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

After a jury trial in the United States district court, Appellant, an attorney, was convicted on bribery, extortion, and conspiracy charges stemming from his involvement in a scheme to purchase the votes of three corrupt town councilmen on two zoning matters. During the trial, the district court admitted into evidence under Fed. R. Evid. 801(d)(2)(E) a number of recorded statements about Appellant made by one of the councilmen to a government informant. On appeal, Appellant argued that some of these statements should have been excluded as hearsay, and challenged the admission of all the statements on constitutional grounds under the Confrontation Clause. Appellant also claimed the district court erred in calculating his sentence under the United States Sentencing Guidelines. The First Circuit Court of Appeals affirmed, holding (1) the district court did not clearly err in admitting the challenged statements; and (2) the sentence imposed was appropriate. View "United States v. Ciresi" on Justia Law

Appellant Juan Colon-Rodriguez was convicted in 2009 on twelve counts of making false statements on Farm Service Agency (FSA) loan applications and one count of defrauding a financial institution. The district sentenced Appellant to thirty-seven months' imprisonment on each count, to be served concurrently. The First Circuit Court of Appeals (1) affirmed two of the challenged convictions, holding that the evidence was sufficient to support these convictions; (2) vacated the third challenged conviction, holding that no rational jury could have concluded that the government proved all elements of this offense beyond a reasonable doubt; and (3) affirmed the sentence, holding that the sentence was substantively reasonable. View "United States v. Colon-Rodriguez" on Justia Law

Appellant Ivan Gonzalez-Cancel aspired to run for Governor of Puerto Rico as Partido Nuevo Progresista's ("PNP") candidate in the 2012 general election. When he applied for the job, however, PNP said he was not qualified. Gonzalez-Cancel and Jose Barbosa, a supporter of Gonzalez-Cancel's candidacy, sued PNP and Puerto Rico's Elections Commission in federal court, alleging that the decision violated their constitutional rights. The district court dismissed the complaint for lack of jurisdiction, concluding that Appellants' claims did not fall within one of the few narrow exceptions required for a federal court's intervention in state or local electoral disputes. The First Circuit Court of Appeals affirmed, holding that the exercise of federal jurisdiction over this election dispute was not appropriate. View "Gonzalez-Cancel v. Partido Nuevo Progresista" on Justia Law

After Mark Jones repeatedly failed to pass an examination to receive a license required by his employer of all persons in that position, by a date of which he had many months' notice, he requested for the first time that the date be extended due to his medical condition. When his employer declined, and Jones declined to pursue an open alternate position at lesser pay, his employment ended. He then sued under both federal and state disability laws. The district court entered summary judgment for the employer. The First Circuit Court of Appeals affirmed, bypassing the question of whether Jones met the definition of "disability" and holding that the reasonable accommodation provisions of both statutes did not save his case. View "Jones v. Nationwide Life Ins. Co." on Justia Law

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