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

After a jury trial, the jury returned a conviction finding Defendant guilty of wire fraud and mail fraud. The district court upset the conviction and ordered a new trial, concluding that the government's closing argument was improper and may have tainted the jury's verdict. When the case was retried, the jury again convicted Defendant of the charges. The district court again granted a new trial, determining that the government's different closing argument led the jury to convict on an improper basis. The First Circuit Court of Appeals reversed and reinstated the jury's verdict of conviction, holding that the government's comments in its closing argument at the second trial were not improper. Remanded for sentencing. View "United States v. Carpenter" on Justia Law

After a jury trial, four former San Juan Municipal Police Department officers (Appellants) were convicted of several charges arising from the excessive use of force against a citizen who was beaten to death while in police custody. Appellants challenged their respective convictions and sentences on appeal. The First Circuit Court of Appeals affirmed the convictions and sentences, ultimately finding none of Appellants' arguments meritorious. Among the various arguments advanced by Appellants was that the district court erred when sentencing one Appellant by using the less favorable U.S. Sentencing Guidelines in effect on the date of sentencing rather than the Guidelines manual in effect at the time of the offense. The Court held that the "one book" rule of the Guidelines does not violate the Ex Post Facto Clause of the Constitution as applied to a series of grouped offenses such as Appellant's. View "US v. Pagan-Ferrer" on Justia Law

In 2011, the FBI obtained a criminal complaint and warrant for Appellant's arrest. Several criminal charges were brought against Appellant, including sending letters to public officials threatening murder. The warrant was based on the use of a 2005 DNA profile of Appellant, which resulted in no charges against Appellant, that was used during the 2011 investigation and found to be a match to the DNA recovered from the threatening letters sent in 2011. Appellant filed a motion to suppress the fruits of the use of his 2005 DNA profile in securing the 2011 warrant. The trial court denied the motion. Appellant conditionally pled guilty to the charges and then appealed, arguing that the method of obtaining his DNA violated the Fourth Amendment. The First Circuit Court of Appeals affirmed the district court's denial of Appellant's motion to suppress, holding (1) the method of obtaining Appellant's 2005 DNA sample violated the Fourth Amendment; but (2) application of the exclusionary rule in this case would be outweighed by the resulting costs to the criminal justice system. View "United States v. Thomas" on Justia Law

After a jury trial, Petitioner was convicted of first-degree murder in state court. Petitioner's conviction was upheld on appeal. Petitioner subsequently filed a petition for a writ of habeas corpus in the federal district court, asserting (1) the prosecutor improperly commented on his failure to testify in violation of the Fifth Amendment, and (2) he received ineffective assistance of counsel because his attorney inadvertently failed to produce certain medical records to the prosecution during discovery, which prevented counsel from questioning the defense's witness, a psychiatrist, about them at trial. The district court denied the petition. The First Circuit Court of Appeals affirmed, holding (1) any error on the part of the prosecution was harmless; and (2) the omission of the records was not prejudicial, and whether or not Appellant's trial counsel made a strategic choice to omit the evidence this was not an error so serious that Defendant was deprived of his Sixth Amendment right to counsel. View "Pena v. Dickhaut" on Justia Law

The City of Springfield enacted two local ordinances that imposed new legal duties on (1) property owners to maintain property during the foreclosure process and provide a $10,000 cash bond per foreclosure to the City, and (2) mortgagees to attempt a settlement through negotiations before foreclosing. In dispute was the definition of "owner" in the first ordinance, which included mortgagees who were not in possession and had begun the foreclosure process. The ordinance imposed the duties on the mortgagees whether the mortgagors were still in possession. Six banks sued in state court, seeking to have the ordinances invalidated as inconsistent with and preempted by comprehensive state laws governing foreclosure and property maintenance and as inconsistent with state and federal constitutional guarantees. The case was removed to federal district court, which concluded that the ordinances were valid. The banks appealed. The First Circuit Court of Appeals certified dispositive state law questions to the Massachusetts Supreme Judicial Court because the outcome of the case depended on unresolved questions of Massachusetts law and raised significant policy concerns better suited for resolution by that state court. View "Easthampton Savings Bank v. City of Springfield" on Justia Law

