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

After a jury trial, Appellant was convicted of seventeen counts of mail fraud, wire fraud, bank fraud, and aggravated identity theft. Appellant appealed, arguing (1) the trial court violated his Sixth Amendment right to confront the witnesses against him by admitting testimony of a forensic examiner about another examiner's prior examination; and (2) the evidence was insufficient to support his aggravated identity theft convictions. The First Circuit Court of Appeals upheld Appellant's convictions on all counts, holding (1) the evidence was sufficient to allow a reasonable jury to conclude beyond a reasonable doubt that Appellant was guilty of aggravated identity theft; and (2) the district court did not plainly err in admitting the testimony of the forensic examiner about the conclusions in another examiner's report, as the statements did not affect Appellant's substantial rights. View "United States v. Soto" on Justia Law

Defendants, Baldwin and Gladys Ihenacho, were the owners and operators of a neighborhood pharmacy. Defendants were convicted of dispensing and shipping drugs to customers pursuant to invalid online prescriptions for Internet pharmacy operations headquartered in the Dominican Republic. Baldwin pled guilty to almost all of the charges. Gladys went to trial, and a jury convicted of her eight counts. The First Circuit Court of Appeals affirmed Baldwin's sentence and Gladys's convictions, holding (1) the district court did not err in applying the fraud sentencing guideline to Baldwin and in calculating the loss caused by Baldwin's offenses for purposes of the fraud guideline; and (2) the evidence was sufficient to support Gladys's convictions for distributing controlled substances, conspiracy, and money laundering. View "United States v. Ihenacho" on Justia Law

While fleeing from the United States Coast Guard, Claimant and his crew tossed more than $8 million into the Caribbean Sea. The Coast Guard subsequently recovered the currency. The government filed this action seeking to have the $8 million, along with additional money found on the crew members' persons, forfeited to the United States. Claimant, who was convicted of knowingly failing to obey a federal law enforcement officer's order to slow down or stop, filed a claim of ownership for the currency. The district court granted summary judgment for the government, holding that Claimant had not shown a colorable interest in the seized currency, and therefore, Claimant failed to establish standing to challenge the forfeiture. The First Circuit Court of Appeals affirmed in part and reversed in part, holding (1) the district court had jurisdiction over a portion of the currency; (2) Claimant did not have constitutional standing the contest the forfeiture of the $8 million; but (3) Claimant did have standing to contest the forfeiture of the $10,000 found on his person. View "United States v. Duyzing" on Justia Law

Plaintiff, a female, brought federal and state claims alleging gender discrimination against the Town of Dennis, Massachusetts, the Town golf course, and several individuals after the golf course refused to let Plaintiff participate in a men's golf tournament. The district court granted summary judgment for Plaintiff and held a trial on damages. The court ruled (1) awarded Plaintiff $34,600 in attorney's fees and costs, (2) rejected Plaintiff's request that the jury be instructed on punitive damages, (3) denied Plaintiff's request for an injunction ordering Defendants to adopt a policy barring gender-based discrimination. Both parties appealed, challenging the nature and extent of Plaintiff's remedy. The First Circuit Court of Appeals (1) affirmed the district court's treatment of punitive damages; (2) vacated the denial of injunctive relief where the district court failed to explain its decision to grant or refuse such relief; and (3) vacated the award of attorney's fees, holding that the district court erred in reducing Plaintiff's requested award based on, inter alia, Plaintiff's rejection of a settlement offer. View "Joyce v. Town of Dennis" on Justia Law

Appellant was convicted of first degree murder. Appellant subsequently commenced this action under the Freedom of Information Act (FOIA) seeking information from the FBI he believed would exonerate him. The government asserted various exemptions to disclosure of the documents' full contents and produced certain heavily redacted documents. After producing these documents, the government moved for summary judgment. The district court granted the government's motion, concluding that the FBI's search was adequate and that it properly claimed the exemptions asserted. The court also awarded Appellant attorneys' fees after significantly reducing the number of compensable hours and the requested hourly rate of Appellant's counsel. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in granting summary judgment to the government, as Appellant failed to raise a triable issue as to the government's treatment of his FOIA request; and (2) the district court did not abuse its discretion in calculating the fee award in this case. View "Moffat v. United States Dep't of Justice" on Justia Law

