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

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

The Supreme Court affirmed the decision of the district court entering summary judgment for the United States and rejecting the lawsuit brought by Appellant asking the district court to overturn the finding of the Food and Nutrition Service (FNS) of the United States Department of Agriculture that Appellant was disqualified from further participation in the supplemental nutrition assistance program (SNAP), holding that there was no error.FNS disqualified Appellant from further participation in SNAP after investigating evidence of unlawful trafficking in SNAP benefits. Thereafter, Appellant brought this action seeking to overturn the FNS's liability finding and asking the court to vacate the order of program disqualification as arbitrary and capricious. The district court entered summary judgment for the United States. The Supreme Court affirmed, holding (1) the district court did not err in entering summary judgment in favor of the United States on the liability issue; and (2) the sanction of the permanent disqualification order from the program was neither arbitrary nor capricious. View "AJ Mini Market, Inc. v. United States" on Justia Law

The First Circuit affirmed the judgment of the district court determining that Act 90, passed by the Legislative Assembly of Puerto Rico in 2019, was preempted by federal law, holding that the district court did not err.Act 90 requires that Medicare Advantage plans compensate Puerto Rico healthcare providers in Puerto Rico at the same rate as providers are compensated under traditional Medicare. Plaintiffs, several entities that managed Medicare Advantage plans, filed suit seeking a declaratory judgment and an injunction barring the "mandated price provision," arguing that the Medicare Advantage Act preempted the challenged provision and that provision was unconstitutional. The district court ruled in favor of Plaintiffs. The First Circuit affirmed, holding that Act 90's mandated price provision was preempted by federal law. View "Medicaid & Medicare Advantage Products Ass'n of Puerto Rico, Inc. v. Emanuelli-Hernandez" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's motion for attorneys' fees, which he filed more than two years after successfully representing Appellee before both the Social Security Administration (SSA) and the district court, holding that the district court properly denied the motion as untimely.In his motion requesting attorneys' fees under 42 U.S.C. 406(b), Appellant argued that the statute does not contain a fixed time for filing a section 406(b) petition. The district court denied the fee request as untimely, concluding that such a motion must be filed within a reasonable time of the SSA's decision awarding benefits. The First Circuit affirmed, holding that, given that Appellant failed to file his section 406(b) petition in a timely manner, the district court did not err in denying his request for attorneys' fees. View "Pais v. Kijakazi" on Justia Law

In this case arising from what the Social Security Administration (SAA) did to Appellants, Marie Pagan-Lisboa and Daniel Justiniano-Ramirez, after Jose Hernandez-Gonzalez and Samuel Torres-Crespo admitted to fraudulently helping people get disability-insurance benefits from the SAA, the First Circuit held that Appellants were entitled to a new redetermination proceeding.With the help of Hernandez-Gonzalez and Torres-Crespo, Pagan-Lisboa applied for and started getting disability benefits from the SAA. An ALJ determined that Pagan-Lisboa did not have sufficient evidence to support her initial benefits claim and terminated her benefits. An ALJ also canceled Justiniano-Ramirez's benefits benefits on the grounds that Hernandez-Gonzalez had provided fraudulent evidence in support of the benefits. Thereafter, Appellants sued a putative class action, arguing that the SAA could not terminate their benefits without letting them contest the existence of fraud in their cases. The court of appeals affirmed the ALJ's decision in Justiniano-Ramírez's case and remanded Pagan-Lisboa's case back to the agency. The First Circuit held (1) the judge erred in not accepting Justiniano-Ramírez's amended complaint, which showed that he had exhausted his administrative remedies; and (2) the judge did not wrongly dismiss Appellants' policy challenges to the redetermination procedure. View "Pagan-Lisboa v. Social Security Administration" on Justia Law

The First Circuit dismissed these consolidated appeals, and a companion appeal, arising out of long-running litigation between Puerto Rico and several Federally Qualified Health Centers (FQHCs) over the Commonwealth's failure to make payments to the FQHCs, holding that the orders appealed from were void.Here, the FQHCs asserted new claims that the Commonwealth failed fully to pay the statutorily required reimbursement amounts for the services they provided to underserved patients under the Medicaid Act. The First Circuit dismissed the appeals, holding that the Court lacked jurisdiction to resolve the merits of the underlying orders because they were void. View "HealthproMed Foundation, Inc. v. Department of Health And Human Services" on Justia Law

