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

The First Circuit affirmed Defendant's conviction of conspiracy to deprive a person of civil rights and sentence of eighty-seven months in prison, holding that the evidence was sufficient to sustain Defendant's conviction and that there was no other reversible error.Specifically, the Court held (1) the district court did not err in denying Defendant's motions for judgment of acquittal based on the insufficiency of the evidence; (2) the district court properly admitted testimony of two government witnesses under Fed. R. Evid. 404(b); (3) the district court did not violate Defendant's rights under the Sixth Amendment's Compulsory Process Clause or the Fourteenth Amendment's Due Process Clause; (4) the district court did not abuse its discretion by denying Defendant's second motion for a new trial based on newly discovered evidence; and (5) Defendant's sentence was procedurally reasonable. View "United States v. Martinez-Mercado" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's request to challenge the reliability of his victim's testimony by cross-examining the victim at Defendant's resentencing hearing, holding that the district court did not violate Defendant's procedural due process rights by disallowing cross-examination of the victim at Defendant's resentencing.Defendant pleaded guilty to kidnapping for ransom. The First Circuit remanded the case for resentencing. On remand, the district court judge sentenced Defendant to eight months less than his previous sentence. On appeal, Defendant argued that his procedural due process rights were violated when the judge denied him the opportunity to contest misinformation about his treatment of the victim during the abduction by cross-examining the victim, which led to the imposition of a sentence based on inaccurate information. The First Circuit disagreed and affirmed, holding that the district court did not err in denying Defendant's request to cross-examine the victim at Defendant's resentencing hearing. View "United States v. Berrios-Miranda" on Justia Law

The First Circuit vacated in part the district court's grant of Defendants' motion to dismiss Plaintiff's complaint, holding that the warrantless search in this case violated the Fourth Amendment because the circumstances, including deception by law enforcement officers, vitiated the consent given by Plaintiff.Plaintiff alleged that he consented to FBI agents' entry into his home and search of his computers only because the officers lied about the true reason of why there were there and what they were looking for. The district court granted Defendants' motion to dismiss for failure to state a claim. The First Circuit vacated in part and affirmed in part, holding (1) because the totality of the circumstances pointed to a situation involving beguilement, the government did not meet its burden to prove voluntariness, and therefore, the warrantless entry into Plaintiff's home and the search and seizure of his computer violated the Fourth Amendment; (2) Defendants were not entitled to qualified immunity on Plaintiff's search-based Fourth Amendment claim because any reasonable officer would have recognized that the circumstances were impermissibly coercive; and (3) even if Plaintiffs' malicious prosecution claim had merit, Defendants would be entitled to qualified immunity. View "Pagan-Gonzalez v. Moreno" on Justia Law

The First Circuit affirmed the district court's partial entry of summary judgment in favor of Defendants on Plaintiff's age discrimination claim and his family's derivative tort claims and the denial of Plaintiff's motion for summary judgment, holding that the district court's summary judgment rulings were proper.Plaintiff and five of his family member brought this action under Puerto Rico law against Plaintiff's former employer and its insurance carrier alleging unjust dismissal and age discrimination in employment, his family asserting derivative tort claims arising from the alleged age discrimination. The district court granted summary judgment for Defendants on all but the unjust dismissal claim and denied Plaintiff's cross-motion for summary judgment. The First Circuit affirmed, holding that, under the facts of this case, summary judgment was properly granted. View "Ramos-Santiago v. WHM Carib LLC" on Justia Law

The First Circuit affirmed the judgment of the district court granting judgment as a matter of law to Defendant-employer on Plaintiff’s age discrimination claims and Puerto Rico law claims and granting in part Defendant’s summary judgment motion, holding that there was no error in the proceedings below.After Plaintiff was laid off as part of Defendant’s effort to cut costs, Plaintiff sued the hospital under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621-634 and Puerto Rico antidiscrimination and tort law. The district court granted summary judgment in part for Defendant, finding that Defendant had facially legitimate, non-discriminatory grounds to terminate Plaintiff’s position. A jury trial ensued, but at the close of evidence the district court granted Defendant’s motion for judgment as a matter of law. The First Circuit affirmed, holding that there were fatal and uncontradicted defects in Defendant’s prima facie theory of liability as established by the evidence at trial. View "Hoffman-Garcia v. Metrohealth, Inc." on Justia Law

