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

A group of immigration attorneys, a law firm, and a legal services organization challenged practices by the Department of Homeland Security and its component agencies involved in immigration enforcement and adjudication. They alleged that the agencies routinely require noncitizens and their counsel to obtain key records through the Freedom of Information Act (FOIA), rather than providing them directly during immigration proceedings. The plaintiffs claimed this so-called “Nondisclosure Policy” causes delays, omissions, and additional burdens that impede their ability to represent clients effectively and limit their capacity to take on more cases.The United States District Court for the District of Massachusetts reviewed the case in multiple stages. Initially, the court dismissed claims related to removal proceedings and due process violations, but allowed the APA claim regarding asylum proceedings to proceed. After the plaintiffs amended their complaint to add allegations about ICE’s practices following Dent v. Holder, the court again dismissed the removal-related claims, finding no disclosure obligation in those proceedings. The surviving claim then proceeded to summary judgment, where the district court found insufficient evidence of a formal agency-wide policy and ruled that the government’s use of FOIA did not violate relevant regulations or the APA, granting summary judgment for the government.On appeal, the United States Court of Appeals for the First Circuit examined whether the plaintiffs had Article III standing to bring their claims. The court determined that the plaintiffs failed to establish the existence of a uniform, agency-wide Nondisclosure Policy, and concluded their alleged injuries were too speculative and were not sufficiently concrete to confer standing. The court distinguished this case from precedents like Havens Realty Corp. v. Coleman and Alliance for Hippocratic Medicine, holding that voluntary expenditures and increased burdens do not, by themselves, amount to an injury in fact. The First Circuit affirmed the district court’s judgment for the government on the basis of lack of standing. View "Greater Boston Legal Services v. Dep't of Homeland Security" on Justia Law

The defendant was charged in connection with a large-scale health care fraud scheme involving Arbor Homecare Services LLC, a company she controlled. Over several years, Arbor fraudulently billed Massachusetts’ Medicaid program, MassHealth, for more than $99 million. The government alleged that the defendant orchestrated the scheme, laundered proceeds through domestic and Kenyan financial accounts, and used the funds to acquire properties and businesses. After an initial mistrial, the defendant was retried and convicted by a jury on charges of conspiracy to commit health care fraud, health care fraud, and money laundering. She was sentenced to 144 months in prison, fined $250,000, and ordered to pay restitution.Prior to the retrial, the defendant cycled through numerous attorneys, at times expressing a desire to proceed without counsel and at other times seeking to hire new counsel if her assets were released from civil forfeiture. The United States District Court for the District of Massachusetts conducted multiple Faretta colloquies, warning her of the risks of self-representation. Ultimately, the court found her waiver of counsel to be knowing, intelligent, and voluntary, and permitted her to proceed pro se with standby counsel. The court also denied her motion to suppress evidence obtained from her cell phone during a border search, finding the search supported by reasonable suspicion.On appeal to the United States Court of Appeals for the First Circuit, the defendant argued that her conviction should be reversed due to alleged violations of her right to counsel and due process, and that the cell phone evidence should have been suppressed. She also challenged the calculation of her sentence, disputing the loss amount and the application of a sophisticated-means enhancement. The First Circuit affirmed the district court’s decisions, holding that her waiver of counsel was constitutionally valid, her suppression argument was waived, and her sentencing challenges were either waived or without merit. View "US v. Newton" on Justia Law

