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

A drug interdiction in Caribbean waters by the United States Coast Guard ended with the arrest and indictment of multiple defendants, including Appellant. The Coast Guard determined that the vessel was "without nationality" and subject to the jurisdiction of the United States under the Maritime Drug Law Enforcement Act (MDLEA). Appellant was convicted of possession with the intent to distribute more than 1140 pounds of cocaine and heroin while on board a vessel in violation of the MDLEA. On appeal, Appellant argued that Congress lacked the authority under the Piracies and Felonies Clause to criminalize drug trafficking on board a vessel in international waters under the MDLEA without requiring a nexus between the conduct and the United States. The First Circuit Court of Appeals affirmed, holding that any jurisdictional error under the MDLEA related to Appellant's conviction did not constitute plain error in this case. View "United States v. Nueci-Pena" on Justia Law

James "Whitey" Bulger was the leader of a criminal organization in Boston from 1972 to 1999. An indictment returned by a federal grand jury charged Bulger with a number of federal offenses, including violations of the Racketeer Influenced and Corrupt Organizations (RICO) Act, and the indictment alleged that Bulger committed nineteen murders ancillary to the RICO conspiracy. Bulger's case was assigned to U.S. District Court Judge Richard Stearns. Bulger moved that Judge Stearns recuse himself, arguing that the judge's prior employment as head of the U.S. Attorney's Criminal Division in Boston and his close friendship with FBI Director Robert Mueller created an appearance of impropriety necessitating recusal. Judge Stearns denied the motion. Bulger subsequently petitioned the First Circuit Court of Appeals for a writ of mandamus requiring reversal of the judge's order denying the motion for recusal. In an opinion written by Hon. David H. Souter, the First Circuit granted the petition and ordered the case to be reassigned to a different judge "because it is clear that a reasonable person would question the capacity for impartiality of any judicial officer with the judge's particular background in the federal prosecutorial apparatus in Boston during the period covered by the accusations." View "In re Bulger" on Justia Law

Defendant pled guilty to one count of importing codone. The guilty plea was based on an incident in which, based on tips from three confidential informants (CIs), federal agents apprehended Defendant at the Canadian border, handcuffed him to a hospital bed, and monitored Defendant's bowel movement, in which Defendant passed a condom containing 104 eighty-milligram and five forty-milligram oxycodone pills. The district court assigned Defendant a drug quantity equivalent to 2,637 eighty-milligram oxycodone pills based in part on uncharged conduct described by the CIs and sentenced Defendant to 108 months in prison. The First Circuit Court of Appeals affirmed, holding that the district court did not err in (1) denying Defendant's motion to force the government to disclose the CIs' names, as the court correctly weighed the correct factors in finding that the government's interest in preserving the CIs' anonymity tipped the scale against disclosure; and (2) calculating the drug quantity attributable to Defendant, as the CIs' statements were sufficiently reliable. View "United States v. Mills" on Justia Law

Defendant entered a plea of guilty to distributing cocaine base pursuant to a binding plea agreement. More than seven months later, Defendant filed a motion to vacate his guilty plea, which the district court denied. The court subsequently sentenced Defendant to serve ninety months in prison. Defendant appealed, arguing that his plea was neither voluntary nor knowing because he did not realize at the time he entered it that the sentencing guidelines were merely advisory. The First Circuit Court of Appeals affirmed, holding that the district court did not err in denying Defendant's motion to vacate his guilty plea, as (1) the proffered reason for revoking the plea was implausible; and (2) the waiver of appeal provision contained in the plea agreement was valid, and enforcement of the waiver would not result in a miscarriage of justice. View "United States v. Chambers" on Justia Law

Plaintiffs brought two citizen enforcement actions under the Clean Water Act (CWA) against Defendants pursuant to 33 U.S.C. 1365(a). The suits were dismissed without prejudice due to defects in the service or contents of earlier pre-suit notices. Plaintiffs then brought their most recent citizen suit, which the district court dismissed without prejudice, finding that Plaintiffs had failed to allege or establish several mandatory prerequisites to a citizen suit under the CWA in their pre-suit notice. The First Circuit Court of Appeals reversed in part, holding that the district court erred in dismissing the case, as (1) Plaintiffs' pre-suit notice satisfied the requirement that the notice identify the potential plaintiffs, provide basic contact information, and allow the putative defendants to identify and remedy the alleged violations; and (2) therefore, the enforcement action may proceed. View "Paolino v. JF Realty, LLC" on Justia Law

