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

The parties in this case were a group of chess players and their opponent, the Puerto Rico Chess Federation. The chess players filed suit against the chess federation in Puerto Rico court, alleging violations of their rights under the United States and Puerto Rico constitutions and Puerto Rico law. The chess federation successfully removed the case to federal court. The chess players subsequently filed a second case, again in Puerto Rico court, excluding any claims under federal law. The federation also removed this case. The district court consolidated the two cases and declared jurisdiction over the second case under the All Writs Act. Ultimately, the district court granted summary judgment in favor of the federation on all claims. The First Circuit Court of Appeals affirmed in part and reversed in part, holding (1) the district court had federal subject matter jurisdiction over the first case but did not have subject matter jurisdiction over the second case; and (2) the district court incorrectly granted summary judgment to the federal on some of the chess players' Commonwealth law claims. View "Ortiz-Bonilla v. Federacion de Ajedrez de P.R., Inc." on Justia Law

After a jury trial, Defendant, a corrections officer, was convicted of drug and weapons charges for providing security for a drug transaction orchestrated by the FBI as part of a sting operation. The First Circuit Court of Appeals affirmed subject to a limited remand, holding (1) the district court did not err in refusing to instruct the jury on entrapment, as the evidence was insufficient to raise a jury issue of entrapment; and (2) the sentence imposed by the district court was procedurally sound and substantively reasonable. Remanded for correction of a reference in the written judgment that caused no prejudice to Defendant. View "United States v. Diaz-Maldonado" on Justia Law

Defendants, Jimmy Carrasquillo-Rodriguez (Carrasquillo) and Jesus Pabellon Rodriguez (Pabellon), were convicted on drug and gun charges arising from a reverse sting operation set up by Drug Enforcement Administration (DEA) agents seeking to reduce the flow of illegal narcotics from the Dominican Republic to Puerto Rico. With one exception, the First Circuit Court of Appeals affirmed both Defendants' convictions and Carrasquillo's sentence, holding (1) Carrasquillo's conviction for possession of a firearm with an obliterated serial number was not supported by sufficient evidence; (2) the evidence was sufficient to sustain the remaining convictions challenged by Defendants; (3) the language in the verdict form did not constitute plain error sufficient to warrant a new trial; (4) the district court did not plainly err in its instructions to the jury; and (5) the district court did not err in sentencing Carrasquillo. View "United States v. Pabellon-Rodriguez" on Justia Law

Puerto Rico law operated to cause hundreds of thousands of motor vehicle owners to pay twice for liability insurance. Commonwealth law declared motor vehicle owners to be entitled to a refund of the excess premiums paid, but large amounts of unclaimed refunds accumulated. The Commonwealth subsequently placed the unclaimed refunds with its Treasury Secretary with the condition that, if not claimed within five years, the funds escheated to the Commonwealth without notice to the vehicle owners. In Garcia-Rubiera II, the First Circuit Court of Appeals held that the Commonwealth's failure to notify vehicle owners of their reimbursement rights violated their procedural due process rights. On remand, the district court ordered the Commonwealth to notify vehicle owners of their reimbursement rights, to publish notices in two newspapers alerting the owners of their rights, and to give owners a 120-day grace period for them to claim reimbursement. The First Circuit again remanded for the district court to craft with "the benefit of further guidance" an injunction that more fittingly remedied the Commonwealth's constitutional violations and ordered no duplicate premiums to escheat to the Commonwealth until it established and complied with a reimbursement procedure meeting the requirements of due process. View "Garcia-Rubiera v. Fortuno" on Justia Law

Defendant pleaded guilty to conspiring to possess with intent to distribute heroin, possessing with the intent to distribute heroin, conspiring to import heroin, and importing heroin into the United States. Defendant was sentenced to twenty-four months' imprisonment and two years of supervised release. Defendant appealed, arguing that her sentence was procedurally and substantively flawed. The First Circuit Court of Appeals affirmed, holding that the district court (1) did not err in denying Defendant's request for a continuance of the sentencing hearing; (2) did not abuse its discretion in choosing to impose a term of imprisonment; and (3) afforded Defendant an adequate opportunity to allocute. View "United States v. Pacheco" on Justia Law

