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

The case involves a dispute about the interpretation of the National Voter Registration Act ("NVRA"), specifically Section 8(i)(1). The plaintiff, Public Interest Legal Foundation, Inc. ("PILF"), requested a copy of the Maine Party/Campaign Use Voter File ("Voter File") from the Secretary of State for the State of Maine, Shenna Bellows. The Secretary denied the request under Exception J of Maine's Privacy Law, which restricts the use and publication of the Voter File.The United States Court of Appeals for the First Circuit held that Section 8(i)(1) of the NVRA applies to the Voter File and that Maine's restrictions on the use and publication of the Voter File are preempted by the NVRA. The court reasoned that both federal and state law require Maine election officials to create and update voter registration records, and these activities fall within Section 8(i)(1). The Voter File, as an electronic report generated from the Central Voter Registration system, reflects the additions and changes made by Maine election officials in carrying out voter list registration and maintenance activities. Therefore, it is a record concerning the implementation of those activities, and its use is subject to disclosure under Section 8(i)(1). The Use Ban and Publication Ban under Exception J, as applied to PILF, were found to be preempted by the NVRA, and the fines for violating these restrictions were also preempted. View "Public Interest Legal Foundation, Inc. v. Bellows" on Justia Law

The United States Court of Appeals for the First Circuit reversed a lower court's dismissal of a lawsuit brought by the government of Mexico against several U.S. gun manufacturers and a gun distributor. The lawsuit alleges that these companies facilitated illegal gun trafficking into Mexico, causing significant harm to the country. The lower court had dismissed the case based on the Protection of Lawful Commerce in Arms Act (PLCAA), which generally prohibits lawsuits against gun manufacturers and sellers for harm caused by the criminal misuse of their products. On appeal, the First Circuit held that the PLCAA does apply to lawsuits initiated by foreign governments for harm suffered outside the United States. However, the court also found that Mexico's lawsuit plausibly alleges a type of claim that is statutorily exempt from the PLCAA's general prohibition, specifically, that the defendants knowingly violated federal and state statutes applicable to the sale or marketing of firearms, and that this violation was a proximate cause of the harm Mexico suffered. The case was remanded back to the lower court for further proceedings. View "Estados Unidos Mexicanos v. Smith & Wesson Brands Inc." on Justia Law

The case involves the defendant-appellant, Augusto Valdez, who appealed from his guilty plea and conviction for which he received 120 months' imprisonment, followed by a five-year term of supervised release. Valdez raised two issues: firstly, he asserted that the district court should have granted his motion to withdraw his guilty plea because he conspired only with a confidential source and not a co-conspirator, and that the court did not ensure that he knew he couldn't conspire illegally with a government agent. Secondly, he sought to vacate his sentence because the district court should have, on its own initiative, verified his eligibility for the safety valve under U.S.S.G. § 5C1.2.The United States Court of Appeals for the First Circuit affirmed the decision of the district court. The court found that Valdez knowingly and voluntarily entered his guilty plea and was not misled about the nature of the conspiracy charge, thereby rejecting his argument that his plea was not knowing, voluntary, and intelligent. His argument that he could not be convicted for conspiring only with a government agent was rejected because the facts revealed two true conspirators: Valdez and a Texas source. The court also found that Valdez waived his right to argue for the application of the safety valve because he failed to object to the PSR and requested the mandatory minimum sentence, which was inconsistent with his later argument for the application of the safety valve. View "United States v. Valdez" on Justia Law

In this case, the Town of Milton, Massachusetts, petitioned for a judicial review of the Federal Aviation Administration's (FAA) final order authorizing a new flight procedure at Boston's Logan International Airport. The new procedure, aimed at increasing safety and efficiency, covers a narrower swath of airspace over the Town of Milton. The Town argued that the FAA's environmental analysis of the noise impacts failed to comply with the National Environmental Policy Act (NEPA). However, the United States Court of Appeals For the First Circuit dismissed the Town's petition, ruling that the Town does not have standing to challenge the FAA's final order. The court concluded that the harms the Town asserted, including the impact of noise on its residents and the time and money spent addressing these issues, were not legally cognizable harms to the Town itself. The court agreed with other courts of appeals that have dismissed municipal NEPA challenges to FAA orders for lack of Article III standing because those challenges failed to show cognizable injury to the municipalities themselves. View "Milton, MA v. FAA" on Justia Law

