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

In 2020, a federal grand jury indicted David DeQuattro, an architect, and Cedric Cromwell, Chairman of the Mashpee Wampanoag Tribal Council and President of the Mashpee Wampanoag Gaming Authority. They were charged with various federal offenses, including bribery and extortion, related to Cromwell allegedly soliciting and DeQuattro allegedly providing checks and other items of value to protect a contract between DeQuattro's firm and the Gaming Authority for building a casino on tribal land.The United States District Court for the District of Massachusetts held a jury trial where DeQuattro was convicted of one count of federal-program bribery, and Cromwell was convicted of two counts of federal-program bribery and multiple counts of Hobbs Act extortion. However, the District Court later entered a judgment of acquittal on the Hobbs Act-related counts, determining that the Hobbs Act did not clearly abrogate tribal immunity. Both defendants appealed their § 666 convictions, and the government cross-appealed the judgment of acquittal on the Hobbs Act counts.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed both the § 666 convictions and the judgment of acquittal. The court found that the evidence did not suffice to show that the RGB contract was "business" of the Tribe, as required under § 666, because the Gaming Authority, which entered the contract, was a separate legal entity from the Tribe and received almost all its funding from a third party. The court also reversed the District Court's judgment of acquittal on the Hobbs Act convictions, holding that tribal officials do not enjoy immunity from federal criminal prosecution and that the evidence was sufficient to show Cromwell's intent to engage in a quid pro quo arrangement. The case was remanded for further proceedings consistent with this opinion. View "United States v. Dequattro" on Justia Law

Two pilots, Luis F. Bonnet and Carlos R. Benítez Maldonado, were employed by Benítez Aviation, Inc. (BAI), which managed a Cessna aircraft. In April and May 2019, Bonnet and Benítez piloted several flights without the required certificates for commercial operations. The FAA suspended their Airline Transport Pilot (ATP) certificates for 270 days, alleging they operated the flights as air carriers or commercial operators without proper certification. The pilots received their regular salaries but no additional compensation for these flights.The FAA issued a Notice of Proposed Certificate Action, which the pilots appealed to the National Transportation Safety Board (NTSB). An administrative law judge (ALJ) upheld the FAA's suspension order, finding that the flights were conducted for compensation and hire, thus requiring compliance with Part 135 regulations. The NTSB affirmed the ALJ's decision, concluding that the flights were subject to air carrier or commercial operator requirements and that the pilots violated multiple FAA regulations. The NTSB also found that the ALJ did not exhibit bias and that the 270-day suspension was appropriate.The United States Court of Appeals for the First Circuit reviewed the case. The court held that substantial evidence supported the NTSB's findings that the flights were operated as common carriers for compensation, thus requiring Part 135 certification. The court also found that the pilots were responsible for ensuring compliance with FAA regulations, regardless of BAI's role in booking the flights. The court upheld the NTSB's decision, including the 270-day suspension of the pilots' certificates, finding it justified based on the pilots' regulatory violations and the potential risk to passenger safety. The petition for review was denied. View "Bonnet v. Whitaker" on Justia Law

The case involves James Harper, who challenged an IRS "John Doe" summons issued to Coinbase, a cryptocurrency exchange, seeking records of numerous customers, including Harper. Harper argued that the IRS's actions violated his Fourth and Fifth Amendment rights and did not meet statutory requirements under the Administrative Procedure Act (APA). The IRS had issued the summons to investigate potential tax noncompliance among Coinbase users.The United States District Court for the District of New Hampshire dismissed Harper's complaint. The court found that Harper lacked a reasonable expectation of privacy in his Coinbase account information and that the records were Coinbase's property, not Harper's. The court also concluded that the IRS summons was reasonable and that Harper had received constitutionally adequate process. Additionally, the court dismissed Harper's statutory challenge, ruling it was an improper collateral attack on prior district court proceedings that had enforced the summons and found it met statutory standards.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that Harper lacked a protectable interest under the Fourth or Fifth Amendment. It held that Harper had no reasonable expectation of privacy in the information he voluntarily provided to Coinbase and that the records were Coinbase's property. The court also found that Harper's due process claim failed because he had no protected liberty interest in the confidentiality of his financial information. Finally, the court ruled that the IRS summons was not "final agency action" under the APA, thus not subject to judicial review.The First Circuit affirmed the district court's dismissal of Harper's complaint, concluding that Harper's constitutional and statutory claims were without merit. View "Harper v. Werfel" on Justia Law

