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

Appellant pleaded guilty to two counts related to his involvement in a drug ring. After a plea colloquy, the district judge sentenced Appellant to 327 months on count one and life imprisonment on count two, to run consecutively. Thereafter, the district judge twice resentenced Appellant. Before the First Circuit, Appellant argued that the judge lacked authority for actions taken after entry of the first sentence and that flaws in the initial plea colloquy warranted vacation of the first judgment. The First Circuit originally affirmed the initial guilty plea and original sentence. The Court subsequently granted the petition for panel rehearing and withdrew its previous opinion on the matter. The First Circuit ultimately vacated all judgments and orders of the district court, holding (1) the district judge lacked the authority to modify the original sentence, and therefore, the amended judgment and all of the judge’s subsequent actions were null and void; and (2) because Appellant did not appreciate that he faced the risk that the initial punishment would be reinstated by the Court, the Court simply vacated the original sentence and remanded for resentencing. View "United States v. Sevilla-Oyola" on Justia Law

Appellant was charged with being a felon in possession of a firearm. Appellant entered into a written plea agreement with a commitment that the government would recommend a sentence of no more than fifty-six months. Thereafter, Appellant tendered his guilty plea. The district court set a guideline sentencing range significantly higher than that anticipated by the parties and subsequently imposed a mid-range sentence of 103 months. The First Circuit affirmed the sentence, holding that the district court did not abuse its discretion in imposing the 103-month sentence, as it fell within the bounds of reasonableness, and Appellant’s remaining claims of error were without merit. View "United States v. Vega-Salgado" on Justia Law

Defendant pled guilty under a plea agreement to conspiring to distribute at least fifty kilograms of marijuana and to distributing or aiding and abetting the distribution of marijuana. A judge with the First Circuit used a preponderance standard in finding facts that increased Defendant’s mandatory-minimum sentence, ultimately sentencing Barnes to 210 months’ imprisonment and five years’ supervised release. Defendant appealed, arguing that drug quantity must be treated as an element of the offense and thus proved beyond a reasonable doubt. The First Circuit affirmed based on controlling caselaw. After Defendant sought certiorari, the Supreme Court held in Alleyne v. United States that most facts that increase statutory minimum penalties must be proved beyond a reasonable doubt. The Supreme Court then granted certiorari, vacated the judgment, and remanded for further consideration in light of Alleyne. The First Circuit vacated Defendant’s sentence and remanded for resentencing, holding that the Alleyne error in this case was not harmless beyond a reasonable doubt. View "United States v. Barnes" on Justia Law

Plaintiff was an exotic dancer employed by an adult entertainment club (“Club”) operated in Providence, Rhode Island by Defendant, a Rhode Island corporation. Plaintiff sued the Club, alleging that she was injured when a fellow dancer assaulted her. The Club removed the action to the United States District Court of the District of Massachusetts and then moved to dismiss the action for improper venue and want of in personam jurisdiction. The district court’s Judge Saylor subsequently transferred the case to the District of Rhode Island, determining that the Club had insufficient contacts with Massachusetts to warrant the exercise of personal jurisdiction. The Club again moved to dismiss, alleging that the suit had been commenced outside the applicable limitations period. Plaintiff did not respond to this motion. The district court summarily granted the motion and dismissed the action. On appeal, Plaintiff challenged Judge Saylor’s determination that the Massachusetts district court lacked personal jurisdiction over the Club. The First Circuit affirmed, holding that Plaintiff’s argument was not reviewable on appeal. View "Cioffi v. Gilbert Enters., Inc." on Justia Law

Defendant was driving a rental car he had retrieved from his son’s girlfriend when he was stopped by a police officer. The officer subsequently discovered a bag on the passenger seat containing a gun and two boxes of ammunition. Defendant was charged with being a felon in possession of a firearm. Defendant moved to suppress the evidence, arguing that the stop was illegal. The district court denied the motion to suppress, concluding that because Defendant was an unlicensed, unauthorized driver of the rental car, he did not have standing to challenge the stop. A jury returned a guilty verdict, and Defendant was sentenced to 210 months in prison. The First Circuit vacated the conviction and remanded for an evidentiary hearing, holding that the district court erred as a matter of law in concluding that Defendant lacked standing to challenge the constitutionality of the stop. View "United States v. Starks" on Justia Law

