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

A Colorado-based technology company specializing in wireless communications collaborated with a Massachusetts micro-display company to develop a headset, formalizing their respective rights in a contract. The contract established joint intellectual property ownership for the project and designated the Massachusetts company to select counsel and prosecute patents. The selected law firm worked with both companies during patent prosecution, opening billing files and receiving powers of attorney from the Colorado company’s employees. Over time, disputes arose regarding patent applications, including amendments that allegedly benefited the Massachusetts company at the expense of the Colorado company, abandonment of applications, and filing disclaimers—often without informing the Colorado company.After the business relationship ended in 2009, the Colorado company only discovered alleged misconduct by the law firm years later when investigating its patent portfolio in response to a potential acquisition. Subsequent litigation in the U.S. District Court for the District of Colorado led to the law firm’s disqualification due to a found attorney-client relationship, and discovery revealed possible concealment and conflicts of interest.The Colorado company then sued the law firm and individual attorneys in the United States District Court for the District of Massachusetts, alleging legal malpractice and related claims. The district court granted summary judgment for the law firm, concluding all claims were untimely under the statute of limitations, not saved by equitable tolling, and that no attorney-client relationship existed.Upon review, the United States Court of Appeals for the First Circuit held that whether the malpractice claims were timely is a factual question suitable for a jury, not summary judgment, and that an attorney-client relationship existed as a matter of law for the relevant period. The appellate court reversed the district court’s timeliness and relationship rulings on the legal malpractice claim, vacated determinations regarding other claims, and remanded for further proceedings. View "BlueRadios, Inc. v. Hamilton, Brook, Smith & Reynolds, P.C." on Justia Law

The case centers on Orlando González Tomasini, who filed civil rights and tort claims against the United States Postal Service, his former employer, alleging that psychological and medical conditions prevented him from working. His then-wife, Juliette Irizarry-Miranda, was initially a co-plaintiff but eventually became a defense witness after a contentious divorce and ongoing custody dispute over their son. On the eve of trial, the Postal Service accused González of witness tampering, specifically of seeking to dissuade Irizarry from testifying by conditioning custody concessions on her refusal to take the stand. Irizarry recorded part of a phone call between them, and the Postal Service submitted this as evidence.Prior to the current appeal, the case was heard in the United States District Court for the District of Puerto Rico, where a magistrate judge presided by consent of the parties. The magistrate judge held a three-day evidentiary hearing to address the witness tampering allegations. After hearing testimony from González, Irizarry, and a social worker, the court found by clear and convincing evidence that González had engaged in witness tampering. As a sanction for this fraud on the court, the magistrate judge dismissed González’s case.The United States Court of Appeals for the First Circuit reviewed the district court's decisions. The First Circuit affirmed the district court in all respects, holding that the evidentiary hearing was appropriately ordered, the finding of witness tampering was not clearly erroneous, and the sanction of dismissal was within the court’s discretion. The appellate court found that González’s conduct constituted a fraud on the court, justifying dismissal, especially given the egregiousness of the witness tampering and its potential impact on the integrity of judicial proceedings. Judgment was affirmed for the Postal Service. View "Gonzalez Tomasini v. Steiner" on Justia Law

The plaintiff brought claims against her former employer alleging violations of federal and state wage and hour laws. After removal to the United States District Court for the District of Rhode Island, some claims were resolved at summary judgment, leaving the federal wage claims for trial. Before trial, the parties participated in a court-ordered mediation before a magistrate judge, during which they reached an oral settlement agreement whose terms were recited on the record. The agreement included payment to the plaintiff, confidentiality, non-defamation, and no-rehire clauses, as well as dismissal of the action with prejudice. Both parties, including the plaintiff and her counsel, confirmed their assent to the agreement.Following the mediation, the defendant prepared written settlement documents and a stipulation of dismissal. However, the plaintiff refused to sign, asserting she felt pressured and that certain terms were ambiguous or not sufficiently definite. The district court reviewed these objections after the defendant moved to enforce the settlement. The court found the agreement enforceable, denied the plaintiff’s request for an evidentiary hearing on alleged undue influence due to lack of factual support, and ordered her to execute the documents. After the plaintiff failed to comply, the court ultimately dismissed the case with prejudice under Federal Rule of Civil Procedure 41(b).On appeal, the United States Court of Appeals for the First Circuit held that the district court did not err in enforcing the oral settlement agreement or in denying the plaintiff’s motion for reconsideration and request for an evidentiary hearing. The appellate court found no genuine dispute of material fact as to the existence or terms of the settlement and affirmed the district court’s judgment, awarding costs and attorney fees to the defendant. View "Maccarone v. Siemens Industry, Inc." on Justia Law

