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

In this case, four police officers in Puerto Rico pursued two young men suspected of engaging in a drug deal. One officer shot 17-year-old Calep Carvajal in the back as he fled on a bicycle. Defendant José Cartagena apprehended and handcuffed Carvajal, and was accused of pistol-whipping him while he was on the ground. Additional assaults allegedly occurred during and after transport to the police station. Cartagena later filed a false report about the incident and lied to a juvenile prosecutor about Carvajal’s injuries. Federal charges were brought under various statutes, including civil rights violations and obstruction of justice.After a grand jury indictment, three officers pleaded guilty. Cartagena initially entered a plea but withdrew it and went to trial in the United States District Court for the District of Puerto Rico. He was convicted by a jury on all counts and sentenced to concurrent prison terms. On appeal, he challenged the sufficiency of the evidence and asserted that his Sixth Amendment Confrontation Clause rights were violated when the prosecution introduced a hearsay statement from the victim, who was not available for cross-examination.The United States Court of Appeals for the First Circuit reviewed the case. It found the evidence sufficient to support convictions on most counts but determined that the admission of the victim’s testimonial hearsay statement, offered through a government medical expert, violated Cartagena’s Confrontation Clause rights as to the count involving the alleged pistol-whipping during the arrest. The court vacated the conviction on that count, affirmed the convictions on the other counts, and remanded the case for further proceedings consistent with its opinion. View "US v. Cartagena" on Justia Law

Two former police officers sued their employer, the Puerto Rico Police Department, alleging illegal retaliation after one reported age discrimination to the Equal Employment Opportunity Commission and the other testified in support. The plaintiffs claimed that, as a result, they suffered adverse employment actions such as dangerous shift changes, loss of duties, and fabricated complaints. The challenged conduct primarily occurred after Puerto Rico filed for financial reorganization under PROMESA, a federal statute enacted in response to the Commonwealth’s fiscal crisis.The United States District Court for the District of Puerto Rico presided over the case while Puerto Rico’s reorganization plan was pending in the Title III court. After the reorganization plan’s "Effective Date" passed, and while the plaintiffs’ suit was ongoing, the Department asserted that the claims had been discharged under the plan because the plaintiffs had not timely filed proofs of claim. The District Court agreed, permanently stayed the case, and enjoined the plaintiffs from pursuing their claims, finding that the claims must have arisen at least in part before the plan’s Effective Date since the suit was filed prior to that date. The District Court did not address the plaintiffs' judicial estoppel argument or their contention that post-petition claims were not dischargeable.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s judgment, but on different grounds. The appellate court held that the plaintiffs’ retaliation claims qualified as administrative expense claims under PROMESA (via incorporation of the Bankruptcy Code), and because the plaintiffs did not timely file such claims before the administrative claims bar date, they were discharged by the plan. The court also rejected the plaintiffs' judicial estoppel argument, finding no inconsistency in the Department’s litigation positions. The First Circuit’s judgment affirmed the permanent stay and injunction. View "Villalobos-Santana v. PR Police Department" on Justia Law

Two individuals challenged the Puerto Rican electoral commission and its acting president, arguing that restrictions on early and absentee voting during the 2020 general election unlawfully burdened the right to vote for citizens over sixty, especially considering the COVID-19 pandemic. In August 2020, they brought suit under 42 U.S.C. § 1983, seeking relief on constitutional grounds. The district court promptly issued a preliminary injunction, then a permanent injunction, allowing voters over sixty to vote early by mail. After judgment, the plaintiffs were awarded nearly $65,000 in attorneys’ fees under 42 U.S.C. § 1988.While the fee motion was pending, Puerto Rico’s government was in the process of debt restructuring under Title III of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA). The restructuring plan, confirmed in January 2022, discharged claims against Puerto Rico arising before the plan’s effective date unless creditors filed proof of claim by a set deadline. Defendants argued in the U.S. District Court for the District of Puerto Rico that the attorneys’ fees award was subject to the plan’s discharge and enjoined from collection, because the plaintiffs had not filed a timely administrative expense claim. The district court rejected this, finding the fee award unrelated to the bankruptcy case.On appeal, the United States Court of Appeals for the First Circuit concluded that the claim for attorneys’ fees, though arising from post-petition litigation, related to events before the plan’s effective date. The court held that because the plaintiffs had actual knowledge of the restructuring proceedings but did not file a timely proof of claim, their fee claim was discharged under the confirmed plan and enjoined from collection. The First Circuit reversed the district court’s order, holding that the discharge injunction applied to the attorneys’ fee award. View "Ocasio v. Comision Estatal de Elecciones" on Justia Law

