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

Defendant, a convicted sex offender, moved from the District of Columbia to Massachusetts without complying with the Sex Offender Registration and Notification Act (SORNA). Defendant was subsequently arrested and indicted for violating 18 U.S.C. 2250(a), which criminalizes a knowing failure to abide by SORNA's registration requirements. Defendant filed a motion to dismiss the indictment, arguing that SORNA exceeds Congress's constitutional authority, that it includes an unconstitutional delegation of legislative power, and that no regulations have validly applied SORNA to offenders whose convictions, like Defendant's, pre-date SORNA. The district court denied the motion. Defendant pled guilty to the charge but preserved his right to appeal the denial of his motion to dismiss the indictment. The First Circuit Court of Appeals affirmed the denial of Defendant's motion, holding that Defendant was subject to SORNA's registration requirements when he traveled to Massachusetts, and because he failed to register, his conviction under section 2250(a) was proper. View "United States v. Whitlow" on Justia Law

This suit arose from a 2010 change to the certification and enrollment process for providers in the Commonwealth's Supplemental Educational Services program, funded under federal law. Appellant, a certified educational services provider based in Puerto Rico, filed a civil rights action pursuant to 42 U.S.C. 1983 against Defendant, personally and in his official capacity as Puerto Rico's Secretary of Education, alleging that the change in the certification and enrollment process unilaterally and arbitrarily disadvantaged Appellant vis-a-vis its competitors. The district court dismissed the amended complaint in its entirety, finding that it lacked sufficiently well-pled facts to support a plausible claim that Defendant had violated Appellant's due process, equal protection, or commercial free speech rights. The First Circuit Court of Appeals affirmed on alternate grounds, holding that Defendant was entitled to qualified immunity as to all claims. View "Rocket Learning, Inc. v. Rivera-Sanchez" on Justia Law

Plaintiff, an instructor in graphics who did not have a Ph.D., was denied a tenure-track position at the University of Puerto Rico. Three others, all of whom had Ph.D.s as the description required, did receive tenure-track positions. Plaintiff filed administrative discrimination charges, followed by a Title VII lawsuit against the University. The district court granted summary judgment for the University. The First Circuit Court of Appeals affirmed, holding that the Ph.D. requirement for tenure-track positions was a legitimate, nondiscriminatory reason for the University's actions and that Plaintiff did not meet her burden of showing that the articulated reason was pretextual. View "Johnson v. Univ. of P.R." on Justia Law

After a jury trial, Defendant was convicted of first degree murder based on extreme atrocity or cruelty. The jury rejected Defendant's insanity defense. After unsuccessfully filing a motion for a new trial and a motion to consider, Defendant filed this habeas corpus petition, alleging several errors on the part of the motion judge. The district court denied the petition. The First Circuit Court of Appeals affirmed, holding that the motion judge did not err in ruling (1) the trial court did not need to hold a competence hearing sua sponte; (2) trial counsel was not constitutionally deficient; (3) the trial court did not need to inquire into Defendant's waiver of his right to testify; and (4) appellate counsel was not constitutionally deficient. View "Rosenthal v. O'Brien" on Justia Law

The United States Postal Services (USPS) terminated Plaintiff's employment contract after discovering, through a sting operation, that Plaintiff had stolen mail containing money. The Postal Service Board of Contract Appeals (PSBCA) convened an evidentiary hearing and determined that Plaintiff's breach of his employment contract justified the decision to terminate his contract. Plaintiff did not appeal this decision. Meanwhile, Plaintiff initiated a Federal Tort Claims Act (FTCA) suit against the United States for the actions of USPS employees on the date of the sting, alleging six torts. The district court dismissed three of the claims and granted summary judgment to the government on the remaining claims. The First Circuit Court of Appeals affirmed the district court as to all claims, holding (1) the district court correctly concluded that the PSCBA's findings precluded relitigation of the factual issues in Plaintiff's FTCA suit; and (2) summary judgment was properly granted as to Plaintiff's FTCA claims for negligent supervision, malicious prosecution, and invasion of privacy by postal inspectors. View "Rios-Pineiro v. United States" on Justia Law

