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

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The First Circuit affirmed the decision of the district court denying Appellant's motion to vacate an arbitrator's award, holding that Appellant's attack on the merits of the arbitral award was unavailing. IBC Advanced Alloys Corp. purchased a Beralcast Corporation from Gerald Hoolahan and Gary Mattheson in exchange for cash and shares in the IBC. When Hoolahan decided to sell his shares in the company one year later, he was blocked. Hoolahan later discovered that Mattheson hadn't been similarly blocked when he placed his shares on the market. Hoolahan initiated an arbitration against IBC. During a subsequent hearing it was discovered that IBC had harbored ill-will against Hoolahan, causing it to block Hoolahan's attempt to sell. The arbitrator awarded Hoolahan damages in the amount he would have received if he had sold his shares at the same rate Mattheson received. After IBC unsuccessfully requested that the arbitrator modify the award IBC asked the district court to vacate the award. The district court denied relief. The First Circuit affirmed, holding that IBC did not make a showing that the arbitrator acted in manifest disregard of the law when deciding the award. View "Hoolahan v. IBC Advanced Alloys Corp." on Justia Law

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In this breach of contract action the First Circuit affirmed as not clearly erroneous the district court's judgment in favor of Defendant after a bench trial finding no binding contract between the parties, holding that Plaintiff offered no persuasive argument that the district court committed clear error. The First Circuit in this case clarified the difference between facts sufficient to make a claim plausible for pleading purposes and facts sufficient to render a judgment against the claimant clearly erroneous. In a prior decision, the First Circuit reviewed a grant of a motion to dismiss for failure to state a claim and stated that the Court could "plausibly infer" that the parties had formed a contract. The Court emphasized that just because a complaint states a plausible claim for relief does not mean that the claimant has conclusively proven that claim. With the case before the First Circuit a second time, the Court held that by reading too much into its prior ruling, Plaintiff misapprended the manner in which the burden of proof rested once the district court tried the case to a decision and further provided no persuasive argument that the district court committed clear error on remand by determining that no contract existed between the parties. View "APB Realty, Inc. v. Georgia-Pacific LLC" on Justia Law

Posted in: Contracts
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The First Circuit affirmed Defendant's conviction of interstate transportation of a minor with intent to engage in criminal sexual activity, holding that the district court did not err in denying Defendant's motion to suppress the confession he made during the second phase of his custodial interrogation. In support of his motion to suppress Defendant argued that the interrogation violated his Fifth Amendment rights as set forth in Miranda v. Arizona, 384 U.S. 436 (1966), and Edwards v. Arizona, 451 U.S. 477 (1981). The district court denied the motion, finding that Defendant initiated the second phase of the interview, that Defendant did not thereafter reinvade his right to counsel, and that Defendant knowingly and voluntarily waived his Miranda rights before confessing. The First Circuit affirmed, holding that Defendant's confession was admissible at trial for all of the reasons determined by the district court. View "United States v. Carpentino" on Justia Law

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The First Circuit affirmed the district court's dismissal of Plaintiff's claims alleging that Defendants violated the Massachusetts Consumer Protection Act, Mass. Gen. Laws ch. 93A, and the Massachusetts Fair Debt Collection Practices Act, Mass. Gen. Laws ch. 93, 49, holding that both counts were time-barred. Plaintiff filed her complaint against the current holder of a mortgage on her property and the servicer of the mortgage loan, alleging that the loan was predatory because at its inception the lender knew or should have known that Plaintiff would not be able to repay it. Defendants removed the case to federal district court and then moved to dismiss the complaint. The district court dismissed the chapter 93A count as time-barred and the second count on the ground that chapter 93, 49 does not provide private right of action. The First Circuit affirmed the dismissal of both counts, albeit on different grounds, holding that both the chapter 93A claim and the chapter 93, 49 claims were time-barred. View "O'Brien v. Deutsche Bank National Trust Co." on Justia Law

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The First Circuit reversed Defendant's conviction, holding that the district court erred in denying Defendant's motion to suppress seized evidence because law enforcement officers' warrantless entry into the house where Defendant was living, on the grounds that exigent circumstances existed, was unconstitutional, and there was no evidence demonstrating a different exception to the warrant requirement applied. Defendant was convicted of sixteen counts of production of child pornography and one count of possession of child pornography involving prepubescent minors. Defendant appealed the denial of his motion to suppress, arguing that the warrantless entry into his mother's house, where he was living, was presumptively unreasonable and that no exception to the warrant requirement existed. The First Circuit agreed and remanded the case to the district court to determine whether consent to the entry was given, holding that entry into the home on the basis of exigency was unconstitutional and could not serve as justification for the search and seizure that followed. View "United States v. Rodriguez-Pacheco" on Justia Law