An employee of the Falmouth Public Schools in Maine, enrolled in a health insurance plan administered by Anthem Health Plans of Maine, Inc., challenged the plan’s exclusion of coverage for weight-loss medications. After being diagnosed with obesity and prescribed FDA-approved weight-loss drugs, the employee’s requests for coverage were repeatedly denied. Her medical providers appealed to Anthem, supporting the necessity of the medication, but Anthem maintained its denial, citing the plan’s explicit exclusion of weight-loss medications regardless of obesity diagnosis.The employee, on behalf of herself and a proposed class, sued Anthem’s parent company, Elevance Health, Inc., in the United States District Court for the District of Maine. She alleged that the exclusion constituted disability discrimination under Section 1557 of the Patient Protection and Affordable Care Act, which incorporates the nondiscrimination requirements of Section 504 of the Rehabilitation Act. Elevance moved to dismiss, arguing the complaint failed to plausibly allege disability discrimination. The district court granted the motion, reasoning that the exclusion applied to all enrollees, regardless of disability status, and did not target disabled individuals for discriminatory treatment. The court found the allegations of discrimination to be conclusory and insufficient to support claims of intentional, proxy, or disparate impact discrimination.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The appellate court held that the plaintiff failed to plausibly allege that the exclusion of weight-loss medication coverage constituted discrimination under Section 1557. The court concluded that the exclusion was facially neutral, did not serve as a proxy for disability discrimination, and did not result in a lack of meaningful access to plan benefits for disabled individuals. Accordingly, the dismissal of the complaint was affirmed. View "Holland v. Elevance Health, Inc." on Justia Law

A black-owned construction company was not invited to bid as general contractor on a major Boston public housing redevelopment project after participating in pre-construction work. Years earlier, the developer had called the company’s president to discuss possible involvement, but the parties disputed what promises, if any, were made during that conversation. The construction company performed pre-construction work and was later selected as general contractor for the first phase (Camden), but after performance and communication issues arose during that project, the developer chose a different, white-owned company for the second phase (Lenox). The construction company did not protest at the time but later sued, alleging breach of contract, quasi-contract, violation of Massachusetts consumer protection law, and racial discrimination under 42 U.S.C. § 1981.The matter was first brought in Massachusetts state court, then removed to the United States District Court for the District of Massachusetts based on federal question jurisdiction. After discovery, the developer moved for summary judgment. The District Court granted summary judgment for the developer, finding no enforceable contract or promise had been made regarding the Lenox phase, that the quasi-contract and Chapter 93A claims failed as derivative, and that there was insufficient evidence of racial discrimination.The United States Court of Appeals for the First Circuit affirmed the District Court’s decision. The First Circuit held that the summary judgment record did not contain evidence from which a reasonable jury could find an enforceable implied-in-fact contract or a promise sufficient for promissory estoppel. It further held that the plaintiff failed to create a triable issue of fact regarding pretext or discriminatory intent under § 1981, given the legitimate business reasons cited for the company’s exclusion. Thus, summary judgment on all claims was proper. View "John B. Cruz Construction Co. v. Beacon Communities Corp." on Justia Law

