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

The First Circuit affirmed Defendant’s convictions and sentence for federal carjacking and weapons counts, holding that Defendant’s arguments on appeal failed.Specifically, the Court held (1) the force clause in 18 U.S.C. 924(c)(1)(A), which defines a crime of violence, encompassed Defendant’s 18 U.S.C. 2119 convictions for carjacking; (2) Defendant’s arguments that section 924(c) is unconstitutional, both facially and as applied, were without merit; (3) the evidence was sufficient to support the convictions; and (4) the district court did not err in instructing the jury as to what the government had to prove to sustain Defendant’s convictions. View "United States v. Cruz-Rivera" on Justia Law

The First Circuit affirmed the judgment of the district court excluding certain evidence during trial in this case alleging violations of the Fourth Amendment and 42 U.S.C. 1983, holding that Plaintiff’s grounds for attacking one set of evidentiary rulings were not advanced below and that Plaintiff’s remaining challenge was moot.On appeal, Plaintiff challenged the district court’s rulings on her motions in limine, which resulted in the exclusion of evidence concerning the procurement and validity of a search warrant, and the district court’s refusal to admit her medical bills into evidence. The First Circuit held (1) Plaintiff’s first assignment of error was predicated on legal theories and arguments that were raised for the first time on appeal and thus could not be addressed on appeal; and (2) because the medical bills were relevant only to the issue of damages and the jury found no liability, all issues regarding damages were moot. View "Campbell v. Ackerman" on Justia Law

The First Circuit affirmed the sentence imposed in connection with the district court’s revocation of Defendant’s supervised release, holding that Defendant’s sentence did not violate the Eighth Amendment’s prohibition of cruel and unusual punishment and that the sentence was substantively reasonable.After he was released from federal custody following a drug trafficking conviction, Defendant pleaded guilty to felony drug possession in state court. The district court revoked Defendant’s supervised release and imposed a sentence of twenty-four months’ imprisonment, concluding that Defendant’s conduct violated his conditions of supervised release. On appeal, Defendant challenged the substantive reasonableness of his sentence and argued that because his drug addiction is a disease, sentencing him to a term of imprisonment for manifesting a condition of his disease was cruel and unusual punishment. The First Circuit disagreed, holding (1) it is not “clear or obvious” that the practice of incarcerating defendants for drug use and possession is unconstitutional; and (2) Defendant’s two-year sentence is not substantively unreasonable. View "United States v. Sirois" on Justia Law

The First Circuit affirmed Defendant’s conviction and sentence for participating in a conspiracy to bribe an agent of an organization receiving federal funds and of receiving a bribe, holding that there was no error or abuse of discretion in the trial court proceedings.Defendant, a former Puerto Rico Superior Court Judge, was found guilty of both counts by a jury. Defendant was sentenced to sixty months of imprisonment for one count and 120 months of imprisonment for the other count, to be served concurrently. The First Circuit affirmed, holding (1) there was sufficient evidence supporting Defendant’s convictions; (2) Defendant did not demonstrate that any alleged error in the government’s opening statement and closing argument or in the admission of certain testimony affected his substantial rights or that they impaired the fairness, integrity, or the public reputation of the judicial proceedings; (3) the district court did not abuse its discretion in upholding a witness’s invocation of his Fifth Amendment privilege; and (4) any claimed sentencing error would be harmless. View "United States v. Acevedo-Hernandez" on Justia Law

The First Circuit affirmed the district court’s denial of Appellant’s 28 U.S.C. 2255 petition, holding that Appellant’s three prior convictions were Armed Career Criminal Act (ACCA) predicates, and therefore, Appellant’s sentence as an armed career criminal was proper.On appeal, Appellant argued that his sentence under the ACCA was unconstitutional under Johnson v. United States, 135 S. Ct. 2551 (2015), Supreme Court precedent decided after his earlier appeal from his conviction was rejected. The First Circuit disagreed, holding that three of Appellant’s convictions qualified as violent felonies under the ACCA’s force clause, and therefore, the district court did not err in dismissing Appellant’s section 2255 petition. View "Lassend v. United States" on Justia Law