A group of current and former policyholders brought a lawsuit in federal court against their automobile insurance companies, alleging that the insurers’ rate-setting practices violated Massachusetts law. The insurers, who serve present and former U.S. military members, determine eligibility for insurance with each affiliate based on the policyholders’ highest military pay grade. The plaintiffs claimed that, by using “income” and “occupation” in this way, the insurers violated state regulations prohibiting such criteria in setting insurance rates. The plaintiffs sought declaratory and injunctive relief, as well as restitution for alleged overcharges.The United States District Court for the District of Massachusetts denied the insurers’ motion to dismiss under Rule 12(b)(6). The court then certified for interlocutory appeal the question of whether the filed rate doctrine bars the relief that the plaintiffs seek. The district court reasoned that some of the requested remedies might not be barred by the doctrine and clarified that the controlling question raised several distinct sub-questions about the application of the doctrine under Massachusetts and federal law. The parties did not seek administrative review of the insurance rates in question, and the Massachusetts Attorney General did not intervene in the administrative or judicial proceedings.The United States Court of Appeals for the First Circuit reviewed the case. The court held that Massachusetts law, not the federal filed rate doctrine, governs whether private parties can bring suit under Chapter 93A for alleged violations involving insurance rates approved by the state Commissioner of Insurance. The First Circuit found that there is no controlling precedent under Massachusetts law and certified two questions to the Massachusetts Supreme Judicial Court regarding whether such private suits are authorized and whether the answer differs by the type of relief sought. The First Circuit retained jurisdiction pending the SJC’s response. View "Wright v. United Services Automobile Association" on Justia Law

A married couple acquired a residential property in Maine, building their home on a subdivided lot. In 2005, the husband alone obtained a mortgage on the property to pay off an earlier joint mortgage, but the wife did not sign the new note. After their divorce, the husband quitclaimed his interest in the property to the wife, then filed for bankruptcy. The mortgage lender and its successors initiated multiple foreclosure actions over the years. In a 2012 foreclosure judgment, only the husband was held liable, as the wife had been dismissed from the suit. The wife later obtained a declaratory judgment in state court: although not personally liable on the debt, her property interest was found to be subject to the mortgage. No payments were made on the mortgage after 2010, and the loan fully matured before the current foreclosure attempt.The lender, U.S. Bank, sent both spouses a statutorily required notice under Maine law before foreclosing, but the notice incorrectly labeled the principal as "Payments" and failed to strictly comply with statutory requirements. When U.S. Bank sued for foreclosure in the U.S. District Court for the District of Maine, the wife argued that the notice was deficient. The District Court agreed, granting summary judgment for her based on the notice's noncompliance. The court also found that the wife was entitled to notice as a "mortgagor," even though she had not signed the note, and rejected arguments that the earlier foreclosure judgment against the husband precluded her from raising defenses.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court's judgment. The First Circuit held that Maine’s statutory notice requirement applies even after a loan has matured, to a spouse whose property interest is subject to the mortgage but who did not sign the note, and after a prior foreclosure judgment against the signing spouse. The court also held that a noncompliant notice mandates judgment for the mortgagor under the law applicable to this case. View "U.S. Bank Trust, N.A. v. Bowden" on Justia Law

The defendant, an American citizen, applied for a temporary emergency passport at the U.S. Embassy in Senegal after fleeing Cape Verde, where he faced two pending homicide charges and other criminal accusations. The Cape Verdean authorities had confiscated his passports and identification, but shortly after his release from pretrial detention (with instructions not to leave the country), he traveled to Senegal and claimed to have lost his American passport. Based on these events, he was charged in the United States with knowingly making false statements on a passport application, specifically that he had lost his passport in Dakar.Proceedings in the United States District Court for the District of Massachusetts included the denial of the defendant’s motion to exclude evidence regarding the Cape Verdean homicide charges, on the grounds that such evidence was relevant to motive. The district court also declined to give a missing witness instruction regarding the absence of a Cape Verdean official and did not ask a proposed voir dire question about potential juror bias related to the homicide charges. The jury convicted the defendant, who then appealed to the United States Court of Appeals for the First Circuit.The United States Court of Appeals for the First Circuit found that the district court did not abuse its discretion by declining to give a missing witness instruction or by prohibiting argument about the absent Cape Verdean official. However, the appellate court concluded that the district court erred in not questioning potential jurors about bias from the homicide charges and in admitting evidence specifically referencing those charges, which was unduly prejudicial. Nonetheless, because the evidence of guilt was overwhelming, the court held these errors to be harmless and affirmed the conviction. View "US v. Barros Brandao" on Justia Law

