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

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The First Circuit affirmed Defendant's conviction, entered upon his guilty plea, for one count of being a felon in possession of a firearm and sentence of fifteen years of incarceration followed by three years of supervised release, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant failed to establish plain error on his argument that his plea colloquy was facially invalid because of an omission that rendered his guilty plea unknowing and involuntary; (2) Defendant waived his right challenge the sufficiency of the indictment by pleading guilty; (3) although Defendant's challenge to the government's failure to file substantial assistance motions fell outside the scope of the appeal waiver, this Court nevertheless holds that the district court did not err in declining to hear evidence before sentencing; (4) Defendant's prior convictions under the Massachusetts drug distribution statute were properly characterized as Armed Career Criminal Act predicates; and (5) the district court did not err in deciding to proceed with sentencing despite argument from defense counsel that the government had failed to honor the terms of a cooperation agreement. View "United States v. Doe" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed the convictions of Appellants Edilio Benjamin-Hernandez (Benjamin) and Johanni Balbuena-Hernandez (Balbuena) on multiple charges stemming from a conspiracy to transport cocaine from the Dominican Republic to Puerto Rico, holding that Appellants were not entitled to relief on their claims of error.On appeal, Appellants challenged the district court's denial of their motion to dismiss and argued that the evidence presented at trial was insufficient to support the convictions. Benjamin also raised two evidentiary challenges. The First Circuit affirmed, holding (1) there was no violation of the Speedy Trial Act's seventy-day limit; (2) no Sixth Amendment violation occurred in this case; and (3) there was sufficient evidence supporting Appellants' convictions. View "United States v. Benjamin-Hernandez" on Justia Law

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The First Circuit affirmed the judgment of a federal district judge in Maine sentencing Defendant on drug-distribution and communications-device counts, holding that the sentence was neither procedurally nor substantively unreasonable.In 2019, a Maine federal grand jury indicted Defendant for possessing drugs (crack and heroin) with intent to distribute and for using a communications device to commit a drug crime. Defendant pled guilty. The Maine federal judge varied downwards to 137 months and structured his term to run concurrently with the remainder of a Connecticut sentence. The First Circuit affirmed the sentence imposed, holding that nothing Defendant argued on appeal persuaded the Court that his below-guidelines sentence was implausible or indefensible. View "United States v. Perry" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed the judgment of the district court denying Defendant's motion to withdraw his guilty plea and sentencing him to consecutive sentences of life imprisonment for discharging a firearm during and in relation to a crime of violence resulting in death and attempted carjacking, holding that there was no error or abuse of discretion.On appeal, Defendant argued that the district court abused its discretion in denying his motion to withdraw his guilty plea and that his sentence was neither procedurally nor substantively reasonable. The First Circuit disagreed and affirmed, holding (1) the district court did not abuse its discretion in denying Defendant's motion to withdraw his guilty plea; and (2) there was no significant procedural or substantive error. View "United States v. Bruzon-Velazquez" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed the judgment of the district court confirming certain damages awarded to The University of Notre Dame (USA) in England (Notre Dame) by a foreign arbitral tribunal in a contractual dispute relating to construction defects, holding that Notre Dame's petition for judicial confirmation of the awards was not time-barred.Notre Dame brought this action against TJAC Waterloo, LLC and ZVI Construction Co., who were, respectively, the seller and renovator of a dormitory that Notre Dame had agreed to purchase. The dispute was submitted to arbitration. After the arbitrator entered the awards, Notre Dame moved the district court to confirm the awards and entered summary judgment in its favor. The district court granted Notre Dame's request for judicial confirmation. The First Circuit affirmed, holding that Notre Dame's motion for judicial confirmation was not time-barred. View "University of Notre Dame (USA) in England v. TJAC Waterloo, LLC" on Justia Law

