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

After a jury trial, Defendant was convicted of being a felon in possession of a firearm. Defendant appealed the district court's denial of his motion to suppress the firearm, arguing that it was obtained through an illegal search and seizure, as well as the district court's determination that he was an armed career criminal. The First Circuit Court of Appeals affirmed, holding (1) the investigatory stop and pat-frisk the led to the discovery of the firearm were constitutionally permissible, as (i) the Terry stop of Defendant was lawful, and the duration of the stop was not unnecessarily prolonged; and (ii) the officer had a reasonable suspicion that Defendant might be armed and dangerous, thus justifying the frisk; and (2) the district court did not err in sentencing Defendant as an armed career criminal. View "United States v. Mouscardy" on Justia Law

After Plaintiff was suspended, he was discharged from his employment with the Massachusetts Bay Transportation Authority (MBTA). An arbitrator ruled that the MBTA had lacked just cause to terminate him, and the MBTA subsequently reinstated Plaintiff to his former position. Thereafter, Plaintiff filed a complaint against the MBTA, alleging, among other things, that his discharge constituted racial discrimination and that the MBTA unlawfully retaliated against him for writing a letter to Senator Edward Kennedy after MBTA officials recommended firing Plaintiff. The district court granted summary judgment to the MBTA on all claims. The First Circuit Court of Appeals affirmed, holding (1) MBTA's merely questionable behavior did not show minimally sufficient evidence of pretext sufficient to support a discrimination claim; and (2) the district court correctly held that there was no causal link between Plaintiff's letter and his termination. View "Pearson v. Mass. Bay Transp. Auth." on Justia Law

Petitioner, a native and citizen of Mexico, lawfully entered the United States as a visitor but overstayed his visit. Petitioner later conceded removability and sought relief in the form of asylum and withholding of removal (WOR). An immigration judge (IJ) found that Petitioner was ineligible for asylum and for WOR. The Board of Immigration Appeals (BIA) affirmed, finding, among other things, that Petitioner had failed to show that he was targeted in the past or that there was a clear probability he would be targeted in the future on account of a protected ground for WOR. Petitioner subsequently filed a motion to reopen his removal proceedings, which the BIA denied. The First Circuit Court of Appeals denied Petitioner's petition for review, holding that the BIA was within its discretion in finding that Petitioner untimely filed his motion and that none of the exceptions to the deadline applied. View "Lopez v. Holder" on Justia Law

Plaintiffs commenced this action in federal district court challenging the constitutionality of the Transportation Security Administration's (TSA) use of Advanced Imaging Technology (AIT) body scanners and enhanced pat-downs as methods of passenger screening at United States airports, contending that the TSA's use of these screening procedures violated their rights against unreasonable searches and seizures and their right to privacy and interstate travel. The district court dismissed Plaintiffs' claims on the ground it was without jurisdiction to entertain the claims because the case should have been directly filed with the First Circuit Court of Appeals. Appellants appealed. In the meantime, the AIT scanners were refashioned so they no longer generated the revealing images of passengers' bodies that gave rise to this lawsuit. The First Circuit vacated the judgment below and remanded with instructions to dismiss the case based on mootness, holding that Plaintiffs' claims had become moot. View "Redfern v. Napolitano" on Justia Law

These consolidated appeals comprised two putative class actions brought by skycaps affiliated with two major airlines. After Defendants, the airlines, each introduced a $2 per bag fee for curbside service for departing passengers at airports that did not inure to the benefit of the skycaps, Plaintiffs sued the airlines for unjust enrichment and tortious interference, among other claims. The district court dismissed the unjust enrichment and tortious interference claims as preempted by the Airline Deregulation Act (ADA). Plaintiffs appealed, contending that the ADA does not preempt common-law claims. The First Circuit Court of Appeals affirmed after an analysis of statutory language, congressional intent, and case law, holding that the ADA preempted Plaintiffs' common-law claims. View "Brown v. United Airlines, Inc." on Justia Law

