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

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The First Circuit dismissed Appellant's appeal from his plea of guilty to two of thirty-four child pornography possession charges for which he was indicted, holding that Appellant's waiver of appeal was valid and enforceable.Pursuant to a plea agreement, Appellant pled guilty to counts nineteen and thirty-four of the indictment, and the government dismissed the remaining thirty-two counts. The plea agreement contained a waiver of appeal clause. Appellant testified under oath that he understood the terms of the agreement, including the waiver of appeal. The district court imposed a sentence at the top of the Guidelines range and a lifetime term of supervised release. Appellant appealed, challenging the procedural and substantive reasonableness of his sentence. The First Circuit dismissed the appeal, holding that Appellant's waiver of appeal was valid, enforceable, and barred further consideration of his arguments. View "United States v. Boudreau" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed Defendant's two convictions for possessing a firearm as a prohibited person, in violation of 18 U.S.C. 922(g)(1) and 18 U.S.C. 924(a)(2), holding that sufficient evidence supported the convictions and that no governmental misconduct occurred during the grand jury proceedings.After a trial, the jury returned a guilty verdict on both counts against Defendant, and the district court sentenced him to sixty-six months' imprisonment, to be followed by three years of supervised release. The First Circuit affirmed, holding (1) the government presented sufficient competent evidence to prove the material elements of the charges brought against Defendant; (2) the district court did not err by not striking certain testimony; and (3) the district court did not abuse its discretion in denying Defendant's motion to dismiss the superseding indictment on the ground that the government committed misconduct during the grand jury proceedings to obtain it. View "United States v. Jackson" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed in part and reversed in part the judgment of the district court dismissing Plaintiff's amended complaint bringing claims for product disparagement and related torts, holding that some of Plaintiff's claims were sufficiently plausible to warrant further proceedings.Plaintiff, a medical device company that designed and manufactured customized hip and knee replacements, brought this complaint against Aetna, Inc. and its wholly owned subsidiary (collectively, Aetna) alleging state common-law claims for product disparagement, tortious interference with both contractual and advantageous relations, and unfair trade practices, in violation of Mass. Gen. Laws chapter 93A. The district court granted Aetna's motion to dismiss for failure to state a claim. The First Circuit reversed in part, holding that the district court correctly dismissed Plaintiff's claim for tortious interference with contractual relations but erred in dismissing Plaintiff's claim for tortious interference with advantageous relations. View "Conformis, Inc. v. Aetna, Inc." on Justia Law

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The First Circuit affirmed the judgment of the district court dismissing Appellants' complaint against the Town of Lynnfield, Massachusetts and several of the town's agencies and employees (collectively, Lynnfield) in this dispute over Appellants' spring water business, holding that there was no error or abuse of discretion.Appellants owned and operated the Pocahontas Spring in Lynnfield, Massachusetts, which sat on protected wetlands subject to state and local regulations. When Appellants sought to revive their spring water business and to maintain the Spring for Native Americans as a source of healing water. Appellants brought this complaint alleging that Lynnfield conspired to have neighbors lodge false complaint about Appellants' allegedly unlawful activities at the Spring and Lynnfield would respond to intimidate Appellants and interfere with their business. The First Circuit affirmed the district court's dismissal of the complaint, holding that Appellants' failure adequately to brief their two First Amendment claims proved fatal in this case. View "Gattineri v. Town of Lynnfield, Mass." on Justia Law

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The First Circuit affirmed the judgment of the district court imposing two four-level enhancements and sentencing Defendant to sixty months' imprisonment, holding that there was no error in the specific components in Defendant's sentence and that the sentence was neither procedurally nor substantively unreasonable.Defendant entered a straight plea to possessing or transferring a machine-gun, dealing in firearms without a license, and possessing a firearm without a serial number. The district court imposed two four-level enhancements - one for trafficking and one for possessing a firearm in connection with another felony - and sentenced Defendant to sixty months' imprisonment. The First Circuit affirmed, holding (1) there was no error in the application of either enhancement; and (2) the sentence was not unreasonable. View "United States v. Bishoff" on Justia Law