A New Hampshire court issued a warrant to search Defendant's home after a state trooper submitted a supporting affidavit detailing the trooper's suspicion that Defendant's home contained a marijuana grow operation. Based on the items seized from Defendant's home, Defendant was charged with manufacturing marijuana, possessing marijuana with the intent to distribute, and possessing a firearm in furtherance of a drug trafficking crime. Defendant moved to suppress the evidence, arguing that the search warrant lacked probable cause. The district court suppressed the evidence, finding that the trooper recklessly omitted from his affidavit information material to a probable cause determination. The First Circuit Court of Appeals affirmed, holding that the search warrant at issue contained reckless material omissions, and the omitted information, when included back into the affidavit, failed to establish probable cause. View "United States v. Gifford" on Justia Law

Plaintiff, a Massachusetts corporation engaged in international asset recovery operations, filed a complaint against Defendants, the Republic of Ukraine and some of its agents and instrumentalities, for, inter alia, breach of contract after Plaintiff performed asset recovery work for which Defendants allegedly did not compensate Plaintiff. Defendants filed a motion to dismiss on the grounds that they were entitled to immunity under the Foreign Sovereign Immunities Act (FSIA). The district court denied the motion in regard to the breach of contract claim, concluding that jurisdiction could be asserted over that claim under the commercial activity exception to the FSIA. The First Circuit Court of Appeals affirmed the district court's exercise of jurisdiction over Plaintiff's breach of contract claim, holding that Defendants' transactions with Plaintiff constituted commercial activity exempt from immunity under FSIA. View "Universal Trading & Inv. Co. v. Bureau for Representing Ukrainian Interests" on Justia Law

After a jury trial, Defendants - Santos-Rivera, Diaz-Correa, and Carrasquillo-Ocasio - were convicted of conspiracy to possess with the intent to distribute drugs and drug possession for their rule in a criminal organization operating a "drug point" in a public housing project in Puerto Rico. Diaz-Correa was also convicted of conspiracy to possess firearms in furtherance of drug trafficking crimes. Diaz-Correa and Carrasquillo-Ocasio challenged their convictions on appeal, and Carrasquillo-Ocasio and Santos-Rivera challenged their sentences. The First Circuit Court of Appeals affirmed the judgments of the district court, holding (1) the evidence was sufficient for a reasonable factfinder to conclude beyond a reasonable doubt that Diaz-Correa and Carrasquillo-Ocasio were involved in the drug trafficking conspiracy and drug distribution activities at the housing project; (2) there was sufficient evidence to conclude that Diaz-Correa had agreed to use firearms to promote the drug-trafficking operation; (3) the case involved an instance of prosecutorial misconduct during closing argument, but the error was harmless; and (4) the district court did not err in the sentences imposed on Carrasquillo-Ocasio and Santos-Rivera. View "United States v. Santos-Rivera" on Justia Law

Defendant, a native of Russia, assumed the name, identifying information, and life history of Fionghal MacEoghan for more than twenty years. After law enforcement officials discovered Defendant's appropriation of MacEoghan's identity, Defendant was charged with, inter alia, aggravated identity theft, wire fraud, and providing false information to obtain federal financial aid in a nine count indictment. During trial, Defendant testified that he believed he had been lawfully adopted by MacEoghan's biological father, and thus that he had taken on MacEoghan's identity through legitimate means. The jury rejected Defendant's defense and found him guilty of eight counts of the indictment. The First Circuit Court of Appeals affirmed, holding that the district court did not err (1) in excluding a proposed expert witness in Soviet adoption practices and cultural difference between the former Soviet Union and the United States; and (2) in admitting evidence pertaining to Defendant's prior larceny conviction. View "United States v. Tetioukhine" on Justia Law

Defendant was convicted of two counts of carjacking resulting in death. After a penalty phase hearing, the jury recommended that Defendant be sentenced to death on both counts. The district court imposed a sentence of death. The First Circuit Court of Appeals affirmed. Defendant subsequently filed a writ of habeas corpus, claiming that juror dishonesty during the voir dire process prior to the penalty phase hearing deprived him of an impartial jury. After an evidentiary hearing, the district court vacated the death sentence and ordered a new penalty phase hearing. The First Circuit affirmed, holding that the death sentence must be vacated and a new penalty phase hearing undertaken because the juror's dishonesty deprived Defendant of the right to an impartial jury. View "Sampson v. United States" on Justia Law