Justia U.S. 1st Circuit Court of Appeals Opinion Summaries
United States v. Gerrish
The United States Court of Appeals For the First Circuit examined a case where the defendant, Derek Gerrish, challenged the constitutionality of a search of his vehicle during his pretrial release on several state criminal charges. During this period, Gerrish was subjected to at least six different bail conditions, five of which allowed for searches of his person, vehicle, or residence at any time without reasonable suspicion. The search in question led to the discovery of fentanyl and other contraband, resulting in Gerrish pleading guilty to possession with intent to distribute fentanyl.Gerrish argued that the search of his vehicle was unconstitutional, despite the terms of his bail conditions. The district court denied his motion to suppress the evidence, citing two reasons: the officers had reasonable suspicion of criminal activity, and Gerrish's bail conditions permitted such a search.On appeal, the defendant argued that both of the district court's reasons were incorrect. The appeals court, however, only focused on the bail condition rationale, as it found it conclusive. The court noted that Gerrish knowingly agreed to bail conditions authorizing searches without suspicion and did not challenge the reasonableness of these conditions. Furthermore, it emphasized that the issue at hand was not the search itself, but the bail conditions that authorized it.The court rejected Gerrish's argument that such bail conditions could not be imposed pre-trial or pre-guilty plea, referring to precedent which stated that acceptance of such conditions significantly diminishes a defendant's reasonable expectation of privacy. It also dismissed Gerrish's claim of a conflict with a Ninth Circuit decision, stating that Maine law requires "least restrictive" bail conditions tailored to the defendant's individual circumstances, thereby eliminating the Ninth Circuit's concerns about mandatory waiver of rights.The judgment of the district court was thus affirmed. View "United States v. Gerrish" on Justia Law
Posted in:
Constitutional Law, Criminal Law
United States v. Vasquez-Rodrigue
In this case, the defendant, Danybelkis Vasquez-Rodrigue, appealed her jury conviction for conspiracy to distribute and possess over 400 grams of fentanyl. Vasquez-Rodrigue argued that the district court erred in denying her requested jury instruction on duress, claiming she was threatened into participating in the drug conspiracy. The United States Court of Appeals for the First Circuit rejected Vasquez-Rodrigue's argument, concluding that she had failed to show she either intentionally or recklessly placed herself in a situation where it was probable she would be subjected to duress.The court noted that by the time Vasquez-Rodrigue alleges she was threatened, she had already completed the crime of conspiracy by agreeing to collect a drug debt, coordinating the collection with the debtor, collecting the money, and remitting thousands of dollars to individuals in Mexico and the Dominican Republic. The court also noted that a reasonable person in Vasquez-Rodrigue's position would have understood the danger of getting involved with a drug conspiracy, especially one selling kilogram amounts of drugs and exporting tens of thousands of dollars out of the country.The court also rejected Vasquez-Rodrigue's separate argument that a different duress test, imposing fewer burdens on the defendant, should apply in cases in which the sole charged offense is conspiracy. The court noted that the First Circuit has routinely applied the conventional duress test in conspiracy cases. Thus, the court affirmed Vasquez-Rodrigue's conviction. View "United States v. Vasquez-Rodrigue" on Justia Law
Posted in:
Criminal Law
United States v. MacVicar
The case involves a defendant, Kevin MacVicar, who pled guilty to a single count of possession of child pornography and was sentenced by the district court to a seven-year term, which was below the guidelines sentencing range. The defendant appealed his sentence, arguing it was both procedurally flawed and substantively unreasonable. The U.S. Court of Appeals for the First Circuit rejected these claims and affirmed the district court's sentence.The defendant contended that the district court failed to consider his significant mental health treatment efforts and his need for continued treatment when determining the appropriate sentence. The appellate court disagreed, finding that the record clearly showed the sentencing court had adequately considered all relevant factors, including the mitigating factors that the defendant claimed were overlooked.The defendant also argued that his sentence was substantively unreasonable because the district court placed too much weight on the severity of the offense and not enough on other sentencing factors. The appellate court rejected this argument as well, stating that the sentencing court had provided a plausible sentencing rationale and reached a defensible result. It was not the court's role to adjust the weight given to individual sentencing factors according to the defendant's preferences. Therefore, the defendant's sentence was affirmed. View "United States v. MacVicar" on Justia Law
