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

The First Circuit affirmed Defendant's convictions for one count of conspiracy and one count of structuring the export of monetary transactions, holding that there was no error in the proceedings below.Defendant's convictions arose from his role in assisting the leader of conspiracy in smuggling cash through the Logan International Airport in Boston and onto a plane headed to Portuguese islands in the Atlantic Ocean. The First Circuit affirmed the convictions, holding (1) the district court did not err in denying Defendant's motion to suppress certain evidence against him; (2) the district court did not err by admitting into evidence certain statements that the leader made to undercover agents and to admit records of Defendant's phone contacts with the leader; (3) there was no merit to Defendant's argument that the district court erred by refusing to issue certain jury instructions that Defendant argued he requested; and (4) Defendant's remaining allegations of error were without merit. View "United States v. Melo" on Justia Law

The First Circuit affirmed the judgment of the district court granting Defendants' motion to dismiss Plaintiffs' complaint alleging that Defendants knew that Mount Ida College was on the brink of insolvency but concealed this information, holding that Plaintiffs' claims were properly dismissed.Mount Ida, a higher education institution in Massachusetts, permanently closed after providing its students six weeks' notice that it was closing. Plaintiffs, current and prospective students, brought a putative class action against Mount Ida, its board of trustees, and five Mount Ida administrators (collectively, Defendants), alleging seven Massachusetts state law claims. The district court dismissed the complaint. The First Circuit affirmed, holding (1) Plaintiffs' breach of fiduciary duty claim failed; (2) the district court did not err in dismissing Plaintiffs' violation of privacy claim; (3) no claims were stated for fraud, negligent misrepresentation, or fraud in the inducement; (4) Plaintiffs' allegations did not plausibly allege a breach of implied contract; and (5) the district court properly dismissed Plaintiffs' Mass. Gen. Laws ch. 93A claim. View "Squeri v. Mount Ida College" on Justia Law

The First Circuit vacated the district court's decision granting summary judgment to the City of Somerville, Massachusetts and dismissing Plaintiff's claim that the City unlawfully forced him to retire as a police officer when it discovered that he had basically no vision in one eye, holding that Plaintiff raised a triable issue of fact precluding summary judgment.Plaintiff brought this lawsuit alleging violations of the Americans with Disabilities Act, the Rehabilitation Act, and Massachusetts discrimination law. In granting summary judgment to the City, the district court ruled in part that no reasonable jury could find that Plaintiff could perform high-speed pursuit driving, which the court concluded was an essential function of his job. The First Circuit vacated the summary judgment, holding that Plaintiff raised a triable issue of fact as to whether his monocular vision rendered him unqualified to perform the essential job functions of an incumbent officer in the City's police department. View "Melo v. City of Somerville" on Justia Law

The First Circuit held that the special measure of constitutional protection to which police officers, in the motor vehicle context, performing community care taking functions are entitled extends to police officers performing community caretaking functions on private premises, including homes.Plaintiff's person and firearms were allegedly seized after Defendants, police officers, entered his home. Plaintiff brought several claims against Defendants, including claims brought under 42 U.S.C. 1983 and under state law. The district court granted summary judgment in favor of Defendants on Plaintiff's federal and state-law claims, concluding that the officers' conduct at Plaintiff's residence constituted a reasonable exercise of their caretaking responsibilities and thus did not violate Plaintiff's Fourth Amendment rights. The First Circuit affirmed, holding that Defendants' actions did not exceed the proper province of their community caretaking responsibilities. View "Caniglia v. Strom" on Justia Law

The First Circuit affirmed Defendant's conviction of possession of child pornography, holding that the district court did not err in denying Defendant's motions to suppress and for a hearing pursuant to Franks v. Delaware, 438 U.S. 154 (1978).After agents executing a search warrant of Defendant's residence discovered digital files containing images and videos of child pornography on Defendant's computers Defendant filed a motion to suppress and, in the alternative, for a Franks hearing. The district court denied both motions. Defendant then entered a conditional guilty plea to possession of child pornography. The First Circuit affirmed, holding (1) there was no evidence that the affidavit contained egregious misrepresentations sufficient to necessitate a Franks hearing to attack the warrant application, let alone to render the warrant invalid due to a misrepresentation; and (2) the warrant was adequately supported and the evidence obtained was admissible. View "United States v. Larson" on Justia Law

