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

This case required the First Circuit Court of Appeals to explore the parameters of the doctrine of quasi-judicial immunity. The underlying litigation was a will contest turned conspiracy case. The plaintiff prevailed in probate court after two and a half years of legal wrangling. By the time Plaintiff was found to be the sole lawful heir of the decedent, the estate's assets were depleted. Seeking retribution, the plaintiff sued several persons involved in the will contest, alleging a wide-ranging conspiracy. In a preliminary ruling, the district court concluded that two of the defendants, a lawyer who had served as a court-appointed discovery master and the lawyer's firm, were immune from suit by reason of quasi-judicial immunity. The court certified this ruling as a partial final judgment. The First Circuit affirmed, holding (1) the district court did not err in certifying the ruling; and (2) the court-appointed discovery master was entitled to share in the judge's immunity from suit, and the law firm whose partner enjoyed quasi-judicial immunity was entitled to share in that immunity for helping the partner to perform his judicial tasks. View "Nystedt v. Nigro" on Justia Law

Defendant was arrested and ordered to be detained on criminal charges. An initial indictment and several superseding indictments followed charging Defendant with several drug offenses. The last indictment was filed in October 2011. Defendant filed motions seeking dismissal of the fourth superseding indictment and release from custody under the section 3164 of the Speedy Trial Act. The district court ordered Defendant's discharge. Fifteen minutes later, Defendant was re-arrested on a new criminal complaint for drug possession. Defendant was re-indicted on four counts virtually identical to the counts charged in the October 2011 indictment and again pled not guilty. Pursuant to the Ninth Circuit's decision in United States v. Tirasso, the district court found that re-indictment on the same offense does not restart section 3164's ninety-day clock and granted Defendant's motion for release. The First Circuit Court of Appeals reversed, holding that when an indictment is dismissed upon the motion of a defendant, the dismissal is without prejudice and that defendant is again detained awaiting trial, section 3164's ninety-day clock restarts at the moment that Defendant is re-arrested, regardless of the nature of the charges in the new complaint. View "United States v. Worthy" on Justia Law

An undercover United States Customs Task Force operation involving efforts on land, at sea, and in the air ended with the arrests of Defendants, Saturnino Tatis-Nunez, Cesar Hernandez-De la Rosa, Carols Espinal-Almeida, and Jacobo Peguero-Carela. Each defendant was indicted on, and ultimately convicted of, one count of conspiracy to possess with intent to distribute, and one count of conspiracy to import, 418 kilograms of cocaine. All Defendants appealed, raising a myriad of challenges that spanned jury voir dire to sentencing. After considering each claimed error, the First Circuit Court of Appeals affirmed Defendants' convictions and sentences, holding that none of Defendant's claims of error had merit. View "United States v. Espinal-Almeida" on Justia Law

Following a bench trial, Appellant was convicted of thirteen counts for crimes involving child pornography. Appellant appealed, challenging various rulings rulings by the district court before and after the trial. This case presented complex questions of first impression in the First Circuit regarding the admissibility of evidence in the wake of the Supreme Court's recent Confrontation Clause jurisprudence. After careful review, the First Circuit Court of Appeals concluded that the admission of certain evidence violated Appellant's Confrontation Clause rights, and the admission of this evidence was harmless as to some counts of conviction but not as to others. The Court thus reversed Appellant's convictions on certain counts and remanded for resentencing or a new trial. View "United States v. Cameron" on Justia Law

Appellant, a federal prisoner, appealed from the district court's denial of his 28 U.S.C. 2255 petition, which was largely focused on a variety of ineffective assistance of counsel claims. Appellant also appealed from the court's denial, as untimely, of his second motion to amend the petition. Appellant asserted on appeal that the second motion to amend was timely and that he should have been allowed to pursue a claim that he was improperly subject to sentencing as an armed career criminal because one prior offense was not a predicate in light of Johnson v. United States. The First Circuit Court of Appeals affirmed both decisions, holding (1) the second motion to amend did not raise an independent Johnson theory and thus the claim was forfeited; and (2) the second motion to amend was untimely. View "Turner v. United States" on Justia Law

Defendant defrauded a number of investors in a series of schemes that used the mails. All told, investors lost about six million dollars. Defendant also laundered money he received from the fraud by buying himself a $180,000 sport car. A federal jury convicted Defendant of seven counts of mail fraud and one count of money laundering. Defendant was sentenced to 192 months imprisonment and ordered to pay $6,030,145 in restitution and to forfeit certain property. The First Circuit Court of Appeals affirmed Defendant's convictions, denied his request for a new trial, and affirmed his sentence, holding (1) because the only identified error in evidentiary rulings was harmless, Defendant was not entitled to a new trial on the basis of cumulative error; and (2) the district court correctly calculated the number of victims and the amounts of forfeiture and of restitution. View "United States v. DeSimone" on Justia Law

Appellant was indicted in federal district court on two counts of being a felon in possession of firearms and ammunition. Appellant moved to suppress the ammunition as well as inculpatory statements he made in connection with his arrest. After an evidentiary hearing, the district court denied the motion. Appellant subsequently entered a conditional guilty plea on both counts, reserving his right to appeal the denial of his suppression motion. Appellant then appealed. The First Circuit Court of Appeals affirmed, holding that the district court properly declined to grant Appellant's suppression motion, as the stop that led to the discovery of the ammunition (1) was justified at its inception and did not constitute an unlawful seizure, and (2) was not transformed into a de facto arrest requiring Miranda warnings. View "United States v. Rabbia" on Justia Law

After they were fired from their jobs, Appellants filed suit in federal district court against their former employer (Employer) and against the severance plan (Plan) established by Employer pursuant to ERISA. The complaint asserted federal claims under ERISA, ADEA, ADA, and other federal laws, and also asserted a breach of contract claim, an employment discrimination claim, and an unjustified dismissal claim under Puerto Rico law. The district court granted Appellees' motion for summary judgment. Appellants challenged that ruling as well as a number of the district court's other orders. The First Circuit Court of Appeals affirmed, holding that there was no error in the management of this case or the grant of Appellees' motion for summary judgment. View "Cruz v. Bristol-Myers Squibb Co., PR, Inc." on Justia Law

A jury convicted Defendant of participating in an oxycodone distribution conspiracy, and he received a sentence of 210 months. On appeal, Defendant raised several challenges to his conviction and sentence, the most important of which was that the district court erred in refusing to suppress evidence that Drug Enforcement Administration (DEA) agents obtained from Defendant's cellular telephone, without a warrant, two weeks after they seized the phone. The First Circuit Court of Appeals affirmed, holding (1) any error on the suppression issue was harmless, and therefore the Court did not need to address whether the agents' activity was lawful under the Fourth Amendment; and (2) Green's other claims also lacked merit. View "United States v. Green" on Justia Law

In this case a corporation abruptly cashiered a member of senior management, which prompted the employee to file suit for age discrimination and retaliation. After a protracted trial, the jury found the employer guilty of retaliation and returned a seven-figure verdict in the employee's favor. The district court allowed the liability finding to stand, trimmed the damages but doubled what remained, refused to grant either judgment notwithstanding the verdict or an unconditional new trial, and awarded the prevailing plaintiff attorneys' fees and an equitable remedy. The First Circuit Court of Appeals affirmed the judgment below except vacated the previously remitted award of emotional distress damages and directed the district court to order the plaintiff either to remit all of that award in excess of $200,000 or else undergo a new trial on that issue. The Court also directed the district court to adjust its award of multiplied damages to reflect the plaintiff's response to this remittitur. View "Trainor v. HEI Hospitality, LLC" on Justia Law