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

Between February 2014 and December 2015, United States Postal Inspection Service (USPIS) agents in Puerto Rico identified a pattern of suspicious packages being sent between Puerto Rico and New York. Upon inspection, these packages were found to contain cocaine and large sums of money concealed in household items. The investigation led to Miguel A. Reyes-Ballista (Reyes) and two co-conspirators. Reyes was indicted and, after a six-day trial, a jury convicted him of participating in two conspiracies to possess with intent to distribute cocaine and three counts of possession with intent to distribute cocaine.Reyes was sentenced to 170 months in prison with four years of supervised release. He appealed his convictions, arguing that the government provided insufficient evidence to support the jury's verdict. Reyes also sought a new trial, claiming ineffective assistance of counsel due to inadequate communication with his attorney and poor performance at trial, which he argued violated his Sixth Amendment right to counsel.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the evidence presented at trial, including testimony from co-conspirators, surveillance footage, and fingerprint evidence, was sufficient to support Reyes's convictions for conspiracy. The court noted that Reyes's arguments regarding the credibility of witnesses and the lack of direct evidence placing him inside the post office did not undermine the jury's verdict. The court also dismissed Reyes's Sixth Amendment claim as premature, indicating that such claims are typically better suited for collateral proceedings where a more developed record can be established.The First Circuit affirmed Reyes's convictions and dismissed his Sixth Amendment claim without prejudice, allowing him the opportunity to raise the issue in a future collateral proceeding. View "United States v. Reyes-Ballista" on Justia Law

In early 2025, the National Institutes of Health (NIH) and the Department of Health and Human Services (HHS) implemented a new policy prohibiting NIH from funding certain categories of scientific research grants. Two groups of plaintiffs, including private research organizations, individual researchers, and several states, sued, alleging that the new policy and the resulting grant terminations violated the Administrative Procedure Act (APA) and the U.S. Constitution. They argued that the policy was arbitrary and capricious, as the prohibited research categories were undefined and the rationale for discontinuing the research was circular.The United States District Court for the District of Massachusetts held a trial on the merits and ruled in favor of the plaintiffs, finding the agencies' actions to be "breathtakingly arbitrary and capricious." The court set aside the new policy and related grant terminations as illegal under the APA. The court found that the decisions were based on circular reasoning, lacked a rational connection to the facts, and ignored significant reliance interests. The government then moved for a stay of the district court's order pending appeal, which the district court denied.The United States Court of Appeals for the First Circuit reviewed the case. The court concluded that the district court had jurisdiction to review the agency action under the APA and to grant declaratory relief. The court found that the district court's orders did not enforce a contractual obligation to pay money but rather provided declaratory relief that set aside agency actions as arbitrary and capricious. The court also determined that the grant terminations were reviewable under the APA and that the Department had failed to show a likelihood of success on the merits. The court denied the Department's motion for a stay, concluding that the balance of equities and the public interest favored the plaintiffs. View "American Public Health Assn v. National Institutes of Health" on Justia Law

In 2023, Maine voters passed "An Act to Prohibit Campaign Spending by Foreign Governments" to prevent foreign governments and entities influenced by them from contributing to or influencing elections. The Act also requires media platforms to ensure they do not distribute communications that violate this prohibition, with violators facing civil and criminal penalties. Several companies and individuals, including Central Maine Power (CMP) and Versant Power, challenged the Act, claiming it violated the First Amendment. The district court granted a preliminary injunction against the Act, and Maine appealed.The United States District Court for the District of Maine granted the preliminary injunction, finding that the Act was likely unconstitutional under the First Amendment. The court held that the Act's prohibition on spending by entities with at least 5% foreign ownership was not narrowly tailored to a compelling state interest. It also found that the definition of "foreign government-influenced entity" was overly broad and likely to stifle domestic speech regardless of actual foreign influence. The court declined to sever the unconstitutional provisions from the rest of the Act, reserving the issue for later consideration.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court agreed that the Act's 5% foreign ownership threshold was not narrowly tailored and that the definition of "foreign government-influenced entity" was overly broad. The court also found that the Act's restrictions on contributions and expenditures were likely unconstitutional. The court did not address the issue of severability, leaving it for the district court to decide. The court also did not find it necessary to discuss the preemption determination in affirming the injunction. View "Central Maine Power Co. v. Commission on Governmental Ethics and Election Practices" on Justia Law