A patron at Encore Boston Harbor Casino challenged the casino's practice of redeeming slot-machine tickets. When patrons finish using a slot machine, they receive a TITO ticket, which can be redeemed for cash. The casino offers two redemption options: cashier cages, which provide full cash value, and self-serve kiosks (TRUs), which dispense only bills and issue a TRU ticket for any remaining cents. The TRU ticket can be redeemed at the cashier cage or used in another slot machine. The plaintiff argued that this practice was unfair and deceptive, violating Massachusetts regulations and consumer protection laws.The case was initially filed in Massachusetts state court and then removed to federal court. The district court dismissed the plaintiff's unjust enrichment claim, ruling that an adequate legal remedy was available under Chapter 93A. The court later granted summary judgment in favor of the defendants on the remaining claims, including breach of contract, promissory estoppel, conversion, and unfair and deceptive business practices. The court found that the casino's practice did not violate its internal controls or Massachusetts regulations and that the plaintiff failed to show the practice was unfair or deceptive.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's dismissal of the unjust enrichment claim, agreeing that Chapter 93A provided an adequate legal remedy. The court also upheld the summary judgment on the remaining claims, concluding that the casino's practice of issuing TRU tickets for cents did not violate regulations or constitute unfair or deceptive practices. The court found no evidence that the practice was immoral, unethical, oppressive, or unscrupulous, and ruled that the plaintiff's common law claims also failed. View "Schuster v. Wynn Resorts Holdings, LLC" on Justia Law

The case involves Alam & Sarker, LLC, a convenience store in New Bedford, Massachusetts, which was disqualified from participating in the federal Supplemental Nutrition Assistance Program (SNAP) by the United States Department of Agriculture's Food and Nutrition Service (FNS). The FNS's decision was based on data indicating irregular SNAP transactions at the store, including a high number of back-to-back transactions and unusually large purchases, which suggested trafficking in SNAP benefits.The United States District Court for the District of Massachusetts granted summary judgment in favor of the FNS. The court found that the transaction data provided sufficient evidence of trafficking and that the store failed to rebut this inference with significantly probative evidence. The Market's opposition, which included customer statements and inventory records, was deemed insufficient to create a genuine issue of material fact.The United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that the FNS's reliance on SNAP transaction data was appropriate and that the Market did not provide adequate evidence to counter the strong inference of trafficking. The court also rejected the Market's procedural due process claim, noting that the de novo hearing in the district court cured any potential procedural deficiencies at the administrative level. The court concluded that the Market received all the process that was due and upheld the permanent disqualification from SNAP. View "Alam & Sarker, LLC v. US" on Justia Law

Jonathan Mullane, a law student intern at the United States Department of Justice (DOJ) in 2018, was terminated from his position due to ex parte communications with a law clerk regarding a pro se case he had filed. Subsequently, the United States Securities and Exchange Commission (SEC) rescinded an internship offer to him. Mullane requested documents related to his termination from both the DOJ and SEC under the Freedom of Information Act (FOIA) and the Privacy Act. He claimed that the agencies did not conduct adequate searches and improperly withheld documents. The agencies moved for summary judgment, and the district court granted their motions in full.The United States District Court for the District of Massachusetts granted summary judgment in favor of the DOJ and SEC, dismissing Mullane's claims. Mullane appealed the district court's decision regarding the DOJ, arguing that the DOJ's search for documents was inadequate and that the district court erred in holding that the Privacy Act imposes a jurisdictional exhaustion requirement. Mullane also challenged the district court's denial of his requests for pre-dismissal discovery.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the DOJ conducted an adequate search for documents under FOIA, as the search was reasonably calculated to discover the requested documents. The court also found that Mullane had waived any argument against the district court's conclusion that the Privacy Act's exhaustion requirements are jurisdictional. Consequently, the First Circuit affirmed the district court's grant of summary judgment in favor of the DOJ, dismissing Mullane's FOIA and Privacy Act claims. View "Mullane v. Department of Justice" on Justia Law

Xiomara Santiago was hired as the Deputy Director for the Head Start Program in Utuado, Puerto Rico. Following a mayoral election, the new mayor, Jorge Pérez, terminated her employment. Santiago claimed her dismissal violated her Fourteenth Amendment due process rights and was politically motivated, violating her First Amendment rights. She sought a preliminary injunction to be reinstated.The United States District Court for the District of Puerto Rico held hearings and ultimately denied Santiago's request for a preliminary injunction. The court concluded that Santiago had not shown a likelihood of success on the merits of either her due process or political discrimination claims. The magistrate judge's Report & Recommendation, which the district judge adopted, found that Santiago's initial hire was contrary to Puerto Rico law, meaning she did not have a property interest in her employment. Additionally, the court found insufficient evidence to support her claim of political discrimination.The United States Court of Appeals for the First Circuit reviewed the district court's decision. The appellate court affirmed the lower court's ruling, agreeing that Santiago had not demonstrated a likelihood of success on the merits of her claims. The court noted that Santiago's argument regarding the incorrect application of Puerto Rico law was waived because it was raised for the first time on appeal. Furthermore, the court found no clear error in the district court's assessment that Santiago's political affiliation was not a substantial factor in her termination. The court concluded that the district court did not abuse its discretion in denying the preliminary injunction. View "Santiago v. Municipality of Utuado" on Justia Law