The Town of Mendon, Massachusetts set forth zoning restrictions regulating the size and height allowances for buildings operating adult-entertainment businesses, limiting the operating hours of such businesses, and banning the sale or consumption of alcohol on their premises. The stated purposes for these bylaws were to control the secondary effects uniquely related to adult entertainment. Showtime Entertainment, LLC filed suit, claiming (1) the restrictions on its operating hours and size and height of its building were unconstitutional restrictions of expressive activity protected by the First Amendment; and (2) the alcohol restrictions violated the Massachusetts Declaration of Rights. The district court entered summary judgment in favor of Mendon, concluding that the restrictions were sufficiently tailored towards controlling the secondary effects of speech. The First Circuit (1) reversed the summary judgment in favor of Mendon as it related to the bylaws regarding the size, height, and operating hours of Showtime’s business, holding that the bylaws unconstitutionally infringed on Showtime’s right to engage in a protected expressive activity; and (2) certified to the Massachusetts Supreme Judicial Court questions related to Mendon’s restriction on adult entertainment occurring within establishments licensed to serve alcohol. View "Showtime Ent., LLC v. Town of Mendon" on Justia Law

Plaintiff received benefits under her employer’s long-term disability benefit plan before the administrator for the long-term disability program determined she was no longer eligible for benefits. The administrator denied Plaintiff’s appeal as untimely for her failure to appeal within the benefit plan’s 180-day deadline. Plaintiff filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), claiming that her failure to comply with the 180-day deadline should have been excused because the benefit plan’s written instrument did not mention the deadline. The district court dismissed Plaintiff’s benefits challenge as well as her two other ERISA claims for statutory penalties and for breach of fiduciary duty. The First Circuit affirmed, holding that the district court did not err in (1) dismissing Plaintiff’s benefits challenge, as Plaintiff failed to meet the deadline for appealing internally the decision to cut off her long-term disability benefits, and the benefit plan had expressly incorporated that deadline into the benefit plan’s written instrument; and (2) ruling that Plaintiff could not recover statutory penalties against the administrator or that she had waived her claim for breach of fiduciary duty. View "Tetreault v. Reliance Standard Life Ins. Co." on Justia Law

In 1996, TWA Flight 800 exploded in mid-air and crashed eight miles south of Long Island, New York. After an investigation that was the largest and most expensive in the history of the National Transportation Safety Board (NTSB), the NTSB accepted the CIA’s assessment of eyewitness accounts and concluded that a mechanical explosion caused the crash. Theorizing that the CIA was covering up the true cause of the crash, Plaintiff requested certain documents from the investigation. The district granted summary judgment for the CIA, concluding that the Freedom of Information Act permitted the agency to withhold the requested documents. The First Circuit affirmed the district court’s order granting the CIA’s motion for summary judgment, holding that the CIA properly withheld the materials under the Act. View "Stalcup v. Cent. Intelligence Agency" on Justia Law

After a jury trial, Defendant was convicted of being a felon in possession of one or more firearms and of knowingly possessing one of more firearms. Defendant appealed, arguing that the evidence was insufficient to prove that he knowingly possessed the firearms and that he knew the firearms were stolen. The First Circuit affirmed Defendant’s firearms convictions, holding (1) the jury’s finding that Defendant knowingly possessed the shotguns found in the trunk of the car he was driving when he was found by police was supportable on the record; and (2) there was sufficient evidence to support the jury’s finding that Defendant knew the shotguns were stolen. View "United States v. Ridolfi" on Justia Law

At issue in this case was the mandatory detention provision of the Immigration and Nationality Act, 8 U.S.C. 1226(c), which provides that the Attorney General shall take into custody any alien who has committed certain predicate crimes “when the alien is released.” The general rule under section 1226 is that aliens arrested and charged with removal may be released on bond pending removal proceedings. Aliens subject to mandatory detention, however, are generally ineligible for bail. Petitioners, two aliens, committed a predicate crime listed in section 1226(c) but were not taken into custody by the Attorney General until years after being released from state custody. Petitioners filed separate petitions for writ of habeas corpus, arguing that their detention without opportunity for release on bond was unauthorized by law. The district court granted habeas corpus relief in each case. The First Circuit affirmed, holding that Petitioners were not subject to mandatory detention under section 1226(c) because they were not timely detained under any reasonable interpretation of the statute. View "Castaneda v. Souza" on Justia Law