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

Defendant purchased a stolen handgun. Two days later, Defendant returned the gun in exchange for the money he paid. Based on the time he possessed the weapon, Defendant was indicted and convicted of one count of possession of a stolen firearm and was sentenced to a $100 special assessment, a one-month jail term, and a two-year term of supervised release. The First Circuit Court of Appeals vacated Defendant's conviction and remanded the case for a new trial, holding that the district court erred when it declined to instruct the jury on "innocent possession," which would have allowed Defendant to make out a defense of innocent possession of the stolen weapon. View "United States v. Baird" on Justia Law

Plaintiff, the former proprietor of a now-defunct bar and restaurant in Wrentham, Massachusetts, sued the Town of Wrentham and several town officials, alleging that Defendants maliciously imposed excessive regulatory requirements on his restaurant in retaliation for his opposition to certain town policies. Defendant filed causes of action for federal civil rights violations and violations of the state unfair trade practices law. The district court dismissed Defendant's complaint for failure to state a claim, concluding (1) the 42 U.S.C. 1983 claims were vague, failed to connect any of the alleged harms to any particular defendant, and did not establish a basis for municipal liability; and (2) the state law claim did not suggest any business contest or allege any unfair act or deceptive practice. The First Circuit Court of Appeals affirmed, holding that the district court did not err in its judgment. View "Gianfrancesco v. Town of Wrentham" on Justia Law

At issue in this case was Puerto Rico's controlled access law, which authorized gated communities, called urbanizations, which could control access to public streets within their confines. In 2004, Appellants, religious organizations, brought suit under 42 U.S.C. 1983, alleging that the controlled access regime unconstitutionally impeded their ability to proselytize from house to house. The suit was brought against several Commonwealth defendants and thirty-three municipalities and urbanizations. In Watchtower I, the First Circuit Court of Appeals determined that the CAL was constitutional on its face but that some municipalities and urbanizations were applying the law in ways that bore unreasonably on Jehovah's Witnesses' access to public streets. On remand, the district court dismissed the Commonwealth defendants. Appellants appealed the order dismissing the Commonwealth defendants. The First Circuit Court of Appeals dismissed Appellants' appeal for lack of jurisdiction, as the order was not final and the order did not have the practical effect of refusing injunctive relief and thus was not immediately appealable. View "Watchtower Bible & Tract Soc'y of N.Y., Inc. v. Colombani" on Justia Law

After a jury trial, Appellants were each convicted under 18 U.S.C. 1347 and 1349 for making fraudulent claims to, and obtaining payment from, insurance companies participating in Massachusetts' no-fault automobile insurance program. The First Circuit Court of Appeals affirmed Appellants' convictions, holding that the district court (1) correctly determined that the defrauded insurance companies constituted "health care benefit programs" within the jurisdictional reach of section 1347; (2) did not err in concluding that Appellants' scheme affected interstate commerce as is required for a constitutionally valid application of section 1347; and (3) did not violate Appellants' Fifth and Sixth Amendment rights in denying proposed voir dire questions concerning the ethnic minority group to which they belonged. View "United States v. Gelin" on Justia Law

After a vehicle pursuit, an officer of the Yarmouth, Massachusetts Police Department shot and killed Andre Martins. Plaintiff, individually and as administratrix of Martins' estate, brought a civil rights action against the officer and the Town of Yarmouth (collectively, Defendants). Defendants filed a motion for summary judgment, arguing that Plaintiff failed to establish that the officer's use of force violated Martins' constitutional rights and that, in the alternative, the officer was entitled to qualified immunity. The district court denied the motion. The First Circuit Court of Appeals dismissed Defendants' interlocutory appeal for lack of jurisdiction, holding that Defendants (1) failed to establish that, within the Scott v. Harris framework, Plaintiff's account of the shooting was so discredited by the record that no reasonable jury could believe her; and (2) failed to convince the Court that they were entitled to immunity. View "Campos v. Van Ness" on Justia Law

