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

This appeal concerned a commercial dispute between business rivals. Ira Green, Inc. (Green) sued Military Sales & Service Co. (MilSal) in federal district court, alleging tortious interference and defamation. After an eight-day jury trial, the district court entered a final judgment for MilSal on all the tried counts. The district court denied Green’s motion for a new trial and taxed costs in favor of MilSal. Green appealed, asserting that a new trial was necessary because of a serious of legal errors, including error in the trial court’s failure to poll the jury despite Green’s request for such a poll. The First Circuit affirmed, holding (1) Green waived its request for a jury poll due to its failure to act reasonably to preserve its rights, and even if the jury-poll request was merely forfeited, the poll’s omission cannot be said to have affected Green’s substantial rights; and (2) upon consideration of the remainder of Green’s claims, there was no reversible error. View "Ira Green, Inc. v. Military Sales & Serv. Co." on Justia Law

Appellant was involved in a wide-ranging drug trafficking organization. After a trial, in which she was tried alone, Appellant was found guilty of conspiracy to possess with intent to distribute controlled substances and conspiracy to launder money. The district court sentenced Appellant to 121 months’ imprisonment as to each count, to be served concurrently. The First Circuit affirmed the convictions and sentence, holding (1) the evidence was sufficient to support the drug conspiracy conviction; (2) Appellant’s argument that the money laundering conviction should be vacated pursuant to United States v. Santos because the government failed to prove that the monies laundered were net profits of drug-trafficking failed because the government needed only to prove that the laundered funds were gross revenues; (3) the district court did not err when it gave a willful blindness instruction to the jury; and (4) the district court did not plainly err when it relied on the money laundering proceeds to establish a base offense level at sentencing. View "United States v. Adorno-Molina" on Justia Law

Appellant, a former plumbing inspector for the Town of Sangerville, sued a Town Selectman, asserting claims of common law slander and violations of his constitutional right to due process. The claims stemmed from the Selectman’s statement at a public meeting that Appellant had made “less than quality decisions” while serving as plumbing inspector. The Selectman filed an offer of judgment, which Appellant accepted. After judgment was entered, Appellant initiated this reach and apply action against Argonaut Insurance Company seeking to recover for the slander count and due process claims. The district court granted summary judgment for Argonaut, concluding that the exclusions in the insurance policies for “employment-related” practices barred Appellant’s recovery. The district court agreed and denied Appellant’s motion. The First Circuit affirmed, holding that because Appellant’s judgment against the Selectman arose from an employment-related dispute, the insurance policies unambiguously excluded coverage for claims arising from employment-related practices. View "Ruksznis v. Argonaut Ins. Co." on Justia Law

After a jury trial in Massachusetts state court, Petitioner was convicted of assaulting and raping a two-year-old child and sentenced to life imprisonment. Petitioner’s application for further appellate review was denied. Petitioner filed this petition for a writ of habeas corpus in the federal district court, arguing (1) the evidence against him, which was entirely circumstantial, was so insufficient that no reasonable jurist could have concluded that a rational jury could have found him guilty beyond a reasonable doubt; and (2) the trial court erred in refusing to permit him to cross-examine the victim’s mother about her potential bias arising from pending criminal charges against her. The district court denied the petition but issued a certificate of appealability as to both issues. The First Circuit affirmed, holding (1) the state courts could reasonably conclude that a rational jury could find beyond a reasonable doubt that Petitioner was the perpetrator; and (2) the state court’s exclusion of evidence about the victim’s mother’s pending criminal charges was not an unreasonable application of law clearly established by Supreme Court precedent. View "Winfield v. O'Brien" on Justia Law

In 1997, Appellant began working for Banco Popular de Puerto Rico (BPPR). After Appellant retired in 2009, BPPR made a final calculation of Appellant’s pension, which yielded monthly payments significantly lower than earlier estimates had suggested. Seeking the higher amount he had expected, Appellant brought claims under ERISA, a theory of estoppel, and Puerto Rico contract law. The district court (1) dismissed the ERISA and contract claims, concluding that Appellant failed to state a claim under ERISA and that ERISA preempted the commonwealth claims; and (2) granted summary judgment against Appellant on the estoppel claim, concluding that the unambiguous terms of the benefits plan precluded a claim for estoppel. The First Circuit affirmed, holding (1) Appellant could not recover under ERISA because he could not be awarded relief under the terms of BPPR’s retirement plan; (2) the district court properly held that Appellant’s commonwealth claims “relate to” the ERISA-regulated plan and, accordingly, they were preempted; and (3) because Appellant did not show any ambiguity in the plan, his equitable estoppel claim necessarily failed. View "Guerra-Delgado v. Banco Popular de P.R." on Justia Law

