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

Articles Posted in U.S. 1st Circuit Court of Appeals

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Plaintiff received coverage under Johnson & Johnson’s Long-Term Disability Plan while working for a subsidiary of Johnson & Johnson. Later, Johnson & Johnson and Medical Card System, Inc. (together, Appellees) terminated Plaintiff’s long-term disability benefits. The district court upheld the denial, holding that the plan administrator had ample basis for finding Plaintiff did not cooperate fully during the Functional Capacity Examination (FCE) and was thus ineligible for continuing benefits. Plaintiff again appealed, arguing, among other things, that the plan administrator abused its discretion in crediting an examination by a physical therapist over the opinion of his treating physician. The First Circuit Court of Appeals affirmed, holding (1) the plan administrator’s finding that Plaintiff was uncooperative during his final FCE was supported by substantial evidence, and therefore, the administrator’s decision to terminate Plaintiff’s long-term disability benefits was neither arbitrary nor capricious; and (2) the administrator did not abuse its discretion in determining whether there existed grounds for termination of Plaintiff’s benefits. View "Ortega-Candelaria v. Johnson & Johnson" on Justia Law

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Appellant entered into a mortgage contract with Pawtucket Credit Union (PCU) for the purchase of real property in Rhode Island. The mortgage agreement included a private contractual remedy, authorized by R. I. Gen. Laws 34-11-22, that allowed PCU, in the event Appellant defaulted on her loan payments, to accelerate its loan and invoke its statutory power of sale. PCU later declared Appellant in default, invoked its statutory power of sale, and began the foreclosure process. Appellant filed suit against PCU in federal district court, alleging that foreclosure pursuant to section 34-11-22 violated her federal and state due process rights. The district court dismissed the case for lack of subject matter jurisdiction. The First Circuit Court of Appeals affirmed, holding that none of the statutory bases cited in Appellant’s complaint conferred federal jurisdiction. View "Grapentine v. Pawtucket Credit Union" on Justia Law

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This case arose from the misconduct of Annie Dookhan, a chemist at a Massachusetts state testing laboratory, who falsely certified drug testing results. Appellant was indicted for possession of crack cocaine with intent to distribute. Appellant pleaded guilty to the charge, but when news broke about Dookhan’s perfidy, Appellant moved to withdraw his plea. The district court denied relief, concluding that Appellant had not shown that Dookhan’s misconduct was material to his guilty plea. The First Circuit Court of Appeals affirmed, holding that the district court did not abuse its discretion in finding no fair and just reason for allowing Appellant to withdraw his guilty plea. View " United States v. Merritt" on Justia Law

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John Zullo paid David Lombardo to perform work in Zullo’s house. Lombardo, however, had misrepresented his credentials, and Zullo incurred additional expense to have the inadequate work fixed. Zullo subsequently obtained a Massachusetts state court judgment against Lombardo, which Lombardo never paid. After Lombardo later filed for Chapter 7 bankruptcy, Zullo began an adversary proceeding in the bankruptcy court, alleging that Lombardo’s debt to him was nondischargeable under 11 U.S.C. 532(a)(6), which excepts from bankruptcy discharge “any debt…for willful and malicious injury by the debtor to…to the property of another entity.” The bankruptcy court ultimately granted summary judgment for Lombardo on the 11 U.S.C. 532(a)(6) claim, and the Bankruptcy Appellate Panel affirmed. At issue before the First Circuit was whether the bankruptcy court erred in denying Zullo’s request for leave to amend his complaint. The First Circuit affirmed, holding that the bankruptcy court did not abuse its discretion in denying Zullo’s request where Zullo provided no explanation for the seventeen-month delay between filing his complaint and seeking leave to amend. View "Zullo v. Lombardo" on Justia Law

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After a jury trial, Defendant was convicted for being a felon in possession of a firearm and for possession of a firearm in a school zone. Defendant was sentenced to sixty months imprisonment on both counts. The First Circuit affirmed the conviction and sentence as to the felon in possession count but reversed the conviction and sentence as to the possession of a firearm in a school zone count, holding that the prosecution’s evidence was insufficient to prove the requisite element that Defendant knew or reasonably should have known he was in a school zone while possessing a firearm. View "United States v. Guzman-Montanez" on Justia Law