Defendant bought a custom-made yacht with the help of a loan from Barclays Bank. When Defendant stopped making payments on the loan, Barclays repossessed the yacht and sold it pursuant to the Florida UCC. Barclays got less than what Defendant owed on the yacht, and therefore, Barclays sued Defendant for the deficiency. Defendant moved for summary judgment, arguing that Barclays was barred from recovering the deficiency because, in violation of the mortgage's terms, it did not provide Defendant with proper notice of the sale. The district court denied Defendant's motion and sua sponte granted summary judgment in favor of Barclays. The First Circuit Court of Appeals affirmed, holding that the notice Barclays provided to Defendant was sufficient. View "Barclays Bank PLC v. Poynter" on Justia Law

After a jury trial, Defendant was found guilty of bank burglary. In sentencing Defendant, the district court applied a sentencing guideline intended for cases of robbery, rather than the burglary guideline Defendant proposed. The resulting sentence was roughly twice what it would have been under the burglary guideline. Defendant appealed, challenging the constitutionality of the district court's decision to sentence him under a guideline intended for robbery. Without reaching Defendant's constitutional claim, the First Circuit Court of Appeals remanded for resentencing because, under the sentencing guidelines and the introduction to the guidelines' statutory appendix, where the guidelines specify more than one offense guideline for a particular statutory offense and no plea agreement stipulates to a more serious offense, the district court must select the most appropriate guideline based only on conduct charged in the indictment. View "United States v. Almeida" on Justia Law

Plaintiff, an international affairs specialist at the Puerto Rico State Department, filed a complaint against the Department, ten of its employees, the Commonwealth (collectively, the State Department defendants), and the Puerto Rico Ports Authority. Plaintiff alleged that the State Department defendants had discriminated against her due to her political views and that they had denied her the rights and benefits to which she was entitled under federal and local law. As against the Ports Authority, Plaintiff alleged it slandered her by publishing false information regarding an arrest for marijuana, which prevented her from fulfilling her work duties. The district court found that Plaintiff's complaint failed to state a claim upon which relief could be granted and dismissed the complaint. Plaintiff appealed, requesting a reversal of the district court's refusal to grant leave to amend the complaint based upon its finding that amendment would be futile. The First Circuit Court of Appeals affirmed, holding that the district court did not abuse its discretion in denying the requested amendment. View "Flores-Silva v. McClintock-Hernandez" on Justia Law

Defendant was indicted for drug-trafficking charges. Through a succession of court-appointed attorneys, Defendant filed motions to suppress certain evidence and to dismiss the indictment on speedy trial grounds. The district court denied the motions, and Defendant entered a conditional guilty plea to the charges. Prior to sentencing, Defendant moved pro se to withdraw his guilty plea and requested a new court-appointed attorney, which the district court appointed. The court then rejected Defendant's motion and sentenced Defendant to 240 months in prison. The First Circuit Court of Appeals affirmed, holding that the district court (1) did not err in denying Defendant's motion to suppress; (2) did not err in refusing to dismiss the indictment on speedy trial grounds; (3) did not abuse its discretion in concluding Defendant had not shown a fair and just reason for withdrawing his guilty plea; and (4) did not err in sentencing Defendant. View "United States v. Gates" on Justia Law

Matrix Construction Co. was a South Carolina corporation with its principal place of business in South Carolina. Matrix was the general contractor on a project to renovate schools in South Carolina. Matrix hired Contract Supply as a subcontractor. Contract Supply had a relationship with BlueTarp Financial, a company providing commercial credit to the construction industry that had its principal place of business in Maine. After Matrix accepted Contract Supply's bid, Matrix signed BlueTarp's account agreement, which stated that disputes would be governed by the laws of Maine. Matrix later learned that Contract Supply was not paying its suppliers and stopped paying Contract Supply. BlueTarp filed this action for breach of contract and unjust enrichment in the federal district court for the District of Maine invoking diversity jurisdiction. The district court dismissed the case for lack of personal jurisdiction over Matrix. BlueTarp appealed, arguing that the forum selection clause in the account agreement authorized jurisdiction in the Maine district court and, in any event, Matrix had sufficient connections with Maine to satisfy the personal jurisdiction requirements. The First Circuit Court of Appeals reversed, holding that, having found the relatedness, purposeful availment, and reasonableness factors satisfied, the district court had personal jurisdiction over Matrix. View "Bluetarp Fin., Inc. v. Matrix Constr. Co." on Justia Law