A nurse employed by Puerto Rico’s State Insurance Fund Corporation reported sexual harassment by a coworker in 2020 and subsequently filed an administrative charge of discrimination and retaliation. After dropping her sexual harassment claim, she pursued a retaliation claim, arguing that she endured a hostile work environment and was involuntarily transferred to a different office. The incidents underlying her claim included several allegedly meritless disciplinary actions and the eventual transfer.The United States District Court for the District of Puerto Rico granted a preliminary injunction separating her from the coworker and, after trial, a jury found in her favor on the retaliation claim, awarding $300,000 in damages. The district court later denied her request for a permanent injunction seeking reassignment to her former office and expungement of disciplinary records. The court awarded her approximately $301,000 in attorney fees and costs, but she challenged the amount as insufficient. Finally, although the defendant did not appeal the judgment or fee award, the district court stayed execution of both under Puerto Rico law, pending approval of a payment plan by the Secretary of Justice.The United States Court of Appeals for the First Circuit affirmed the denial of permanent injunctive relief and the attorney fee award, finding that the district court did not abuse its discretion on either point and that the fee reductions and denial of injunctive remedies were reasonable. The Court of Appeals also vacated the stay of execution of judgment and fees, holding that Puerto Rico’s statutory payment plan requirement could not delay enforcement of a federal judgment under Title VII. The case was remanded for further proceedings consistent with these rulings. View "Garcia Colon v. State Insurance Fund Corporation" on Justia Law

Soscia Holdings, LLC operated the Flat River Reservoir Dam in Rhode Island. In July 2022, the Rhode Island Department of Environmental Management (DEM), acting under state law, ordered Soscia to reduce the Dam’s water flow to maintain specific water levels in Johnson’s Pond. Soscia was later assessed monetary penalties by DEM for alleged violations of the permitting statute. During these proceedings, the Town of Coventry condemned the Dam and Johnson’s Pond, paying Soscia just compensation for the property.The case was first reviewed by the United States District Court for the District of Rhode Island. This court dismissed all claims against the State of Rhode Island and DEM based on Eleventh Amendment immunity. The court also dismissed the § 1983 individual capacity claims against two DEM officials on the grounds of qualified immunity, and rejected Soscia’s claim under the Rhode Island Constitution. However, the court allowed § 1983 official capacity claims for prospective injunctive relief against the DEM officials to proceed. After Soscia amended its complaint, the district court ultimately dismissed the remaining federal constitutional claims and declined to exercise jurisdiction over the remaining state law claims.The United States Court of Appeals for the First Circuit reviewed the appeal. Soscia argued that it continued to face ongoing enforcement actions and monetary penalties, and thus maintained a property interest and the right to seek injunctive and declaratory relief. The First Circuit found that the district court’s opinions thoroughly and correctly explained why Soscia’s federal claims failed to state a plausible claim for relief, and that new arguments raised on appeal were either waived or did not meet the standard for plain error review. The First Circuit affirmed the judgment of the district court. View "Soscia Holdings, LLC v. Rhode Island" on Justia Law

The case centers on Orlando González Tomasini, who filed civil rights and tort claims against the United States Postal Service, his former employer, alleging that psychological and medical conditions prevented him from working. His then-wife, Juliette Irizarry-Miranda, was initially a co-plaintiff but eventually became a defense witness after a contentious divorce and ongoing custody dispute over their son. On the eve of trial, the Postal Service accused González of witness tampering, specifically of seeking to dissuade Irizarry from testifying by conditioning custody concessions on her refusal to take the stand. Irizarry recorded part of a phone call between them, and the Postal Service submitted this as evidence.Prior to the current appeal, the case was heard in the United States District Court for the District of Puerto Rico, where a magistrate judge presided by consent of the parties. The magistrate judge held a three-day evidentiary hearing to address the witness tampering allegations. After hearing testimony from González, Irizarry, and a social worker, the court found by clear and convincing evidence that González had engaged in witness tampering. As a sanction for this fraud on the court, the magistrate judge dismissed González’s case.The United States Court of Appeals for the First Circuit reviewed the district court's decisions. The First Circuit affirmed the district court in all respects, holding that the evidentiary hearing was appropriately ordered, the finding of witness tampering was not clearly erroneous, and the sanction of dismissal was within the court’s discretion. The appellate court found that González’s conduct constituted a fraud on the court, justifying dismissal, especially given the egregiousness of the witness tampering and its potential impact on the integrity of judicial proceedings. Judgment was affirmed for the Postal Service. View "Gonzalez Tomasini v. Steiner" on Justia Law

