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

The appellant worked for the appellee as an information technology employee in Boston for over twenty-five years. In August 2019, the company placed her on a three-month performance improvement plan (PIP), which she completed successfully. Approximately ten months after completing the PIP, she resigned from her position. She subsequently brought suit against her former employer, claiming, among other things, that she was subjected to unlawful age discrimination when she was placed on the PIP and then constructively discharged.The United States District Court for the District of Massachusetts granted summary judgment to the employer. The court found that no reasonable factfinder could conclude that the PIP constituted an adverse employment action or that the circumstances of her resignation amounted to a constructive discharge. In the district court’s view, the plaintiff’s successful completion of the PIP, the absence of demotion or pay reduction, and the lack of substantial changes in her responsibilities meant she did not suffer an adverse employment action. The court also concluded that the comments and actions by her supervisors did not create intolerable working conditions that would force a reasonable person to resign.On appeal, the United States Court of Appeals for the First Circuit first addressed the timeliness of the appeal. The court determined that the appellant’s pro se motion for extension of time to file a notice of appeal met the requirements to be treated as a timely notice of appeal, making the appeal timely. On the merits, the First Circuit affirmed the district court’s judgment. It held that, under the Supreme Court’s standard in Muldrow v. City of St. Louis, the PIP did not alter the terms or conditions of employment, and that the record did not support a finding of constructive discharge. The decision of the district court was affirmed. View "Walsh v. HNTB Corporation" on Justia Law

Jacob Parlin was arrested after law enforcement, investigating a narcotics operation, intercepted communications implicating him in drug transactions. The Drug Enforcement Administration (DEA) began wiretapping a suspected dealer’s phone, capturing conversations among Parlin, the dealer, and a third party, which discussed drug sales and pricing strategies. Following these intercepts, officers stopped Parlin's vehicle and discovered nearly two pounds of pure methamphetamine, along with drug paraphernalia and a small quantity of drugs indicative of personal use.A federal grand jury indicted Parlin on conspiracy to distribute and possession with intent to distribute fifty grams or more of methamphetamine, as well as substantive distribution and possession charges. At trial in the United States District Court for the District of Massachusetts, Parlin objected to a police officer's testimony about the typical amount of methamphetamine held by users versus distributors, arguing the officer was giving undisclosed expert testimony. The court allowed the testimony, finding it was based on the officer’s personal observations. Parlin was convicted by a jury on both counts. He then moved for acquittal or a mistrial, asserting the testimony was improper; the district court denied these motions, determining the testimony was appropriately limited and other evidence supported the verdict.Parlin appealed to the United States Court of Appeals for the First Circuit, contending the district court erred by admitting the officer’s opinion testimony and that, without it, the evidence was insufficient to prove intent to distribute. The First Circuit held that, even if admitting the testimony was error, it was harmless given the overwhelming evidence of Parlin's intent to distribute, including recorded phone calls and the large quantity of drugs. The court affirmed Parlin’s conviction on both counts. View "United States v. Parlin" on Justia Law

A woman from Honduras entered the United States without inspection in 2012 and applied for asylum, withholding of removal, and protection under the Convention Against Torture. She based her claims primarily on her bisexual identity and described various events from her past, including childhood abuse by her father, witnessing violence in her community, receiving derogatory comments and a single unfulfilled threat from an unknown man, and experiencing a burglary. She testified that, although bisexuality is not accepted in Honduras, she lived openly as a bisexual woman for over two years without suffering physical harm due to her sexual orientation. She submitted evidence of discrimination and violence against sexual minorities in Honduras, as well as reports on country conditions.An Immigration Judge (IJ) conducted a merits hearing, found her testimony generally credible, but denied all relief. The IJ concluded that the harm she described did not rise to the level of persecution, that she failed to show her sexual orientation was a central reason for any harm, and that the Honduran government was not shown to be unwilling or unable to protect her from private actors. The IJ also found she did not establish a well-founded fear of future persecution. The Board of Immigration Appeals (BIA) dismissed her appeal, affirming the IJ’s findings and holding that she waived any challenge to the denial of protection under the Convention Against Torture.The United States Court of Appeals for the First Circuit reviewed both the IJ’s and BIA’s decisions, applying the substantial evidence standard. The court held that substantial evidence supported the agency’s conclusions that she failed to demonstrate past persecution, a nexus to a protected ground, or governmental unwillingness or inability to protect her. The court denied her petition for review. View "Maldonado-Ruiz v. Bondi" on Justia Law