The First Circuit affirmed the orders of the district court judge’s rulings dismissing Plaintiff’s sexual orientation discrimination claim and granting summary judgment for Defendant on Plaintiff’s unjust discharge and age discrimination claims and awarded Defendant its costs on this appeal, holding that the judge committed no reversible error.In this diversity case governed by Puerto Rico law, the district court judge dismissed Plaintiff’s claims against her former employer on Defendant’s motions to dismiss and for summary judgment. The First Circuit affirmed, holding (1) the judge properly dismissed Plaintiff’s sexual orientation discrimination claim because Plaintiff did not plausibly plead that her firing constituted sexual orientation discrimination; and (2) the judge properly granted summary judgment for Defendant on Plaintiff’s unjust discharge and age discrimination claims. View "Villeneuve v. Avon Products, Inc." on Justia Law

The First Circuit affirmed the decision of the district court denying Defendant’s motion to suppress and sentencing Defendant, holding that the evidence was not obtained in violation of Defendant’s Fourth Amendment rights and that Defendant was properly sentenced.Defendant was convicted for producing six videos depicting him sexually assaulting a three-year-old child. Defendant appealed the denial of his motion to suppress evidence recovered from his residence and statements he made to law enforcement at his residence and during a later interrogation. The district court concluded that Defendant knowingly and voluntarily consented to the search of his residence and that there was no Fourth Amendment violation. At sentencing, Defendant argued that the charges were multiplicitous because the videos were taken during one continuous sexual assault. The district court disagreed and sentenced Defendant to a fifty-year term of imprisonment. The First Circuit affirmed, holding (1) even assuming that law enforcement committed a Fourth Amendment violation before encountering Defendant, any prior illegality did not influence Defendant’s subsequent consent to the search of his computer and hard drives, and Defendant’s consent to the search was knowing and voluntary; and (2) the proper unit of prosecution under 18 U.S.C. 2251(a), the federal child pornography statute, is each video depicting the victim. View "United States v. Smith" on Justia Law

The First Circuit affirmed Defendant’s conviction and sentence for two counts of conspiracy to possess and possession with intent to distribute heroin and cocaine base, holding, among other things, that the district court did not err in denying Defendant’s motions to suppress two warrants obtained by law enforcement and evidence obtained from Defendant’s warrantless arrest.Specifically, the Court held (1) there was no error int he issuance of precise location information (PLI) warrants by a magistrate judge allowing monitoring of the locations of Defendant’s two cell phones; (2) the cell phones were not tracking devices under 18 U.S.C. 3117; (3) the PLI warrants did not violate Fed. R. Crim. P. 41(b); (4) the use of rebuttal testimony from a pretrial services officer to impeach a witness was proper; and (5) the sentencing court’s adoption of two sentencing enhancements was not procedurally unreasonable. View "United States v. Ackies" on Justia Law

The First Circuit affirmed the judgment of the district court entering judgment against Defendant on Plaintiff’s discrimination action and awarding Plaintiff compensatory and punitive damages, holding that the district court did not err in denying Defendant’s motions for judgment as a matter of law and a new trial, and Defendant’s other assignments of error were unavailing.Plaintiff, a citizen of Massachusetts, brought suit against Defendant, a New York-based real estate firm and Plaintiff’s former employer, claiming that Defendant fired him because of his age and disability. Defendant removed the suit from the Massachusetts Superior Court to a federal district court in Boston. The district court applied the New York City Human Rights Law (NYCHRL), N.Y.C. Admin. Code 8-101-10. The jury found that Defendant discriminated against Plaintiff on the basis of age and awarded him $1,275,000 in both compensatory and punitive damages. The First Circuit affirmed, holding (1) the district court correctly applied the NYCHRL; (2) the district court judge correctly instructed the jury; and (3) there was sufficient evidence to support the jury’s verdict. View "Rinsky v. Cushman & Wakefield, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant’s motion to suppress incriminating evidence found during a search and seizure by a local police officer after approaching Defendant, who was seated in a car with his friend in a parking lot, and asking him several questions, holding that the search and seizure were lawful.Based on Defendant’s answers to the officer’s questions, the officer searched the vehicle, found drugs and drug paraphernalia, and arrested Defendant. After Defendant consented to the search of his backpack, further incriminating evidence was found. Defendant moved to suppress the government’s evidence, arguing that the officer lacked reasonable suspicion to initiate and continue the inquiries that led to the discovery of the contraband. The district court denied the motion. The First Circuit affirmed, holding that the district court did not err in finding no Fourth Amendment violation and denying Defendant’s motion to suppress. View "United States v. Tanguay" on Justia Law