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

In 2011, in order to combat the use of anonymous prepaid cell phone for criminal purposes, the Puerto Rico Governor signed into law the Registry Act, which requires telephone companies and other sellers of prepaid phones to provide information about the purchasers of the phones to the government of Puerto Rico, which then compiles a registry with the names, numbers, and addresses of the purchasers. Plaintiff, a non-profit corporation that represents the interests of the wireless communications industry, sought declaratory and injunctive relief, arguing that the Registry Act was preempted by the federal Stored Communications Act (SCA) because the SCA prohibits Plaintiff’s members from turning over to the government without a subpoena the information required by the Registry Act. The district court granted Plaintiff’s motion for a permanent injunction. The First Circuit Court of Appeals affirmed, holding that the Registry Act is preempted by the SCA, and its enforcement should be enjoined. View "CTIA - The Wireless Assoc. v. P.R. Telecomms. Regulatory Bd." on Justia Law

Plaintiffs in this case were former officers and a former cadet of the Boston Police Department (Department) who were fired after testing positive for cocaine, a current officer who tested positive and underwent rehabilitation as an alternative to termination, and a former applicant whose contingent job offer was revoked after a positive test. Each Plaintiff was black. Plaintiffs filed suit against the Department, alleging, inter alia, that the Department’s drug testing program, which used hair samples to test for illegal drug use, caused a disparate impact on the basis of race in violation of Title VII of the Civil Rights Act. The district court granted summary judgment to the Department on all claims. The First Circuit Court of Appeals (1) vacated the grant of summary judgment as to Plaintiffs’ Title VII claim and reversed the district court’s denial of Plaintiffs’ motion for partial summary judgment on the question of whether they had proved a prima facie case of disparate impact under Title VII, holding that Plaintiffs proved beyond reasonable dispute a prima facie case of disparate impact under Title VII; and (2) otherwise affirmed. View "Jones v. City of Boston" on Justia Law

Defendant was indicted with one count of cyberstalking in violation of 18 U.S.C. 2261A. Pursuant to a plea agreement, Defendant entered a conditional plea of guilty to the cyberstalking charge. Defendant was sentenced to a term of sixty months’ imprisonment, the statutory maximum. On appeal, Defendant challenged the district court’s denial of his motion to dismiss the cyberstalking charge in the indictment and argued that his sentence above the Guidelines range was unreasonable. The First Circuit Court of Appeals affirmed, holding (1) section 2261A was constitutionally applied to Defendant and is not overbroad; and (2) the district court’s decision to vary upward rather than depart downward was not an abuse of discretion. View "United States v. Sayer" on Justia Law

In 2000, Plaintiff, a former scallop fisherman, was prosecuted by an enforcement arm of the National Oceanic and Atmospheric Administration (“NOAA”). The ALJ sustained all charges against Plaintiff. The district court sustained findings of liability on two charges of fishing in a prohibited area, vacated a false statement charge against Plaintiff, and remanded. On remand, Plaintiff reached a settlement with the government. In 2012, Plaintiff filed a complaint alleging that his prior prosecution by the NOAA constituted malicious prosecution and abuse of process under the Federal Tort Claims Act (“FTCA”). The district court dismissed Plaintiff’s claims. The First Circuit Court of Appeals affirmed, holding (1) the actions of federal prosecutors are immune from this type of suit under the FTCA, but there can be FTCA recovery for the actions of investigative or law enforcement officers who have committed the wrongful acts specified; and (2) Plaintiff failed to state a claim that any law enforcement officer wrongfully induced a malicious prosecution or acted to abuse process. View "Yacubian v. United States" on Justia Law

Brothers Angel Ayala-Vazquez (“Alaya”) and Luis Cruz-Vazquez (“Cruz”) (collectively, “Appellants”) were arrested and indicted following a federal investigation into a wide-ranging drug trafficking organization (“DTO”) based out of two housing projects in Bayamon, Puerto Rico. Unlike dozens of other defendants who entered guilty pleas, Appellants stood trial together. Appellants were both convicted of multiple criminal charges related to their involvement in the DTO, and each Appellant was sentenced to life imprisonment. The First Circuit Court of Appeals affirmed the convictions and Cruz’s life sentence, holding (1) the evidence introduced at trial was sufficient to support the jury verdicts; (2) the trial judge’s comments at trial did not deprive Appellants of a fair trial; and (3) the district judge did not abuse his discretion in sentencing Cruz to life imprisonment, and Cruz failed to overcome the sentence’s presumption of reasonableness. View "United States v. Ayala-Vazquez" on Justia Law