This action arose out of Plaintiffs' alleged breach of a conservation restriction appurtenant to their Hudson, Massachusetts home. Plaintiffs and members of the Hudson Conservation Commission clashed over Plaintiffs' compliance efforts. In the meantime, a Hudson Police captain filed charges against Plaintiff for criminal harassment and threat to commit a crime based on Plaintiff's alleged misconduct to his neighbors. All charges were later dropped against Plaintiff. Plaintiffs subsequently filed a 42 U.S.C. 1983 suit against the Town of Hudson, the Commission, and several state and local officials, alleging that Commission members, an administrator, and a building inspector violated the equal protection clause by selectively enforcing local laws against them and that the conduct of town officials and other defendants were so outrageous as to constitute substantive due process violations. The district court dismissed the suit. The First Circuit Court of Appeals affirmed, holding that Plaintiffs' complaint did not plead facts sufficient to support any of their federal claims. View "Freeman v. Town of Hudson" on Justia Law

Plaintiff, a professor at the University of Massachusetts, applied to the Drug Enforcement Administration (DEA) for registration to manufacture marijuana for clinical research. An ALJ recommended that the DEA granted Plaintiff's application. The DEA Deputy Administrator Administrator rejected the ALJ's recommendation and denied Plaintiff's application. The Administrator then denied Plaintiff's motion for reconsideration. The First Circuit Court of Appeals denied Plaintiff's petition for review, holding (1) the Court had jurisdiction to consider Plaintiff's petition for review; (2) under Chevron, USA, Inc. v. Natural Resources Defense Council, Inc., the Administrator's interpretation of the Controlled Substances Act was permissible; and (3) the Administrator's findings were reasonable and supported by the evidence. View "Craker v. Drug Enforcement Admin." on Justia Law

Relator brought a federal False Claims Act (FCA) suit against Millennium Laboratories of California (Millennium) and several physicians, alleging that Millennium encouraged physicians to bill the government multiple times for single drug tests and to perform excessive, medically unnecessary original and confirmation tests. Prior to the filing of the complaint, Millennium filed a suit against Relator's employer, Calloway Laboratories (Calloway), in California state court. Millennium attached emails from from Calloway employees to third parties suggesting fraudulent activity in Millennium's billing practices. The district court dismissed Relator's complaint, finding that the prior disclosure constituted a jurisdictional bar to Relator's suit. The First Circuit Court of Appeals held that the court erred in dismissing all of Relator's claims when only some of them had been disclosed by way of being substantially similar to the information contained in Millennium's prior California suit. Remanded for the district court's consideration of whether Relator's remaining FCA claim was sufficiently pled. View "United States ex rel. Estate of Cunningham v. Millennium Labs. of Cal., Inc." on Justia Law

After a jury trial, four defendants (Defendants) were convicted of one count of conspiracy to possess with intent to distribute narcotics and one count of conspiracy to use or carry firearms in furtherance of a drug trafficking crime. After considering all of the evidence, including evidence of seven murders committed in furtherance of the narcotics conspiracy, the district court sentenced each Defendant to life imprisonment on the first count and ten years' imprisonment on the second count, to be served consecutively. The First Circuit Court of Appeals affirmed, holding (1) the evidence was sufficient to support the guilty verdicts as to each defendant; (2) the district court did not err in imposing the life sentences as to three of the defendants; and (3) the court did not err in denying severance as to the fourth defendant. View "United States v. Rodriguez-Reyes" on Justia Law

Defendant was a Marine Corps veteran who worked as a civilian employee with the U.S. Department of Veterans Affairs. Defendant was convicted of fraud in connection with his own receipt of veterans benefits. Defendant appealed, contending (1) statements he made during an interview with a Criminal investigator for the Veterans Administration Office of the Inspector General were coerced because they forced him to choose between losing his job or surrendering his right to remain silent under the Fifth Amendment, and (2) the restitution he was ordered to pay as part of his sentence should have been offset by other benefits he might have claimed from the Veterans Administration. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in refusing to suppress statements Defendant made to the Veterans Administration investigator; and (2) the court's restitutionary order was proper. View "United States v. Palmquist" on Justia Law