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

Plaintiffs were several dismissed or demoted employees of the State Insurance Fund Corporation, a public corporation that administered Puerto Rico's workers' compensation program. Before the adverse employment actions took effect, Plaintiffs requested informal administrative hearings before the Corporation. Plaintiffs then filed administrative appeals before the Corporation's board of appeals. The board had not acted on the appeals when Plaintiffs sued the Corporation and several of its officers in the U.S. district court, alleging political discrimination and due process violations stemming from adverse employment actions. The district court abstained under Younger v. Harris and dismissed Plaintiffs' claims, finding that Plaintiffs voluntarily engaged the wheels of an administrative procedure before filing an action in federal court. The First Circuit Court of Appeals reversed, holding (1) the district court erred in abstaining based on Younger, and dismissal was not the remedy in any event; and (2) a stay of the federal proceedings was appropriate in this case pending the Puerto Rico Supreme Court's decision in Gonzales Segarra v. State Ins. Fund Corp. View "Casiano-Montanez v. State Ins. Fund Corp." on Justia Law

Plaintiff, a nurse working for Employer, was injured during a horseback riding accident. Plaintiff's employment was later terminated. Plaintiff filed a complaint against Employer, alleging Employer retaliated against her for requesting an accommodation in violation of the Americans with Disabilities Act (ADA) and the Maine Human Rights Act (MHRA). The district court granted summary judgment in favor of Employer, concluding that Plaintiff had failed to adduce evidence that Employer's stated basis for terminating Plaintiff was pretextual and that Plaintiff's evidence of retaliatory animus was too conclusory and speculative to take to trial. The First Circuit Court of Appeals vacated the entry of summary judgment on Plaintiff's retaliation claims under the ADA and MHRA, holding that Plaintiff presented sufficient evidence to bring to a jury. Remanded. View "Kelley v. Corr. Med. Servs., Inc." on Justia Law

After a bench trial, Defendant was convicted of violating and conspiring to violate the federal wire-fraud statute, a law that criminalizes a scheme to defraud involving an interstate-wire communication. Defendant appealed, arguing (1) because the evidence failed to show that he had caused an interstate-wire transmission, his wire-fraud convictions could not stand; and (2) the evidence did not show the existence of a coconspirator, so the conspiracy conviction must fail. The First Circuit Court of Appeals affirmed Defendant's convictions, holding (1) because a factfinder could rationally find the use of interstate wires in this case, the evidence was sufficient to uphold Defendant's wire-fraud convictions; and (2) the evidence was sufficient for a sensible factfinder to find that Defendant and a co-conspirator agreed on the essential nature of a wire-fraud conspiracy. View "United States v. Tum" on Justia Law

In 1989, Appellant was tried and convicted of murder in a Massachusetts state court. After serving fourteen years of his sentence, Appellant moved for a new trial on the ground that exculpatory evidence had been withheld by several Boston police officers involved in his prosecution, including Timothy Callahan, a police detective. Appellant's motion was granted and he was released from prison in 2003. After his release, Appellant filed a civil action in federal district court against Callahan, a Boston police commissioner, two police officers, and the City of Boston, alleging that his constitutional due process rights were violated by the withholding of material exculpatory evidence during his criminal trial. After a jury deadlocked on the issue of whether Callahan's failure to disclose evidence caused Appellant's conviction, a retrial was held. The retrial jury determined in 2009 that Callahan had withheld evidence and determined that his actions caused Appellant's conviction. Appellant was awarded damages of $14 million. The First Circuit Court of Appeals remanded the case to the district court for a new trial, holding that Callahan was entitled to a new trial because the district court judge erred in instructing the retrial jury on causation. View "Drumgold v. Callahan" on Justia Law

In 2008, a federal grand jury indicted co-defendants Carolyn Kravetz and Boris Levitin on charges stemming from a scheme to defraud restaurant franchisor Dunkin' Brands Inc. Defendants pled guilty in February 2010. Jim Edwards, a journalist who specialized in coverage of the advertising industry for Bnet.com, began covering the proceedings in 2009. During the proceedings, Edwards noticed that various documents were filed under seal in the criminal case. Edwards subsequently moved to unseal the documents. Kravetz opposed the motion, and the district court denied the motion. The First Circuit Court of Appeals vacated in part and remanded, holding (1) a presumption of public access attached to Defendants' sentencing memoranda and sentencing letters submitted by third parties on Defendants' behalf; and (2) therefore, the district court was required to state with greater specificity its reasons for denying Edwards' motion to unseal these documents. View "United States v. Kravetz" on Justia Law