Plaintiff was fifty-five years old when he was hired to work as an assistant manager at Walgreens. In 2011, Walgreens terminated Plaintiff’s employment after Plaintiff failed to provide what Walgreens considered to be adequate customer service. Plaintiff filed suit in federal court, alleging that his employment was terminated because of his age, in violation of the Age Discrimination in Employment Act and Mass. Gen. Laws ch. 151B, 4(1B). The district court granted summary judgment for Walgreens. The First Circuit Court of Appeals affirmed, holding that Plaintiff (1) did not raise any genuine issue as to whether Walgreens believed the truth of its stated reason for terminating him; (2) did not demonstrate pretext through a showing that Walgreens violated its policy to uniformly enforce the rules; and (3) did not demonstrate that Walgreens’ proffered reason for terminating him was pretext designed to disguise age discrimination. View "Adamson v. Walgreen Co." on Justia Law

In 1997, in response to Congress’s enactment of the Personal Responsibility and Work Opportunity Reconciliation Act, which narrowed the eligibility of non-citizens for Medicaid and other federal benefits, the state of Maine extended state-funded medical assistance benefits to certain legal aliens rendered ineligible for Medicaid. In 2011, the Maine Legislature terminated these benefits. Appellants moved for a preliminary injunction against enforcement of the 2011 legislation, alleging that the state violated their equal protection rights by providing state-funded medical assistance benefits to United States citizens while denying those benefits to similarly situated non-citizens due solely to their alienage. The district court denied Appellants’ motion for a preliminary injunction. The First Circuit Court of Appeals affirmed the district court’s denial of a preliminary injunction, holding that Appellants’ equal protection claim failed on the merits because the state of Maine was not obligated to extend equivalent state-funded benefits to Appellants in the first place, and therefore, the termination of those benefits did not violate the Equal Protection Clause. View "Bruns v. Mayhew" on Justia Law

Defendant was charged with structuring financial transactions to evade reporting requirements in violation of 31 U.S.C. 5324(a)(3). After a trial, Defendant was convicted and sentenced. The First Circuit Court of Appeals affirmed Defendant’s conviction and sentence, holding (1) Defendant was not denied his right to a speedy trial under the Speedy Trial Act and the Sixth Amendment; (2) Defendant’s claim that his counsel provided ineffective assistance required further factual development; (3) consistent with due process, Defendant could be convicted of structuring his transactions in a way that demonstrated his intent to evade the reporting requirements, even though he actually failed to evade them; and (4) the district court did not err in its evidentiary rulings, and the court’s sentencing guidelines calculation was not erroneous. View "United States v. Souza" on Justia Law

Defendant was indicted for aiding and abetting in the possession of a firearm with an obliterated serial number. Defendant filed a motion to suppress a series of inculpatory statements. Specifically, Defendant sought to suppress (1) a statement he made to his arresting officer, arguing that he was questioned while in formal custody but prior to being given Miranda warnings, and (2) all statements he made during his formal interrogation, arguing that the questioning resumed impermissibly soon after his initial refusal to make a statement and continued after his unambiguous request for counsel. The district court denied the motion to suppress. The First Circuit Court of Appeals affirmed, holding (1) Defendant waived his argument for suppression of the statement he made to his arresting officer; and (2) there was no violation of Defendant’s right to remain silent during his formal interrogation, and Defendant did not invoke his right to counsel in a manner sufficiently unambiguous and direct as to require the cessation of questioning. View "United States v. Oquendo-Rivas" on Justia Law

In 2002, Appellant was convicted in Massachusetts state court on charges of forcibly raping his nephew, J.B., and J.B.’s friend when both boys were fifteen years old. Appellant appealed his conviction, arguing that his attorney provided ineffective assistance by failing to seek to have admitted evidence that Appellant’s sister had accused J.B. of sexually assaulting three of Appellant’s nieces. The Massachusetts appeals court affirmed. Appellant later filed a petition for habeas corpus in federal district court, arguing that he received ineffective assistance of counsel in his state court trial. The district court denied relief. The First Circuit Court of Appeals affirmed, holding that the Massachusetts appeals court reasonably applied federal law in rejecting Appellant’s claim of ineffective assistance of counsel. View "Collins v. Roden" on Justia Law