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

The First Circuit affirmed the judgment of the trial court convicting Defendants - Rolando Millan-Machuca, Roberto Casado-Berrios, Miguel Rivera-Calcano, and Giordano Santana-Meledez - of racketeering and drug trafficking conspiracies, holding that Defendants' claims on appeal were unavailing.Specifically, the First Circuit held (1) the evidence was sufficient to support the convictions; (2) there was no merit to Defendants' claims of error in the admission of certain evidence; (3) Defendants' sentences were reasonable; and (4) Rivera-Calcano's claims of ineffective assistance of counsel at his sentencing hearing is dismissed without prejudice. View "United States v. Millan-Machuca" on Justia Law

The First Circuit affirmed in part and reversed in part the judgment of the district court granting judgment in favor of Plaintiff in this discrimination and retaliation action, holding that Defendant was entitled to judgment as a matter of law in part.Plaintiff filed suit against Abbott Laboratories alleging age discrimination and retaliation under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621-34, Puerto Rico Law 100 and Puerto Rico Law 155. A jury found for Plaintiff and awarded $4 million for emotional distress and $250,000 for back pay. The district court entered judgment against Abbott on all counts but reduced the damages to just over $500,000. The First Circuit reversed in part, holding (1) Abbott was entitled to judgment as a matter of law on Plaintiff's ADEA claims and her corresponding claims under Law 100 and Law 115; but (2) Abbott failed to preserve its challenge to a separate finding that Abbott retaliated against Plaintiff for reporting to the State Insurance Fund. View "Gonzalez-Bermudez v. Abbott Laboratories P.R. Inc." on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Casco, Inc.'s claim for dolus under Article 1902 of the Puerto Rico Civil Code, P.R. Laws Ann. tit. 31, 3408, awarding relief to Casco on its claims for unjust impairment and unjust termination under Puerto Rico's Dealer Protection Act, P.R. Laws Ann. tit. 10, 278 (Law 75) and granting judgment on John Deere Construction & Forestry Company's counterclaim to recover amounts owed to it by Casco, holding that Casco was not entitled to relief on its allegations of error.Specifically, the First Circuit held (1) the jury's findings of liability against Deere under Law 75 were not unreasonable, and the district court correctly denied Deere's post-judgment motions regarding the Law 75 claims; (2) the district court properly dismissed Casco's dolus claim as not legally viable; (3) the district court correctly granted relief on Deere's counterclaim; and (4) the district court did not abuse its discretion by declining to upset the jury award or order a new trial on damages. View "Casco, Inc. v. John Deere Construction & Forestry Co." on Justia Law

The First Circuit vacated the order of the district court granting summary judgment in favor of Lincare, Inc. and rejecting Jeffrey Joseph's racial discrimination challenge to the termination of his employment, holding that the district court erred in excluding several documents from the summary judgment record and that Joseph had enough evidence to warrant a trial.On appeal, Joseph argued, among other things, that the district court erred in excluding several documents as unauthenticated hearsay evidence and in granting summary judgment. The First Circuit agreed and remanded the case for further proceedings, holding (1) the district court erred in excluding the documents as "unauthenticated and hearsay evidence," and the error was not harmless; and (2) the record, supplemented with the stricken documents, provides a reasonable basis for a jury finding in Joseph's favor. View "Joseph v. Lincare, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment to Gold Medal Bakery, Inc. and dismissing Robert Thompson's claims brought after he was fired, holding that the district court did not err or abuse its discretion.After he was fired, Thompson brought this complaint alleging that Gold Medal terminated his employment in violation of the anti-retaliation provision of the Family and Medical Leave Act (FMLA) and federal and state disability discrimination laws. The district court granted summary judgment to Gold Medal on all claims. The First Circuit affirmed, holding (1) the district court properly determined that, as a matter of law, Thompson could not establish that he was a "qualified individual" under the Americans with Disabilities Act at the time of his firing; (2) the district court did not err in granting summary judgment to Gold Medal on Thompson's FMLA retaliation claim; and (3) Thompson's remaining arguments were unavailing. View "Thompson v. Gold Medal Bakery, Inc." on Justia Law

The First Circuit affirmed the convictions received by Defendants, three former employees of the New England Compounding Center (NECC), for a number of federal offenses related to aspects of NECC's operation that were identified in the course of a federal criminal investigation into NECC's medication, holding that there was no prejudicial error.In 2012, patients across the country began falling ill after having been injected with a contaminated medication compounded by NECC. After many of these patients died, a federal criminal investigation ensued. A jury found Stepanets, Svirskiy, and Leary each guilty of committing multiple federal crimes. The First Circuit affirmed Defendants' convictions and Stepanets' sentence, holding (1) there was sufficient evidence to support the convictions; (2) it was not clear or obvious error under the Eighth Amendment for the district court to impose the sentence that Stepanets received; (3) Svirskiy's challenges to his convictions were without merit; and (4) Leary's arguments on appeal were unavailing. View "United States v. Stepanets" on Justia Law

The First Circuit affirmed Defendant's conviction in the United States District Court for the District of Maine for possessing a firearm in furtherance of drug trafficking, holding that the district court did not err in denying Defendant's motion for a hearing under Franks v. Delaware, 438 U.S. 154 (1978).After he was charged, Defendant filed a motion to suppress evidence discovered during a search of his home due to what he claimed were false statements and omissions in the affidavit supporting the application for the search warrant. The district court denied the suppression motion, including Defendant's request for an evidentiary hearing. The First Circuit affirmed, holding that the district court did not err in denying Defendant's Franks motion. View "United States v. Alexandre" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment in favor of Defendants, the City of Framingham and Brian Simoneau, in this lawsuit raising Massachusetts Whistleblower Act claims and speech retaliation claims under Garcetti v. Ceballos, 547 U.S. 410 (2006), holding that the district court did not err.Vincent Stuart, a former Framingham police officer, brought this action alleging that the termination of his employment was in retaliation for his speech. The district court granted summary judgment for Defendants on both the First Amendment speech-retaliation and the Massachusetts Whistleblower Act claims. The First Circuit affirmed, holding that the district court did not err in concluding that there was not a triable question that Stuart's complaint was a substantial or motivating factor in his suspension and termination. View "Stuart v. City of Framingham, Massachusetts" on Justia Law

The First Circuit affirmed Defendant's conviction of unlawful possession of a firearm, holding that there was no error in the proceedings below.Law enforcement officers stopped Defendant as he drove by in a vehicle that the officers believed matched the description of a vehicle that had just been involved in a shooting. The officers arrested Defendant and then deployed a firearm-detecting dog to inspect the outside of the vehicle. The dog sniff results where then used to obtain a search warrant for the vehicle. Based on the results of the search, Defendant was convicted of unlawful possession of a firearm. The Supreme Court affirmed, holding (1) the district court did not err by denying Defendant's motion to suppress; and (2) Defendant was not entitled to a new trial due to certain evidentiary rulings because there was no error, either individually or cumulatively. View "United States v. Centeno-Gonzalez" on Justia Law

The First Circuit reversed the decision of the district court granting Defendant's motion to suppress the evidence discovered during an inventory search of a vehicle that a Massachusetts State Police trooper stopped on a highway, holding that the trooper had reasonable suspicion to make the stop.In his motion to suppress, Defendant argued that the warrantless search of his vehicle violated the Fourth Amendment. In response, the government argued that the inventory search fell within the community caretaking function. The district court disagreed, holding that there was no non-investigatory reason to conduct the inventory search. The First Circuit reversed, holding that the district court erred in granting Defendant's motion to suppress. View "United States v. Rivera" on Justia Law