The First Circuit affirmed in part and reversed in part the district court’s grant of summary judgment in favor of Medina & Medina, Inc. in this employment discrimination lawsuit, holding that summary judgment was properly granted as to Plaintiff’s discriminatory wage disparity claims and gender-based hostile work environment claims but improperly granted as to Plaintiff’s federal and Puerto Rico age-based hostile work environment claims and retaliation claims.The district court held that Plaintiff failed to produce sufficient evidence to survive summary judgment as to any of her claims. The First Circuit held (1) based on the evidence proffered by both parties, summary judgment was appropriate on Plaintiff’s discriminatory wage disparity and and gender-based hostile work environment claims; (2) where Plaintiff produced evidence that she was taunted about her age nearly every single day for over two years, summary judgment was not appropriate as to Plaintiff’s age-based hostile work environment claim; (3) there was a genuine issue of fact that precluded summary judgment on Plaintiff’s claims of retaliation; and (4) Plaintiff’s supplemental claims brought pursuant to Puerto Rico law were properly disposed of upon summary judgment. View "Rivera-Rivera v. Medina & Medina, Inc." on Justia Law

The First Circuit reversed the judgment of the bankruptcy court allowing The Patriot Group, LLC to amend its pleadings in its adversary complaint requesting denial of the discharge in bankruptcy of Steven Fustolo’s debt and denying Fustolo’s discharge pursuant to the newly added claim, holding that the allowance of this belated amendment failed to satisfy the prescripts of due process underlying Fed. R. Civ. P. 15(b)(2) and was therefore an abuse of discretion. Specifically, the Court held that Appellant did not receive adequate notice of an unpleaded claim and did not provide his implied consent. Therefore, the bankruptcy court’s order must be reversed and the case remanded for further proceedings. View "Fustolo v. Patriot Group LLC" on Justia Law

The First Circuit affirmed the district court’s dismissal of a complaint filed by George Gillis against William Chase in this third complaint against Chase, Gillis III, seeking to reopen Gillis I.Gillis was operating a truck at a construction site when he struck and fatally injured Edward Hansen. Gillis was charged with motor vehicle homicide in state court but was acquitted after a trial. Gillis then sought vindication by filing lawsuits. Gillis I asserted that William Chase, the police chief when Hansen’s death occurred, violated his constitutional rights by knowingly charging him with a crime without probable cause. The district court dismissed the case for failure to state a claim. In Gillis II, Gillis sued two different defendants, and the case was dismissed on summary judgment. Gillis III, against Chase alone, sought to reopen Gillis I. Gillis argued that Chase conspired to charge Gillis in the criminal case as the result of undue influence exerted by a defendant in Gillis II. The district court found that Gillis III was time barred and failed to state a claim. The First Circuit affirmed, holding that the district court’s judgment was not in error. View "Gillis v. Chase" on Justia Law

The First Circuit affirmed the district court’s judgment in favor of the Town of Camden, Maine on Plaintiff’s complaint claiming that Camden deprived him of his procedural due process rights when Camden laid him off because it violated the recall provision in his collective bargaining agreement (CBA).Plaintiff, a police dispatcher with Camden for thirty-one years, was laid off after Camden moved its police department’s dispatch operations to the Knox County Sheriff’s Department in the Town of Rockland. Plaintiff sued Camden pursuant to 42 .U.S.C. 1983. The jury returned a verdict in favor of Camden, determining (1) the CBA conditioned an employee’s recall right on the written submission, after layoff, of the employee’s mailing address and telephone number; and (2) Plaintiff had not contacted the town manager with his contact details after his layoff. The First Circuit affirmed, holding that the jury’s determination undid Plaintiff’s case because, without a right to recall, there was no deprivation of a protected property interest and no violation of Plaintiff’s due process rights. View "Clukey v. Town of Camden, Maine" on Justia Law

The First Circuit affirmed the entry of a jury verdict awarding over $1.3 in compensatory damages and $1.3 million in punitive damages to Plaintiff, a black female former employee of the Massachusetts Bay Transportation Authority (MBTA), who claimed that her supervisors at the MBTA conspired to terminate her employment because of her race.The Court held (1) the evidence was sufficient to support the compensatory damages award for wrongful termination and to justify the punitive damages amount; (2) the trial judge committed clear error in imposing a sanction for removing the entry of default, but the MBTA failed to show that it was prejudiced by the default sanction order; (3) MBTA failed to show that it was prejudiced when the trial judge allowed a hostile work environment theory not explicitly pled in the complaint to go to the jury; and (4) MBTA waived its claim that it should be able to take advantage of Buntin v. City of Boston, 857 F.3d 69 (1st Cir. 2017), decided while this case was on appeal. View "Dimanche v. Massachusetts Bay Transportation Authority" on Justia Law