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

Sterling Suffolk Racecourse, LLC (SSR) applied for a license to place a casino in certain areas of Massachusetts. Caesars Entertainment Corporation and three Massachusetts affiliates (collectively, Caesars) were the proposed operators of the casino. The Massachusetts Gaming Commission issued an investigatory report concluding that Caesars was unsuitable as an operator, which caused Caesars to accede to SSR’s request that it withdraw from their contractual relationship. Caesars brought this action under 28 U.S.C. 1983 against certain Commission officials in their individual and official capacities and also brought a state law claim subject to supplemental jurisdiction. The district court dismissed the federal claims under Fed. R. Civ. P. 12(b)(6) as beyond the scope of federal affordable relief and dismissed the state law claim as standing alone. The First Circuit affirmed, holding (1) because Caesars alleged no cognizable protected property interest, its Fifth and Fourteenth Amendment due process claims were correctly dismissed for failure to state a claim; and (2) Caesars’ class-of-one Fourteenth Amendment equal protection claim could not be recognized against a state actor given the breadth of discretion provided by the Massachusetts casino licensing statute. View "Caesars Mass. Dev. Co., LLC v. Crosby" on Justia Law

In 2008, removal proceedings were commenced against Petitioner, a Guatemalan national. Petitioner conceded removability and cross-applied for discretionary relief under the Nicaraguan Adjustment and Central American Relief Act (NACARA) in the form of special rule cancellation of removal or for asylum, withholding of removal, or protection under the United Nations Convention Against Torture (CAT). An Immigration Judge (IJ) denied Petitioner’s NACARA claim, concluding (1) special rule cancellation of removal under NACARA was not an appropriate exercise of discretion; and (2) Petitioner's remaining claims were without merit. The Board of Immigration Appeals (BIA) upheld the IJ’s decision. The First Circuit dismissed Petitioner’s petition for judicial review for want of jurisdiction, holding (1) under the circumstances of this case, the Court lacked jurisdiction to review the BIA’s denial of special rule cancellation of removal; and (2) Petitioner’s remaining claims of error were unexhausted and, thus, unsuitable for judicial review. View "Ramirez-Matias v. Holder" on Justia Law

In 2011, the Department of Health and Human Services (“Department”) directly awarded federal grant funds to Planned Parenthood of Northern New England (“Planned Parenthood”). New Hampshire Right to Life filed a lawsuit under the Freedom of Information Act (“FOIA”) seeking documents related to the Department’s decision to award the federal grant to Planned Parenthood. The Department released more than 2,500 pages of documents but withheld documents, citing FOIA exemptions for confidential commercial information and inter- or intra-agency memoranda. The district court concluded that the “vast majority” of documents were properly withheld under FOIA exemptions 4 and 5. The First Circuit affirmed the district court’s rulings, holding that the Department met its burden to show that exemption 4 applied to Planned Parenthood’s submitted documents and that exemption 5 applied to the Department’s withheld internal documents. View "N.H. Right to Life v. U.S. Dep’t of Health & Human Servs." on Justia Law

Federal authorities instituted removal proceedings against Petitioner, a Chinese national. Petitioner failed to appear at the scheduled hearing, and an immigration judge (IJ) entered an order of removal in absentia. Almost a decade later, Petitioner moved to reopen his removal proceedings, alleging ineffective assistance of counsel. The IJ denied the motion to reopen as untimely. Petitioner unsuccessfully appealed to the Board of Immigration Appeals (BIA). Petitioner sought judicial review, which was interrupted by the First Circuit’s remand of the case upon a motion by the government for consideration of whether Petitioner qualified for relief based on changed circumstances in his homeland. The BIA concluded that Petitioner failed to present evidence demonstrating a material change in China’s country conditions since he was ordered removed. Petitioner then filed a new petition for judicial review. The First Circuit denied the petitions for review, holding (1) Petitioner was not entitled to an exception to the filing deadline due to lack of notice; (2) the IJ did not abuse her discretion in failing to apply equitable tolling; and (3) the First Circuit lacked jurisdiction to hear and determine Petitioner’s claim that the BIA engaged in impermissible factfinding. View "Wan v. Holder" on Justia Law

Appellant had leased the same apartment at a San Juan, Puerto Rico housing cooperative (Cooperative) for several years. While living at the cooperative, Appellant received benefits under the Section 8 federal housing assistance program, which enabled her to pay her rent. When the Housing Finance Authority concluded that Appellant’s apartment unit was “over-housed” for Section 8 purposes, the Cooperative informed Appellant that she would have to pay market-rate rent without the Section 8 assistance. Appellant subsequently submitted a request to the Cooperative for reasonable accommodation on account of her disability, stating that she could not move to a different unit without compromising her health. The Cooperative denied Appellant’s request. After filing an administrative complaint without success, Appellant filed suit in federal court, alleging that the Cooperative had violated the Fair Housing Act by failing to provide the requested accommodation, by engaging in a pattern of discriminatory actions against her, and by retaliating against her because she had recently prevailed in a separate HUD proceeding against the Cooperative. The district court (1) found in the defendants’ favor regarding the reasonable accommodation and disparate treatment claims; and (2) concluded that it lacked jurisdiction to decide the retaliation claim. The First Circuit (1) affirmed the district court’s grant of summary judgment on the reasonable accommodation and disparate treatment claims; and (2) reversed the district court’s decision to dismiss Appellant’s retaliation claim, holding that the district court had jurisdiction to decide this claim. View "Batista v. Cooperativa de Vivienda" on Justia Law