The case involves Puerto Rico's attempt to enact Law 29, which aimed to relieve municipalities from contributing to the Commonwealth's reformed public pension funding scheme. The Financial Oversight and Management Board for Puerto Rico (the Board) challenged the law, and the Title III court overseeing Puerto Rico's debt restructuring declared Law 29 a nullity and of no effect. This decision was not appealed. La Liga de Ciudades de Puerto Rico (La Liga) argued that the Title III court's order did not authorize the Board to recover funds retained by municipalities under Law 29 before the order took effect.The United States District Court for the District of Puerto Rico, interpreting its own prior order, granted motions to dismiss filed by the Board and other defendants. The court dismissed some claims on the merits and others for lack of standing. The court held that the Title III court's order applied retroactively, nullifying Law 29 from its inception and allowing the Board to recover the funds.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's dismissal of La Liga's complaint. It held that the Title III court's order declaring Law 29 a nullity and of no effect applied retroactively, covering the period from the law's enactment. The court found that the Title III court had the authority under PROMESA to nullify Law 29 from its inception and that the Board's actions to recover the funds were justified. The court also addressed standing issues, affirming that La Liga had standing to sue the Board and CRIM but not the executive branch defendants. View "La Liga de Ciudades de P.R. v. Financial Oversight and Management Board" on Justia Law

The case involves the restructuring of Puerto Rico's public debts under Title VI of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA). The dispute centers on whether the final transaction documents or the preliminary documents control the terms of the debt restructuring. The preliminary documents included a Valid Claim Requirement, which stipulated that new bonds would only be issued if valid claims were made. However, the final transaction documents did not include this requirement.The U.S. District Court for the District of Puerto Rico initially approved the restructuring plan, which included the terms set forth in the preliminary documents. However, the court also noted that the final terms would be subject to the execution and delivery of definitive documents. When the final documents were executed, they did not include the Valid Claim Requirement. The district court later ruled that the final documents, not the preliminary ones, governed the transaction, and overruled objections based on the omission of the Valid Claim Requirement.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's decision, holding that the final transaction documents control the terms of the debt restructuring. The court emphasized that the preliminary documents were explicitly provisional and subject to final documentation. The final documents, which did not include the Valid Claim Requirement, were deemed to be the definitive terms of the restructuring. The court also noted that the Requisite Bondholders had approval rights over the final documents and did not object to the absence of the Valid Claim Requirement.Thus, the First Circuit affirmed the district court's ruling, concluding that the final transaction documents govern the debt restructuring, and the Valid Claim Requirement from the preliminary documents does not apply. View "FOMB v. AmeriNational Community Services, LLC" on Justia Law

Ronald Tilley, the appellant, was convicted for robbing a credit union in Bangor, Maine, in 2019. His pre-sentence investigation report (PSI Report) revealed two prior convictions involving potential sexual misconduct, leading to a suggestion for special conditions of supervised release requiring Tilley to participate in sex-offender treatment. The first conviction in 2005 involved an incident where Tilley's then-wife accused him of choking and sexually assaulting her. The second conviction in 2008 was for violating a protective order and involved sexually explicit text messages allegedly exchanged between Tilley and his underage niece. Tilley objected to the sex-offender treatment conditions, leading to a compromise requiring him to undergo a Sexual Offense Assessment and Treatment Evaluation (SOATE).The SOATE, conducted by a licensed clinical social worker, placed Tilley in the "well below average risk" category for sexual recidivism due to the time elapsed since his last sexual misconduct. However, the assessment recommended caution due to a deceptive response in a sexual history polygraph. The SOATE also diagnosed Tilley with antisocial personality disorder and opioid use disorder, and recommended that he have no unsupervised contact with minors and participate in weekly group therapy for sexually problematic behavior.Based on the SOATE report, the government petitioned to add several special conditions to Tilley's supervised release terms, including participation in sex-offender treatment and restrictions on associating with minors. Tilley objected to these conditions, arguing that they were not supported by his previous convictions and that the relevance of these convictions was significantly mitigated by the time elapsed without any sexual misconduct incidents.The United States District Court for the District of Maine granted the government's petition, finding that the proposed modifications promoted the goals of supervised release. The court also found the conditions restricting Tilley's association with minors to be proportionate and reasonably related to the goals of supervised release and his history and characteristics.Tilley appealed, arguing that the district court relied on "clearly erroneous facts" in imposing the modified conditions. The United States Court of Appeals for the First Circuit reviewed the case for abuse of discretion and found no clear error. The court upheld the district court's decision, concluding that the modified conditions were reasonable and supported by the record. View "US v. Tilley" on Justia Law