The case involves a defendant who was recruited in Puerto Rico to act as a courier, transporting two suitcases containing approximately eleven kilograms of cocaine on a flight to Newark, New Jersey. Airport authorities in San Juan discovered the drugs before the defendant boarded the flight. After her arrest, she admitted to knowingly transporting the suitcases for a promised payment of $1,500, a sum far less than the drugs’ street value.Following her guilty plea to conspiracy and possession with intent to distribute cocaine, the United States District Court for the District of Puerto Rico sentenced her to forty-eight months in prison and forty-eight months of supervised release. The Probation Office recommended a three-level reduction in her Sentencing Guidelines offense level based on her minor or minimal role, highlighting other individuals who recruited her, organized the transport, and prepared the luggage. The government objected, arguing she was indispensable to the offense. The district court agreed with the government and denied the mitigating-role reduction, focusing primarily on her own conduct and the fact she was the one transporting the drugs.On appeal, the United States Court of Appeals for the First Circuit reviewed whether the district court properly conducted the required comparative culpability analysis under the Sentencing Guidelines. The appellate court held that the district court erred by failing to consider the roles of all participants in the criminal activity and by not applying the multi-step analysis clarified in United States v. Guía-Sendeme. The First Circuit vacated the sentence and remanded for resentencing so the district court could properly assess the defendant’s eligibility for a mitigating-role reduction, consistent with current precedent and the proper legal framework. View "United States v. Robles-Lopez" on Justia Law

A black-owned construction company was not invited to bid as general contractor on a major Boston public housing redevelopment project after participating in pre-construction work. Years earlier, the developer had called the company’s president to discuss possible involvement, but the parties disputed what promises, if any, were made during that conversation. The construction company performed pre-construction work and was later selected as general contractor for the first phase (Camden), but after performance and communication issues arose during that project, the developer chose a different, white-owned company for the second phase (Lenox). The construction company did not protest at the time but later sued, alleging breach of contract, quasi-contract, violation of Massachusetts consumer protection law, and racial discrimination under 42 U.S.C. § 1981.The matter was first brought in Massachusetts state court, then removed to the United States District Court for the District of Massachusetts based on federal question jurisdiction. After discovery, the developer moved for summary judgment. The District Court granted summary judgment for the developer, finding no enforceable contract or promise had been made regarding the Lenox phase, that the quasi-contract and Chapter 93A claims failed as derivative, and that there was insufficient evidence of racial discrimination.The United States Court of Appeals for the First Circuit affirmed the District Court’s decision. The First Circuit held that the summary judgment record did not contain evidence from which a reasonable jury could find an enforceable implied-in-fact contract or a promise sufficient for promissory estoppel. It further held that the plaintiff failed to create a triable issue of fact regarding pretext or discriminatory intent under § 1981, given the legitimate business reasons cited for the company’s exclusion. Thus, summary judgment on all claims was proper. View "John B. Cruz Construction Co. v. Beacon Communities Corp." on Justia Law

Two individuals each owned companies that distributed snack foods for a larger food company. Years earlier, they had joined a class action lawsuit claiming that the company misclassified them as independent contractors rather than employees. That class action ended in a settlement, which included an optional provision: class members could agree to arbitrate future disputes in exchange for an additional payment. Both individuals opted into that provision and accepted the payment, thereby agreeing to resolve future disputes through arbitration.Several years later, the two individuals brought a new lawsuit in the United States District Court for the District of Massachusetts, again asserting claims related to alleged misclassification and seeking damages. The defendant company moved to stay the case and compel arbitration under the Federal Arbitration Act (FAA), citing the prior agreement. The plaintiffs opposed, arguing that they were exempt from the FAA as transportation workers under Section 1. The district court rejected that exemption argument, but did not order arbitration. Instead, it stayed and administratively closed the case without entering judgment, stating it was not compelling arbitration but was closing its doors to further proceedings.The United States Court of Appeals for the First Circuit reviewed the district court’s handling. The court held that, although the district court did not expressly deny the motion to compel arbitration, its actions amounted to a denial, and thus appellate jurisdiction existed under 9 U.S.C. § 16(a)(1)(B). The First Circuit vacated the district court’s order and remanded the case for further proceedings, directing the district court to determine whether the motion to compel arbitration should be granted or denied and to explain its reasoning. The court also clarified that, under the parties’ agreement, any compelled arbitration must proceed on an individual, not class, basis. View "Perruzzi v. The Campbell's Company" on Justia Law

Two individuals entered into a loan agreement and mortgage with a bank in Puerto Rico, using their home as collateral. After a decade, they faced financial difficulties and stopped making payments. The bank denied a request to modify the loan but proposed a short sale. The bank then initiated foreclosure proceedings in Puerto Rico’s Court of First Instance, resulting in a judgment against the borrowers. Multiple short sale offers were rejected until one was conditionally accepted, but the sale did not close in time and the home was foreclosed. Subsequently, the bank garnished funds from the borrowers, who then filed for Chapter 13 bankruptcy.The United States Bankruptcy Court for the District of Puerto Rico confirmed the borrowers’ Chapter 13 plan, noting their intent to pursue claims against the bank. The borrowers filed an adversary proceeding seeking damages and other relief. The bank moved to dismiss the adversary complaint, but the bankruptcy court denied this motion, allowing the case to proceed. The borrowers later filed a similar complaint in the United States District Court for the District of Puerto Rico and moved to withdraw the adversary proceeding to the district court. The district court denied the withdrawal as untimely and dismissed the separate federal case. After the borrowers completed their bankruptcy plan and received a discharge, the bankruptcy court dismissed the adversary proceeding for lack of subject matter jurisdiction.On appeal, the United States Court of Appeals for the First Circuit held that the bankruptcy court erred in finding it automatically lost jurisdiction over the adversary proceeding post-discharge. The appellate court vacated and remanded the case for further proceedings, instructing the lower courts to reassess jurisdiction and properly address the borrowers’ motion for withdrawal and their jury trial request. View "Guallini-Indij v. Banco Popular de Puerto Rico" on Justia Law

