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

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

After a jury trial, Defendant was convicted of thirty-three counts of wire fraud and five counts of money laundering arising from his role in a mortgage fraud scheme. The district court imposed a below-Guidelines sentence of seventy-two months’ incarceration and ordered restitution of nearly $2.2 million. The First Circuit affirmed Defendant’s conviction and sentence, except that it vacated in part the restitution order, holding (1) the evidence was sufficient to support the convictions as to twenty-eight of the wire fraud counts and all of the money laundering counts; (2) the district court did not abuse its discretion as to three of its adverse evidentiary rulings; (3) the prosecutor did not commit misconduct in his closing argument; (4) Defendant’s seventy-two month sentence was both procedurally and substantively reasonable; and (5) the district court erred in calculating restitution. Remanded. View "United States v. Foley" on Justia Law

This appeal was the third time the First Circuit opined on United States’ prosecution of Defendant for mail and wire fraud. The Court first affirmed a district court order setting aside a jury verdict of guilty in favor of a new trial. After a second jury also found Defendant guilty, the Court reversed a district court order setting aside that verdict and remanded for sentencing. Here, the Court considered Defendant’s argument on direct appeal that the lengthy duration of this criminal proceeding violated his constitutional and statutory speedy trial rights. The First Circuit affirmed the orders of the district court on all counts, holding (1) Defendant’s Sixth Amendment rights were not violated; (2) the government did not violate the Speedy Trial Act in this case; (3) the district court did not err when it denied Defendant’s motion for acquittal or motion for a new trial based on newly discovered evidence; and (4) the district court did not abuse its discretion in sentencing Defendant. View "United States v. Carpenter" on Justia Law

The American Freedom Defense Initiative (AFDI) asked the Massachusetts Bay Transportation Authority (MBTA) to display a pair of paid, private advertisements on the trains, buses, and transit stations that the MBTA operates. The MBTA refused to display the advertisements, which concerned the Israeli-Palestinian conflict, concluding that AFDI’s submissions violated one of its Guidelines, namely, the prohibition on advertisements containing material that “demeans or disparages” individuals or groups. AFDI brought suit in federal court alleging a violation of the First Amendment and seeking a preliminary injunction ordering the MBTA to run the ads. The district court denied relief. The two cases were consolidated on appeal. The First Circuit affirmed, holding that the MBTA’s restriction on the display of advertisements that “demean or disparage” does not violate the First Amendment, either on its face or as applied. View "Am. Freedom Defense Initiative v. Mass. Bay Transp. Auth." on Justia Law

After a jury trial, Defendant, a member of a prominent political family allegedly involved in the Rwandan genocide, was convicted of two counts of procuring citizenship illegally by making false statements to the government. Specifically, the jury found that Defendant misrepresented her political affiliations and her participation in the genocide. The First Circuit affirmed Defendant’s convictions and sentence, holding (1) the evidence was sufficient to support the convictions; (2) any error in the court’s evidentiary rulings was harmless given the vast array of evidence against Defendant; (3) the trial court did not err in denying Defendant’s motion for a mistrial based on prosecutorial misconduct; and (4) Defendant’s 120-month sentence was reasonable. View "United States v. Munyenyezi" on Justia Law

Defendant confessed to robbing a federal credit union and was convicted for this crime. Prior to trial, Defendant twice moved to suppress his confession, arguing that it was coerced in violation of his Fifth Amendment rights. Specifically, Defendant argued that where his girlfriend was also in police custody for the robbery at the time of his interrogation and a significant portion of his interview dealt with the impact that his cooperation would have on her prospects for release, the officers’ references to his girlfriend during the interrogation overpowered his will. The district court denied the motions. The First Circuit affirmed, holding that, under the circumstances of this case, the officers did not act permissibly and that Defendant voluntarily chose to confess. View "United States v. Hufstetler" on Justia Law

Upon Defendant’s return from Puerto Rico from Colombia by airplane, heroin was discovered in hidden compartments of Defendant’s laptop computer and Sony Playstation game console. Defendant was indicted for possession with intent to distribute one kilogram or more of heroin. Defendant moved to suppress the heroin and any statements he made to United States Customs and Border Protection officers during further secondary questioning. The motion was denied. Defendant entered a conditional plea and then appealed the denial of his motion to suppress. The First Circuit held (1) the district court did not err in denying Defendant’s motion to suppress the heroin and statements made as to his travels to and from Colombia and his plans upon reentry; but (2) the statements Defendant made regarding his drug trafficking activity should have been suppressed because the officers’ failure to give Defendant his Miranda warnings constituted a Fifth Amendment violation. Remanded so that Defendant could opt to withdraw his plea and proceed to trial should he choose to do so. View "United States v. Molina-Gomez" on Justia Law