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

Plaintiffs were Massachusetts-based producers of “reggaeton” music. This case centered on seven songs released on an album distributed by Defendants that allegedly infringed upon copyrights held by Plaintiffs and breached contracts to which Plaintiffs claimed to be parties and/or third-party beneficiaries. The district court granted Defendants’ motion for summary judgment, concluding (1) with respect to the copyright claims, Plaintiffs failed to register their copyrights in the underlying compositions they claimed were infringed, as required under 17 U.S.C. 411(A); and (2) with respect to the breach of contract claims, there was no evidence of a direct agreement between the parties or of third-party beneficiary status. The First Circuit Court of Appeals affirmed, holding that the district court did not err in granting summary judgment for Defendants on the copyright and contract claims. View "Alicea v. Ayala" on Justia Law

Plaintiff, who worked for Metropolitan Life Insurance Co. (“MetLife”), made a claim for long-term disability benefits (LTD). In 2005, the claim was approved. That same year, MetLife denied Plaintiff’s assertion that he was entitled to a larger payment calculation. In 2012, Plaintiff filed suit against MetLife under the Employee Retirement Income Security Act of 1974 (ERISA), claiming that MetLife had been underpaying his monthly benefits since 2005. The district court granted MetLife’s motion for summary judgment, concluding that Plaintiff’s suit was barred by the six-year statute of limitations. The First Circuit Court of Appeals affirmed, thus rejecting Plaintiff’s theory that the LTD plan must be analogized to an installment plan so as to alter the accrual date of his claim, holding that Plaintiff’s claim against MetLife was barred by the statute of limitations. View "Riley v. Metro. Life Ins." on Justia Law

Defendant pleaded guilty to carjacking resulting in serious bodily injury, use of a firearm during and in relation to a crime of violence, and possession of a stolen firearm. Defendant was sentenced to a term of immurement above the top of the applicable guideline sentencing range. On appeal, Defendant contended that his sentence was procedurally flawed and substantively unreasonable because the sentencing court focused too little on the potentially mitigating factors of his upbringing and mental capacity and too much on the high incidence of crime in the community. The First Circuit Court of Appeals affirmed Defendant’s sentence, holding that the sentence the district court chose was not unreasonable. View "United States v. Santiago-Rivera" on Justia Law

A law enforcement officer placed a GPS device on Defendant’s vehicle without a warrant and used that device to track Defendant’s movements for forty-seven days. The GPS monitoring ultimately led to Defendant being charged with, and pleading guilty to, possessing and conspiring to possess heroin with the intent to distribute it. After Defendant moved to suppress the evidence obtained as a result of the warrantless GPS monitoring, the Supreme Court decided United States v. Jones, which held that the installation and use of a GPS tracker on an automobile constitutes a Fourth Amendment search. The district court denied Defendant’s motion to suppress, determining that the exclusionary rule should not apply in this case because the officers had relied in good faith on pre-Jones legal precedent. Before the parties briefed the case on appeal, the First Circuit Court of Appeals decided United States v. Sparks, in which the Court held that eleven days of pre-Jones warrantless GPS tracking fell under the good-faith exception to the exclusionary rule. The First Circuit affirmed, holding that, for the reasons articulated in Sparks and United States v. Baez, another case decided today, the exclusionary rule applied to the officers’ warrantless GPS monitoring of Defendant's vehicle. View "United States v. Oladosu" on Justia Law

Defendant pled guilty to four counts of arson. On appeal, Defendant argued that the district court erred by denying his motion to suppress evidence that the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) obtained by monitoring his automobile using a global positioning system (GPS) device. The ATF began the GPS tracking, without a warrant, in August 2009 and continued for nearly one year. After Defendant filed his notice of appeal, the First Circuit Court of Appeals decided United States v. Sparks, in which the Court held that the warrantless installation of a GSP device on a defendant’s car and the use of that device to monitor the defendant’s movements for eleven days fell within the good-faith exception to the exclusionary rule because the monitoring had occurred before the U.S. Supreme Court decided United States v. Jones, which held that the installation and use of a GPS tracker on an automobile constitutes a Fourth Amendment search. In the instant case, the First Circuit affirmed the denial of Defendant’s suppression motion, holding that this case fell within the rule laid out in Sparks, although the pre-Jones warrantless GPS tracking was of a significantly longer duration than that in Sparks. View "United States v. Baez" on Justia Law