The First Circuit affirmed the district court's judgment reversing the magistrate's order that had quashed an administrative subpoena duces tecum as to the recordings of certain telephone conversations, holding that the magistrate judge clearly erred in finding that Appellants met their burden of proving that an employer's interception of the telephone calls was intentional.When investigating whether Patient Services, inc. (PSI) had engaged in an illegal kickback scheme, the Government issued an administrative subpoena duces tecum to PSI for all recorded conversations of PSI officers and employees. This appeal concerned conversations that were recorded on the extension of Karen Middlebrooks. Middlebrooks's telephone conversations were recorded while she was working in PSI's call center on the second floor where calls were regularly recorded. At issue was whether PSI intentionally continued recording Middebrooks's calls after her transfer to the third floor, where calls were not regularly recorded, in violation of Title III of the Omnibus Crime Control and Safe Streets Act. The magistrate judge ruled that the recordings violated Title III. The district court reversed. The First Circuit affirmed, holding that the magistrate judge clearly erred in finding that Appellants met their burden of proving that PSI's interception of calls from Middlebrooks's extension after her move to the third floor was intentional. View "In re HIPAA Subpoena" on Justia Law

The First Circuit affirmed the order of the district court finding that Plaintiff was disabled as defined under 20 C.F.R. 404.1520 and awarding her benefits, holding that there was very strong evidence of Plaintiff's disability, without any contrary evidence, to justify an award of benefits.At age thirty-four, Plaintiff filed applications for Social Security Disability Benefits and Supplemental Security Income. The Commissioner of Social Security denied Plaintiff's applications. In an independent assessment of her claim, an ALJ agreed with the Commissioner's decision, finding that Plaintiff was not disabled as defined under the Social Security Act. A federal magistrate judge found that substantial evidence did not support the ALJ's denial of benefits and recommended reversing the Commissioner's decision and remanding the case for further development of the facts. The district court agreed with the magistrate judge's findings but bypassed the need for further fact-finding and awarded benefits. The First Circuit affirmed, holding that there was overwhelming evidence to support a finding of disability and an award of benefits and that a remand for further proceedings was unnecessary. View "Sacilowski v. Saul" on Justia Law

The First Circuit issued this narrow opinion in response to the Commonwealth of Massachusetts's appeal from the district court's denial of its "Motion Regarding Substantial Compliance and To Terminate Monitoring and Court Supervision" and reversed, holding that the district court's analysis was flawed.The underlying suit was long-running class-action litigation concerning the Commonwealth of Massachusetts's compliance with federal statutory requirements for provision of services to a plaintiff class of Medicaid-eligible children with serious emotional disturbances. The district court found the Commonwealth liable for violating Medicaid provisions as to "reasonable promptness" and "early and periodic screening, diagnosis, and treatment" services. The court then issued remedial orders and a court monitor was appointed. Later the Commonwealth filed the motion at issue. Plaintiffs agreed that the court could terminate monitoring and reporting over the portions of the judgment the Commonwealth was in substantial compliance with. The district court denied the motion in its entirety. The First Circuit reversed, holding that the district court's analysis was flawed from the outset. View "Rosie D. v. Baker" on Justia Law

The First Circuit declared that exclusion of otherwise eligible residents of Puerto Rico from receiving the disability benefits that are granted to persons residing in the fifty States, the District of Columbia, and the Northern Mariana Islands under the Supplemental Security Income (SSI) provisions of Title XVI of the Social Security Act, 42 U.S.C. 1381-1383(f) is not rationally related to a legitimate government interest and is invalid.While residing in New York, Defendant became eligible and commenced receiving SSI disability benefits. The benefits were discontinued when the Social Security Administration became award that Defendant had moved to Puerto Rico. The United States subsequently brought suit against Defendant seeking to collect the amount the SSA claimed was owed by Defendant due to the allegedly improper payment of SSI benefits since Defendant's relocation to Puerto Rico. Defendant raised as an affirmative defense that the exclusion of Puerto Rico residents from the SSI program violated the Equal Protection Clause. The district court granted summary judgment for Defendant, holding that Congress's actions in this case failed to pass rational basis constitutional muster. The First Circuit affirmed, holding that the Fifth Amendment forbids the categorial exclusion of Puerto Rico residents from SSI coverage. View "United States v. Vaello-Madero" on Justia Law