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

Defendant pleaded guilty to two counts of drug-trafficking and one count of money laundering. Defendant was sentenced to a 168-month term of imprisonment, a sentence that was at the bottom of his Guidelines imprisonment range. The First Circuit affirmed, holding (1) the district court did not violate Defendant’s due process rights where it allowed Defendant to present evidence of his alleged minor role in the crimes, allowed Defendant to testify regarding the alleged coercion he felt from his co-defendants, and cross-examined Defendant as to whether he faced retaliation after he left the conspiracy; (2) Defendant was not entitled to a minor role adjustment; (3) the district court did not err by declining to award a downward departure for coercion and duress; and (4) Defendant’s sentence was reasonable. View "United States v. Torres-Landrua" on Justia Law

After a jury trial in a Massachusetts state court, Petitioner was found guilty of operating a motor vehicle under the influence of alcohol, third offense, and negligent operation of a motor vehicle. Petitioner appealed, asserting that the prosecutor’s comments during cross-examination and closing argument constituted unconstitutionally forbidden commentary on his post-Miranda silence. The Massachusetts Appeals Court (MAC) affirmed, and the Supreme Judicial Court summarily denied Petitioner’s application for further appellate review. Thereafter, Petitioner sought habeas relief in the federal district court, arguing that the MAC’s decision was contrary to or an unreasonable application of clearly established federal law because the prosecutor’s questions and comments on his post-Miranda silence contravened Doyle v. Ohio and, therefore, abridged his due process rights. The district court denied habeas relief. The First Circuit affirmed, holding that even if the MAC misapplied the Doyle rule and a Doyle error occurred, any comment on Petitioner’s silence was harmless when considered in the context of the trial as a whole. View "Cronin v. Comm’r of Probation" on Justia Law

Plaintiff was a life insurance agent with the New Life Insurance Company for more than forty years. In 2009, Plaintiff was informed that his agent contract would be terminated. In 2012 and 2014, Plaintiff filed two separate suits against New York Life, alleging, in addition to several common-law claims, age discrimination under both Massachusetts law and the federal Age Discrimination in Employment Act. The U.S. District Court of the District of Massachusetts consolidated the two cases. The district court then granted summary judgment for New York Life on all claims. The First Circuit affirmed, holding (1) Plaintiff’s state law age discrimination claims were time barred; (2) no reasonable jury could conclude that New York Life engaged in age discrimination under federal law in terminating his agent contract; and (3) no reasonable jury could conclude that the termination breached Plaintiff’s contract with New York Life or violated any of Plaintiff’s common law rights. View "Santangelo v. New York Life Ins. Co." on Justia Law

When the government of Puerto Rico changed hands after the November 2012 General Elections, the government passed laws to “reorganize” different agencies. One of those laws was Law 180-2013, which made the position of the Chair of the Puerto Rico Industrial Commission (PRIC) freely removable. The Governor subsequently removed Plaintiff, the then-Chair, and appointed a replacement. Plaintiff brought suit against the Governor and the new PRIC Chair, alleging violations of his First, Fifth, and Fourteenth Amendment constitutional rights and violations of Puerto Rico constitutional and statutory law. The district court found that Plaintiff was likely to succeed on his due process claim and issued a preliminary injunction that vacated the appointment of his replacement and reinstated Plaintiff. The First Circuit remanded with instructions to vacate the preliminary injunction and to dismiss without prejudice Plaintiff’s due process claim, holding that Plaintiff was not entitled to federal injunctive relief for his due process claim given the conceded adequacy of Commonwealth remedies. View "Torres-Rivera v. Lozada-Crespo" on Justia Law

In 2012, Defendant pleaded guilty to one count of failing to register as a sex offender. Defendant was sentenced to twenty-one months in prison and seven years of supervised release. The terms of Defendant’s supervised release included a series of special conditions prohibiting him from contact with minors and requiring him to undergo sex offender treatment. Defendant sought to vacate his conviction or, alternatively, the special conditions. The First Circuit affirmed in part and reversed in part, holding (1) a waiver of appeal barred Defendant’s appeal of his conviction as well as his appeal of most of the special conditions; but (2) in order to avoid a miscarriage of justice, the Court declined to enforce the waiver as to Defendant’s appeal of the conditions that would prevent him from having contact with or residing with his son or other minors, as these conditions would deprive Defendant of far more liberty than was reasonably necessary. Remanded. View "United States v. Del Valle-Cruz" on Justia Law