At issue in this case was services that Maine Medical Center provided to Medicare/Medicaid “dual-eligible” patients, that is, patients covered by both Medicare and the state-administered Medicaid insurance program, MaineCare. The Secretary for the Department of Health and Human Services denied Maine Medical’s claim for partial federal reimbursement of “bad debt” for the fiscal years 2002 and 2003. A “bad debt” is an amount considered to be uncollectible for covered services that may be eligible for federal reimbursement under certain conditions. The Secretary denied reimbursement because Maine Medical had not acquired from MaineCare a state-issued remittance advice to use as proof. The district court affirmed. The First Circuit affirmed, holding that it was not arbitrary and capricious for the Secretary (1) to demand that Maine Medical provide documentation from the State confirming the identity of Medicaid-eligible beneficiaries and qualified Medicare beneficiaries, the amount that is the State’s to pay, and the State’s refusal to pay; and (2) to deny Maine Medical’s reimbursement claims that were unsupported by such documentation. View "Me. Med. Ctr. v. Burwell" on Justia Law

South Kingstown School Committee (Committee) runs one of Rhode Island’s public school districts. Rhode Island has accepted federal funding under the Individuals with Disabilities Education Act (IDEA). Appellant, the mother of P.J., a disabled child the Committee was responsible for educating, filed a due process complaint seeking additional educational services for P.J. from the Committee. The Committee settled with Appellant pursuant to a Settlement Agreement under which the Committee agreed to perform four evaluations of P.J. After Appellant demanded ten additional evaluations, the Committee filed a due process complaint of its own. A Hearing Officer ruled against the Committee, concluding that some of the evaluations of P.J. had not been appropriate. The Committee then filed suit in federal district court. The district court reversed. The First Circuit affirmed, holding (1) the district court did not err in determining that the Settlement Agreement relieved the Committee of any obligation to perform or fund one of the evaluations; and (2) the district court did not err in concluding that there was insufficient factual support for Appellant’s other evaluation request. Remanded. View "S. Kingstown Sch. Comm. v. Joanna S." on Justia Law

This long-running dispute over Puerto Rico’s dairy industry resulted in the principal parties settling. Pursuant to the settlement, the Department of Agriculture for the Commonwealth of Puerto Rico and others (collectively, the "Department") agreed to promulgate a regulation that would significantly rework the pricing and structure of the dairy market. Intervenors Industria Lechera de Puerto Rico, Inc. ("Indulac") and the Puerto Rico Dairy Farmers Association, who were excluded from the bargaining table, objected to the settlement, alleging that the regulation violated Puerto Rico’s constitutional and statutory law. The district court approved the settlement agreement. Indulac appealed. The First Circuit dismissed the appeal, holding that it lacked appellate jurisdiction to hear Indulac’s appeal because it was untimely. View "Vaqueria Tres Monjitas, Inc. v. Industria Lechera de P.R., Inc." on Justia Law

The National Oceanic and Atmospheric Administration (NOAA) issued Frontier Fishing a notice of violation and assessment and a notice of permit sanction after determining that Frontier Fishing was liable for trawling in a restricted gear area in violation of regulations promulgated under the Magnuson-Stevens Fishing Conservation and Management Act. Frontier Fishing denied liability. On appeal, Frontier Fishing argued that the record lacked substantial evidence for a rational finding that its vessel trawled in the restricted area. The district court upheld the NOAA Administrator’s final decision. The First Circuit affirmed, holding that substantial evidence supported the NOAA’s finding. View "Frontier Fishing Corp. v. Pritzker" on Justia Law

Petitioner, an Indonesian citizen, submitted an application for asylum, alleging that she experienced persecution as an Indonesian Christian. An Immigration Judge (IJ) denied Petitioner’s application for asylum and granted her request for voluntary departure, concluding that Petitioner’s account did not rise to the level of past persecution, nor did Petitioner demonstrate that she would be persecuted if she returned to Indonesia. The Board of Immigration Appeals (BIA) affirmed the IJ’s decision and dismissed Petitioner’s appeal. The First Circuit granted Petitioner’s petition for review and vacated the order of removal, holding that the IJ’s and BIA’s legal conclusions were not supported by substantial evidence in the record. Remanded to the BIA to make a well-reasoned determination as to Petitioner’s eligibility for asylum. View "Panoto v. Holder" on Justia Law