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

Defendant entered a conditional plea of guilty to being a felon in possession of two firearms, reserving the right to appeal the denial of his motion to suppress. The district court subsequently sentenced Defendant as an armed career criminal to fifteen years imprisonment. The First Circuit affirmed, holding (1) district court correctly refused to suppress two statements Defendant made regarding the presence of firearms inside his residence based on alleged Miranda violations; and (2) the district court did not err in labeling Defendant an armed career criminal subject to an enhanced sentence under the Armed Career Criminal Act. View "United States v. Davis" on Justia Law

After a jury trial, Defendant was convicted on federal criminal charges of conspiracy and attempt to affect commerce by robbery, among other charges. The First Circuit vacated Defendant’s sentence and remanded for resentencing. After the district court resentenced Defendant, Defendant filed a motion in Massachusetts state court for a new trial on a prior state conviction that had been relied upon to increase his federal sentence. The state court vacated Defendant’s prior conviction. Defendant filed a petition and an amended petition for writ of habeas corpus arguing that he received ineffective assistance of counsel in his federal trial and that the vacatur of his prior state court conviction entitled him to resentencing. The district court denied the petition. The district court affirmed, holding (1) there was not a reasonable probability that the perceived shortcomings of Defendant’s counsel affected the result in this case; and (2) the district court did not err in concluding that Defendant’s petition for resentencing was untimely. View "Rossetti v. United States" on Justia Law

This long-running dispute over Puerto Rico’s dairy industry resulted in the principal parties settling. Pursuant to the settlement, the Department of Agriculture for the Commonwealth of Puerto Rico and others (collectively, the "Department") agreed to promulgate a regulation that would significantly rework the pricing and structure of the dairy market. Intervenors Industria Lechera de Puerto Rico, Inc. ("Indulac") and the Puerto Rico Dairy Farmers Association, who were excluded from the bargaining table, objected to the settlement, alleging that the regulation violated Puerto Rico’s constitutional and statutory law. The district court approved the settlement agreement. Indulac appealed. The First Circuit dismissed the appeal, holding that it lacked appellate jurisdiction to hear Indulac’s appeal because it was untimely. View "Vaqueria Tres Monjitas, Inc. v. Industria Lechera de P.R., Inc." on Justia Law

In Puerto Rico, the Controlled Access Law (CAL) allows private citizens to protect themselves against violent crimes by maintaining gated residential communities that incorporate public streets. In 2004, two corporations operated by the governing body of the Jehovah’s Witnesses brought suit against municipal defendants alleging that the CAL unconstitutionally infringed on the Jehovah’s Witnesses’ right to engage in door-to-door ministry. The district court established a remedial scheme that attempted to balance the competing interests of the parties. Both the Jehovah’s Witnesses and the municipalities appealed. The First Circuit upheld the district court’s solution but modified it in some aspects, holding that the district court did not abuse its discretion in crafting the remedy at issue. View "Watchtower Bible & Tract Soc’y of N.Y., Inc. v. Colombani" on Justia Law

For more than twenty years, the Maine Department of Health and Human Services (DHHS) provided Medicaid coverage for nineteen- and twenty-year-old children whose families met low-income requirements. In 2012, Maine DHHS submitted a state plan amendment to the federal DHHS plan seeking to drop that coverage. The federal DHHS Secretary declined to approve the amendment because it did not comply with 42 U.S.C. 1396a(gg), which requires states accepting Medicaid funds to maintain their Medicaid eligibility standards for children until October 1, 2019. Maine DHHS petitioned for review, contending that the statute is unconstitutional under the Spending Clause and violates the doctrine of equal sovereignty as articulated in Shelby County v. Holder. The First Circuit affirmed, holding that the statute is constitutional as applied in this case, as (1) application of section 1396a(gg) in these circumstances does not exceed Congress’s power under the Spending Clause; and (2) the equal sovereignty doctrine of Shelby County is not applicable in this case, and any disparate treatment caused by section 1396a(gg) is sufficiently related to the problem the statute was designed to address. View "Mayhew v. Burwell" on Justia Law

