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

A Puerto Rico agency, the Milk Industry Regulatory Office (ORIL), revoked a dairy farmer's license and ordered him to sell his milk production quota rights. When the farmer, Luis Manuel Ruiz Ruiz, failed to comply, ORIL planned to auction the quota rights. Ruiz, who had filed for Chapter 12 bankruptcy in 2015, argued that the auction violated the automatic stay provision of the Bankruptcy Code.The bankruptcy court enjoined ORIL from auctioning the quota without court permission, finding that the planned auction violated the automatic stay. The court granted partial summary judgment to Ruiz, determining that ORIL's actions were not protected by the police power exception. ORIL appealed to the United States District Court for the District of Puerto Rico, which affirmed the bankruptcy court's decision, agreeing that the police power exception did not apply.The United States Court of Appeals for the First Circuit reviewed the case. The court held that ORIL's plan to auction Ruiz's milk quota fell within the police power exception to the automatic stay under 11 U.S.C. § 362(b)(4). The court reasoned that the auction was part of enforcing a judgment obtained in an action to enforce ORIL's regulatory power, which is not a money judgment. The court emphasized that ORIL's actions were aimed at protecting public health and welfare by regulating milk production and distribution, rather than advancing a pecuniary interest.The First Circuit reversed the judgments of the bankruptcy and district courts, directing judgment in favor of ORIL. The court concluded that ORIL's planned auction did not violate the automatic stay and was protected by the police power exception. View "Milk Industry Regulatory Office v. Ruiz Ruiz" on Justia Law

The National Association of Government Employees, Inc. (NAGE) challenged the constitutionality of the Debt Limit Statute, alleging that it posed an imminent risk to its members, who are federal employees. NAGE claimed that if the debt limit was not raised, its members would face layoffs, furloughs, unpaid work, and loss of pension funding. NAGE sought declaratory and injunctive relief against Treasury Secretary Janet Yellen and President Joseph R. Biden.The United States District Court for the District of Massachusetts dismissed the case for lack of subject matter jurisdiction. The court found that NAGE's claims of past injuries were moot due to the passage of the Fiscal Responsibility Act, which suspended the debt limit until January 1, 2025, and required the Treasury Secretary to make whole the G Fund accounts. The court also determined that NAGE's claims of future harm were too speculative to establish standing, as they relied on a series of unlikely events, including a federal default, which has never occurred.The United States Court of Appeals for the First Circuit affirmed the district court's dismissal. The appellate court agreed that NAGE lacked standing to pursue prospective relief because the anticipated future harms were speculative and not certainly impending. The court also found that NAGE's claims of past injuries were moot, as the Fiscal Responsibility Act had addressed the immediate concerns, and there was no reasonable expectation that the same harm would recur. The court rejected NAGE's arguments that the voluntary-cessation and capable-of-repetition-yet-evading-review exceptions to mootness applied, concluding that the legislative action was independent and not related to the litigation, and that the risk of future harm was not reasonably expected. View "National Association of Government Employees, Inc. v. Yellen" on Justia Law

The case involves Lucas Sirois and Alisa Sirois, who were indicted for conspiracy to distribute and possess with intent to distribute marijuana under the Controlled Substances Act (CSA). They sought to enjoin the Department of Justice (DOJ) from prosecuting them, arguing that their conduct was in substantial compliance with the Maine Medical Use of Cannabis Act, which allows for the use, distribution, possession, and cultivation of medical marijuana under state law. The defendants claimed that the DOJ's prosecution violated the Rohrabacher-Farr Amendment, which prohibits the DOJ from using funds to prevent states from implementing their medical marijuana laws.The United States District Court for the District of Maine denied the defendants' request for injunctive relief. The court held a hearing where the government presented evidence that the defendants' operations, particularly a grow operation known as the "Shoe Shop," violated Maine's medical marijuana laws by operating as a collective and engaging in black-market sales. The court found that the government had met its burden of production, showing a substantial evidentiary basis for the prosecution. However, the defendants failed to meet their burden of persuasion to demonstrate that the prosecution lacked a substantial evidentiary basis or was arbitrary or irrational.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the District Court's decision. The appellate court held that the defendants did not show by a preponderance of the evidence that they were in substantial compliance with Maine's medical marijuana laws. The court noted significant evidence that the Shoe Shop operated as a collective and that Lucas Sirois engaged in black-market sales. The court concluded that the defendants failed to demonstrate that the DOJ's prosecution would prevent Maine from giving practical effect to its medical marijuana laws, as required under the Rohrabacher-Farr Amendment. Therefore, the denial of the motion to enjoin the prosecution was affirmed. View "United States v. Sirois" on Justia Law

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