After a jury trial, Appellant was convicted of conspiracy to both possess with intent to distribute and to distribute cocaine and attempted possession with intent to distribute cocaine. The convictions stemmed from a reverse sting operation set up by law enforcement authorities in Massachusetts after Appellant talked with an informant in Peru about purchasing cocaine there. The First Circuit Court of Appeals affirmed, holding (1) the district court did not abuse its discretion in choosing the language for its conspiracy instruction; and (2) the district court did not err in failing to instruct the jury on either affirmative defense of withdrawal or entrapment. View "United States v. Guevara" on Justia Law

Employee, a scientist formerly employed by a University, claimed her supervisor (Supervisor) sexually harassed her. Employee complained about the harassment, but University dismissed Employee's complaint. Employee subsequently resigned from her position and brought this lawsuit against University and Supervisor (collectively, Defendants), claiming that she was sexually harassed by Supervisor, retaliated against by University for filing the administrative sexual harassment complaint, and constructively discharged in violation of Title VII of the Civil Rights Act of 1964. Employee also raised supplemental Commonwealth claims. The district court granted summary judgment in favor of Defendants, finding that Employee failed to make out a prima facie case for any of the relief she sought. The First Circuit Court of Appeals (1) affirmed the grant of summary judgment on the Title VII retaliation and constructive discharge claim; but (2) vacated the grant of summary judgment on the Title VII sexual harassment claim and the Puerto Rico law claims prohibiting sexual harassment in employment and gender based discrimination. View "Gerald v. Univ. of Puerto Rico" on Justia Law

Defendant pled guilty to conspiring to possess narcotics with intent to distribute. Although his plea agreement contained a waiver-of-appeal provision, Defendant nevertheless attempted to appeal. Defendant's principal claim on appeal was that the district court erred in the sentence it imposed. The government responded by arguing that the claim was foreclosed by the terms of the plea agreement. The First Circuit Court of Appeals (1) enforced the waiver of appeal, holding that the waiver of appeal was enforceable; (2) rejected Defendant's parallel ineffective assistance of counsel claim as unripe; and (3) dismissed Defendant's appeal. View "United States v. Rivera-Orta" on Justia Law

Defendant pleaded guilty to a single count of possessing a firearm as a convicted felon. The district court sentenced Defendant to five years in prison. The sentence was well above the top of the applicable guideline sentencing range. Defendant appealed, contending that the district court did not make an individualized assessment of the relevant sentencing factors but, rather, relied on impermissible considerations. The First Circuit Court of Appeals affirmed Defendant's sentence, holding (1) the district judge gave individualized attention to Defendant's situation; (2) it is permissible for a sentencing court to consider the incidence and trend lines of particular types of crime in the affected community, and the assignment of appreciable weight to the need for deterrence in this case was a reasonable choice; (3) Defendant's claim of unwarranted sentencing disparity failed; and (4) under the circumstances, Defendant's sentence was substantively reasonable. View "United States v. Flores-Machicote" on Justia Law

The police investigation of a hit-and-run resulted in the arrests of Robert and Mario Robinson, father and son, and the seizure of Robert's car. All of the charges against both Mario and Robert were eventually dismissed by the state trial court. The Robinsons subsequently filed suit against the City and eight police officers who were present for or involved in various phases of the investigation, arrest, and detention. The Robinsons raised state and federal constitutional claims based on allegations of unlawful arrest, the use of excessive force, and the unreasonable seizure of the car. They also asserted several state law claims. The district court granted summary judgment to the defendants on most of the Robinson's claims with the exception of the claims of excessive force, assault and battery, aiding and abetting, and civil conspiracy. The district court later granted summary judgment for three of the police officer defendants as to the civil conspiracy and aiding and abetting claims. The court then dismissed the remaining claims. The First Circuit Court of Appeals affirmed, holding that based on the record, the defendants acted lawfully. View "Robinson v. Cook" on Justia Law