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

The First Circuit vacated Appellant's conviction for willfully violating 18 U.S.C. 922(n) - the federal prohibition on the receipt of a firearm by someone "under indictment for a crime punishable by imprisonment for a term exceeding one year" - and vacated Appellant's sentence, holding that an instructional error and the application of a "trafficking of firearms" enhancement were in error.Appellant was convicted of violating 18 U.S.C. 922(n) and 18 U.S.C. 922(a)(1)(A), the federal prohibition on "dealing in firearms" without a license. The First Circuit vacated the judgment in part, holding (1) the trial court erred in instructing the jury as to the "willfully" element of the section 922(n) offense; (2) remand was required for an evidentiary hearing on Appellant's claim of actual conflict of defense counsel under the Sixth Amendment; and (3) the trial court erred in applying the "trafficking" enhancement, and the error was not harmless. View "United States v. Daniells" on Justia Law

The First Circuit affirmed the district court's order entering summary judgment in favor of Defendant with respect to Plaintiff's assertion that he was wrongfully deprived of thousands of dollars in commissions he alleged he was due, holding that there was no error.After he resigned, Plaintiff brought suit against Defendant, his former employer, asserting claims for nonpayment of wages under the Act, breach of contract, unjust enrichment, and quantum meruit. Defendant successfully removed the action to federal district court, which granted summary judgment in favor of Defendant. The First Circuit affirmed, holding that the district court (1) did not err in granting in part Defendant's motion to strike certain portions of his response to the summary judgment motion; and (2) did not err in granting summary judgment against Plaintiff on his claims. View "Klauber v. VMware, Inc." on Justia Law

The First Circuit granted in part Petitioner's petition for review of an order of the Board of Immigration Appeals (BIA) affirming the denial of Petitioner's application for deferral of removal under the Convention Against Torture (CAT) and vacated the BIA's order denying Petitioner CAT relief as to Ecuador, holding that remand was required for further proceedings.Petitioner was charged with removability for entering the country without admission or parole. Petitioner conceded removability and sought deferral of removal under CAT. An immigration judge (IJ) denied relief. The BIA affirmed. Petitioner petitioned for review and was subsequently removed to Ecuador. The First Circuit vacated the BIA's decision insofar as it denied Petitioner's CAT claim linked to the vernal violence in Ecuadorian prisons, holding that the BIA and IJ failed to apply the proper legal test in assessing whether the Ecuadorian government would consent or acquiesce to acts of torture by private actors in Ecuadorian prisons. View "Murillo Morocho v. Garland" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant, following a jury trial, of various firearm and controlled substance offenses, holding that none of Defendant's challenges on appeal had merit.Specifically, the First Circuit held (1) the district court correctly concluded that the search warrant leading to Defendant's arrest was clearly supported by probable cause, and therefore, there was no error in the denial of Defendant's motion to suppress; (2) the district court did not err in concluding that the evidence was sufficient to support Defendant's convictions on the firearm charges; and (3) the district court's seventy-two-month sentence on count one was substantively reasonable. View "United States v. Sylvestre" on Justia Law

The First Circuit affirmed the order of the district court dismissing Plaintiffs' claims that the closure of in-person education due to the COVID-19 pandemic deprived children of the free appropriate public education to which they were entitled and deprived and parents of their right to participate in their children's education, holding that none of Plaintiffs' claims were cognizable in federal court.Plaintiffs, three children with disabilities and their parents on behalf of a putative class, sued the Governor of Massachusetts, the Commissioner of Schools for Massachusetts, the Massachusetts Department of Elementary and Secondary Education, and several school districts and their superintendents, claiming that the closure of in-person education during the COVID-19 pandemic violated Plaintiffs' rights under the IDEA and that Defendants illegally discriminated against Plaintiffs on the basis of disability in violation the Americans with Disabilities Act and 42 U.S.C. 1983. The district court granted Defendants' motion to dismiss. The First Circuit affirmed, holding that Plaintiffs' claims were properly dismissed in full either because Plaintiffs lacked standing to request the relief they sought, because the claims were moot, and/or because Plaintiffs failed to exhaust administrative remedies. View "Roe v. Healey" on Justia Law

