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

Defendant was convicted of producing child pornography. The district court sentenced Defendant to a term of imprisonment and advised that it would order Defendant to pay restitution to the victim for mental health treatment. The district court wanted to simply order payment directly to the victim, but Defendant objected, saying the victim might not use the money for treatment. The court ordered payment to the Crime Victims Fund, from which payment would be made to provide the victim with therapy. On appeal, Defendant argued that the district court erred in ordering the payment be made to the Fund rather than to the victim. The First Circuit Court of Appeals vacated and remanded with direction for the court to enter a restitution order payable to the victim, as there was no basis for accommodating Defendant’s original desire to monitor how his victim used the restitution payment. View "United States v. Montalvo-Cruz" on Justia Law

After a jury trial, Appellant was convicted of aiding and abetting interference with commerce by threats of violence and using a firearm during the commission of a crime of violence. On appeal, Appellant argued, among other things, that the district court violated his Sixth Amendment right to counsel of choice because the court forbade him from retaining new counsel without giving him an opportunity to be heard on the issue. The First Circuit Court of Appeals agreed with Appellant and vacated his conviction, holding that the district court violated Appellant’s right to counsel when it forbade Appellant from retaining substitute defense counsel without conducting any inquiry into Appellant’s conflict with present counsel. View "United States v. Diaz-Rodriguez" on Justia Law

On February 26, 2010, Plaintiff, who worked for the Parole Board of Puerto Rico, was terminated pursuant to Law 7, which implemented a brute-force reduction in the size of the government to improve Puerto Rico’s dire financial straits. On February 3, 2011, the union to which Plaintiff belonged prevailed on its suit in which it sought to reinstate Plaintiff and other unionized Parole Board employees. Although Plaintiff was reinstated to her position, eight months later she sued the members of the body charged with implementing Law 7, alleging that they had deprived of her due process of law in violation of 42 U.S.C. 1983. The federal district court dismissed Plaintiff’s section 1983 claim with prejudice on the grounds that it was time-barred under the applicable statute of limitations. The First Circuit Court of Appeals affirmed the district court’s order of dismissal, holding that the court did not err in dismissing Plaintiff’s action. View "Alamo-Hornedo v. Puig" on Justia Law

Plaintiff was charged in state court with offenses related to the manufacture and possession of marijuana after a neighbor reported to the police that the door was wide open at Plaintiff’s vacant home, and the police entered the home. The charges were dropped when a state court judge suppressed the evidence found in Plaintiff’s home. Plaintiff subsequently sued the Town of Eastham, two police officers, and a crime-scene investigator who had assisted in the search in the federal district court, alleging, among other claims, that Defendants had deprived him of his Fourth Amendment rights in violation of 42 U.S.C. 1983. The district court dismissed the complaint, holding that the officers who searched Plaintiff’s home were entitled to qualified immunity. The First District Court of Appeals affirmed, holding that because there is no clearly established law that would deter reasonable police officers from affecting an entry such as the one in this case, the individual defendants were entitled to qualified immunity. View "Macdonald v. Town of Eastham" on Justia Law

Evan Ardente’s yacht was insured by Standard Fire Insurance Company. After Ardente purchased the yacht, it stopped navigating properly, and its top speed had decreased due to water damage to the yacht’s hull. Specifically, water was seeping into balsa wood, which is not waterproof, around installation holes and spreading throughout the hull. Ardente presented a claim to Standard Fire. Standard Fire denied coverage on the ground that the claim fell within an exclusion for manufacturing defects. Ardente sued Standard Fire for breach of contract, among other claims. The district court granted summary judgment for Standard Fire on all claims except for the breach of contract allegation. On that claim, the court granted Ardente summary judgment with respect to liability, concluding that the damage fell within an exception to the exclusion for manufacturing defects. The First Circuit Court of Appeals reversed the district court’s order granting Ardente summary judgment on his breach of contract claim, holding that the damage to the yacht did not fall within the exception to the manufacture-defect exclusion, and therefore, Standard Fire was entitled to summary judgment on the breach of contract claim. View "Ardente v. Standard Fire Ins. Co." on Justia Law

