pendent state law claims. The federal district court entered three separate rulings at issue on appeal: it granted Marvic's motion to dismiss Foss's copyright claim, it denied Foss's motion to withdraw certain statements that the court had deemed admitted, and it granted Marvic's motion for summary judgment on Foss's state law claims. The First Circuit affirmed, holding that the district court did not err or abuse its discretion as to the disputed rulings. View "Foss v. Marvic, Inc." on Justia Law

Posted in: Copyright
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The First Circuit vacated the ruling of the district court denying Plaintiffs' motion for a preliminary injunction in this case, holding that record lacked necessary findings and that remand was required.This case arose from a decision by the Speaker of the New Hampshire House of Representatives to enforce a House rule precluding any representative from participating in proceedings involving the full House, including House matters, other than in person. Plaintiffs, including seven members of the House who claimed to suffer from medical conditions making them vulnerable to COVID-19, brought this action arguing that the Speaker was required to allow them to participate remotely under Title II of the Americans with Disabilities Act, 42 U.S.C. 12132, and section 504 of the Rehabiliation Act, 29 U.S. 794. The district court denied Plaintiffs' motion for a preliminary injunction. The First Circuit vacated the district court's decision, holding that the court erred in finding that the doctrine of legislative immunity shielded the Speaker from having to comply with the ADA and/or Section 504. View "Cushing v. Packard" on Justia Law

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The First Circuit affirmed the judgment of the district court denying Appellant's petition for a writ of habeas corpus, holding that Appellant was not entitled to relief.Appellant was convicted in Massachusetts of murder in the first degree. The Massachusetts Supreme Judicial Court affirmed. In his habeas petition, Appellant argued that testimony was erroneously introduced at trial that he had given to a grand jury without being advised of his privilege against self-incrimination. Appellant presented this same argument in his challenge to his conviction on appeal and in his appeal of the denial of his motion for a new trial, all without success. The district court denied Appellant's habeas petition. The Supreme Judicial Court affirmed, holding that Appellant's Fifth Amendment rights were not violated by the admission of his grand jury testimony. View "Woods v. Medeiros" on Justia Law

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In this appeal arising from a contract action, the First Circuit affirmed the judgment of the district court denying Appellants' post-trial request for a declaratory judgment, holding that the district court did not abuse its discretion.Appellants, Covidien LP and Covidien Holding Inc. (collectively Covidien), brought this action against Brady Esche, a former employee, who assigned medical device patent rights to a company he subsequently founded, seeking declaratory judgment to the effect that Esch assign his rights, title, and interest in the patent applications to Covidien. Covidien also alleged that Esch breached his obligations under employment and/or separation agreements he signed. The jury found that Esch breached confidential information and awarded Covidien damages. Covidien subsequently moved for a declaratory judgment asking that Esch be required to assign to Covidien the inventions he subsequently made. The district court denied the request. The First Circuit affirmed, holding that the district court did not abuse its discretion in denying Appellants' post-trial declaratory judgment request. View "Covidien LP v. Esch" on Justia Law

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The First Circuit denied the petition filed by Petitioner, a Salvadoran national, seeking judicial review of a decision of the Board of Immigration Appeals (BIA) upholding an adverse decision by an immigration judge (IJ) denying Petitioner's application for withholding of removal, holding that Petitioner was not entitled to relief.Specifically, the First Circuit held (1) substantial evidence in the record supported the agency's determination that Petitioner failed to show an entitlement to withholding of removal based on a clear probability of either past or future religious persecution; (2) Petitioner waived his argument that the BIA erred in rejecting his "social group" claim; and (3) the BIA did not abuse its discretion by not remanding the case to the IJ for further proceedings. View "Sanchez-Vasquez v. Garland" on Justia Law