The U.S. Department of Education announced a reduction in force (RIF) on March 13, 2025, affecting about half of its employees. Subsequently, twenty-one states and several labor organizations and school districts filed lawsuits against the Secretary of Education, the Department, and the President, claiming that the RIF violated the U.S. Constitution and the Administrative Procedure Act (APA). They also sought an injunction against the transfer of certain functions out of the Department, announced by the President on March 21, 2025.The U.S. District Court for the District of Massachusetts consolidated the cases and granted the plaintiffs' motions for a preliminary injunction. The court found that the plaintiffs were likely to succeed on the merits of their claims, determining that the RIF and the transfer of functions were likely ultra vires and violated the APA. The court concluded that the actions were arbitrary and capricious, lacking a reasoned explanation and failing to consider the substantial harms to stakeholders.The United States Court of Appeals for the First Circuit reviewed the case. The court denied the appellants' motion for a stay pending appeal. The court found that the appellants did not make a strong showing that they were likely to succeed on the merits, particularly regarding the APA claims. The court also determined that the plaintiffs would suffer substantial injury without the injunction, as the RIF made it effectively impossible for the Department to carry out its statutory functions. The court concluded that the public interest favored maintaining the injunction to ensure the Department could fulfill its legal obligations. View "New York v. McMahon" on Justia Law

Plaintiffs, who own or operate gasoline service stations in Puerto Rico, offered two different prices to consumers: a higher price for those using credit or debit cards and a lower price for those paying with cash. In 2013, Puerto Rico's legislature enacted Law 152-2013, amending Law 150-2008 by removing a provision that allowed merchants to offer cash discounts. Plaintiffs ceased offering the lower price due to the threat of fines and criminal prosecution. They sued the Commonwealth of Puerto Rico, arguing that Law 150 is preempted by federal law and is unconstitutionally vague.The United States District Court for the District of Puerto Rico rejected the plaintiffs' arguments and granted the Commonwealth's motion to dismiss for failure to state a claim. The court found that neither the Cash Discount Act (CDA) nor the Durbin Amendment preempted Law 150. The court also declined to address the constitutional vagueness argument, noting that the complaint did not allege that Law 150 is unconstitutionally vague.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the CDA and the Durbin Amendment do not preempt Law 150. The CDA regulates the conduct of credit card issuers, not merchants or states, and does not confer an absolute right to offer cash discounts. The Durbin Amendment regulates payment card networks, not states, and does not preempt state legislation restricting cash discounts. The court also found that the plaintiffs did not properly plead a vagueness claim in their complaint, rendering the claim unpreserved for appellate review. Consequently, the First Circuit affirmed the district court's dismissal of the case. View "Asociacion de Detallistas de Gasolina de PR Inc. v. Commonwealth of Puerto Rico" on Justia Law

Four businesses involved in the cultivation, manufacture, possession, and distribution of marijuana within Massachusetts, in compliance with state laws, sued the Attorney General of the United States in 2023. They claimed that the Controlled Substances Act (CSA) exceeded Congress's powers under Article I of the U.S. Constitution and violated the Due Process Clause of the Fifth Amendment. They sought a declaratory judgment and an injunction to prevent the enforcement of the CSA against their intrastate activities.The United States District Court for the District of Massachusetts dismissed the plaintiffs' claims for failing to state a claim upon which relief could be granted. The court reasoned that the Supreme Court's decision in Gonzales v. Raich, which upheld the CSA's application to intrastate marijuana activities under the Commerce Clause, was controlling. The District Court also found no precedent for recognizing a fundamental right to cultivate, process, and distribute marijuana, thus rejecting the plaintiffs' substantive due process claim.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the District Court's dismissal. The First Circuit held that the CSA's regulation of intrastate commercial marijuana activities was within Congress's power under the Commerce Clause and the Necessary and Proper Clause. The court found that Congress had a rational basis for concluding that intrastate marijuana activities substantially affect interstate commerce. Additionally, the court rejected the plaintiffs' substantive due process claim, holding that there is no fundamental right to cultivate, manufacture, possess, and distribute marijuana. The court emphasized that historical practices and recent state legislative trends do not establish such a fundamental right. View "Canna Provisions, Inc. v. Bondi" on Justia Law

Victor Soto-Sanchez was convicted of possession of a controlled substance with intent to distribute. He appealed his conviction and sentence, arguing that his Sixth Amendment right to confront witnesses was violated when a police officer testified about an informant's tip. He also challenged the application of a two-point enhancement for obstruction of justice in his sentencing.The United States District Court for the District of Maine allowed the police officer's testimony, overruling Soto-Sanchez's objections on Confrontation Clause and hearsay grounds. The court provided a limiting instruction to the jury, stating that the informant's statements were not to be considered for their truth but to explain the officer's investigative steps. The jury found Soto-Sanchez guilty, and the court applied the obstruction of justice enhancement based on Soto-Sanchez's alleged attempts to influence a witness.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed that Soto-Sanchez's Sixth Amendment rights were violated but deemed the error harmless due to overwhelming evidence against him, including physical evidence and witness testimony. The court also rejected Soto-Sanchez's sentencing challenge, concluding that he had waived his arguments regarding the obstruction of justice enhancement. Consequently, the First Circuit affirmed Soto-Sanchez's conviction and sentence. View "United States v. Soto-Sanchez" on Justia Law