Posted in: Criminal Law
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The First Circuit dismissed these consolidated appeals involving the Defendant's request for retention of a seal of judicial records up until the expiration of his sentence, holding that the appeals were moot.Appellant pleaded guilty to crimes and was sentenced to a brief term of incarceration, during which the district court sealed portions of the record pertaining to Appellant's cooperation with the government. In accordance with local practice, the court ordered that the seal be lifted once Appellant's imprisonment ended. Appellant objected, requesting that the seal remain in place until the expiration of his term of supervised release. The district court overruled the objection but left the seal in place during Appellant's appeal. During the pendency of that appeal, Appellant violated the terms of his supervised release and was sentenced to a new prison term and supervised release term. When he was released yet again on supervision, a second appeal concerning the sealing order was pending, and the two appeals were consolidated. Before adjudication, Appellant violated the conditions of his supervised release for a second time and was sentenced to a term of imprisonment with no supervised release to follow. The First Circuit dismissed the appeals, holding that they were moot. View "United States v. Rydle" on Justia Law

Posted in: Criminal Law
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In this suit brought under the Racketeering Influence and Corrupt Organizations Act (RICO), the First Circuit remanded this matter for further review, holding that the district court erred in dismissing the complaint based on the doctrine of forum non conveniens.Medtronic Medical CR SRL, a Costa Rica limited liability company, brought suit under RICO alleging that Defendants, Puerto Rico residents, orchestrated fraudulent schemes. The district court granted Defendants' motion to dismiss based on the doctrine of forum non conveniens, concluding that Costa Rica was an adequate alternative forum. The First Circuit remanded the case, holding that intervening and developing circumstances required reconsideration of the most efficient, prudential path forward. View "Medtronic Medical CR SRL v. Feliciano-Soto" on Justia Law

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The First Circuit affirmed the judgment of the district court determining that Act 90, passed by the Legislative Assembly of Puerto Rico in 2019, was preempted by federal law, holding that the district court did not err.Act 90 requires that Medicare Advantage plans compensate Puerto Rico healthcare providers in Puerto Rico at the same rate as providers are compensated under traditional Medicare. Plaintiffs, several entities that managed Medicare Advantage plans, filed suit seeking a declaratory judgment and an injunction barring the "mandated price provision," arguing that the Medicare Advantage Act preempted the challenged provision and that provision was unconstitutional. The district court ruled in favor of Plaintiffs. The First Circuit affirmed, holding that Act 90's mandated price provision was preempted by federal law. View "Medicaid & Medicare Advantage Products Ass'n of Puerto Rico, Inc. v. Emanuelli-Hernandez" on Justia Law

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The First Circuit denied Petitioner's petition for review of an immigration judge's (IJ) denial of his application for withholding of removal, holding that the Petitioner's arguments were unavailing.Petitioner, a native and citizen of El Salvador, was subject to removal. Petitioner expressed fear of persecution or torture with the asylum officer. The asylum officer rejected Petitioner's reasonable fear claim, concluding that there was insufficient evidence to find that Petitioner had been attacked because of a protected ground. The IJ upheld the asylum officer's decision. The First Circuit affirmed, holding that the IJ did not err by dismissing Petitioner's gang-related claim. View "Reyes-Ramos v. Garland" on Justia Law

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The First Circuit vacated the judgment of the district court granting summary judgment in favor of Unitil Service Corporation and dismissing the complaint brought by the Department of Labor (DOL) seeking overtime compensation under the Fair Labor Standards Act's (FLSA) for hours worked in excess of forty hours per week for dispatchers and controllers (collectively, Employees) employed by Unitil, holding that the district court erred.In entering its judgment, the district court concluded that Employees were administrative, exempt from the FLSA, and thus not entitled to overtime pay because their "primary duty" was "directly related" to the general business operations of Unitil Service's customers. On appeal, Unitil argued that Employees were exempt administrative employees under federal law and, as such, were not entitled to overtime payments. The First Circuit vacated the judgment below, holding that the district court improperly did not apply a "relational" analysis comparing the business purpose of Unitil and/or its customers to the primary duty of Employees. View "Walsh v. Unitil Service Corp." on Justia Law