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

Pursuant to a plea agreement, Defendant pleaded guilty to conspiring to possess with intent to distribute various controlled offenses, possessing marijuana with intent to distribute, and possessing firearms in furtherance of a drug-trafficking offense. The district court sentenced Defendant to an eighty-four-month sentence on the firearms possession count, to run consecutively to the other sentences. Defendant appealed, challenging the reasonableness of the sentence for the gun charge. The First Circuit affirmed, holding that the sentence was procedurally and substantively reasonable and “sufficient, but not greater than necessary” to further the legitimate goals of sentencing. View "United States v. Rivera-Gonzalez" on Justia Law

Plaintiffs in this case were fourteen maintenance, domestic, and warehouse workers who were abruptly fired from the Puerto Rico executive mansion shortly after Luis Fortuño-Burset (“Fortuño”), the newly-elected governor, took office. In 2009, Plaintiffs sued Fortuño, Fortuño’s wife, and two executive staffers, alleging that they were terminated in violation of the First Amendment because they affiliated with Fortuño’s rival political parties. The district court entered summary judgment dismissing Plaintiffs’ political discrimination claim. The First Circuit affirmed both the summary judgment dismissals of Plaintiffs’ First Amendment claim and the denial of their motion to reconsider, holding (1) the record lacked sufficient evidence that Defendants were aware of Plaintiffs’ political affiliations, and thus, Plaintiffs’ First Amendment claim failed on that ground; and (2) the district court did not err in denying Plaintiffs’ request to reconsider the judgment. View "Ocasio-Hernandez v. Fortuno-Burset" on Justia Law

Even after receiving investments from four investors of over $20 million from 2001 to 2005, Access Cardiosystems, Inc. filed for Chapter 11 bankruptcy protection in 2005. Four investors filed a third amended complaint against Access’s founder, director, and officer, Randall Fincke, alleging, among other claims, that Fincke had violated the Massachusetts blue sky law. The bankruptcy court found as a matter of fact that Fincke had made a false statement of material fact to investors in violation of the blue sky law and that one such investor was entitled to $1.5 million in damages for his investments that Fincke solicited “by means of” that material misstatement. On appeal, these findings were affirmed by the district court. The Supreme Court affirmed, holding (1) the bankruptcy court did not err in finding that Fincke knew or should have known of the falsity of the misstatement and that the falsity could not be cured by warnings; (2) it was not inconsistent for the bankruptcy court to find this particular misstatement was material to investors; and (3) the bankruptcy’s finding as to damages was not in error. View "Fincke v. Radley" on Justia Law

Appellant had leased the same apartment at a San Juan, Puerto Rico housing cooperative (Cooperative) for several years. While living at the cooperative, Appellant received benefits under the Section 8 federal housing assistance program, which enabled her to pay her rent. When the Housing Finance Authority concluded that Appellant’s apartment unit was “over-housed” for Section 8 purposes, the Cooperative informed Appellant that she would have to pay market-rate rent without the Section 8 assistance. Appellant subsequently submitted a request to the Cooperative for reasonable accommodation on account of her disability, stating that she could not move to a different unit without compromising her health. The Cooperative denied Appellant’s request. After filing an administrative complaint without success, Appellant filed suit in federal court, alleging that the Cooperative had violated the Fair Housing Act by failing to provide the requested accommodation, by engaging in a pattern of discriminatory actions against her, and by retaliating against her because she had recently prevailed in a separate HUD proceeding against the Cooperative. The district court (1) found in the defendants’ favor regarding the reasonable accommodation and disparate treatment claims; and (2) concluded that it lacked jurisdiction to decide the retaliation claim. The First Circuit (1) affirmed the district court’s grant of summary judgment on the reasonable accommodation and disparate treatment claims; and (2) reversed the district court’s decision to dismiss Appellant’s retaliation claim, holding that the district court had jurisdiction to decide this claim. View "Batista v. Cooperativa de Vivienda" on Justia Law

A jury found Appellant guilty of one count of possession with intent to distribute more than 500 grams of cocaine. Appellant was tried a second time on the drug trafficking charge after the First Circuit concluded that Appellant’s Sixth Amendment right to confrontation had been violated at his first trial. At retrial, a jury again found Appellant guilty of the drug possession charge. At sentencing, the district court treated Appellant as a career offender under the Sentencing Guidelines. The First Circuit affirmed the conviction but remanded for resentencing without the career offender enhancement, holding (1) the government’s delay in bringing the indictment did not violate Appellant’s due process rights; (2) the district court did not abuse its discretion in denying Appellant’s motion to dismiss the indictment for prosecutorial misconduct; (3) the court did not commit reversible error in its evidentiary rulings or in instructing the jury; (4) the court’s refusal to continue Appellant’s sentencing hearing, if error, was harmless; and (5) in designating Appellant as a career offender, the district court relied on a predicate offense that does not qualify for that purpose. View "United States v. Ramos-Gonzalez" on Justia Law

At issue in this case was services that Maine Medical Center provided to Medicare/Medicaid “dual-eligible” patients, that is, patients covered by both Medicare and the state-administered Medicaid insurance program, MaineCare. The Secretary for the Department of Health and Human Services denied Maine Medical’s claim for partial federal reimbursement of “bad debt” for the fiscal years 2002 and 2003. A “bad debt” is an amount considered to be uncollectible for covered services that may be eligible for federal reimbursement under certain conditions. The Secretary denied reimbursement because Maine Medical had not acquired from MaineCare a state-issued remittance advice to use as proof. The district court affirmed. The First Circuit affirmed, holding that it was not arbitrary and capricious for the Secretary (1) to demand that Maine Medical provide documentation from the State confirming the identity of Medicaid-eligible beneficiaries and qualified Medicare beneficiaries, the amount that is the State’s to pay, and the State’s refusal to pay; and (2) to deny Maine Medical’s reimbursement claims that were unsupported by such documentation. View "Me. Med. Ctr. v. Burwell" on Justia Law

After a jury trial in 2007, Defendant was convicted of two drug trafficking counts. At sentencing, the sentencing judge made a drug quantity finding and increased the mandatory minimum sentence for each count. Defendant appealed, arguing that a jury must find beyond a reasonable doubt any fact leading to the imposition of a higher mandatory minimum sentence. The First Circuit affirmed. After Alleyne v. United States was decided, Defendant initiated a collateral attack on his sentence. The district court denied Defendant’s motion for habeas relief under 28 U.S.C. 2255. The First Circuit affirmed, holding that the rule announced in Alleyne does not apply retroactively to sentences challenged on an initial petition for collateral review. View "Butterworth v. United States" on Justia Law