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

The First Circuit affirmed in part and vacated and remanded in part the district court’s dismissal of Appellant’s complaint claiming that he was fired from his job in retaliation for accusing his employer of violating the Anti-Kickback Statute (AKS) and making false representations in customer contracts, holding that Appellant plausibly pleaded that he engaged in protected conduct within the meaning of a False Claims Act (FCA) retaliation claim.The district court dismissed the complaint after finding that Appellant did not allege sufficient facts to show he was engaged in protected conduct within the meaning of the retaliation provision of the FCA. The First Circuit affirmed as to the contractual language claim but vacated and remanded as to the AKS claim, holding that Appellant plausibly pleaded that the concerns he raised about certain payments could have led to an FCA action. View "Guilfoile v. Shields" on Justia Law

The First Circuit affirmed Defendant’s conviction and sentence without prejudice to his right to raise his claim of ineffective assistance of counsel in a collateral proceeding brought pursuant to 28 U.S.C. 2255, holding that Defendant’s ineffective assistance of counsel claim ought not to be aired for the first time on direct appeal.Defendant pleaded guilty to violating the Mann Act, 18 U.S.C. 2423(a) and was sentenced to a 327-month term of immurement. On appeal, Defendant argued for the first time that he received ineffective assistance of counsel. The First Circuit affirmed, holding that this case did not qualify for an exception to the general rule that an ineffective assistance of counsel claim must first be raised in the district court. View "United States v. Miller" on Justia Law

The First Circuit affirmed the district court’s dismissal of Appellant’s federal petition for writ of habeas corpus filed pursuant to 28 U.S.C. 2254, holding that the district court did not err in dismissing the petition.In his petition, Appellant challenged his convictions under Massachusetts law for murder and other offenses, arguing that he received ineffective assistance of counsel, in violation of the Sixth Amendment to the United States Constitution. The district court denied relief. Because Appellant’s case was adjudicated on the merits in state court, the Antiterrorism and Effective Death Penalty Act’s (AEDPA) highly deferential standard of review applied. See 28 U.S.C. 2254(d). The First Circuit affirmed the district court’s denial of habeas relief, holding that any error on the part of counsel was not unsustainable under AEDPA’s deferential review standard. View "Walker v. Medeiros" on Justia Law

In this 42 U.S.C. 1983 case, the First Circuit affirmed the judgment of the district court granting summary judgment in favor of Kathy Bergeron, a corrections officer, holding that no reasonable juror could conclude that Bergeron was deliberately indifferent to the health and safety of Plaintiff, an inmate, under the Eighth Amendment based on the facts presented by Plaintiff.Plaintiff was severely beaten by other inmates in a cell at a medium-security prison. In his complaint, Plaintiff alleged that Bergeron was deliberately indifferent while doing a round, leading to a delay in his being provided with medical treatment, which exacerbated his injuries. The district court granted summary judgment for Bergeron. The First Circuit affirmed, holding that Plaintiff failed to produce enough evidence for a jury to conclude that Bergeron had the requisite culpable state of mind of deliberate indifference to Plaintiff’s need for medical care. View "Leite v. Goulet" on Justia Law

The First Circuit affirmed the judgment of the district court concluding that Plaintiff was not discriminated against but that Defendant’s decision to terminate her employment, rather than impose lesser discipline, was in retaliation for protected conduct, holding that the district court’s rulings were not erroneous or an abuse of discretion.In her complaint, Plaintiff, a former employee of the U.S. Postal Service, argued that her termination was unlawfully discriminatory due to her race and national origin and, independently, was in retaliation for her having filed earlier complaints. Defendant appealed the ruling that Defendant’s termination was in retaliation for protected conduct, and Plaintiff appealed the remedy awarded - back pay but not reinstatement or front pay. The First Circuit affirmed, holding that there was no error in the district court’s judgments. View "Anderson v. Brennan" on Justia Law