Appellant, an inmate at the Bristol House of Correction, filed this action pursuant to 42 U.S.C. 1983 against Appellees, both of whom were staff nurses at the correctional institution, alleging that the medical treatment he received from Appellees for injuries resulting from a fight with several correctional officers violated his Eighth and Fourteenth Amendment rights because Appellees exhibited “deliberate indifference” to his serious medical needs. The district court granted summary judgment in favor of Appellees and dismissed the section 1983 action. The First Circuit reversed and remanded, holding that this case presented triable issues of fact to be resolved by fact-finders. View "Perry v. Roy" on Justia Law

Plaintiffs, current and previous employees of the Puerto Rico State Insurance Fund Corporation (SIFC), filed two similar lawsuits alleging that Defendants, the SIFC and its administrators, selectively enforced Puerto Rico’s merit principle against them in violation of the Equal Protection Clause. The district courts granted summary judgment to Defendants, concluding that Plaintiffs failed to identify similarly situated individuals treated differently by Defendants. The First Circuit affirmed on the same basis, holding that Plaintiffs’ Equal Protection claims failed as a matter of law because Plaintiffs failed to identify employees of a similar category that were similarly situated but who were treated differently by Defendants. View "Aponte-Ramos v. Alvarez-Rubio" on Justia Law

In 2008, the government returned an indictment charging Appellees and sixteen others with drug-related crimes. After a jury trial, Appellees, along with one other defendant, were found guilty of conspiracy to distribute and possess with intent to distribute cocaine and marijuana. The evidence presented at trial established at least two conspiracies. The First Circuit vacated Appellees’ convictions, holding (1) there was insufficient evidence to support Appellees’ convictions on the first conspiracy, but (2) there was arguably sufficient evidence to convict Appellees on the other conspiracy, an uncharged conspiracy to distribute only cocaine. The Court vacated the convictions due to a material variance between the second conspiracy and the single overarching conspiracy charged in the indictment. The district court entered a judgment of acquittal. Subsequently, the government obtained a new indictment charging Appellees with conspiracy to distribute and possess with intent to distribute cocaine. The district court dismissed the indictment on double jeopardy grounds. The government appealed, arguing that the current indictment alleged a factually distinct and separate conspiracy from the earlier indictment and conviction. The First Circuit reversed, holding that the government’s decision to bring the current indictment charging Appellees with the second conspiracy was not barred by the Double Jeopardy Clause. View "United States v. Szpyt" on Justia Law

After the government of Puerto Rico changed hands in 2012, the legislature enacted a law repealing Reorganization Plan No. 1-2011 and abolished four positions that the Plan had created. The legislature also enacted other laws creating new positions that were substantially similar to the abolished positions. Several of the displaced former officials brought suit in federal court. This interlocutory appeal was from one of those suits. Plaintiff brought federal 42 U.S.C. 1983 claims, as well as Commonwealth law claims. The district granted a preliminary injunction on due process grounds that reinstated Plaintiff and vacated the political appointment of his replacement. The Puerto Rico Supreme Court subsequently issued its opinion in the nearly identical case of Diaz-Carrassquillo v. Garcia-Padilla, which confirmed the availability of relief in Commonwealth court. The First Circuit remanded with instructions to vacate the preliminary injunction, holding that, in light of the relief now available in Puerto Rico courts under Diaz-Carrasquillo and the importance of this case to the Commonwealth’s constitutional balance of powers, the rule that “no injunction ought to issue against officers of a State” except under certain circumstances applied here. View "Allman v. Garcia-Padilla" on Justia Law

After a jury trial, Defendant was convicted of one count of conspiracy to commit a drug trafficking offense and three counts of criminal use of a communications facility to facilitate a trafficking offense. Defendant was sentenced to 300 months of imprisonment. The First Circuit affirmed, holding (1) Defendant’s challenge to his conspiracy conviction and sentence under the Confrontation Clause failed; (2) none of Defendant’s challenges to his sentence had merit; and (3) neither Defendant’s challenge to the admission of certain recorded phone calls during trial use at trial, nor his contention that Maine was not a proper venue for the trial, was persuasive. View "United States v. Razo" on Justia Law