Plaintiff filed a 42 U.S.C. 1983 action against Defendant, the Secretary of the Commonwealth of Massachusetts, alleging that, in retaliation for Plaintiff's anti-regulatory stance, Defendant used his oversight powers to retaliate unlawfully against Plaintiff. The federal district court dismissed the complaint on immunity grounds. At issue before the First Circuit Court of Appeals was the scope and extent of the immunities offered to state officials, such as Defendant, whose duties encompass both prosecutorial and adjudicatory functions. The First Circuit affirmed the district court, holding that, notwithstanding Defendant's dual roles, Defendant was, with one exception, entitled to absolute immunity from Plaintiff's suit. View "Goldstein v. Galvin" on Justia Law

Defendant was charged with failing to register under the Sex Offender Registration and Notification Act. After a competency hearing, the district court found that Defendant was mentally incompetent and committed him to the custody of the attorney general to be hospitalized. While this interlocutory appeal was pending, the district court issued an order finding it unlikely that Defendant would be able to face the charges against him and ordering that Defendant be further evaluated. The First Circuit Court of Appeals affirmed the district court's order, holding (1) a defendant challenging an order finding him incompetent and committing him to the custody of the attorney general under 18 U.S.C. 4241(d)(1) can seek immediate review of such order; (2) the issue on appeal did not become moot after the district court issued its order finding it unlikely that Defendant would attain competency in the foreseeable future; (3) the district court applied the correct legal standard to determine Defendant's competency; and (4) the district court did not clearly err in finding Defendant incompetent. View "United States v. Mahoney" on Justia Law

Boston College (BC) undertook research into the armed conflict surrounding the independence movement of Northern Ireland during the second half of the Twentieth Century. BC compiled extensive personal interviews and testimonies from formerly active participants in that period. The materials were subject to strict confidentiality agreements entered into between BC and the interviewees. In 2011, a commissioner appointed to represent the United States (Petitioner) issued a subpoena to compel the production by BC of the recordings and/or transcripts of all interviews collected by the project's researchers containing information about an apparent casualty of the interstitial conflict in Northern Ireland. BC filed a motion to quash the subpoena. The district court denied BC's request, ordering that eighty-five interviews in BC's possession be turned over to Petitioner for eventual transfer to UK authorities. The First Circuit Court of Appeals affirmed in part and vacated in part the district court's order, holding that the district court abused its discretion in ordering the production of several of the interviews which did not contain any information relevant to the 2011 subpoena. Remanded. View "United States v. Trs. of Boston College" on Justia Law

Pursuant to a non-binding plea agreement, Defendant pled guilty to a charge of conspiracy with intent to distribute controlled substances. The district court imposed a 210-month incarcerative sentence after applying a sentencing enhancement for possession of a dangerous weapon during and in the course of the crime of conviction and construing the guideline sentencing range accordingly. The First Circuit Court of Appeals affirmed Defendant's sentence, holding (1) the district court's rejection of the sentencing recommendation vitiated Defendant's waiver of appeal in its entirety, and therefore, this appeal was not circumscribed; (2) the dangerous weapons enhancement was adequately grounded in the record; and (3) the sentencing court considered the relevant 18 U.S.C. 3553(a) factors and adequately explained the sentence. View "United States v. Murphy-Cordero" on Justia Law

Plaintiff was a police dispatcher with the Town of Camden Police Department for thirty-one years until his department was eliminated and he was laid off. In the year following Plaintiff's termination, at least two positions opened with the police department for which Plaintiff was qualified. The Town did not recall Plaintiff to either position. Plaintiff subsequently brought a procedural due process against the Town under 42 U.S.C. 1983, alleging that the Town deprived him of a constitutionally protected property interest in his right to be recalled to employment. The district court dismissed Plaintiff's complaint. The First Circuit Court of Appeals vacated the district court's order, holding (1) the district court correctly found that Plaintiff's complaint alleged a protected property interest in his recall right; but (2) the district court erred in concluding that Plaintiff's potential recourse to state law foreclosed his section 1983 claim, as Plaintiff's injury could not be fully redressed by recourse to a state law breach of contract claim or the grievance procedures in a collective bargaining agreement. Remanded. View "Clukey v. Town of Camden" on Justia Law