The IRS held a tax lien against Patrick Hannon’s property, including a parcel of land Hannon owned in Newton, Massachusetts. The IRS discharged that specific parcel from its tax lien under 26 U.S.C. 6325(b)(2)(A) to allow the City of Newton could take the property by eminent domain, and the IRS authorized the discharge upon its receipt of a portion of the amount paid by Newton. Following the taking, Hannon sued Newton in Massachusetts state court and was awarded damages for undercompensation. Both the government and Rita Manning, a lower-priority creditor who had obtained a judgment against Hannon, intervened and asserted priority to receive the damages award. A federal district court entered summary judgment in favor of Manning on the issue of whose lien had priority, concluding that the IRS’s decision to discharge the property from federal tax liens in exchange for payment from the taking meant the government had relinquished any tax lien on the later damages award. The First Circuit Court of Appeals reversed, holding (1) the IRS certificate issued under section 6325(b)(2)(A) did not release any claims the IRS had on the post-taking proceeds awarded to Hannon; and (2) the IRS tax lien on those post-taking proceeds was valid and thus senior to Manning’s judgment lien. View "Hannon v. United States" on Justia Law

Harold Evans-Garcia and Eric Joel Carrion-Cruz (together, Defendants) were each convicted of a carjacking resulting in death and sentenced to life imprisonment without the possibility of parole. Both Defendants committed the crimes when they were younger than eighteen years old. Each of them unsuccessfully appealed and petitioned for habeas relief. Subsequently, the U.S. Supreme Court decided Miller v. Alabama, in which the Court held that the Eighth Amendment to the U.S. Constitution forbids a sentencing scheme that mandates life imprisonment without the possibility of parole for juvenile offenders. Thereafter, Defendants sought certification to pursue a new habeas petition to secure a potential reduction in their sentences pursuant to Miller. The First Circuit Court of Appeals granted certification to Evans-Garcia but denied it to Carrion-Cruz, holding (1) Evans-Garcia made a prima facie case showing that the new rule announced in Miller qualified as a basis for habeas relief on a second or successive petition; but (2) Carrion-Cruz’s request must be denied because he was not sentenced pursuant to any statute or guideline that mandated a sentence of life without parole. View "Evans-Garcia v. United States" on Justia Law

On September 22, 2011, a grand jury returned a one-count indictment charging Appellant with conspiracy to defraud the United States. The indictment alleged that, from about March 29, 2005 until at least June 22, 2007, Appellant knowingly and willfully participated in a sham marriage to secure a change in immigration status for her spouse. Appellant filed a motion to dismiss the indictment as time-barred, alleging that she committed no overt act in furtherance of the conspiracy within the five-year period before the return of the indictment. Following a bench trial, Appellant was convicted of the charge. On appeal, Appellant revived her argument that the indictment should have been dismissed as time-barred because the conspiratorial object was achieved on October 7, 2005, when her spouse attained conditional lawful permanent resident status, and any subsequent acts could not have been in furtherance of an already-completed conspiracy. The First Circuit Court of Appeals affirmed, holding that the district court correctly found Appellant’s signing of Form I-751 on June 22, 2007 on her spouse’s behalf was an overt act committed in furtherance of the objects of the conspiracy as alleged in the indictment. View "United States v. Stewart" on Justia Law

Appellant was charged with possessing body armor after having been convicted of a “crime of violence” as defined by 18 U.S.C. 16. The crimes that Appellant was previously convicted of under Massachusetts law included breaking and entering in the daytime, breaking and entering at night, assault and battery with a dangerous weapon, and possession of a burglarious instrument. The district court ruled that, at a minimum, Appellant’s convictions for breaking and entering satisfied the requirements of section 16. Appellant entered a condition guilty plea to the offense, reserving the right to challenge the determination that he had previously been convicted of a crime of violence. The First Circuit Court of Appeals reversed Appellant’s conviction, holding that none of the crimes for which Appellant was previously convicted, as defined under Massachusetts law, qualified as a crime of violence under section 16. View "United States v. Fish" on Justia Law

After a jury trial in the U.S. District Court, Appellant was convicted of possession of a firearm by a convicted felon and possession of a firearm with an obliterated serial number. Prior to trial, Appellant unsuccessfully moved to suppress incriminating statements he made to police over the course of several encounters, arguing that any waiver of his Miranda right to remain silent was a product of threats and coercion. On appeal, Appellant contended that the district court failed to instruct the jury, under 18 U.S.C. 3501(a), to “give such weight to the confession as the jury feels it deserves under all the circumstances.” The First Circuit Court of Appeals affirmed, holding (1) there was no meaningful difference between the instruction called for by section 3501 and the instruction given at Appellant’s trial; and (2) even if courts should follow more closely the precise language of section 3501, any error on the court’s part to do so in this case went unchallenged and was unlikely to have affected the outcome of Appellant’s trial. View "United States v. Colon" on Justia Law