The First Circuit affirmed Defendant's convictions for one count of conspiracy to make false statements and to conceal in connection with healthcare benefit programs and two counts of false statements in connection with healthcare benefit programs, holding that the district court did not err in denying Defendant's motion to suppress or in instructing the jury.Specifically, the First Circuit held (1) the district court did not err in denying Defendant's motion to suppress data that the government had acquired pursuant to a warrant because even if the government's conduct violated the Fourth Amendment there was nothing in the record to show that any of the evidence introduce at trial should have been suppressed; and (2) the district court did not err in instructing the jury about the inferences that it could draw from the fact that a particular witness was not called to testify. View "United States v. Aboshady" on Justia Law

The First Circuit affirmed the district court's grant of summary judgment on Appellant's federal law claims under the Age Discrimination and Employment Act, and on the state-law claims for discrimination, retaliation based on a complaint of age discrimination, and failure to investigate and vacated the summary judgment on the state law claims for retaliation based on a report of gender discrimination, breach of contract, intentional interference with contractual relations, and defamation, holding that the court erred in granting summary judgment as to these claims.This lawsuit arose from events that led to Appellant's retirement from his position as Fire Chief for the Fire Department of the Town of Marshfield, Massachusetts. The district court granted summary judgment in favor of the Town on all of Appellant's federal and state law claims. The First Circuit affirmed in part and vacated in part, holding (1) summary judgment was properly granted as to some of Appellant's claims; but (2) as to the remaining state law claims, there was no analogue to the common law claims in the federal law claims that were addressed, and rather than attempt to resolve the state law issues that were in dispute as to these claims, their dismissal was directed without prejudice. View "Robinson v. Town of Marshfield" on Justia Law

The First Circuit affirmed the judgment of the district court denying Plaintiff's claims of sex discrimination and retaliation on summary judgment and declining Plaintiff's request to alter or amend that ruling under Fed. R. Civ. P. 59(e), holding that there was no reversible error in the proceedings below.This complaint stemmed from Plaintiff's unsuccessful pursuit of tenure within Harvard University's Anthropology Department. Plaintiff alleged that Harvard denied her tenure on the basis of sex discrimination and retaliation for engaging in protected conduct in violation of several state and federal antidiscrimination laws. The district court dismissed Plaintiff's claims on summary judgment and then denied Plaintiff's Rule 59(e) motion to alter or amend the summary judgment. The First Circuit affirmed, holding (1) the district court did not err in finding that Plaintiff did not meet her burden of showing Harvard's stated reason for denying tenure was merely pretext for discrimination; (2) because Plaintiff could not establish a causal link between her protected activity and the adverse employment decision, her retaliation claims failed; and (3) the district court did not err in denying Plaintiff's Rule 59(e) motion. View "Theidon v. Harvard University" on Justia Law

The First Circuit affirmed the district court decision denying Appellant's petition for habeas corpus relief, holding that the state court's evaluation of Appellant's constitutional claim was not contrary to, nor involved an unreasonable application of, federal law.Appellant was convicted in Rhode Island state court on felony assault and firearms charges. The Rhode Island Supreme Court affirmed. Appellant then applied for postconviction relief based on the ineffective assistance of counsel. The trial justice denied relief, and the Supreme Court affirmed. Appellant later filed a petition for a writ of habeas corpus in federal court, claiming ineffective assistance of counsel in violation of the Sixth Amendment. The district court concluded that Appellant's counsel's performance was constitutionally deficient but that the state Supreme Court's conclusion that Appellant had failed to satisfy the prejudice prong was not an unreasonable application of clearly established federal law. The First Circuit affirmed, holding (1) the Rhode Island Supreme Court's use of the incurable prejudice standard did not lead to a decision "contrary to" federal law; and (2) the Supreme Court's application of Strickland was not unreasonable. View "Chum v. Coyne-Fague" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment to Defendants on Plaintiff's Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621, and relinquishing supplemental jurisdiction over his claims under Puerto Rico law, holding that a reasonable jury could not find pretext discrimination and that the district court did not abuse its discretion in declining to exercise continued supplemental jurisdiction.In his complaint, Plaintiff alleged that he was fired on account of his age. The district court concluded that Plaintiff failed to put forth evidence that he was complying with the legitimate job performance expectations for his position and therefore failed to make a prima facie showing of discrimination. The First Circuit affirmed, holding (1) assuming that Plaintiff established a prima facie case, Plaintiff failed to show that his poor performance reviews were pretextual; and (2) while retention was an option, the district court did not exceed the boundary of its discretion in declining to exercise continued supplemental jurisdiction. View "Santana-Vargas v. Banco Santander Puerto Rico" on Justia Law