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

After a jury trial, Defendant was convicted on federal criminal charges of conspiracy and attempt to affect commerce by robbery, among other charges. The First Circuit vacated Defendant’s sentence and remanded for resentencing. After the district court resentenced Defendant, Defendant filed a motion in Massachusetts state court for a new trial on a prior state conviction that had been relied upon to increase his federal sentence. The state court vacated Defendant’s prior conviction. Defendant filed a petition and an amended petition for writ of habeas corpus arguing that he received ineffective assistance of counsel in his federal trial and that the vacatur of his prior state court conviction entitled him to resentencing. The district court denied the petition. The district court affirmed, holding (1) there was not a reasonable probability that the perceived shortcomings of Defendant’s counsel affected the result in this case; and (2) the district court did not err in concluding that Defendant’s petition for resentencing was untimely. View "Rossetti v. United States" on Justia Law

Defendants Manuel Trinidad-Acosta and Ed Cogswell were involved in a conspiracy to distribute cocaine base, or crack cocaine. A grand jury indicted Defendants on one count of conspiracy to possess with the intent to distribute crack cocaine, and Trinidad was also indicted on one count of possessing a firearm in furtherance of a drug trafficking crime. After a trial, Defendants were found guilty as charged. The First Circuit affirmed the convictions and sentences, holding (1) the district court did not err in denying Trinidad’s motion for a mistrial; (2) the evidence was sufficient to support Cogswell’s conviction; (3) the government misrepresented the evidence during its closing argument, but those misstatements were unlikely to have affected the trial’s outcome; and (4) both defendants’ sentences were reasonable. View "United States v. Trinidad-Acosta" on Justia Law

Defendant pleaded guilty to carjacking resulting in serious bodily injury and carriage of a firearm during and in relation to a crime of violence. After a disposition hearing, the district court varied upward and imposed a 240-month term of immurement on the first count to be followed by a 120-month term on the second count. Defendant appealed, challenging both the procedural and substantive reasonableness of his sentence. The First Circuit affirmed, holding that the district court met its obligation to impose a sentence that was “sufficient, but not greater than necessary” to accomplish the goals of sentencing and that Defendant’s sentence fell “within the expansive universe of reasonable sentences.” View "United States v. Narvaez-Soto" on Justia Law

After a jury trial, Defendant was found guilty of conspiring to possess illegal drugs with intent to distribute, conspiring to possess a firearm during and in relation to a drug-trafficking crime, and possessing a firearm in furtherance of a drug-trafficking crime. Defendant appealed, challenging the judge’s decision to admit photos showing him with accused coconspiators and by allowing police officers to testify about the pictures. Defendant argued, among other things, that the evidence suggested he was a conspirator simply because he associated with conspirators. The First Circuit affirmed, holding that the district judge did not err in ruling that the evidence was relevant and that the probative value of the evidence was substantially overbalanced by the danger of unfair prejudice. View "United States v. Rodriguez-Soler" on Justia Law

Defendant and numerous co-defendants were convicted of conspiracy to distribute heroin and cocaine. The sentencing judge made individual drug-quantity determinations based on his review of the record, relying heavily on the testimony of two witnesses who pleaded guilty and received lighter sentences. On appeal, the First Circuit remanded the cases of Defendant and his co-defendants for resentencing and instructed the resentencing judge to make his own credibility determinations of the two witnesses in order to determine drug quantity. After resentencing, the First Circuit again vacated Defendant's and his co-defendants’ sentences on the basis that the resentencing judge did not follow the Court’s instruction to engage in a credibility assessment. After Defendant was again resentenced, Defendant filed a motion under Fed. R. Crim. P. 35(a) to correct his sentence, arguing that the sentencing judge failed to follow the Court’s instruction to make individualized, record-based drug-quantity findings on remand. The First Circuit vacated Defendant’s sentence and remanded his case for the sentencing judge to resolve the credibility issues identified in this case and to make an individualized drug-quantity determination. View "United States v. Correy" on Justia Law