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The First Circuit affirmed the judgment of the district court denying Defendant's latest request to withdraw his guilty plea to conspiring to import Cocaine into the United States and money laundering to promote this conspiracy, holding that the district court did not err in denying Defendant's motion to withdraw his guilty plea.Multiple times before he was sentenced Defendant filed motions to withdraw his guilty plea. As to Defendant's most recent withdrawal motion, the magistrate judge recommended that the district court grant the motion. The district court disagreed and denied Defendant's request to withdraw his plea. The First Circuit affirmed, holding (1) the district court's analysis of the plea withdrawal motion was flawed in two respects, but the district court did not abuse its discretion in denying Defendant's motion to withdraw the guilty plea; and (2) the district court did not err in exercising jurisdiction over Defendant. View "United States v. Fonseca" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed the judgment of the district court dismissing Amyndas Pharmaceuticals, S.A.'s claims against Zealand Pharma A/S and vacated the dismissal of Amyndas's claims against Zealand Pharma U.S., Inc., holding that the district court erred in dismissing Amyndas's claims against Zealand Pharma U.S.When Amyndas was considering separate joint ventures with Zealand Pharma and Alexion Pharmaceuticals, Inc. it shared trade secrets before understanding that neither of the joint ventures would materialize. Zealand Pharma and Zealand US, its newly established affiliate, subsequently announced a partnership with Alexion Pharmaceuticals, Inc. Amyndas sued for misappropriation of trade secrets and other confidential information. The district court (1) dismissed Amyndas's claims against Zealand Pharma on the ground that Amyndas was required to litigate those claims in Denmark; and (2) dismissed Amyndas's claims against Zealand US for failure to state a claim. The First Circuit vacated in part and remanded the case for further proceedings, holding that the district court (1) correctly dismissed Amyndas's claims against Zealand Pharma; and (2) erred in concluding that Amyndas's claims against Zealand US were futile. View "Amyndas Pharmaceuticals, S.A. v. Zealand Pharma A/S" on Justia Law

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The First Circuit affirmed the judgment of the district court convicting Defendant of one count of possession with intent to distribute fentanyl and cocaine base after a traffic stop near Wells, Maine, holding that the district court did not commit plain error in accepting Defendant's guilty plea.On appeal, Defendant argued that the district court impermissibly failed to advise him that he was giving up the right to file pretrial motions at his Rule 11 hearing and that this Court should reverse the denial of his motion to withdraw his guilty plea. The First Circuit affirmed, holding that Defendant's claim on appeal was meritless. View "United States v. Williams" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed the rulings of the district court in this civil action brought under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., holding that none of the parties were entitled to relief on their claims brought on appeal and cross-appeal.Plaintiffs filed an administrative complaint alleging that the Newton Public Schools violated the IDEA by failing to provide their son David with a free appropriate public education, 20 U.S.C. 1412(a)(1). The Massachusetts Bureau of Special Education Appeals rejected the complaint. Thereafter, Plaintiffs brought this complaint. The district court granted judgment for Plaintiffs and ordered Newton to reimburse them for expenses they had incurred in placing their son at a private residential school in Connecticut. Defendants appealed, challenging the court's decision to exclude boarding- and travel-related expenses from the order of reimbursement. The First Circuit affirmed, holding that none of the parties were entitled to relief on their allegations of error. View "Doe v. Newton Public Schools" on Justia Law

Posted in: Education Law
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The First Circuit affirmed the judgment of the district court granting summary judgment to Defendants and dismissing Plaintiff's complaint alleging that he contracted paralytic shellfish poisoning (PSP) after eating a contaminated shrimp at a Puerto Rican restaurant, holding that the district court properly granted summary judgment to Defendants.Plaintiff and several members of his family sued the Puerto Rican restaurant at which he ate and the food distributors that handled the shrimp before its approval at the Restaurante El Nuevo Amanecer in Barranquitas, Puerto Rico, caused his severe illness, which led to him developing complete quadriplegia. The district court granted summary judgment for Defendants, concluding that Plaintiff had failed to present sufficient evidence to establish that his illness was connected to Defendants' acts or omissions. The First Circuit affirmed, holding that the district court properly granted summary judgment in favor of Defendants. View "Gonzalez-Caban v. JR Seafood Inc." on Justia Law

Posted in: Personal Injury