Plaintiff, her son Kyle, and Kyle's girlfriend Catherine lived together. In 2008, Kyle was the driver of a vehicle involved in an accident in New Hampshire. Defendant was among the police officers who responded to the scene. Kyle was then arrested. Catherine, who witnessed the accident, and Plaintiff went to the police station. Defendant warned Catherine against leaving the police department and threatened to obtain a warrant for her arrest if she left. Plaintiff, however, counseled Catherine to leave and escorted her out of the police station. Defendant subsequently filed a criminal complaint charging Plaintiff with witness tampering. The charge was later dismissed. Plaintiff then filed an action against Defendant in the U.S. district court for false arrest under the Fourth Amendment and malicious prosecution under state law. The district court granted summary judgment for Defendant, concluding that Defendant was entitled to qualified immunity on the federal constitutional claim and official immunity on the state-law claim. Finding no error, the First Circuit Court of Appeals affirmed. View "Moses v. Mele" on Justia Law

In 2009, federal agents, acting without a warrant, placed a global positioning system (GPS) tracker on a car used by Craig Sparks. The agents located the car at the scene of a bank robbery and chased down the car on the highway after it fled, all by using the tracker. A subsequent search of the car revealed evidence tying Sparks and Michaud (Appellants) to the bank robbery. After Appellants were indicted for bank robbery, they moved to suppress the evidence obtained as a result of the placement of the GPS tracker on the car. The district court denied the motion, concluding that the case was governed by United States v. Knotts, which held that using a radio-based tracking device to tail a suspect's car was not a Fourth Amendment search. Appellants appealed, arguing that the U.S. Supreme Court's recent decision in United States v. Jones required reversal of the district court's decision. The First Circuit Court of Appeals affirmed without reaching the question, holding that the agents' conduct fit within the good-faith exception to the exclusionary rule, and therefore, the district court did not err in denying Appellants' motion to suppress. View "United States v. Sparks" on Justia Law

Plaintiffs were former employees of the Puerto Rico Administration of Juvenile Institutions. After an election that produced a regime change, Plaintiffs were ousted from their positions, notwithstanding solid qualifications and positive evaluations. Plaintiffs sued several government defendants, invoking 42 U.S.C. 1983 and alleged discrimination based on political affiliation in violation of the First Amendment. Plaintiffs also lodged pendent claims under Puerto Rico law. The district court ruled that the complaint failed to state a claim for relief because it did not assert facts sufficient to establish a prima facie case of political discrimination. The First Circuit Court of Appeals reversed in part, holding (1) the prima facie case is not the appropriate benchmark for determining whether a complaint has met the plausibility standard under Bell Atlantic v. Twombly; (2) the factual allegations in Plaintiffs' complaint, taken as true, state plausible section 1983 claims for political discrimination with respect to two of the defendants; and (3) the pendent claims against those two defendants, which were dismissed without prejudice when the district court declined to exercise supplemental jurisdiction, must be reinstated. Remanded. View "Rodriguez-Reyes v. Molina-Rodriguez" on Justia Law

Plaintiff, an Egyptian-American, filed a workplace discrimination suit against the Mohegan Council, Boy Scouts of America alleging that he was denied career advancement opportunities on account of his religion of Islam and his national origin. After a jury trial, the district court ruled in favor of Plaintiff. The First Circuit Court of Appeals affirmed, holding that the district court did not err in denying Mohegan Council's motion for judgment as a matter of law, where (1) the district court correctly found that Mohegan Council was an "employer" with the requisite fifteen or more employees under the Title VII of the Civil Rights Act of 1964; (2) Plaintiff's complaint with the Massachusetts Commission Against Discrimination was timely filed; and (3) sufficient evidence supported a finding of discrimination. View "Aly v. Mohegan Council, Boys Scouts of Am." on Justia Law

Defendants, both Chinese nationals, shipped tens of millions of dollars worth of sophisticated electronic components from the United States to China with little regard for whether the parts they sold were export-controlled. In 2008, Defendants were arrested and later indicted for thirty-four counts of export-related offenses. The two were ultimately convicted of, among other things, exporting without a license items designated as defense articles on the U.S. Munitions List and items controlled under the Commerce Control List, conspiracy to violate the Munitions List and Commerce Control List restrictions, and conspiracy to file materially false Shipper's Export Declarations (SED) with the Commerce Department. On appeal, Defendants argued that the federal government's arms export control system constituted a regulatory scheme that violated the Due Process Clause. The First Circuit Court of Appeals (1) affirmed the Commerce Control List convictions and SED convictions, holding that the federal government's arms export control system does not violate the Fifth Amendment's Due Process Clause; and (2) vacated the Munitions List convictions, holding that the district court erred by not submitting to the jury an element of the offense, and the error was not harmless. Remanded. View "United States v. Wu" on Justia Law