Russ Irwin brought an arbitration proceeding against Lyman Morse Boatbuilding, Inc. (LMB) of Maine and Cabot Lyman, the controlling owner of LMB, claiming damages related to the allegedly defective construction of a luxury yacht. After Northern Assurance Company of America, the insurer for LMB and Lyman, refused the insureds’ request for defense, LMB and Lyman filed this federal suit seeking to recover the costs and attorneys’ fees they incurred in the arbitration proceeding. The district court concluded that Northern Assurance had a duty to defend Lyman but did not have a duty to defend LMB. The First Circuit affirmed in part, reversed in part, and remanded for entry of judgment in favor of Northern Assurance, holding that, under Maine law, the insurer did not owe a duty to defend LMB or Lyman in the underlying arbitration proceeding. View "Lyman Morse Boatbuilding Inc. v. N. Assurance Co." on Justia Law

This long-running dispute over Puerto Rico’s dairy industry resulted in the principal parties settling. Pursuant to the settlement, the Department of Agriculture for the Commonwealth of Puerto Rico and others (collectively, the "Department") agreed to promulgate a regulation that would significantly rework the pricing and structure of the dairy market. Intervenors Industria Lechera de Puerto Rico, Inc. ("Indulac") and the Puerto Rico Dairy Farmers Association, who were excluded from the bargaining table, objected to the settlement, alleging that the regulation violated Puerto Rico’s constitutional and statutory law. The district court approved the settlement agreement. Indulac appealed. The First Circuit dismissed the appeal, holding that it lacked appellate jurisdiction to hear Indulac’s appeal because it was untimely. View "Vaqueria Tres Monjitas, Inc. v. Industria Lechera de P.R., Inc." on Justia Law

Plaintiff owned a vacant lot in Alton, New Hampshire. In 2002, Plaintiff deeded the lot to his son. Because the town of Alton then held a lien due to unpaid taxes, Plaintiff did not then hold complete title to the property. The taxes were later paid off by Plaintiff’s mortgage, and, in 2005, the town deeded the lot back to Plaintiff. In 2006, Plaintiff’s daughter purchased the property from the son. The daughter’s mortgage was eventually assigned to Defendant. When the daughter stopped making her mortgage payments, Defendant sought to foreclose on the property. Plaintiff brought suit claiming he held title to the lot. The district court granted summary judgment for Defendant. The First Circuit affirmed, holding that the district court correctly granted summary judgment for Defendant where Plaintiff did not meet his burden to establish his good title to the lot and had no basis to contest either his daughter’s title to the property or her mortgage agreement with Defendant. View "Fadili v. Deutsche Bank Nat’l Trust Co." on Justia Law

Plaintiff and Defendant entered into an asset purchase agreement (the Agreement) that contained a provision requiring submission of all disputes concerning the “validity, interpretation and enforcement” of the Agreement to an arbitrator for binding resolution. Plaintiff sued Defendant in federal district court, asserting claims for fraud and breach of contract arising out of the Agreement. Defendant answered the complaint, and the parties began discovery. Several months later, Plaintiff moved to stay proceedings pending arbitration. A magistrate judge denied the motion to stay on the ground that Plaintiff had waived its arbitral rights. The district judge summarily affirmed the denial of the stay. The First Circuit affirmed, holding that the district court did not err in concluding that Plaintiff, through its conduct, waived its right to demand arbitration. View "Joca-Roca Real Estate, LLC v. Brennan, Jr." on Justia Law

Ven-A-Care of the Florida Keys, Inc. filed the first of two qui tam actions alleging that Baxter Healthcare Corporation had defrauded the federal Medicaid and Medicare programs. Ven-A-Care and Baxter eventually reached a settlement agreement. Before the district court dismissed Ven-A-Care’s action against Baxter, Linnette Sun and Greg Hamilton filed a qui tam action against Baxter. Baxter moved for partial summary judgment, asserting that the settlement had released Sun and Hamilton’s claims. Sun and Hamilton then filed a Fed. R. Civ. P. 60(b) motion requesting a reopening of the Ven-A-Care judgment, arguing that the Ven-A-Care settlement could not release their claims until they got a fairness hearing under the False Claims Act. The district court denied the motion and dismissed Sun and Hamilton’s suit, concluding that the Ven-A-Care complaint stated all the essential facts of the fraud alleged by Sun and Hamilton and thus had triggered the False Claims Act’s first-to-file bar. The First Circuit affirmed, holding that because Ven-A-Care’s earlier-filed complaint already provided the essential facts about the same scheme pled in Sun and Hamilton’s complaint, section 3730(b)(5) of the False Claims Act prevented Sun and Hamilton’s suit from going forward. View "United States, ex rel. Sun v. Baxter Healthcare Corp." on Justia Law