Posted in:
Criminal Law
Chun Mendez v. Garland
The case concerns a review petition filed by Mariela Gricelda Chun Mendez and her minor son, natives and citizens of Guatemala. They sought review of the final order of the Board of Immigration Appeals (BIA), which upheld the Immigration Judge's (IJ) denial of asylum and withholding of removal under the Immigration and Nationality Act (INA) and protection under the Convention Against Torture (CAT). The petitioners had fled Guatemala due to violence between their village and the neighboring municipality over land and water rights.The BIA had affirmed the IJ's findings that Chun Mendez did not establish extraordinary circumstances to excuse the late filing of her asylum application and that she did not demonstrate membership in the particular social group (PSG) she had defined for the agency. The court, after a careful review of the case, denied the petition.Chun Mendez claimed she was a member of the PSG of "communal landowners of Ixchiguán, Guatemala that refused to cooperate with criminal gangs." However, she conceded that she did not communally own the land. The court agreed with the government that Chun Mendez failed to exhaust her claim of imputed membership in the PSG before the BIA.Additionally, Chun Mendez alleged that the IJ and BIA failed to meaningfully assess her asylum and withholding of removal claims based on her race as an indigenous woman of Mam descent. However, the court found these race-based claims unexhausted, as Chun Mendez did not raise any race-based claim before the BIA. Consequently, the court denied the petition for review. View "Chun Mendez v. Garland" on Justia Law
Posted in:
Immigration Law
United States v. Sastrom
The defendant, Roy Sastrom, was serving a term of supervised release, a condition of which was modified by the United States District Court for the District of Massachusetts. The court directed Sastrom, upon his release from federal custody, to report directly to a psychiatric hospital in Connecticut, as per his civil commitment order. This case was later transferred to the District of Connecticut. Sastrom appealed, arguing the Massachusetts district court abused its discretion by modifying his supervised release conditions.The United States Court of Appeals for the First Circuit determined that despite the transfer, it retained jurisdiction to review the pre-transfer order. However, the court recognized that Sastrom's case had already proceeded in Connecticut and that the Massachusetts court no longer had authority over his supervised release. Consequently, the court asserted it could not simply remand the case for reassessment of the supervised release conditions.The court concluded that although it had the power to grant relief, the controversy was so attenuated that considerations of prudence and comity for coordinate branches of government counseled the court to withhold relief. The only possible remedy would require significant judicial resources and provide only a remote benefit to Sastrom. Therefore, the court declined to grant this remedy and affirmed the lower court's decision. View "United States v. Sastrom" on Justia Law
Posted in:
Criminal Law
Caribe Chem Distributors, Corp. v. Southern Agricultural Insecticides, Inc.
A Puerto Rican company, Caribe Chem, filed a lawsuit against a Florida company, Southern Agricultural Insecticides, and two Puerto Rican entities. The case was initially non-removable to federal court due to lack of complete diversity among parties. After the Puerto Rican defendants were dismissed from the lawsuit based on the statute of limitations, Southern attempted to remove the case to federal court, citing now-complete diversity of parties. Caribe objected, and the district court ruled in Caribe's favor, ordering the case to be remanded to Commonwealth court. Southern appealed the remand order.The United States Court of Appeals for the First Circuit affirmed the district court's remand order. The court adopted the voluntary/involuntary rule, which states that a lawsuit initially lacking complete diversity can acquire it when all non-diverse parties are dismissed from the action. However, if the non-diverse defendants are dismissed without the plaintiff's acquiescence, the lawsuit is generally not removable. The court ruled that the dismissal of the non-diverse defendants was involuntary since it was over Caribe's objections. The court also stated that the plaintiff's decision not to appeal the dismissal does not make the dismissal voluntary. The court reaffirmed that the voluntary/involuntary rule precludes removal where non-diverse defendants are dismissed without plaintiff's voluntary action. The court also affirmed the district court's denial of Southern's motion to set aside the judgment under Rule 60.
