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

Petitioner, a native and citizen of Guatemala, entered the United States without inspection. The Immigration and Naturalization Service (INS) later issued Petitioner a notice to appear in removal proceedings. An immigration judge (IJ) denied Petitioner's application for withholding of removal but granted his application for voluntary departure. The board of immigration appeals (BIA) affirmed the IJ's decision and dismissed Petitioner's appeal. The First Circuit Court of Appeals denied Petitioner's petition for review, holding (1) the BIA did not err by determining that Petitioner had not been a victim of past persecution in Guatemala; (2) Petitioner's argument that the BIA erred in finding he was not a member of a particular social group was not grounds for granting his petition for review; and (3) imposing a requirement of "social visibility" as to "social groups" did not constitute an arbitrary and capricious agency interpretation. View "Tay-Chan v. Holder" on Justia Law

Defendant, Starbucks Corporation, accumulated tips from containers along individual stores' cash registers and distributed them weekly to baristas and shift supervisors within a store in proportion to the number of hours worked that week by each individual. Plaintiffs, former Starbucks baristas, filed a putative class action state court against Starbucks, asserting that Starbucks' policy violated Massachusetts' Tips Act because it allowed shift supervisors to share in the pooled gratuities. Starbucks removed the case to federal court, alleging class-action diversity jurisdiction. The district court, applying Massachusetts law, concluded that the Defendant's policy regarding pooled gratuities violated the Tips Act, certified a class, and awarded damages in an amount exceeding $14,000,000. The First Circuit Court of Appeals affirmed, holding that the plain language of the Tips Act prohibited Defendant's tip-pooling policy. View "Matamoros v. Starbucks Corp." on Justia Law

The parties in this case were Plaintiff, Madeleine Candelario del Moral, and Defendant, UBS Financial Services, Inc. of Puerto Rico (UBSPR). The lead issue argued here arose from a Puerto Rico judge's verbal order in a divorce contest between Plaintiff and her ex-husband, David Efron. The order vacated a multi-million dollar attachment Plaintiff obtained against Efron's UBSPR accounts. A courtroom clerk later wrote that vacating order up in a document called "minutes," which never got signed by a judge or properly noticed to Plaintiff and Efron. Claiming that the minutes were facially defective, Plaintiff insisted that UBSPR was negligent in letting Efron withdraw millions from certain accounts. The circuit court agreed and granted Plaintiff's motion as to liability. Acting own his own initiative, the circuit court judge (Judge) granted Plaintiff summary judgment on her damages claim too, even though she had expressly limited her motion to the threshold liability issue. The First Circuit Court of Appeals vacated the summary judgment for Plaintiff because there were genuine issues of material fact precluding summary judgment. Remanded for trial. View "Candelario-Del-Moral v. UBS Fin. Servs., Inc. of P.R." on Justia Law

Appellant was indicted in federal district court on two counts of being a felon in possession of firearms and ammunition. Appellant moved to suppress the ammunition as well as inculpatory statements he made in connection with his arrest. After an evidentiary hearing, the district court denied the motion. Appellant subsequently entered a conditional guilty plea on both counts, reserving his right to appeal the denial of his suppression motion. Appellant then appealed. The First Circuit Court of Appeals affirmed, holding that the district court properly declined to grant Appellant's suppression motion, as the stop that led to the discovery of the ammunition (1) was justified at its inception and did not constitute an unlawful seizure, and (2) was not transformed into a de facto arrest requiring Miranda warnings. View "United States v. Rabbia" on Justia Law

After they were fired from their jobs, Appellants filed suit in federal district court against their former employer (Employer) and against the severance plan (Plan) established by Employer pursuant to ERISA. The complaint asserted federal claims under ERISA, ADEA, ADA, and other federal laws, and also asserted a breach of contract claim, an employment discrimination claim, and an unjustified dismissal claim under Puerto Rico law. The district court granted Appellees' motion for summary judgment. Appellants challenged that ruling as well as a number of the district court's other orders. The First Circuit Court of Appeals affirmed, holding that there was no error in the management of this case or the grant of Appellees' motion for summary judgment. View "Cruz v. Bristol-Myers Squibb Co., PR, Inc." on Justia Law