The First Circuit affirmed in part and reversed in part the order of the district court in the underlying action originally brought by Peter Marcus against the American Contract Bridge League (ACBL), where Marcus was formerly employed, holding that the district court erred in part.In the underlying amended complaint, Marcus and his co-plaintiffs sought unpaid overtime wages under the Fair Labor Standards Act (FSLA), 29 U.S.C. 207(a), and Marcus asserted that he was wrongfully discriminated and retaliated against for requesting his claimed pay. The district court entered summary judgment for certain plaintiffs and, as to Marcus's retaliation claim, entered summary judgment for ACBL. The First Circuit reversed in part and remanded the case, holding that the district court (1) erred in denying Plaintiffs' motion to substitute a party; (2) correctly granted judgment in favor of ACBL on Marcus's retaliation claim; (3) erred in granting judgment with respect to the FSLA overtime claims of certain plaintiffs; and (4) otherwise did not err. View "Marcus v. American Contract Bridge League" on Justia Law

The First Circuit affirmed the judgment of the district court denying Plaintiff's request for preliminary injunctive relief challenging the restraint procedures used by the Massachusetts Department of Correction (DOC) under the Eighth Amendment and Title II of the Americans with Disabilities Act of 1990 (ADA), holding that the district court did not err in denying relief.Plaintiff, an inmate who suffered from severe arthritis in his shoulder joints, challenged the restraint procedures used on him by the DOC, including "rear cuffing" with a single standard handcuff, then later rear cuffing using "double cuffs," and still later using custom modified handcuffs. In this action, Plaintiff argued that the unnecessary pain caused by these restraint procedures violated his constitutional and statutory rights and sought an order requiring the DOC to adopt his own proposed restraint procedure. The district court denied Plaintiff's request for preliminary relief. The First Circuit affirmed, holding that the district court properly determined that DOC did not respondent with deliberate indifference to Plaintiff's medical needs and that Plaintiff was unlikely to prevail on the merits of his ADA claim. View "Sosa v. Mass. Dep't of Correction" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's petition for habeas review on the grounds that his trial counsel rendered ineffective assistance, holding that, although this Court's reasoning differs from that of the district court, there was no error in the denial of the habeas petition.Petitioner pled guilty to transporting a minor with the intent to engage in criminal sexual activity. On appeal, Petitioner argued that his trial counsel provided ineffective assistance based on a claim centered on the applicable statute of limitations, which had changed from the time when Petitioner committed the offense of conviction to the time that he was indicted. The district court denied relief. The First Circuit affirmed, holding that Petitioner's trial counsel did not render ineffective assistance by failing to move to dismiss the charges against him on limitations grounds. View "Miller v. United States" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing this lawsuit against the Financial Oversight and Management Board for Puerto Rico (FOMB) and its executive director challenging the FOMB's alleged failure to review a sale agreement on untimeliness grounds, holding that the dismissal was proper, albeit on standing grounds.Appellants - several Puerto Rico corporations and individuals - brought this action claiming that the FOMB's alleged failure to review a $384 million loan sale agreement between the Economic Development Bank for Puerto Rico (BDE) and a private investment company violated their constitutional rights under the Fourteenth Amendment's Due Process and Equal Protection Clauses, and a statutory violation under the Puerto Rico Oversight, Management, and Economic Stability act . The district court granted the FOMB's motion to dismiss, concluding that the claims were time-barred. The First Circuit affirmed but on different grounds, holding that Appellants lacked standing because their complaint failed to allege that the FOMB's inaction caused their claimed injury. View "R&D Master Enterprises, Inc. v. Financial Oversight & Management Bd. for P.R." on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motion to dismiss the indictment against him on double jeopardy grounds after the district court declared a mistrial based on complications brought about by the pandemic, holding that that there was no error.Defendant was charged with transmitting a threatening communication in interstate commerce. During trial, the government's main witness and a case agent took a test that came back positive for COVID-19. The court ultimately ordered a mistrial and dismissed the jurors. Thereafter, Defendant filed a motion to dismiss on double jeopardy grounds. The district court denied the motion. The Supreme Court affirmed, holding that the steps taken by the district court leading to its declaration of a mistrial were within its discretion. View "United States v. Dennison" on Justia Law