A group of eleven current and former employees of the Woods Hole, Martha’s Vineyard and Nantucket Steamship Authority challenged the Authority’s COVID-19 vaccine mandate, which required all employees to be fully vaccinated unless they qualified for a medical or religious exemption. The policy allowed for exemptions if an employee provided sufficient medical documentation or demonstrated a sincerely held religious belief, provided that reasonable accommodations could be made without undue burden to the Authority. Thirteen employees applied for religious exemptions, but only the request of one fully remote employee was granted. One employee received a temporary medical exemption but was ultimately terminated after refusing vaccination once that exemption expired. Four appellants later became vaccinated and remained employed; the remaining seven were fired for noncompliance.After the Authority enacted its policy, the plaintiffs filed suit, alleging violations of their rights under the Massachusetts Declaration of Rights, the First and Fourteenth Amendments, and Massachusetts anti-discrimination law. The state court initially granted a temporary restraining order, but after removal to the United States District Court for the District of Massachusetts, the district court denied their preliminary injunction request. On a prior appeal, the United States Court of Appeals for the First Circuit affirmed the denial as to most claims but remanded for further consideration of the First Amendment claim, instructing the district court to address the relevance of the granted medical exemption and to determine the appropriate level of scrutiny.On remand, the district court again denied a preliminary injunction, finding the policy to be generally applicable and thus subject to rational basis review, which it held the policy satisfied. The United States Court of Appeals for the First Circuit affirmed, holding that the policy’s medical and religious exemptions were not comparable for Free Exercise purposes, the policy was generally applicable, and the Authority’s interests justified the mandate under rational basis review. View "Brox v. Woods Hole, Martha's Vineyard & Nantucket Steamship Authority" on Justia Law

Marilyn Besosa-Noceda moved from Puerto Rico to Texas with her daughter, whose biological father, Emmanuel Santiago-Melendez, objected to the relocation and subsequently filed criminal charges against Besosa, alleging she deprived him of access to his child. Santiago’s complaint led to Besosa’s arrest in Texas and extradition to Puerto Rico. Ultimately, the criminal charges were dismissed after Besosa demonstrated a lack of probable cause.After the dismissal, Besosa filed suit in the United States District Court for the District of Puerto Rico against the police officer who received Santiago’s complaint, the prosecutor who authorized the criminal charges, and the prosecutor’s supervisor. She alleged malicious prosecution under 42 U.S.C. § 1983 and Commonwealth law, claiming her constitutional rights were violated by the initiation of legal process unsupported by probable cause. The defendants moved for summary judgment, which the district court granted. The court found the arrest warrant was issued by a judge based on probable cause and was not obtained through false statements or omissions. The district court also rejected Besosa’s claim that her absence from the probable cause hearings violated her rights, finding no entitlement under Commonwealth law to be present at such hearings.On appeal, the United States Court of Appeals for the First Circuit reviewed Besosa’s arguments, including a challenge to an unresolved discovery dispute and the merits of the summary judgment ruling. The First Circuit held that Besosa failed to invoke the proper procedural mechanism to delay summary judgment pending discovery and that she did not present evidence showing the defendants knowingly provided false information or recklessly disregarded the truth when seeking the arrest warrant. The First Circuit affirmed the district court’s grant of summary judgment for the defendants. View "Besosa-Noceda v. Capo-Rivera" on Justia Law