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

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The First Circuit affirmed on a limited basis the district court's ruling that Plaintiffs suit must be dismissed for lack of personal jurisdiction, holding that dismissal was required.Plaintiff, a New York resident, brought this suit over a for-profit Israeli corporation that ranked the performance of United States investment analysts, claiming that that company defamed her in Massachusetts by posting a low rating of her professional performance. The district court dismissed the suit for lack of personal jurisdiction. The First Circuit affirmed, holding that Plaintiff failed to meet her burden to adduce evidence of specific facts sufficient to satisfy the requirements of constitutional due process for the exercise of personal jurisdiction. View "Lin v. TipRanks, Ltd." on Justia Law

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The First Circuit vacated the judgment of the judgment of the district court granting a motion to compel arbitration filed by the personal representative of the estate of a famous American artist (Estate), dismissing an art publisher's (Publisher) motion for a preliminary injunction as moot, and eventually dismissing the case, holding that the district court erred.At issue was an agreement between the Estate and Publisher. Publisher asserted that the parties' original contract, which included an agreement to arbitration, was terminated and supplanted by a superseding contract that did not contain an arbitration provision. In question was whether the arbitrability of the parties' dispute about the newer contract's enforceability and impact on the earlier agreement to arbitrate should be decided by the court or by arbitrators. The district court concluded that the gateway question of arbitrability was for the arbitrators. The First Circuit reversed, holding that it is the court, and not the arbitrators, that must resolve the disagreement in this case. View "McKenzie v. Brannan" on Justia Law

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The First Circuit affirmed the judgment of the district court denying Petitioner's petition for a writ of habeas corpus seeking to overturn his 2010 New Hampshire conviction for aggravated felonious sexual assault, holding that the district court properly rejected Petitioner's Sixth Amendment claim.In his habeas petition, Petitioner asserted that his Sixth Amendment right to autonomy to determine the objectives of his defense when his counsel took certain actions to present a defense at trial, despite Petitioner's instructions not to do so. The district court denied the petition. The First Circuit affirmed, holding that Petitioner was not denied autonomy to direct the objectives of his defense when his trial counsel presented an active defense contrary to Petitioner's express wishes. View "Kellogg-Roe v. Gerry" on Justia Law

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In this vaccination dispute, the First Circuit denied the motion brought by Appellants seeking an injunction pending appeal, holding that Appellants were not entitled to the injunction.Appellants, eight employees of Mass General Brigham, Inc. (MGB), challenged MGB's application of its mandatory vaccination policy to them individually. The policy was issued in June 2021 requiring all MGB employees to be vaccinated against COVID-19 unless they qualified for a medical or religious exemption. After Appellants' requests for exemptions were denied and they still refused to get vaccinated, MGB placed them on unpaid leave. Appellants sued under Title VII of the Civil Rights Act and the Americans with Disabilities Act, arguing that MGB unlawfully denied their individual exemption requests. The district court denied Appellants' motion for a preliminary injunction, which would have required Appellants' reinstatement from unpaid leave status. The First Circuit denied Appellants' motion for injunction pending appeal, holding that adequate legal remedies foreclosed injunctive relief. View "Together Employees v. Mass General Brigham Inc." on Justia Law

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The First Circuit affirmed the judgment of the district court denying Appellant's motion to suppress evidence recovered during a traffic stop, holding that the district court did not err when it denied the motion to suppress.Appellant entered a conditional guilty plea to possession of a controlled substance with the intent to distribute, reserving the right to appeal the district court's denial of his motion to suppress both statements he made at the scene of his traffic stop and the physical evidence obtained during the stop. In denying the motion to suppress, the district court concluded that the law enforcement officer had reasonable suspicion to stop Defendant's car. The First Circuit affirmed, holding that the officer had a reasonable basis to believe Appellant had committed a traffic infraction and thus to perform a traffic stop. View "United States v. Miles" on Justia Law