Plaintiff was an anatomically male prisoner in her mid-sixties who suffered from gender identity disorder and self-identified as a female. Plaintiff, who was incarcerated in a medium security male prison in Massachusetts, filed a complaint against the Massachusetts Department of Correction (DOC), alleging that the DOC was denying her adequate medical care by not providing her with sex reassignment surgery. Although the DOC was providing Plaintiff with hormonal and other medical treatment, the district court issued an order requiring the Commissioner of the DOC to provide Plaintiff with sex reassignment surgery, concluding that the DOC’s failure to provide the surgery violated Plaintiff’s Eighth Amendment rights. The First Circuit affirmed. The First Circuit reversed the district court’s order of injunctive relief, holding that, in light of the community standard of medical care, the adequacy of the provided treatment, and the DOC’s concerns related to safety and prison security, the care provided to Plaintiff by the DOC did not violate the Eighth Amendment. Remanded with instructions to dismiss the case. View "Kosilek v. Spencer" on Justia Law

Defendants in this case were the Governor of Massachusetts, the Secretary of the Executive Office of Health and Human Services, and the Commissioner of the Massachusetts Department of Children and Families (DCF). Six children brought this class action in federal court on behalf of an estimated 8,500 children who are (or will be) committed to Massachusetts foster care custody as a result of their having suffered from abuse or neglect. Plaintiffs asserted that DCF so exposes the plaintiff class to harm or the risk of harm that it is unconstitutional and violates the Adoption Assistance and Child Welfare Act of 1980. Plaintiffs sought a broad injunction preventing Defendants from subjecting the plaintiff children to practices that violate their rights. The district court granted judgment for Defendants on all claims. The First Circuit affirmed, holding that Plaintiffs failed to demonstrate class-wide constitutional violations, nor a violation of the AACWA, and so injunctive relief was not warranted. View "Connor B. v. Patrick" on Justia Law

A district court issued an arrest warrant for Brian Hunt for failing to pay a fine. Hunt had actually paid the fine, but the payment wasn’t recorded. Four police officers served the warrant at the home of Hunt and his wife (together, Plaintiffs). Hunt requested that he be handcuffed with his hands in front of him because he had recently undergone surgery on his stomach. The officers refused Hunt’s request and, after a scuffle, handcuffed Hunt with his hands behind his back. Plaintiffs sued the officers, asserting violations of Hunt’s federal constitutional rights under 42 U.S.C. 1983 as well as pendent state law claims. The district court declined to grant the police officers qualified immunity on summary judgment. The First Circuit reversed in part, holding (1) Defendants were entitled to qualified immunity on Plaintiffs’ excessive force claim under section 1983, as Hunt had no clearly established right to be cuffed with his hands in front of him when the officers reasonably understood their actions in effectuating the arrest to be constitutional; (2) Defendants were entitled to summary judgment on Plaintiffs’ state law claims of battery and violation of the Massachusetts Civil Rights Act; and (3) the Court lacked jurisdiction to review Plaintiffs’ malicious prosecution claims. View "Hunt v. Massi" on Justia Law

South Kingstown School Committee (Committee) runs one of Rhode Island’s public school districts. Rhode Island has accepted federal funding under the Individuals with Disabilities Education Act (IDEA). Appellant, the mother of P.J., a disabled child the Committee was responsible for educating, filed a due process complaint seeking additional educational services for P.J. from the Committee. The Committee settled with Appellant pursuant to a Settlement Agreement under which the Committee agreed to perform four evaluations of P.J. After Appellant demanded ten additional evaluations, the Committee filed a due process complaint of its own. A Hearing Officer ruled against the Committee, concluding that some of the evaluations of P.J. had not been appropriate. The Committee then filed suit in federal district court. The district court reversed. The First Circuit affirmed, holding (1) the district court did not err in determining that the Settlement Agreement relieved the Committee of any obligation to perform or fund one of the evaluations; and (2) the district court did not err in concluding that there was insufficient factual support for Appellant’s other evaluation request. Remanded. View "S. Kingstown Sch. Comm. v. Joanna S." on Justia Law

Defendant entered a conditional plea of guilty to being a felon in possession of two firearms, reserving the right to appeal the denial of his motion to suppress. The district court subsequently sentenced Defendant as an armed career criminal to fifteen years imprisonment. The First Circuit affirmed, holding (1) district court correctly refused to suppress two statements Defendant made regarding the presence of firearms inside his residence based on alleged Miranda violations; and (2) the district court did not err in labeling Defendant an armed career criminal subject to an enhanced sentence under the Armed Career Criminal Act. View "United States v. Davis" on Justia Law