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

Articles Posted in Aviation
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Two pilots, Luis F. Bonnet and Carlos R. Benítez Maldonado, were employed by Benítez Aviation, Inc. (BAI), which managed a Cessna aircraft. In April and May 2019, Bonnet and Benítez piloted several flights without the required certificates for commercial operations. The FAA suspended their Airline Transport Pilot (ATP) certificates for 270 days, alleging they operated the flights as air carriers or commercial operators without proper certification. The pilots received their regular salaries but no additional compensation for these flights.The FAA issued a Notice of Proposed Certificate Action, which the pilots appealed to the National Transportation Safety Board (NTSB). An administrative law judge (ALJ) upheld the FAA's suspension order, finding that the flights were conducted for compensation and hire, thus requiring compliance with Part 135 regulations. The NTSB affirmed the ALJ's decision, concluding that the flights were subject to air carrier or commercial operator requirements and that the pilots violated multiple FAA regulations. The NTSB also found that the ALJ did not exhibit bias and that the 270-day suspension was appropriate.The United States Court of Appeals for the First Circuit reviewed the case. The court held that substantial evidence supported the NTSB's findings that the flights were operated as common carriers for compensation, thus requiring Part 135 certification. The court also found that the pilots were responsible for ensuring compliance with FAA regulations, regardless of BAI's role in booking the flights. The court upheld the NTSB's decision, including the 270-day suspension of the pilots' certificates, finding it justified based on the pilots' regulatory violations and the potential risk to passenger safety. The petition for review was denied. View "Bonnet v. Whitaker" on Justia Law

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The defendant, Antonio Santonastaso, was convicted of making a false statement to federal investigators and attempted witness tampering. The charges stemmed from a 2018 investigation by the Federal Aviation Administration (FAA) into allegations that Santonastaso was flying a helicopter without the necessary certifications. During the investigation, Santonastaso falsely claimed that he had the requisite certifications to fly and that his previous involvement in a 2000 helicopter theft was part of an undercover operation.The case was first heard in the United States District Court for the District of Massachusetts, where Santonastaso was found guilty. He appealed the decision, arguing that the government's evidence was insufficient to prove his guilt and that the district court erred by not giving a materiality instruction based on the Supreme Court's decision in Maslenjak v. United States.The United States Court of Appeals for the First Circuit affirmed the lower court's decision. The court found that the evidence was sufficient for the jury to find Santonastaso guilty of making a false statement to federal investigators and attempted witness tampering. The court also ruled that the district court did not commit instructional error in rejecting Santonastaso's proposed materiality instruction. The court held that the law-of-the-circuit doctrine foreclosed the application of the Maslenjak materiality standard to § 1001(a) prosecutions, and that the district court's instruction correctly stated the controlling law on materiality. View "United States v. Santonastaso" on Justia Law

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In this case, the Town of Milton, Massachusetts, petitioned for a judicial review of the Federal Aviation Administration's (FAA) final order authorizing a new flight procedure at Boston's Logan International Airport. The new procedure, aimed at increasing safety and efficiency, covers a narrower swath of airspace over the Town of Milton. The Town argued that the FAA's environmental analysis of the noise impacts failed to comply with the National Environmental Policy Act (NEPA). However, the United States Court of Appeals For the First Circuit dismissed the Town's petition, ruling that the Town does not have standing to challenge the FAA's final order. The court concluded that the harms the Town asserted, including the impact of noise on its residents and the time and money spent addressing these issues, were not legally cognizable harms to the Town itself. The court agreed with other courts of appeals that have dismissed municipal NEPA challenges to FAA orders for lack of Article III standing because those challenges failed to show cognizable injury to the municipalities themselves. View "Milton, MA v. FAA" on Justia Law

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This suit arose after American Airlines began charging passengers $2 per bag to use curbside check-in services. A class of skycaps - airport porters who assist passengers with curbside check-in - working at airports throughout the country sued American Airlines. Plaintiffs alleged that American failed adequately to notify customers that skycaps would not receive the proceeds from the new charge and that the compensation decreased significantly following the introduction of the new charge. On behalf of the Massachusetts skycaps, Plaintiff sued for violations of the Massachusetts Tips Law. Plaintiffs also sued on behalf of the class for tortious interference with a contract and unjust enrichment or quantum meruit. The district court dismissed the action, concluding that the federal Airline Deregulation Act preempted each of the skycaps’ claims. The First Circuit affirmed, holding that federal law preempted the skycaps’ state statutory and common law claims. View "Overka v. American Airlines, Inc." on Justia Law

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The FAA issued permits for modernization of the mixed-use Hanscom airport near the historic towns of Lexington and Concord. Opponents raised challenges under the Department of Transportation Act, 49 U.S.C. 303(c), the National Historic Preservation Act, 16 U.S.C. 470f, and the National Environmental Policy Act (NEPA), 42 U.S.C. 4321-4347. The First Circuit rejected the challenges. The FAA adequately examined alternatives; the determination that none would be prudent was reasonable. The agency went beyond considering reasonably foreseeable impacts and considered worst case scenarios.