Defendant confessed to participating in the arson of an African-American church following a seven-hour interrogation. Defendant was subsequently convicted in federal court of conspiracy against civil rights, damage to religious real property, and the use of a fire to commit a felony. Defendant appealed, arguing that the district court erred in denying his motion to suppress the incriminating statements made in his confession because they were obtained through agents’ coercive tactics and in violation of his right to prompt presentment. The First Circuit Court of Appeals affirmed, holding (1) under the circumstances of this case, the agents’ interrogative tactics did not amount to coercion in violation of Defendant’s Fifth Amendment rights; and (2) Defendant’s interrogation did not violate his right to prompt presentment. View "United States v. Jacques" on Justia Law

Union-affiliated benefit funds (collectively, the Fund) sued Employer to recover unpaid employee-related remittances allegedly due under a collective bargaining agreement (CBA). The Fund also sought attorneys’ fees and costs pursuant to both the CBA and ERISA. The district judge awarded the Fund $26,897 in damages, and, in a separate judgment, awarded $18,000 in attorneys’ fees and $16,688 in expenses. Both parties appealed. The First Circuit Court of Appeals reversed the district court’s determination of damages, but the Supreme Court reversed, concluding that the First Circuit lacked jurisdiction to review the damage judgment. On remand, the First Circuit reinstated the cross-appeals challenging the separate judgment for fees and costs and affirmed the district court’s order awarding attorneys’ fees and expenses, holding that the award was not an abuse of the judge’s discretion. View "Int'l Union v. Ray Haluch Gravel Co." on Justia Law

Plaintiff was a real estate broker in Puerto Rico who was a vocal critic of the Puerto Rico Real Estate Examining Board. After the Board denied Plaintiff’s application for a license to establish a bilingual real estate school, Plaintiff filed suit against the Board and several individuals associated with it, claiming that the Board denied her a license in retaliation for her public criticism of the Board, thereby violating her First Amendment rights. The district court dismissed the complaint for failure to state a claim upon which relief could be granted, concluding that the Board had a legitimate non-discriminatory reason - the tardiness of Plaintiff’s application - for rejecting the application. The First Circuit Court of Appeals reversed vacated the district court’s judgment, holding that Plaintiff’s allegations plausibly stated a claim under 42 U.S.C. 1983. Remanded. View "Maloy v. Ballori-Lage" on Justia Law

Plaintiffs, committed animal rights activists, filed this action seeking declaratory and injunctive relief that the Animal Enterprise Terrorism Act (“Act”), which criminalizes “force, violence, and threats involving animal enterprises,” violates the First Amendment. Plaintiffs had never been prosecuted or threatened with prosecution under the Act but claimed that fear of future prosecution and present self-restraint caused them to suffer injury in fact. The district court dismissed the complaint, holding that Plaintiffs failed to establish an injury in fact as required by Article III. The First Circuit Court of Appeals affirmed, holding that Plaintiffs’ unsubstantiated and speculative fear of prosecution under the Act was not a basis for standing under U.S. Const. art. III. View "Blum v. Holder" on Justia Law

Plaintiffs were Massachusetts-based producers of “reggaeton” music. This case centered on seven songs released on an album distributed by Defendants that allegedly infringed upon copyrights held by Plaintiffs and breached contracts to which Plaintiffs claimed to be parties and/or third-party beneficiaries. The district court granted Defendants’ motion for summary judgment, concluding (1) with respect to the copyright claims, Plaintiffs failed to register their copyrights in the underlying compositions they claimed were infringed, as required under 17 U.S.C. 411(A); and (2) with respect to the breach of contract claims, there was no evidence of a direct agreement between the parties or of third-party beneficiary status. The First Circuit Court of Appeals affirmed, holding that the district court did not err in granting summary judgment for Defendants on the copyright and contract claims. View "Alicea v. Ayala" on Justia Law