Defendant pled guilty in Massachusetts federal district court to five counts of crack cocaine distribution and one count of conspiracy to distribute. Defendant was sentenced to 121 months in prison and appealed to challenge the sentence. Specifically, Defendant challenged the quantity of drugs attributed to him. The First Circuit Court of Appeals vacated the sentence and remanded for re-sentencing, holding (1) it was not clear error to conclude that Defendant's then-current and ongoing drug operation included at least one 152-gram purchase; but (2) the finding of two such 152-gram acquisitions, which triggered a mandatory minimum sentence in addition to greatly enlarging the recommended guideline sentence, was error. View "United States v. Marquez" on Justia Law

Erasmo Rojas-Perez (Rojas), the lead petitioner in this case, and his wife, Angelica Garcia-Angeles (Garcia), sought review of a final order of removal issued by the Board of Immigration Appeals (BIA). Petitioners, who had entered the United States without inspection, had filed applications for withholding of removal based on their stated belief that if the family returned to Mexico, their son, a U.S. citizen by virtue of being born in the U.S., could be kidnapped and held for ransom. The BIA reasoned that Petitioners' stated fear was not properly grounded in their belonging to a discernible social group under the Immigration and Nationality Act because "fear of persecution based on perceived wealth does not constitute a particular social group under the [INA]." The First Circuit Court of Appeals denied Rojas's petition for review, as the BIA's determinations were based on substantial evidence in the record. View "Rojas-Perez v. Holder" on Justia Law

This dispute between The Saint Consulting Group (Saint) and its liability insurer, Endurance American Specialty Insurance Company (Endurance), stemmed from Endurance's refusal to defend Saint in a lawsuit against Saint in the Northern District of Illinois. The district court dismissed Saint's lawsuit against Endurance based on an exclusion in the policy that stated explicitly that the policy does not apply to any claim based upon or arising out of any actual or alleged violations of the Sherman Anti-Trust Act or any similar provision of any state law. The First Circuit Court of Appeals affirmed, holding (1) because the second complaint alleged that Saint engaged in an anti-competitive scheme the exclusion was triggered; and (2) the policy did not cover the negligent spoliation claim in the first complaint. View "Saint Consulting Group, Inc. v. Endurance Am. Specialty, Inc." on Justia Law

In an effort to reduce costs and achieve greater efficiency, Employer consolidated two lab operations into one, which resulted in a reduction in positions and in a Union losing jurisdiction over lab testing work that its members had previously performed. At issue in this appeal was Employer's obligations under national labor law to bargain with the union representing the affected employees. The National Labor Relations Board found (1) the lab work transfer decision involved a mandatory subject of bargaining so that Employer's refusal to bargain violated the National Labor Relations Act, and (2) the collective bargaining agreement between Employer and Union did not prohibit the work transfer without the Union's consent. The First Circuit Court of Appeals affirmed, (1) holding that the Board made no error of law in reaching its decision; and (2) granting the Board's petition for enforcement of its order requiring Employer to return to the Union certain work that Employer had transferred. View "Nat'l Labor Relations Bd. v. Solutia, Inc." on Justia Law

Plaintiff was severely injured in a workplace accident and sued Trail King, the custom manufacturer of the trailer involved in the accident. The First Circuit Court of Appeals affirmed a jury's finding that Defendant had not been negligent nor in breach of any warranty. In the trial court in that diversity case, Plaintiffs belatedly attempted to amend their complaint to add another claim, one under Mass. Gen. Laws ch. 93A for unfair and deceptive trade practices. The trial judge denied the motion, finding the effort to amend untimely. Plaintiffs did not appeal this denial in their earlier appeal. This case concerned whether Plaintiffs may now maintain an independent suit for the ch. 93A claims against Trail King. The district court dismissed the claims with prejudice, finding that the doctrine of claim preclusion applied. Plaintiffs appealed, arguing that ch. 93A, 9(8) provides an exception to the normal rules of res judicata. The First Circuit affirmed, holding that under the facts of this case, Plaintiffs may not now bring this ch. 93A claim because of the failure to appeal from the denial of the motion to amend. View "Hatch v. Trail King Indus., Inc." on Justia Law