After a thirty-seven-day jury trial, Appellant was convicted of four terrorism-related counts and three counts premised on allegedly false statements and sentenced to a 210-month term of immurement. Defendant appealed, challenging, inter alia, his convictions on the four terrorism-related counts on the grounds that they were neither supported by the evidence nor constitutionally permissible. The First Circuit Court of Appeals affirmed, holding (1) the evidence was sufficient to convict Defendant on the four terrorism-related counts and on the false statement counts; (2) the trial court did not prejudicially err in its evidentiary rulings; (3) Defendant's convictions were constitutional; and (4) the district court did not err in sentencing Defendant. View "United States v. Mehanna" on Justia Law

Plaintiff filed suit against Kmart Corporation and Sears Holdings Corporation (collectively, Kmart), bringing a federal claim of racial discrimination under 42 U.S.C. 1981 and a pendent state law claim of negligent infliction of emotional distress. Plaintiff, an African-American woman, alleged that a white Kmart sales clerk insulted her with racial slurs and comments while she was placing items on hold in a layaway transaction. The district court dismissed the federal claim for failure to state a claim under section 1981 and dismissed without prejudice the state law claim. Plaintiff appealed the dismissal of her section 1981 claim. The First Circuit Court of Appeals affirmed, holding that Plaintiff failed to make out a section 1981 claim where her only allegation of harm she suffered was from the sales clerk's utterances, and nothing more. View "Hammond v. Kmart Corp." on Justia Law

Petitioner was convicted in Massachusetts Superior Court of first degree murder by reason of extreme atrocity or cruelty. Defendant filed a motion for a new trial, alleging ineffective assistance of counsel, and requested an evidentiary hearing on his claim. The superior court denied the motion for a new trial without holding an evidentiary hearing. The Massachusetts Supreme Judicial Court affirmed. Petitioner subsequently field a petition for writ of habeas corpus in the U.S. district court, reiterating his ineffective assistance claims and arguing that that Massachusetts court's denial of his request for an evidentiary hearing on these claims violated his due process rights. The district court dismissed the petition, concluding that the state court record was sufficient to resolve the case. The First Circuit Court of Appeals affirmed because Petitioner's claim was adjudicated on the merits by the Supreme Judicial Court, and Petitioner failed to raise a substantial issue that might require an evidentiary hearing. View "Garuti v. Roden" on Justia Law

On August 6, Appellant was arrested in Maine and charged by the State for firearm-related crimes. On August 26, the United States ("government") charged Appellant with possession of a firearm by a convicted felon. On August 29, the State dismissed the related State charges. Appellant remained incarcerated by the State for the next month despite the fact the State had dismissed all charges against him. Finally, on October 3, Appellant was arrested by U.S. Marshals and brought before a federal judge. On October 26, a federal grand jury returned an indictment charging Appellant, and Appellant waived his right to contest the government's motion to detain him pending trial. Appellant subsequently filed a motion to dismiss the federal indictment on speedy-trial grounds. The district court denied the motion. The First Circuit Court of Appeals affirmed, holding (1) because Appellant did not enter federal custody until October 3, his October 26 indictment occurred within thirty days of his arrest on federal charges and, therefore, did not violate the Speedy Trial Act; and (2) the district court did not err by failing to impose sanctions against the government for its purported failure to notify Appellant that it had lodged a federal detainer against him. View "United States v. Lewis" on Justia Law

Mother, an Egyptian citizen, acted in violation of a court order when she, together with her two children, boarded an EgyptAir Airlines Company flight to Cairo, Egypt. The father of the children and Mother's former husband (Father) brought this lawsuit against Mother and EgyptAir. Father claimed EgyptAir was negligent in allowing Mother to board the flight despite "red flags" suggesting she was abducting the children. The district court granted summary judgment for EgyptAir, concluding that the airline did not know of Mother's plan to abduct the children and did not owe Defendant or the children a duty to investigate the red flags. The First Circuit Court of Appeals affirmed the dismissal of Father's claims, holding (1) the district court had jurisdiction over the claims; and (2) the claims, which challenged airline ticketing, check-in, and boarding procedures, were preempted under the Airline Deregulation Act. View "Bower v. El-Nady Bower" on Justia Law