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In this case involving a dispute between Portland Pipe Line Corporation (PPLC) and the City of South Portland (the City) the First Circuit certified three questions to the Maine Law Court because this clash raised important questions of state law preemption doctrine and statutory interpretation that are unresolved and may prove dispositive. The parties to this dispute were PPLC, a Maine corporation engaged in the international transportation of oil, and the City, which enacted a municipal zoning ordinance prohibiting the bulk loading of crude oil onto vessels in the City's harbor. The ordinance prevented PPLC from using its infrastructure to transport oil from Montreal to South Portland via underground pipelines. PPLC appealed the district court's dismissal of its claims, arguing that the ordinance was preempted by Maine's Coastal Conveyance Act and was in conflict with federal constitutional law. The First Circuit declined to address the federal questions, concluding that the case lacked controlling precedent and presented difficult legal issues that warranted certification to the Law Court. View "Portland Pipe Line Corp. v. City of South Portland" on Justia Law

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The First Circuit affirmed Defendant's sentence imposed in connection with his plea of guilty to conspiracy to distribute and possess with intent to distribute controlled substances and possession with intent to distribute the same, holding that a defendant's potential future deportation is a factor that a sentencing court may consider under 18 U.S.C. 3553(a). By the time of sentencing, a detainer had been filed against Defendant with an eye toward subsequent deportation. Defendant requested that the sentencing court consider his future deportation and the possibility of a downward variance on that basis. The district court determined that it would not give weight to Defendant's potential deportation when fashioning Defendant's sentence. The court then imposed an eighty-seven-month term of immurement. The First Circuit affirmed, holding (1) under appropriate circumstances, a defendant's potential deportation may properly be considered pursuant to section 3553(a)(1); and (2) the court did not abuse its discretion in determining that it would not give weight to Defendant's potential future deportation. View "United States v. Hercules" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed the sentence imposed in connection with Defendant's plea of guilty to being a felon in possession of a firearm and ammunition, holding that Defendant's appeal waiver barred this appeal. Defendant pled guilty to being a felon in possession of a firearm. The district court sentenced Defendant to thirty-seven months' imprisonment and ordered that the sentence run consecutively to a seven-year sentence Defendant had previously received for an unrelated state drug offense. Defendant appealed, arguing that the district court erred by imposing a consecutive, rather than a concurrent, sentence. The government argued that Defendant's appeal was barred because, as part of his guilty plea, he expressly waived his right to appeal. The First Circuit affirmed, holding that enforcement of the appeal waiver did not result in a miscarriage of justice. View "United States v. Santiago" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed the sentence imposed by the district court in connection with Defendant's plea of guilty to a single count charging him with drug distribution in violation of 21 U.S.C. 841(a)(1), holding that the sentence was supportable when viewed as an upward variance. Relying on a finding that a death resulted from the offense of conviction in this case, the district court imposed an above-the-range term of imprisonment. The court justified the sentence both as an upward departure and an upward variance. On appeal, Defendant challenged his sixty-month sentence both procedurally and substantively. The First Circuit affirmed, holding (1) any error in invoking a departure guideline was harmless where the district court would have imposed exactly the same sentence by means of a variance; (2) the district court did not abuse its discretion by considering in its decision to impose an upward variance the fact that an individual died after using the fentanyl-laced substance knowingly sold to him by Defendant; and (3) the sentence was not outside the universe of reasonable sentencing outcomes and therefore was substantively reasonable. View "United States v. Heindenstrom" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed the district court's order dismissing Plaintiff's disability discrimination and failure to accommodate claims on summary judgment, holding that the district court did not abuse its discretion in partially striking Plaintiff's affidavit submitted in support of his opposition to Defendant's motion for summary judgment and that Plaintiff failed to establish a prima facie case of disability discrimination or a claim for failure to accommodate. Specifically, the Court held (1) the district court did not clearly abuse its discretion in striking Plaintiff's inconsistent statements in his affidavit; and (2) the district court properly granted summary judgment because Plaintiff failed to establish a prima facie case of disability discrimination and that Plaintiff's failure to accommodate claims failed on the merits. View "Flaherty v. Entergy Nuclear Operations, Inc." on Justia Law