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The First Circuit granted in part and denied in part Petitioner's petition for review of the decisions of the Board of Immigration Appeals (BIA) determining that Petitioner's previous conviction constituted a "particularly serious crime" making him ineligible for withholding of removal and denying his application for deferral of removal under the Convention Against Torture (CAT), holding that the BIA erred in part.The lower agencies found that Petitioner's conviction for possession of oxycodone with intent to distribute in violation of Mass. Gen. Laws ch. 94C, 32A(a) was a particularly serious crime rendering him ineligible for withholding of removal and denied his application for deferral of removal under the CAT. The First Circuit denied Petitioner's petition for review insofar as he sought CAT relief but granted the petition in part because the immigration judge informed Petitioner that he was eligible for potential relief only under the CAT and treated Petitioner's conviction for drug trafficking as if it were a per se bar to withholding of removal. The First Circuit remanded the case to the BIA with instructions to give Petitioner a new hearing to determine whether he was entitled to withholding of removal. View "De Carvalho v. Garland" on Justia Law

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The First Circuit affirmed the judgment of the district court granting two summary judgment motions in favor of Defendants in this class action lawsuit, holding that Defendants' actions in this case could not support a claim under the Racketeer Influenced and Corrupt Organizations Act (RICO).In granting the two summary judgment motions at issue, one filed on behalf of all Defendants and on filed behalf of certain Defendants, the district court adopted the findings of law of the Court of Appeals of Puerto Rico in Collazo Burgos v. La Asociación de Suscripción Conjunta del Seguro de Responsabilidad Obligatorio, No. K AC2010-0179, 2017 WL 6884428 (P.R. Cir. Nov. 30, 2017). The court further held that Defendants' actions were required under Puerto Rico law and thus could not support a RICO claim. The First Circuit affirmed, holding that the district court did err under the Erie doctrine in adopting the reasoning of the court of appeals in Collazo Burgos. View "Torres-Ronda v. Nationwide Mutual Insurance Co." on Justia Law

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The First Circuit affirmed the judgment of the district court entering three separate judgment opinions and orders against Puerto Rico Industrial Development Company (PRIDCO) in this action brought by the United States seeking to recover response costs associated with the cleanup of the Maunabo Area Groundwater Contamination Superfund Site, holding that the district court did not err.The United States brought this action under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), 42 U.S.C. 9601 et seq., against PRIDCO, as a potentially responsible party. PRIDCO owned property on the Site that contained elevated levels of hazardous substances in the groundwater that were found downgradient in a public drinking water well. In its orders against PRIDCO, the district court found, inter alia, that the United States had established its prima facie case against PRIDCO for liability under CERCLA and that PRIDCO was liable for $5.5 million in past response costs and would be liable for additional response costs reasonably incurred by the United States. The First Circuit affirmed, holding that the entry of summary judgment and award of response costs was not error. View "United States v. Puerto Rico Industrial Development Co." on Justia Law

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The First Circuit affirmed Defendant's conviction of one count of knowingly distributing child pornography, holding that the district court did not err in excluding the testimony of Dr. Robert Weiss, a therapist and relationship specialist with a speciality in sex addiction.Defendant's prisonmate, Dmitry Bron, was working with law enforcement when Defendant shared his collection of images of child sexual abuse with Bron. At trial, Defendant attempted to pursue an entrapment defense and sought to introduce the testimony of Dr. Weiss. The district court granted the government's motion to exclude Dr. Weiss, concluding that the testimony was not relevant to Defendant's defense. The First Circuit affirmed, holding that the district court did not abuse its discretion in excluding Dr. Weiss's testimony on the ground that it was not relevant. View "United States v. Saemisch" on Justia Law

Posted in: Criminal Law
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In this dispute between the Maine lobster industry and the National Marine Fisheries Service (the Agency) over a rule barring frequently employed methods of lobstering the First Circuit granted the Agency's motion for a stay pending appeal of the district court's issuance a permanent injunction, holding that the Agency was entitled to a stay.In 2021, the Agency issued a rule barring, from October to January each year, the most frequently employed methods of lobstering in an approximately 1,000-square-mile area of the Atlantic Ocean in order to reduce the risk that a right whale would become entangled in the ropes connecting lobster traps to buoys. Plaintiffs brought this action seeking to postpone enforcement of the new rule until the district court could finally decide whether the new rule was lawful. The district court granted Plaintiffs' preliminary request. The Agency appealed and asked the First Circuit to issue a stay of the district court order. The First Circuit granted the government's motion, holding the district court misapprended the record and erred in rejecting the Agency's arguments. View "District 4 Lodge of the International Ass'n v. Raimondo" on Justia Law