This case concerns a dispute among shareholders of Sinovac Biotech Ltd., a biopharmaceutical company incorporated in Antigua and Barbuda. MW Gestion, an investment management firm holding Sinovac securities, sued several other shareholders—including Jiaqiang Li, his company 1Globe Capital LLC, and related individuals—alleging tortious interference with contract and securities fraud. The central issue arose from a Rights Agreement adopted by Sinovac in 2016, which included a "poison pill" provision designed to prevent any single shareholder from acquiring excessive control without triggering dilution of their shares. MW Gestion claimed the defendants concealed the extent of their ownership to circumvent this provision and associated disclosure requirements, thereby harming other shareholders.Prior to this action, Sinovac and 1Globe had litigated related matters in the Delaware Court of Chancery, the U.S. District Court for the District of Massachusetts, and courts in Antigua, all contesting the validity of the Rights Agreement. In 2020, the U.S. Securities and Exchange Commission issued a cease-and-desist order against Li and 1Globe for violations of disclosure requirements. Following a series of stays and the invalidation of the Rights Agreement by the Privy Council in January 2025, the U.S. District Court for the District of Massachusetts denied MW Gestion’s motion to amend its complaint to add a tortious interference with business relations claim, finding MW Gestion had engaged in undue delay by waiting for the Privy Council’s decision.The United States Court of Appeals for the First Circuit reviewed whether the district court abused its discretion in denying leave to amend and whether dismissal of securities fraud claims as time-barred was correct. The First Circuit affirmed both rulings, holding that the district court did not abuse its discretion in finding undue delay and that MW Gestion’s securities fraud claims were untimely because MW Gestion knew or should have known of the facts underlying those claims by May 2020. View "MW Gestion v. 1Globe Capital LLC" on Justia Law

After defaulting on his home mortgage, the plaintiff entered into a loan modification agreement with his mortgage servicer. The agreement allowed for a portion of the loan balance to be forgiven if the plaintiff made timely payments and remained in good standing. However, the plaintiff quickly fell behind on the modified payment schedule and remained delinquent for an extended period. During this time, the servicer issued an IRS Form 1099-C to the plaintiff, listing the amount eligible for forgiveness as a "cancellation of debt." The plaintiff subsequently argued that this form, along with certain communications from the servicer and its successor, meant the debt had been forgiven, even though he had not met the agreement’s conditions.The case was originally filed in Massachusetts state court and removed to the United States District Court for the District of Massachusetts on diversity grounds. The defendants moved for summary judgment after discovery. The plaintiff opposed the motion, arguing that further discovery was needed, particularly regarding the servicer’s tax filings, to support his claim that the debt had been forgiven. The district court denied the plaintiff’s request for additional discovery, finding the requested information irrelevant, and granted summary judgment to the defendants on all claims, including breach of contract, breach of the covenant of good faith and fair dealing, and violation of the Massachusetts consumer protection statute.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s rulings. The appellate court held that the issuance of an IRS Form 1099-C does not, by itself, discharge a debt if the conditions for forgiveness were not met. The court also found no abuse of discretion in denying additional discovery and concluded there was no material factual dispute as to whether the debt had been forgiven. The grant of summary judgment to the defendants was affirmed. View "Dworman v. PHH Mortgage Services" on Justia Law