In 2023, James Broad and Rebecca McCrensky began operating a car-rental agency, Becky's Broncos, LLC, on Nantucket Island without the necessary local approvals. The Town of Nantucket and the Nantucket Town Select Board ordered Becky's to cease operations. Becky's sought preliminary injunctive relief in the District of Massachusetts to continue their business.The District Court for the District of Massachusetts denied Becky's request for a preliminary injunction. The court found insufficient evidence of discriminatory effect under the dormant Commerce Clause and concluded that Becky's had not demonstrated a likelihood of success on the merits of its claims. Becky's appealed the decision.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's denial of the preliminary injunction. The appellate court held that Becky's did not show a likelihood of success on the merits of its dormant Commerce Clause claim, as the ordinance did not discriminate against out-of-state businesses. The court also found that Becky's failed to establish a likelihood of success on its antitrust claims due to a lack of a concrete theory of liability. Additionally, Becky's procedural due process argument was rejected because it did not establish a property interest in the required medallions. Lastly, the court held that the ordinance survived rational basis review under substantive due process, as it was rationally related to legitimate government interests in managing traffic and congestion on the island. View "Becky's Broncos, LLC v. Town of Nantucket" on Justia Law

Miya Water Projects Netherlands B.V. (Miya) filed a lawsuit under the Transparency and Expedited Procedure for Public Records Access Act (TEPPRA) against the Financial Oversight and Management Board for Puerto Rico (the Board). Miya sought access to public records related to a canceled water infrastructure project. The Board, established by Congress in 2016, refused to provide the requested documents, claiming TEPPRA did not apply to it. Miya then sued the Board in the United States District Court for the District of Puerto Rico.The district court dismissed Miya's case, ruling that the Board was protected by Eleventh Amendment immunity, which extends to Puerto Rico. The court applied the arm-of-the-state test and concluded that the Board, as an entity funded by the Commonwealth and with judgments paid by the Commonwealth, shared Puerto Rico's immunity. The court also determined that the Commonwealth did not waive this immunity through TEPPRA, as the statute did not meet the strict standards required to effect such a waiver under federal law.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court's decision de novo. The appellate court agreed with the lower court's findings, holding that Puerto Rico's Eleventh Amendment immunity extends to the Board and that the Commonwealth did not waive this immunity through TEPPRA. The court emphasized that a waiver of Eleventh Amendment immunity must be unequivocally expressed in the statute's text, which TEPPRA did not do. Consequently, the appellate court affirmed the district court's dismissal of Miya's claim for lack of subject matter jurisdiction. View "Miya Water Projects Netherlands B.V. v. Financial Oversight and Management Board" on Justia Law

In June 2022, Karen Read was indicted for murder in Massachusetts. She pled not guilty, and the trial in Norfolk County Superior Court ended in a mistrial due to a non-unanimous jury verdict. The case attracted significant public attention and demonstrators gathered near the courthouse. The demonstrators' behavior, including loud protests and displaying materials directed at trial participants, raised concerns about the fairness of the trial.The state court issued an order creating a 200-foot buffer zone around the courthouse to prevent demonstrations during the trial. This order was challenged in state court but upheld by the Massachusetts Supreme Judicial Court. Before the retrial, the Commonwealth sought a broader order, which the state court granted, expanding the buffer zone to include additional areas around the courthouse. This new order was based on evidence of disruptions during the first trial, including noise from demonstrators that could be heard by jurors.A group of demonstrators filed for a preliminary injunction in the District of Massachusetts to challenge the expanded buffer zone. The district court denied the motion, finding that the order was likely narrowly tailored to serve a significant governmental interest. The plaintiffs then appealed to the United States Court of Appeals for the First Circuit.The First Circuit noted that the plaintiffs clarified they did not challenge the order as applied to courthouse property or seek to engage in noisy protests. They only sought to demonstrate quietly on public property without interfering with trial participants. The court vacated the district court's denial of the preliminary injunction and remanded the case for further proceedings to determine if the order's lack of a mens rea requirement rendered it insufficiently tailored. The court suggested that the state court could amend the order to include a mens rea requirement to address the First Amendment concerns. View "Grant v. Trial Court of the Commonwealth of Massachusetts" on Justia Law