The First Circuit affirmed the decision of the Board of Immigration Appeals (BIA) affirming the immigration judge's (IJ) denial of Petitioner's applications for asylum, withholding of removal, and protection under the Convention Against Torture (CAT), holding that Petitioner was not entitled to relief.Petitioner, who was from Nepal, sought relief based on claims that she experienced past persecution and had a well-founded fear of future persecution at the hands of Maoist insurgents on account of political opinion and membership in a particular social group, in particular, her nuclear family. The IJ granted Petitioner's application for voluntary departure but denied her claims for asylum, withholding of removal, and protection under the CAT. The BIA affirmed. The First Circuit affirmed, holding that the lower agencies did not err in concluding that Petitioner failed to establish that the Nepali government was unwilling or unable to protect her. View "Singh v. Garland" on Justia Law

The First Circuit dismissed the petition for review brought by Petitioner, a Kenyan national, of the decisions of an immigration judge (IJ) and the Board of Immigration Appeals (BIA) regarding whether Petitioner was properly served by U.S. Citizenship and Immigration Services (USCIS) with the notice of its intent to revoke his visa petition and the ensuing official revocation, holding that there was no error.In the wake of his petition to the First Circuit challenging the BIA's affirmance of the IJ's decision denying his requested adjustment of status, USCIS sent a notice of its intent to revoke its approval of Petitioner's visa petition. At issue in this case was whether the IJ and BIA erred in finding that USCIS properly served Petitioner with its intent to revoke his visa. The First Circuit dismissed Petitioner's petition for review, holding that the agencies properly determined that notice was properly and lawfully accomplished based on applicable regulations and USCIS policy. View "Manguriu v. Garland" on Justia Law

The First Circuit denied a petition for review of an order of the Board of Immigration Appeals (BIA) affirming the decision of the immigration judge (IJ) to deny Petitioner's application for withholding of removal and asylum under the Immigration and Nationality Act (INA), holding that Petitioner was not entitled to relief.Petitioner, a citizen of Guatemala, conceded that he was removable but applied for asylum and claimed withholding of removal based on his membership in two particular social groups. The IJ denied Petitioner's applications and ordered him removed. The BIA dismissed Petitioner's appeal. The First Circuit denied Petitioner's petition for review, holding that Petitioner failed to establish eligibility for asylum, and for the same reasons, Petitioner also failed to establish that he was entitled to withholding of removal. View "Hernandez-Mendez v. Garland" on Justia Law

The First Circuit affirmed in part and vacated in part the district court's grant of summary judgment to the United States on Petitioner's claims brought under the Federal Tort Claims Act (FTCA) and to the Suffolk County Sheriff's Department (SCSD) on Petitioner's claims brought under the Rehabilitation Act (RHA), 29 U.S.C. 794, and Americans with Disabilities Act (ADA), 42 U.S.C. 12132, holding that the district court erred in granting summary judgment as to Petitioner's FTCA claims.Petitioner filed this action setting forth FTCA claims against the United States based on the treatment to which he was allegedly subjected while he was in immigration custody, as well as claims brought under the RHA and the ADA based on the alleged discrimination against him owing to his disability during his detention. The district court granted summary judgment for Defendants. The First Circuit vacated the judgment in part, holding that the district court (1) erred in granting summary judgment to the United States as it pertained to Petitioner's FTCA claims; but (2) did not err in awarding summary judgment to SCSD on Petitioner's RHA and ADA claims. View "Thiersaint v. Dep't of Homeland Security" on Justia Law

The First Circuit affirmed the decision of the Department of the Interior's Bureau of Indian Affairs (BIA) to take two parcels of land in Massachusetts into trust for the Mashpee Wampanoag Indian Tribe, holding that the BIA's application of its legal interpretation to the facts was not arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.Appellants brought this action challenging the Interior's 2021 record of decision reaffirming its 2015 decision to take the land into trust for the Tribe, arguing that the Tribe did not qualify as a "tribe" within the meaning of the Indian Reorganization Act, that the Tribe was not "under Federal jurisdiction," and that the parcel of land was not eligible activities under the Indian Gaming Regulatory Act. The district court granted summary judgment for the Interior and the Tribe. The First Circuit affirmed, holding that Appellants were not entitled to relief on any of their allegations of error. View "Littlefield v. U.S. Dep't of the Interior" on Justia Law

The First Circuit denied Petitioners' petitions seeking judicial review of two decisions by the Board of Immigration Appeals (BIA) - one affirming an immigration judge's (IJ) denial of their application for asylum, withholding of removal, and protection under the Convention Against Torture (CAT), and the other denying Petitioners' motion to reopen their proceedings, holding that Petitioners were not entitled to relief.Petitioners applied for relief from removal based on China's politics, specifically persecution by Chinese officials seeking to enforce China's Family Planning Policy, which was in effect when Petitioners first entered the United States. The IJ denied Petitioners' application, concluding that they failed to meet their burden of proof. The BIA dismissed Petitioners' appeal. The First Circuit denied Petitioners' petitions for review, holding that there was substantial evidence to support the agency's decisions in this case. View "M.S.C. v. Garland" on Justia Law