The petitioner, a noncitizen born in Venezuela who later overstayed a travel visa in the United States, became involved in a drug conspiracy led by her abusive husband. She was charged with conspiracy to distribute controlled substances. Her primary concern throughout the criminal proceedings was remaining in the United States, as she had two children who were U.S. citizens. Her court-appointed counsel assured her that accepting a plea agreement would allow her to "work out" any immigration issues after serving her sentence, despite warnings in the plea agreement and at the plea hearing that she "may" be deported. Relying on this advice, she pleaded guilty and was sentenced to 84 months' imprisonment and three years of supervised release.After completing her sentence, the petitioner received a removal notice, prompting her to seek legal assistance. Upon learning that her conviction rendered her mandatorily removable and permanently inadmissible to the United States, she filed a petition for a writ of coram nobis in the United States District Court for the District of New Hampshire. The district court held an evidentiary hearing and found that she had adequately explained her delay in seeking relief, the counsel's advice was constitutionally deficient under Padilla v. Kentucky, and she suffered prejudice because she would not have pleaded guilty if properly advised. The court granted the writ and vacated her conviction, concluding that equitable considerations favored relief.The United States Court of Appeals for the First Circuit reviewed the district court’s grant of coram nobis relief. Applying de novo review to legal conclusions and clear error to factual findings, the First Circuit affirmed the district court’s decision. The main holding is that the petitioner met all requirements for coram nobis relief: timely explanation for delay, ongoing collateral consequences, fundamental error due to ineffective assistance of counsel, and equitable grounds justifying relief. View "Morillo v. US" on Justia Law

The defendant participated as a street-level drug distributor in a Massachusetts-based organization led by another individual. The organization’s operations involved receiving orders through a leader, who then relayed instructions to distributors such as the defendant. These distributors were provided with cars stocked daily with drugs, which they delivered in user-level quantities to customers. The defendant worked in this role for approximately two months, during which intercepted phone calls and a subsequent police stop resulted in the government attributing responsibility to him for distributing over 300 grams of fentanyl and additional amounts of cocaine. Upon arrest, drugs were found hidden in his car.After pleading guilty to conspiracy to possess with intent to distribute and to distribute forty grams or more of fentanyl, the United States District Court for the District of Massachusetts calculated a Guidelines Sentencing Range of forty-six to fifty-seven months. Probation recommended a two-level minor-role reduction under U.S.S.G. § 3B1.2(b), but the court denied this adjustment, reasoning that the defendant did not qualify as substantially less culpable than the average participant and that a recent guideline amendment did not apply to his circumstances. The court imposed a sentence of thirty-six months.The United States Court of Appeals for the First Circuit reviewed the district court’s interpretation of the newly added U.S.S.G. § 2D1.1(e)(2)(B)(ii), which expands the circumstances for minor-role adjustments. The appellate court held that the district court misapplied the guideline by reading into it categorical exclusions for those who possessed more than user-level quantities or who were paid employees in the organization’s business model. The First Circuit vacated the sentence and remanded for resentencing, directing the district court to properly consider the defendant’s primary function based on the totality of the circumstances. View "US v. Vizcaino Vizcaino" on Justia Law

A woman fled Honduras with her partner and daughter after years of harassment and stalking by a man named Jose Funes. Funes sent frequent threatening messages, stalked her at work, threatened her partner’s life, and tried to obtain her whereabouts even after she relocated within Honduras. He also allegedly orchestrated an incident that Alvarado interpreted as an attempted kidnapping of her daughter. Despite reporting these threats to local authorities, police did not intervene. Fearing further harm, the family left Honduras for the United States in 2016, where Funes continued to attempt contact via social media. Alvarado sought mental health treatment in Massachusetts due to ongoing fear.Removal proceedings were initiated in early 2017, and Alvarado applied for asylum, withholding of removal, and protection under the Convention Against Torture, with her partner and daughter as derivative applicants. The Immigration Judge (IJ) denied all claims, finding insufficient corroboration of the alleged kidnapping attempt, questioning her testimony, and determining that the harassment did not rise to the level of persecution. The IJ also made an adverse credibility finding regarding her partner’s affidavit. The Board of Immigration Appeals (BIA) reversed the adverse credibility finding but upheld the denial of relief, concluding that Alvarado had not established past harm rising to the level of persecution or an objectively reasonable fear of future persecution.The United States Court of Appeals for the First Circuit reviewed the final BIA decision under the substantial evidence standard. The court held that substantial evidence supported the agency’s determinations: neither the threats nor the alleged kidnapping attempt compelled a finding of persecution, and Alvarado’s fear of future harm was not objectively reasonable. The court denied the petition for review. View "Alvarado-Hernandez v. Blanche" on Justia Law