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Appellant pled guilty to robbery and brandishing a firearm during a robbery and was sentenced to prison sentences of seventy-two months and eighty-four months, to be served consecutively. Following the imposition of sentence, Appellant argued that the district court improperly departed upward from the applicable Guidelines sentencing range. The district court’s responded that the sentence was not a departure, but rather, the sentence was a variance. Appellant raised the same argument on appeal. The First Circuit affirmed, holding that Appellant received a sentence that in fact varied from the applicable Guidelines range, rather than an upward departure under the Guideliens, and there was no plain error in the variance. View "United States v. Aponte-Vellon" on Justia Law

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The United States sought extradition of Alexander Hilton, a U.S. citizen, to face an attempted murder charge in Scotland. A magistrate judge found Hilton extraditable despite Hilton’s arguments that extradition would increase his risk of suicide and that trial under the Scottish jury system would violate his U.S. Constitutional rights because Scotland requires only a simple majority for conviction. Hilton subsequently sought habeas corpus relief seeking to block extradition. The district court denied relief. The First Circuit affirmed, holding that Defendant’s claim that his extradition would violate his right to due process because of his high risk of suicide and his claim that extradition would violate his constitutional rights because Scotland allows simple majority jury verdicts were both barred by the rule of non-inquiry, which precludes the judicial system from evaluating the fairness and humaneness of another country’s criminal justice system. View "Hilton v. Kerry" on Justia Law

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After an oil drilling rig owned by BP Exploration & Production, Inc. and BP America Production Company (collectively, BP) sank of the Gulf Coast of Louisiana and caused a massive oil spill, Packagen, a manufacturer of packaging products, sought to sell containment boom to BP. Packagen began producing boom after the oil spill, but BP never paid for any of the boom manufactured by Packagen. Packagen filed a five-count complaint against BP in federal district court, invoking diversity jurisdiction and alleging various state-law claims. The district court granted summary judgment in favor of BP. The First Circuit affirmed, holding that the district court did not err in granting summary judgment on Packagen’s negligent and intentional misrepresentation claims, breach of contract claim, unjust enrichment and quantum meruit claim, and promissory estoppel claim. View "Packgen v. BP Exploration & Prod., Inc." on Justia Law

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Katie Graf was injured on the premises of Fat Cat Bar & Grill. Graf was awarded $500,000 in damages and $111,124 in prejudgment interest against Torcia & Sons, Inc, the owner of Fat Cat. Torcia was insured by Hospitality Mutual Insurance Company under a liquor liability insurance policy. Hospitality disclaimed liability for the prejudgment interest portion of the award. Consequently, Graf was granted a writ of attachment on Torcia’s liquor license to secure the excess payment. Graf and Torcia sought payment from Hospitality for the cost of a bond to release the attachment. When Hospitality refused, the parties entered into a settlement agreement under which Graf discharged the attachment of the liquor license and Torcia assigned its rights against Hospitality to Graf. Graf sued Hospitality. A federal judge granted Hospitality’s motion to dismiss, concluding (1) the $500,000 damages award represented the full extent of recoverable proceeds under the policy, and (2) to require Hospitality to pay for the cost of the bond would have expanded Hospitality’s liability in contravention of the terms of the policy. The First Circuit affirmed, holding that the policy unambiguously obligated Hospitality to pay the cost of bonds only for bond amounts that, together with any other liabilities, fell within the liability cap of $500,000. View "Graf v. Hospitality Mut. Ins. Co." on Justia Law

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Mother, a citizen of Colombia who entered the United States illegally, and Father, a naturalized U.S. citizen, married and had a daughter, E.G., born in Massachusetts. When E.G. was two years old Mother and E.G. moved to Columbia, where they lived for two-and-a-half years. E.G. then moved back to the United States to live with Father. When E.G. was five years old, Mother and Father divorced, and Father was granted sole legal and physical custody of E.G. Mother filed a petition pursuant to the Hague Convention on the Civil Aspects of International Child Abduction, alleging that Father wrongfully retained E.G. in the United States. The district court denied Mother’s petition, concluding that the United States was E.G.’s place of habitual residence, and therefore, E.G.’s retention was not wrongful under the Hague Convention. The First Circuit affirmed, holding that E.G.’s habitual residence was the United States, and therefore, Father did not wrongfully retain her under the Hague Convention. View "Sanchez-Londono v. Gonzalez" on Justia Law