The City of Boston, along with its Public Health Commission and Housing Authority, brought suit against two pharmacy benefit managers (PBMs), OptumRx and Express Scripts, alleging that the PBMs had worked with opioid manufacturers to misrepresent the risks of opioid drugs. The City claimed that this conduct violated Massachusetts public nuisance law and resulted in harm to the City. The PBMs removed the case to federal court and argued that the suit was untimely because it was brought after the three-year statute of limitations had expired. The City responded by asserting that its complaint sufficiently alleged a continuing nuisance and that the statute of limitations should be tolled due to the PBMs’ fraudulent concealment of their wrongdoing.The United States District Court for the District of Massachusetts granted the PBMs’ motion to dismiss, finding that the City either knew or should have known of its injuries and of the PBMs’ alleged role before 2021, based on public records and prior litigation, and thus failed to file suit within the statutory period. The district court further ruled that the City had not adequately pled a continuing nuisance, as it did not allege any specific, recent unlawful acts within the limitations period, and rejected the City’s claim of fraudulent concealment, determining that the City had the means to discover the facts needed for its claim. The district court also denied a motion by the PBMs to disqualify the City's law firm, Motley Rice.On appeal, the United States Court of Appeals for the First Circuit affirmed both the dismissal of the City’s state law claim and the denial of the motion to disqualify Motley Rice. The court held that the action was time-barred and that the City had not met the requirements for tolling the statute of limitations or for pleading a continuing nuisance under Massachusetts law. View "The City of Boston v. OptumRx, Inc." on Justia Law

Steven and Virginia Savage were officers and sole shareholders of a company that designed and installed digital planetarium equipment. When their company experienced financial distress, they used personal funds and credit cards to support business operations, but the company eventually defaulted on a large loan personally guaranteed by the Savages. In the year preceding their bankruptcy filing, the Savages received over $700,000 from the company, which they failed to fully disclose in their bankruptcy filings. Their bankruptcy schedules did not mention this income, and significant portions of the transferred funds were not satisfactorily explained, especially regarding rent payments from the company to the Savages and the use of those funds.After the company and the Savages filed for bankruptcy, the creditor, Coastal Capital, objected to the Savages’ discharge in their Chapter 7 proceedings. The United States Bankruptcy Court for the District of New Hampshire held a bench trial and found that, although the Savages explained most of the company funds they received, they failed to account for over $56,000. The court denied the Savages a discharge under 11 U.S.C. § 727(a)(5) for failing to satisfactorily explain the loss or deficiency of assets. The Savages’ post-trial motions were denied, and the United States District Court for the District of New Hampshire affirmed the bankruptcy court’s ruling.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s judgment. The court held that § 727(a)(5) does not require a “substantial” loss of assets to deny discharge, nor does it require that the unaccounted-for funds be enough to pay all liabilities. It also found no clear error in the bankruptcy court’s factual determinations and rejected the Savages’ arguments regarding destruction of evidence and the sufficiency of their explanations. The denial of discharge was affirmed. View "Coastal Capital, LLC v. Savage" on Justia Law

A nurse employed by Puerto Rico’s State Insurance Fund Corporation reported sexual harassment by a coworker in 2020 and subsequently filed an administrative charge of discrimination and retaliation. After dropping her sexual harassment claim, she pursued a retaliation claim, arguing that she endured a hostile work environment and was involuntarily transferred to a different office. The incidents underlying her claim included several allegedly meritless disciplinary actions and the eventual transfer.The United States District Court for the District of Puerto Rico granted a preliminary injunction separating her from the coworker and, after trial, a jury found in her favor on the retaliation claim, awarding $300,000 in damages. The district court later denied her request for a permanent injunction seeking reassignment to her former office and expungement of disciplinary records. The court awarded her approximately $301,000 in attorney fees and costs, but she challenged the amount as insufficient. Finally, although the defendant did not appeal the judgment or fee award, the district court stayed execution of both under Puerto Rico law, pending approval of a payment plan by the Secretary of Justice.The United States Court of Appeals for the First Circuit affirmed the denial of permanent injunctive relief and the attorney fee award, finding that the district court did not abuse its discretion on either point and that the fee reductions and denial of injunctive remedies were reasonable. The Court of Appeals also vacated the stay of execution of judgment and fees, holding that Puerto Rico’s statutory payment plan requirement could not delay enforcement of a federal judgment under Title VII. The case was remanded for further proceedings consistent with these rulings. View "Garcia Colon v. State Insurance Fund Corporation" on Justia Law