View "Caribe Chem Distributors, Corp. v. Southern Agricultural Insecticides, Inc." on Justia Law
Posted in:
Business Law, Civil Procedure
Dutra v. Trustees of Boston University
This appeal, heard by the United States Court of Appeals for the First Circuit, centered on the constitutionality of Massachusetts' Law 80, which retroactively provided immunity to higher education institutions for monetary damages due to actions taken in response to the COVID-19 pandemic. The plaintiffs, students at Boston University (BU), had sued the university for breach of contract and unjust enrichment following BU's transition to remote learning during the Spring 2020 semester. They contended that they had paid for in-person instruction and services, which BU failed to provide.The lower court ruled in favor of BU, holding that the university was entitled to the defense of impossibility as it had to comply with COVID-19 emergency orders. On appeal, the court was required to consider whether the retroactive application of Law 80 to the case violated the Due Process Clause of the United States Constitution.The appellate court found that Law 80 served reasonable public interests related to public health, safety, future compliance, and economic consequences beyond the control of the universities. The court also determined that the plaintiffs' alleged implied contract rights did not constitute vested rights. Furthermore, the court noted that the scope of Law 80 was appropriately limited and did not excessively burden the plaintiffs.Consequently, the court held that Law 80 does not violate due process and affirmed the lower court's judgment, ruling in favor of BU. The court did not need to consider the merits of the lower court's decision to exclude the plaintiffs' expert witness's testimony. View "Dutra v. Trustees of Boston University" on Justia Law
Posted in:
Constitutional Law, Education Law
United States v. Ayala-Vazquez
In 2010, Ángel M. Ayala-Vázquez was indicted and convicted on multiple drug-related charges, including conspiring to possess with intent to distribute and aiding and abetting the possession of with intent to distribute over 280 grams of cocaine base. He was sentenced in 2011 to life imprisonment. In 2021, Ayala filed a motion to reduce his sentence under the First Step Act and for compassionate release due to his hypertension and obesity making him vulnerable to COVID-19.The District Court denied Ayala's motion, concluding that he was ineligible for a sentence reduction under the First Step Act because his sentences were imposed "in accordance with" the amendments made by the Fair Sentencing Act. The court also rejected his request for compassionate release, finding that Ayala failed to demonstrate extraordinary and compelling reasons to warrant such relief. Moreover, the court determined that Ayala posed a danger to other persons and the community.On appeal to the United States Court of Appeals for the First Circuit, the court affirmed the District Court's decision. It concluded that Ayala was indeed convicted of offenses involving 280 grams or more of cocaine base, and his life sentences were in accordance with the Fair Sentencing Act. Therefore, he was not eligible for a sentence reduction under the First Step Act. As for the compassionate release, the court found no abuse of discretion in the District Court's evaluation of Ayala's health conditions and perceived danger to the community. View "United States v. Ayala-Vazquez" on Justia Law
Posted in:
Criminal Law, Health Law
Jakuttis v. Town of Dracut
The case involves Joseph A. Jakuttis, a former officer and detective in the Dracut Police Department, who also served as a Task Force Officer for the federal Drug Enforcement Administration's Cross Borders Initiative. Jakuttis brought multiple federal and state claims against the Town of Dracut, certain Dracut police officers, and members of the federal law-enforcement task force. He alleged that he was demoted and faced retaliation after reporting serious criminal activities implicating two Dracut police officers, which he learned from a confidential drug informant.The United States Court of Appeals for the First Circuit affirmed the dismissal of Jakuttis's Bivens claims against Michael V. O'Hanlon and Richard P. Poirier, Jr., and his §1983 claim against the Town of Dracut, David J. Chartrand Jr., and Demetri Mellonakos. The court ruled that the defendants are entitled to qualified immunity, as they could have reasonably thought that Jakuttis was speaking as part of his official duties rather than as a private citizen when he reported the misconduct, thus not clearly violating his First Amendment rights.The court also affirmed the dismissal of Jakuttis's state-law tort claims against Poirier, as Poirier was deemed to be acting within the scope of his federal employment during the relevant times. However, the court remanded the Massachusetts Whistleblower Act claim against the Town of Dracut and the Intentional Interference with Advantageous Economic Relationship claim against Chartrand and Mellonakos to the District Court. The court reasoned that these state-law claims should be resolved by a state court due to reasons of comity. View "Jakuttis v. Town of Dracut" on Justia Law
Ocean State Tactical, LLC v. Rhode Island
In this case, the United States Court of Appeals for the First Circuit examined an appeal against a district court's refusal to issue a preliminary injunction against the enforcement of a Rhode Island law banning certain large-capacity ammunition magazines. The plaintiffs, a group of gun owners and a registered firearms dealer, argued that the law infringed upon their Second Amendment rights, as well as their rights under the Fifth and Fourteenth Amendments.The Court of Appeals, however, upheld the district court's decision. It noted that the law did not impose a significant burden on the right of armed self-defense, as it did not prevent gun owners from owning other forms of weaponry or ammunition, and the banned magazines were rarely used in self-defense situations. Furthermore, the court found that the law was consistent with a longstanding tradition of regulating firearms in the interest of public safety.The court also rejected the plaintiffs' arguments that the law was retroactive and vague, violating their Fourteenth Amendment rights. It concluded that the law was not retroactive as it did not impose new liability on past actions, and it was not unconstitutionally vague as individuals of ordinary intelligence could understand what it prohibited. The court also found that the plaintiffs were unlikely to succeed on their Fifth Amendment claims, as the law did not effect a physical or regulatory taking of their property. View "Ocean State Tactical, LLC v. Rhode Island" on Justia Law
Posted in:
Civil Rights, Constitutional Law