After a jury trial, Appellant was convicted of conspiracy to possess with intent to distribute and distribution of cocaine and cocaine base and possession of cocaine base. The district court sentenced Appellant to 262 months' imprisonment in 2002. In 2007, the United States Sentencing Guidelines were amended to reduce crack-cocaine base offense levels. Appellant subsequently moved for and was granted a sentence reduction under 18 U.S.C. 3582(c)(2). In 2011, the guidelines were again amended, retroactively lowering the base offenses even further for crack-cocaine offenses. Appellant moved a second time for a reduction of his sentence. The district court denied the motion, concluding that Appellant was ineligible to receive that reduction because the amended guidelines range exceeded Appellant's modified sentence. The First Circuit Court of Appeals affirmed, holding that the district court did not err in determining Appellant was ineligible for a sentence reduction under 18 U.S.C. 3582(c)(2). View "United States v. Hogan" on Justia Law

Defendant pleaded guilty to conspiracy to possess with intent to distribute cocaine. Defendant appealed, asserting that he did not understand the criminal intent required as an element of the crime and that the district court accepted his guilty plea without an adequate factual basis for the mens rea element of the conspiracy charge. The First Circuit Court of Appeals affirmed the conviction, holding (1) the district court did not plainly err in finding Defendant's plea was knowing, intelligent, and voluntary, as the record contained sufficient evidence of Appellant's appreciation of the elements of the charged crime; and (2) there was a suitable factual basis for Appellant's guilty plea. View "United States v. Ramos-Mejia" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to life imprisonment. Appellant subsequently applied for postconviction relief, alleging that the prosecution failed to turn over exculpatory evidence during his trial. The state superior court denied the application, finding that the withheld information was not material under the Brady test for materiality. The Rhode Island Supreme Court affirmed. Appellant then filed a petition for writ of habeas corpus, challenging the state courts' rulings with regard to his postconviction application. The federal district court denied relief. The First Circuit Court of Appeals affirmed, holding (1) the Rhode Island Supreme Court did not use a materiality standard that was contrary to clearly established U.S. Supreme Court law; and (2) the Rhode Island Supreme Court's application of the materiality standard was not an unreasonable application of clearly established U.S. Supreme Court law. View "DeCiantis v. Wall" on Justia Law

Defendants in this case were a Puerto Rico legislator and a Commonwealth businessman who were charged with unlawfully exchanging favorable action on legislation for a trip to Las Vegas to attend a prize fight. After a jury trial, Defendants were convicted of, inter alia, federal program bribery in violation of 18 U.S.C. 666. Defendants appealed, contending, among other issues, that the district court erred in instructing the jury to find guilt on the section 666 counts based on a gratuity theory rather than a bribery theory. The First Circuit Court of appeals (1) vacated Defendants' section 666 convictions, holding that because section 666 does not criminalize gratuities in addition to bribes, the district court erred in its instructions; and (2) directed the district court to enter a judgment of acquittal on Defendants' conspiracy charges, holding that the Double Jeopardy Clause entitled both men to acquittal on their respective conspiracy charges. View "United States v. Bravo-Fernandez" on Justia Law

From 1999 to at least 2007, Defendant illegally downloaded and distributed copyrighted music without authorization. In 2007, a group of recording companies (collectively, "Sony") filed this action against Defendant under the Copyright Act, seeking damages and injunctive relief. Sony pursued claims for thirty copyrighted works, although Defendant allegedly distributed far more than that amount. After a trial, the jury awarded $675,000 in damages, which represented $22,500 for each of thirty songs whose copyright Defendant violated. Defendant appealed, arguing that the award was so large that it violated his constitutional due process rights. The First Circuit Court of Appeals affirmed, holding that the jury's award did not violate Defendant's right to due process. View "Sony BMG Music Entm't v. Tenenbaum" on Justia Law