The case concerns a defendant who, after losing his law license, became involved in schemes such as romance scams and business email compromises, which defrauded victims of millions of dollars. He opened bank accounts for shell companies, received funds from victims deceived by his co-conspirators, and transferred or withdrew the money for personal or further illicit purposes. Even after being confronted by bank investigators, he continued these activities.Previously, the United States District Court for the District of Massachusetts convicted him on charges including wire fraud and money-laundering conspiracy, but the United States Court of Appeals for the First Circuit affirmed only some of those convictions, vacated others, and remanded for resentencing. On remand, the district court imposed a new sentence of 87 months’ imprisonment—below the advisory guidelines range of 108 to 135 months—and reimposed more than $2 million in restitution. The defendant appealed again, challenging both the procedural and substantive reasonableness of his sentence and the amount and scope of restitution ordered.The United States Court of Appeals for the First Circuit reviewed and rejected all of the defendant’s claims. The court held that the district judge correctly applied the sentencing guidelines, including the base offense level, loss amount calculation, and enhancements for money laundering and sophisticated means. The court also found that the district judge properly denied a reduction for zero-point offenders, reasonably found the sentence substantively appropriate given the facts, and correctly ordered restitution, including for losses suffered by a foreign victim through a domestic bank account. The First Circuit affirmed the new sentence and restitution order in full. View "United States v. Abbas" on Justia Law

Two former employees of a global toy and game company sought religious exemptions from the company’s COVID-19 vaccination policy. Both had worked remotely during the pandemic and requested to continue working remotely due to their sincerely held Christian beliefs, which included objections to vaccines developed or tested using tissue from aborted fetuses and a belief that receiving the vaccine would violate their religious principles. After submitting their accommodation requests, both employees experienced workplace actions they alleged were retaliatory and discriminatory. These included formal investigations and written warnings for alleged prior mask policy violations, exclusion from promotion opportunities, reassignment of roles, dissemination of personal medical information, and changes to established workplace practices. Both resigned, asserting that these actions compelled their departures.The plaintiffs initiated legal action in Rhode Island state court, raising claims under Title VII of the Civil Rights Act, the Rhode Island Civil Rights Act, and the Rhode Island Fair Employment Practices Act. The case was removed to the United States District Court for the District of Rhode Island, which granted the employer’s motion to dismiss. The district court determined that the plaintiffs’ objections to vaccination were not based on religion, characterizing their beliefs as moral rather than religious, and held that the complaint failed to allege sufficiently adverse employment actions or a causal connection between the plaintiffs’ accommodation requests and any adverse action.The United States Court of Appeals for the First Circuit reviewed the case. It held that the plaintiffs plausibly alleged that their refusal to take the COVID-19 vaccine was based on bona fide religious beliefs, as recognized in recent circuit precedent. The court concluded that the amended complaint sufficiently pleaded plausible claims of retaliation and religious discrimination under federal and state law. Accordingly, the First Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "DeAngelis v. Hasbro, Inc." on Justia Law

The case concerns a defendant who was serving a term of supervised release following a federal conviction for fentanyl-related offenses. During his supervision, police responded to a domestic disturbance at his apartment, where his wife reported that, after an argument, the defendant struck her and was told to leave. When she locked him out, she stated that he kicked the apartment door, damaging it, re-entered, and took her cell phone. Police and a responding officer documented the damage to the door. The defendant was subsequently charged in state court with vandalism, among other offenses, and federal probation officers sought revocation of his supervised release based on these new alleged criminal acts.The United States District Court for the District of Massachusetts held revocation hearings, during which both documentary evidence, such as police reports and affidavits, and live testimony from the responding officer were presented. The defendant objected to the admission of hearsay statements from his wife, arguing he was entitled to confront her and that the statements were unreliable. The district court found that the interest of justice did not require her appearance, determined her statements were sufficiently reliable, and credited the corroborating testimony of the police officer. The court concluded that the defendant had, by a preponderance of the evidence, committed vandalism under Massachusetts law and revoked his supervised release.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s legal conclusions de novo and factual findings for clear error. The appellate court held that the district court properly admitted the hearsay evidence, conducted the required balancing under Rule 32.1(b)(2)(C), and made supported findings regarding the elements of vandalism. The appellate court concluded there was neither legal error nor clear error and affirmed the revocation of supervised release. View "United States v. Camillo" on Justia Law

A former Boston police officer alleged that the Boston Police Department (BPD) retaliated against her after she reported a fellow officer for rape in 2009. Following her report, both she and the accused officer were placed on leave, and subsequent criminal and internal investigations found her allegations unsubstantiated. She later made additional complaints of misconduct by BPD officials, which were also found unsubstantiated. In response, BPD’s Internal Affairs Department sustained numerous disciplinary charges against her, and she resigned with these charges pending. After her resignation, she applied for various jobs, authorizing prospective employers to request her employment and disciplinary records from BPD. Additionally, BPD included her name and reason for departure in a list provided to the Washington Post in response to a public records request.The Massachusetts Superior Court dismissed her three successive lawsuits against BPD, primarily for procedural reasons, with the last dismissal in 2017 operating as an adjudication on the merits. In federal court, claims based on alleged retaliatory acts before February 2, 2017, were precluded due to the prior state court judgment. The U.S. District Court for the District of Massachusetts allowed her Title VII retaliation claims to proceed only as to BPD’s actions after that date, specifically regarding the release of her records to prospective employers and the Washington Post.The United States Court of Appeals for the First Circuit affirmed the district court’s grant of summary judgment for BPD. The court held that no reasonable jury could find that retaliation was the but-for cause of BPD’s release of employment information, since Doe had authorized those disclosures and there was no evidence of deviation from standard procedure or retaliatory motive. The court also held that BPD’s response to the public records request was legally required and contained accurate information. View "Doe v. City of Boston" on Justia Law

