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

Defendant was convicted, after a four-day trial, of attempting to kill a federal witness with intent to prevent testimony and communication with law enforcement. Defendant was sentenced to 360 months' imprisonment. Defendant appealed, challenging several of the district court's evidentiary rulings and asserting that the prosecution's allegedly improper closing argument severely prejudiced his case. The First Circuit Court of Appeals affirmed the conviction, holding (1) the district court did not err in admitting certain documents and testimony at trial; and (2) statements made by the prosecutor in rebuttal to defense counsel's closing argument, though perhaps improper, did not amount to plain error. View "United States v. Watson" on Justia Law

The State enacted an Act in 2011 pursuant to which health insurers were required to disclose, upon written request from a public school district, aggregate loss information pertaining to any group policies held by the district's employees. Maine Education Association Benefits Trust, which managed a statewide health insurance plan for a substantial segment of Maine's public school work force, subsequently filed suit in the district court, seeking to permanently enjoin the law prior to its enforcement. The Trust alleged that because its information constituted a confidential trade secret, the Act's disclosure requirement resulted in an uncompensated taking proscribed by the Fifth Amendment. The district court denied the Trust's motion for a preliminary injunction. The Supreme Court affirmed, holding that the Trust did not have a reasonable likelihood of success on the merits of its takings claim. View "Me. Educ. Ass'n Benefits Trust v. Cioppa" on Justia Law

The issue in this case concerned a procedural requirement that must be satisfied in order to file suit under Title I of the Americans with Disabilities Act of 1990 (ADA). Pursuant to this requirement, a claimant must exhaust administrative remedies and file her Title I suit within ninety days after receiving a right-to-sue notice from the EEOC. The district court, citing this requirement, concluded that Plaintiff's Title I suit, which was filed 144 days after the EEOC sent the notice, was brought too late. To explain the delay, Plaintiff suggested that she did not receive the right-to-sue notice until nineteen days before she filed suit. The district court concluded that there is a presumption of timely receipt of a mailed notice and that Plaintiff did not furnish sufficient record evidence to rebut this presumption. The Supreme Court affirmed but on other grounds, holding that the action was time-barred, as Plaintiff had constructive notice of the ninety-day filing requirement, and yet her suit was commenced well after the expiration of that filing period. View "Loubriel v. Fondo del Seguro del Estado" on Justia Law

Appellants were players in the Boston real estate market. Along with six coconspirators, Appellants devised and executed a mortgage fraud scheme which netted them illegal profits of nearly $2 million between May 2005 and June 2006. Appellants and their coconspirators were found guilty of one count of conspiring to commit wire fraud and with multiple counts of committing wire fraud. In addition, two defendants were found guilty of multiple counts of money laundering. The First Circuit Court Court of Appeals affirmed Appellants' convictions and sentences, holding, inter alia, (1) there was sufficient evidence to support Appellants' convictions; (2) the district court did not err by admitting into evidence four charts summarizing the financial data in this case; (3) the district court did not err in instructing the jury that it had a duty to return a guilty verdict if it concluded that the government had proven its case beyond a reasonable doubt; and (4) there was no error in the district court's loss calculation methodology and none in its mathematical application of this methodology. View "United States v. Appolon" on Justia Law

At issue on this appeal was whether a petition for habeas corpus was timely filed within the one-year limitations period provided by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). The district court found that Petitioner filed his petition within the one-year window because the running of the limitations period was tolled by proceedings in Massachusetts state court. However, the court rejected the petition on its merits. The First Circuit Court of Appeals affirmed the district court's judgment, albeit on different grounds, holding that Petitioner's petition was filed well outside of AEDPA's one-year limitations period. View "Herbert v. Dickhaut" on Justia Law

The government charged Defendant with one count of interfering with the operation of an aircraft with reckless disregard for human life and one count of making false statements. After a jury trial, the jury found Defendant guilty as charged. The First Circuit Court of Appeals affirmed Defendant's conviction under 18 U.S.C. 1001, vacated Defendant's conviction under 18 U.S.C. 32(a)(5), and remanded, holding (1) the evidence was sufficient to support Defendant's conviction, as the government proved all the elements of the offense beyond a reasonable doubt; and (2) a jury instruction erroneously diluted the mens rea requirement of section 32(a)(5), and the error was not harmless. View "United States v. Sasso" on Justia Law

Defendant Jose Romero-Lopez was convicted after a jury trial of money laundering offenses in violation of 18 U.S.C. 1956 and 982. The First Circuit Court of Appeals affirmed Defendant's conviction, holding that there was no error in the district court's scheduling or evidentiary rulings, where (1) Defendant's due process rights were not violated when the district court advanced the scheduled trial date by one day; and (2) the district court did not err in allowing the prosecution to present evidence relating to (i) Defendant's tax returns and (ii) Defendant's activities and detention by federal authorities when traveling through the San Diego airport. View "United States v. Romero-Lopez" on Justia Law

Appellant appealed his conviction of conspiracy to commit a carjacking and aiding and abetting an attempted carjacking resulting in a death. The First Circuit Court of Appeals affirmed, holding (1) the government presented inappropriate overview testimony from a FBI agent at the outset of its case, but the error was harmless; (2) the government engaged in improper vouching in its closing argument, but Appellant failed to show the requisite prejudice, and therefore the error was harmless; (3) the district court did not err in denying Appellant's Fed. R. Crim. P. 29 motion for a judgment of acquittal, as the government presented sufficient evidence to support Appellant's convictions; and (4) the court did not err in applying the United States Sentencing Guidelines Manual 2B3.1(c) "murder cross reference" in determining the guidelines range for Appellant's sentence. View "United States v. Rodriguez-Adorno" on Justia Law

This appeal involved an award of $59,787 in attorney's fees against unsuccessful plaintiffs in a civil rights action against the Municipality of Adjuntas, its mayor, and Plaintiffs' direct supervisors. Plaintiffs argued that their lawsuit was not so frivolous or unreasonable as to justify an award of fees to Defendants. The First Circuit Court of Appeals agreed, except for one plaintiff's inferior working conditions claim and another plaintiff's claim against a supervisory defendant, as there was no reasonable basis for those claims. The Court vacated the fee award and remanded for further proceedings relating to any attorney's fees incurred by the Municipality of Adjuntas in relation to those claims only. View "Torres-Santiago v. Municipality of Adjuntas" on Justia Law

Two physicians who contracted with HMOs refused to accept capitation payments in place of fee-for-service payments, so the HMOs dropped the physicians' contracts. The physicians brought constitutional and antitrust claims against the companies, which the district court rejected on a motion to dismiss. The physicians appealed. The First Circuit Court of Appeals affirmed, holding (1) because the appellees were not governmental actors, Appellants' constitutional claims failed; and (2) because the appellees that Appellants contended violated the Sherman Act were not independent firms and were, rather, wholly owned subsidiaries of the same parent company, the appellees could not have violated the Act's conspiracy prohibition. View "Gonzalez-Maldonado v. MMM Health Care, Inc." on Justia Law