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

The First Circuit affirmed the judgment of the district court ruling that the underlying suit was time barred as to all defendants in this action brought by Plaintiff under 42 U.S.C. 1983 on behalf of her late son's estate on the six-year anniversary of his death, holding that the lawsuit was time barred.Plaintiff sued jail staff and a medical contractor (collectively, Defendants), alleging that while her son was detained in the Somerset County Jail, Defendants failed to recognize his serious mental illness, thus leading to his death following a suicide attempt. Defendants moved to dismiss the suit as time barred. The district court granted the motion. The First Circuit affirmed, holding that Plaintiff was not entitled to relief on her allegations of error. View "Martin v. Somerset County" on Justia Law

The First Circuit affirmed Defendant's conviction for possession of child pornography, holding that the district court did not err in denying Defendant's motion to suppress or to dismiss the indictment and that the government set forth sufficient evidence to support Defendant's conviction.On appeal, Defendant argued, among other things, that the district court erred in denying his motion to suppress the fruits of a warrantless search of his residence and in denying his motion to dismiss the indictment due to inadequate notice of the warrantless search. The First Circuit affirmed, holding (1) assuming that the search of Defendant's home was in violation of the Fourth Amendment, the facts gathered legally provided an independent and adequate source for the warrant application; (2) the district court did not err in denying Defendant's motion to dismiss the indictment or suppress the fruits of the warrant due to insufficient notice; and (3) there was sufficient evidence to sustain Defendant's conviction under 18 U.S.C. 2252A(a)(5)(B). View "United States v. Royle" on Justia Law

The First Circuit denied Petitioner's petition for review challenging the denial of her application for asylum and withholding of removal, holding that Petitioner failed to establish a connection between her past persecution on account of a statutorily protected ground.Specifically, the First Circuit held (1) Petitioner failed to raise before the Board of Immigration Appeals (BIA) her argument that the BIA's failure to address a procedural error in Petitioner's hearing before the IJ violated her right to due process under the Fifth Amendment, and therefore, this Court was precluded from addressing it now; and (2) the BIA erred by failing to evaluate the severity of Petitioner's mistreatment as a teenager through the eyes of a child, but the error did not warrant remand because Petitioner failed to link her mistreatment to a statutorily-protected ground. View "Varela-Chavarria v. Garland" on Justia Law

The First Circuit affirmed the decision of the district court sentencing Defendant following his guilty plea to a charge of illegally possessing a machine gun, holding that Defendant's upwardly variant sentence stood.On appeal, Defendant argued that the district court erred by classifying him as a "prohibited person" under U.S.S.G. 2K2.1(a)(4)(B) and that his forty-eight-month sentence was both procedurally and substantively unreasonable. The First Circuit affirmed on the issue of whether Defendant's classification as a prohibited person was clear error, holding that it was not. The Court, however, divided evenly on how to rule on Defendant's argument that the district court improperly varied upward eighteen months from the upper end of the guidelines sentencing range. The First Circuit thus affirmed Defendant's sentence, holding that the sentence was reasonable. View "United States v. Flores-Gonzalez" on Justia Law

In these consolidated appeals brought in connection with a federal investigation of an organization that operated in Puerto Rico's prisons and was allegedly involved in carrying out murders-for-hire and trafficking drugs, the First Circuit held that one challenge raised on appeal required a limited remand to the district court and that Appellants were not entitled to further relief.Each of the six appellants in this case was convicted of conspiracy to violate the Racketeer Influenced and Corrupt Organization Act and conspiracy to possess with intent to distribute a controlled substance. The First Circuit granted a limited remand and otherwise affirmed, holding (1) the argument brought by three appellants that hearsay statements by alleged coconspirators were admitted into evidence at trial, in violation of United States v. Petrozziello, 548 F.2d 20 (1st Cir. 1977), required a remand for further fact-finding as to whether the statements were made in furtherance of the alleged conspiracy; (2) Appellants' sufficiency of the evidence challenges failed; and (3) Appellants were not entitled to relief on their remaining allegations of error. View "United States v. Ramos-Baez" on Justia Law

The First Circuit affirmed the judgment of the district court denying Petitioner's petition seeking habeas relief on ineffective assistance of counsel claims, holding that there was no error in the proceedings below.Petitioner was convicted in a Massachusetts state court of three counts each of rape, rape of a child, and assault and battery with a dangerous weapon. The appeals court affirmed the trial court's denial of Petitioner's petition for a new trial. Petitioner then sought habeas relief in a federal district court, claiming that he was denied the constitutionally affective assistance of counsel. The district court denied relief. The First Circuit affirmed upon applying the deference required by the Antiterrorism and Effective Death Penalty Act, holding that Petitioner failed to establish that he was entitled to habeas relief. View "Quintanilla v. Marchilli" on Justia Law

The First Circuit affirmed the judgment of the district court determining that Anonymous Appellant (AA) should be civilly committed upon the expiation of his prison sentence, holding that AA was not entitled to relief on his allegations of error.Seventy-three-year-old AA had a history of incarceration spanning more than five decades. During his incarceration AA began to exhibit psychotic symptoms and was diagnosed with having schizoaffective disorder, bipolar type, and antisocial personality disorder. Based on the concerns of a risk-assessment panel the government filed a petition for the civil commitment of AA pursuant to 18 U.S.C. 4246. The district court granted the petition. The First Circuit affirmed, holding that there was no error in the proceedings below. View "United States v. Anonymous Appellant" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment in favor of Joshua Levy, Acting United States Attorney for the District of Massachusetts, in this case challenging the denial by the United States Department of Justice (DOJ) of Levy's request for information related to a federal police misconduct investigation, holding that there was no error.Anthony Gulluni, District Attorney for Hampden County, Massachusetts, sent DOJ a letter (Touhy request) requesting all Springfield, Massachusetts Police Department (SPD) reports and documents supporting DOJ's specific and general findings in an attempt to identify SPD officers who were subject to the DOJ's findings of specific instances of misconduct and general failures within SPD's practices. DOJ denied Gullini's request in accordance with Touhy regulations. Gullini appealed. The First Circuit affirmed, holding that the district court (1) did not err in applying the arbitrary and capricious standard to its review of DOJ's denial of Gullini's Touhy request; and (2) did not err in finding that DOJ's privilege grounds were not arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with the law. View "Gulluni v. Levy" on Justia Law

The First Circuit affirmed the judgment of the district court granting Defendants' motions to dismiss the underlying lawsuit seeking money damages pursuant Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971) for alleged unconstitutional searches and seizures, holding that the district court did not err.Plaintiffs claimed three Bivens causes of action for money damages related to the searches and seizures. The district court dismissed the complaint, determining that the claims arose within a new Bivens context and that special factors counseled toward denying relief. The First Circuit affirmed, holding that Plaintiffs' claims arose in a new factual scenario of Bivens and involved special factors. View "Quinones-Pimentel v. Cannon" on Justia Law

The First Circuit affirmed Defendant's conviction of one count of possession of a firearm by a convicted felon and his sentence of seventy-two months in prison, varying upward from the applicable guideline sentencing range (GSR), holding that the district court did not err in accepting Defendant's guilty plea and that there was no error in sentencing.On appeal, Defendant argued, among other things, that the district court failed to create a sufficient record demonstrating that his guilty plea was constitutionally valid and in accordance with Fed. R. Crim. P. 11(b)(3). The First Circuit affirmed, holding (1) the district court's acceptance of Defendant's guilty plea was valid; and (2) Defendant's seventy-two-month sentence was substantively reasonable. View "United States v. Cahill" on Justia Law