The case concerns an individual who was convicted under federal law for possessing a firearm after having previously been convicted of a misdemeanor crime of domestic violence. The predicate offense was a 2010 conviction under Maine law for simple assault against his then-wife, to which he pleaded no contest after the original charge of "Domestic Violence Assault" was reduced. Several years later, he was charged federally after he admitted to police that he owned a firearm. At his federal trial, he stipulated to many elements of the offense but sought to introduce evidence that he believed, based on his plea arrangement and representations by the prosecution and his attorney in state court, that he was legally allowed to possess a firearm.Initially, the United States District Court for the District of Maine convicted him, but the United States Court of Appeals for the First Circuit vacated that conviction after the Supreme Court decided Rehaif v. United States, which clarified the knowledge requirement for firearms offenses. On remand, he was retried and again convicted, but a First Circuit panel vacated the conviction due to errors in jury instructions. Sitting en banc, the First Circuit clarified the applicable knowledge standard, vacated the conviction, and remanded for another trial. On further remand, the District Court denied his Second Amendment challenge to the statute, excluded his proffered evidence regarding his belief about firearm possession, and again convicted him after a jury trial.The United States Court of Appeals for the First Circuit held that 18 U.S.C. § 922(g)(9), which prohibits firearm possession by those convicted of misdemeanor crimes of domestic violence, does not violate the Second Amendment, either facially or as applied, in light of the Supreme Court’s guidance in United States v. Rahimi. The court also held that the District Court did not abuse its discretion in excluding evidence of the defendant’s belief about the lawfulness of his conduct, as the statute does not require knowledge that firearm possession is unlawful, only knowledge of the facts that make one ineligible. The conviction and denial of the motion to dismiss were affirmed. View "US v. Minor" on Justia Law

A lawful permanent resident who had lived in the United States for nearly twenty years was twice convicted in Massachusetts for violating a statute that prohibits “open and gross lewdness and lascivious behavior.” Following his second conviction, the government initiated removal proceedings, arguing that his convictions constituted two “crimes involving moral turpitude” (CIMTs) under federal immigration law. The resident contested this classification, contending that the Massachusetts statute did not require lewd intent and thus did not categorically define a CIMT.An Immigration Judge denied the resident’s motion to terminate proceedings and ordered him removed, finding that the statute was categorically a CIMT. The resident appealed to the Board of Immigration Appeals (BIA), which affirmed the order of removal. The BIA concluded that the statute necessarily required lewd intent and thus qualified as a CIMT.The United States Court of Appeals for the First Circuit reviewed the BIA’s decision. The court applied the categorical approach, examining whether the Massachusetts statute required proof of lewd intent as an element for every conviction. The First Circuit determined that a conviction under the statute did not require a finding of lewd intent or sexual motivation; instead, it could be satisfied by intentional, open exposure that caused shock or alarm, even without a lewd purpose. The court found a realistic probability that Massachusetts would apply the statute to conduct not involving moral turpitude.The First Circuit held that the Massachusetts statute is not categorically a crime involving moral turpitude because it does not require proof of lewd intent. The court concluded that the BIA erred as a matter of law and reversed the removal order. The petition for review was granted, the BIA’s decision was reversed, and the matter was remanded for further proceedings. View "Cabral Fortes Tomar v. Bondi" on Justia Law

Eleven individuals residing in the Town of Rockport, Massachusetts, challenged the creation of a new zoning overlay district that would allow high-density, multi-family housing near a commuter rail station. Some plaintiffs live adjacent to or within the boundaries of the affected overlay district. The plaintiffs argued that the adoption of the district should have required a two-thirds vote at the town meeting under state law, rather than the simple majority used, and alleged that the new zoning would negatively impact their property values and personal expectations regarding their property.After the Town held the vote and adopted the overlay district, the plaintiffs filed suit in the United States District Court for the District of Massachusetts, seeking declaratory and injunctive relief on both state statutory and federal constitutional grounds. The Town moved to dismiss the complaint, arguing the plaintiffs lacked standing. In response, the plaintiffs provided additional details in their briefing but did not amend their complaint to allege specific individualized harm. The District Court dismissed the case for lack of subject-matter jurisdiction, finding the plaintiffs had failed to allege sufficient facts to establish standing, and that neither legislative nor abutter standing applied.On appeal, the United States Court of Appeals for the First Circuit reviewed the dismissal de novo. The court held that the plaintiffs had not adequately demonstrated a concrete and particularized injury-in-fact as required by Article III. General, conclusory allegations about diminished property values and expectations were insufficient. The court also found that statutory “abutter” standing and legislative standing theories did not confer standing in federal court for these claims. The appellate court affirmed the district court’s dismissal for lack of standing and subject-matter jurisdiction. View "Kolackovsky v. Town of Rockport" on Justia Law