Following a jury trial, Defendant was convicted of possession with intent to distribute both marijuana and cocaine. Defendant appealed, arguing, among other things, that the district court erred in denying his motion to suppress evidence seized by law enforcement personnel after observing him walking down a residential street at first empty-handed and then rolling a large black suitcase. The First Circuit affirmed, holding (1) the district court properly denied Defendant’s motion to suppress because the stop by law enforcement was permissible, as was the subsequent search of the suitcase; and (2) the evidence was sufficient to support the conviction; (3) the district court’s jury instructions regarding the consideration of expert testimony were not plainly erroneous; and (4) the district court did not err in imposing sentence enhancements and and did not improperly penalize Defendant for failing to admit that he knew what was in the suitcase. View "United States v. Fermin" on Justia Law

After a jury trial, Defendant was convicted of conspiracy to distribute cocaine and heroin and possession with intent to distribute cocaine. Upon Defendant’s third sentencing, the district court found Defendant responsible for in excess of 150 kilograms of cocaine and resentenced him under 21 U.S.C. 841(b)(1)(A) to 280 months of imprisonment as to each count, to be served concurrently. Defendant appealed, arguing that the district court erred under Alleyne v. United States by applying a mandatory minimum sentence without the requisite drug quantity findings by the jury. The First Circuit affirmed Defendant’s convictions, vacated his sentence, and remanded for a fourth sentencing, holding that the district court (1) committed instructional Alleyne errors by failing to charge the jury on the essential element of individualized drug quantity for the conspiracy count and the essential element of drug quantity for the possession count before applying the section 841(b)(1)(A) statutory sentencing range that included a mandatory minimum sentence on each count, but the errors were harmless; and (2) overlooked the First Circuit’s prior remand order by refusing to conduct credibility assessments when calculating individualized drug quantity and by refusing to consider Defendant’s firearm enhancement arguments. View "United States v. Pizarro" on Justia Law

Defendant, a Canadian company, contracted with Plaintiff, a Massachusetts investment bank, to be its exclusive financial advisor for the sale of its business. The parties negotiated and executed the agreement from their respective home offices, contacting each other by phone, e-mail, and internet. Plaintiff later sued in Massachusetts Superior Court alleging breach of contract, among other claims. Defendant removed the case to federal district court. The district court subsequently dismissed the case, concluding that it could not exercise personal jurisdiction over Defendant consistently with the Due Process Clause. The First Circuit reversed, holding that, in light of the nature, number, origin, and duration of the parties’ contacts in this case, the exercise of long-arm jurisdiction by Massachusetts was consistent with fair play and substantial justice. View "C.W. Downer & Co. v. Bioriginal Food & Sci. Corp." on Justia Law

An initial criminal complaint issued against Defendant on August 6, 2010 charging him with a drug-related offense. Over the next fourteen months, the government brought four superseding indictments against him. Five days before jury empanelment was set to begin, Defendant moved to dismiss the fourth superseding indictment, asserting impermissible trial delay. The government conceded a breach of 18 U.S.C. 3161(c)(1), which requires a criminal defendant to be brought to trial within seventy days of the filing of an indictment. The district court determined that the appropriate remedy for exceeding the statutory time limit was a dismissal of the fourth superseding indictment without prejudice and that Defendant’s Sixth Amendment right to a speedy trial had not been violated. Defendant was subsequently convicted. The First Circuit affirmed Defendant’s convictions, holding that the district court (1) properly decided that dismissal without prejudice was the appropriate remedy for the Speedy Trial Act violation; and (2) properly concluded that Defendant had not been deprived of his Sixth Amendment right to a speedy trial. View "United States v. Worthy" on Justia Law

After a jury trial, Appellant was convicted of possessing cocaine base with intent to distribute. The First Circuit affirmed the conviction, holding (1) the district court did not err by declining to grant Appellant’s motion to suppress cocaine found in the trunk of a vehicle in which Appellant was a passenger; (2) the district court did not abuse its discretion by not allowing the attorneys of the driver of the vehicle to testify about her statements claiming responsibility for the drugs; and (3) the district court did not abuse its discretion by not declaring a mistrial based on certain statements made at trial. View "United States v. Awer" on Justia Law