In this case against members of the Rhode Island Board of Bar Examiners the First Circuit reversed the district court’s grant of attorneys’ fees in favor of Plaintiff and affirmed the court’s dismissal of Plaintiff’s amended complaint, holding that Plaintiff’s supposed “prevailing party” status was not justified.Plaintiff, an individual with attention deficit/hyperactivity disorder and anxiety, filed suit against members of the Board challenging the Board’s denial of his request for certain accommodations to assist him in taking the Rhode Island bar exam. The district court issued a temporary restraining order (TRO) requiring the Board to permit Plaintiff the requested accommodations, dismissed Plaintiff’s amended complaint, and allowed Plaintiff’s motion for attorneys’ fees. On review, the First Circuit held (1) Plaintiff’s success in gaining a TRO did not warrant an award of attorneys’ fees; and (2) the district court’s decision to allow the Board’s motion to dismiss the damage claim in the complaint was correct. View "Sinapi v. Rhode Island Board of Bar Examiners" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment in favor of Defendants on Plaintiff’s claim that Defendants conspired against him and violated the Massachusetts Civil Rights Act (MCRA), Mass. Gen. Laws ch. 12, 11H, 11I by depriving him of his protected property right of continued employment with the Salisbury Police Department (SPD), holding that summary judgment was properly granted.In 2010, Cornelius Harrington, the Salisbury town manager, hired Robert St. Pierre to investigate allegations of misconduct by the then-police chief. During the investigation, St. Pierre uncovered evidence of alleged wrongdoing by Plaintiff, an officer at the SPD. After a follow-up investigation, Harrington terminated Plaintiff from his employment. An arbitrator later reversed that decision. Plaintiff retired soon after and filed this lawsuit against Harrington and St. Pierre. The district court granted summary judgment for Defendants. The First Circuit affirmed, holding that summary judgment was proper where Plaintiff offered little evidence beyond bald speculation for the existence of a conspiracy and failed to show that his constitutional rights ere interfered with by “threats, intimidation, or coercion,” as required by the MCRA. View "Thomas v. Town of Salisbury" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment to the City of Providence, Rhode Island (the City) as to Plaintiff’s complaint for discrimination under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213, and related state anti-discrimination laws, holding that the district court properly entered summary judgment on Plaintiff’s claims.Following an injury that he sustained while on duty, Plaintiff, a veteran police officer in the City, sued the City for discrimination. The district court granted summary judgment in favor of the City on all claims, concluding that Plaintiff had failed to establish that he was disabled within the meaning of the ADA and failed to show a cognizable disability as to his state-law claims. Although its reasoning differed from that of the district court, the First Circuit affirmed, holding that summary judgment was properly entered on Plaintiff’s claims. View "Mancini v. City of Providence" on Justia Law

The First Circuit affirmed the district court’s denial of Defendant’s motion to suppress and affirmed Defendant’s conviction of one count of possession of a firearm by a convicted felon, holding (1) there was no basis on which to grant Defendant’s motion to suppress; and (2) there was no error in Defendant’s conviction.On appeal, Defendant argued, among other things, that the district court erred in denying his motion to suppress the handgun at issue because it was discovered during an unconstitutional search of his vehicle. The First Circuit disagreed, holding (1) the search of Defendant’s vehicle was not unconstitutional, and therefore, the weapon was not the fruit of an unlawful search and did not require suppression; and (2) Defendant’s conviction was supported by sufficient evidence of his knowing and intentional possession of the weapon. View "United States v. Davis" on Justia Law

The First Circuit affirmed in part and dismissed in part Defendant’s interlocutory appeal from the district court’s denial of her motion for summary judgment arguing that she was immune to Plaintiff’s damage claims, holding that this Court lacked appellate jurisdiction to the extent Defendant challenged the district court’s assessment of the record.Defendant, a police officer, shot Plaintiff as Plaintiff was cutting himself with a knife in the waiting area of a psychiatric center. Plaintiff sued Defendant under 42 U.S.C. 1983, arguing that Defendant violated his Fourth Amendment right to be free from unreasonable seizures. Defendant moved for summary judgment based, in part, on her qualified immunity to federal damage claims arising out of the performance of her official duties as a public employee. The district court denied the motion, concluding that Defendant could not constitutionally shoot Plaintiff unless he posed an immediate threat to herself or others and only after providing some kind of warning, if feasible. Defendant appealed. The First Circuit (1) dismissed the appeal to the extent it challenged the district court’s assessment of the factual record under Fed. R. Civ. P. 56; and (2) otherwise affirmed the district court’s denial of summary judgment. View "Begin v. Drouin" on Justia Law