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

The City of Springfield enacted two local ordinances that imposed new legal duties on (1) property owners to maintain property during the foreclosure process and provide a $10,000 cash bond per foreclosure to the City, and (2) mortgagees to attempt a settlement through negotiations before foreclosing. In dispute was the definition of "owner" in the first ordinance, which included mortgagees who were not in possession and had begun the foreclosure process. The ordinance imposed the duties on the mortgagees whether the mortgagors were still in possession. Six banks sued in state court, seeking to have the ordinances invalidated as inconsistent with and preempted by comprehensive state laws governing foreclosure and property maintenance and as inconsistent with state and federal constitutional guarantees. The case was removed to federal district court, which concluded that the ordinances were valid. The banks appealed. The First Circuit Court of Appeals certified dispositive state law questions to the Massachusetts Supreme Judicial Court because the outcome of the case depended on unresolved questions of Massachusetts law and raised significant policy concerns better suited for resolution by that state court. View "Easthampton Savings Bank v. City of Springfield" on Justia Law

Plaintiff invented the "Whirlwind" technology for cutting tools. Defendant sought to purchase the Whirlwind technology from Plaintiff. The two men signed a letter of intent that memorialized the parties' mutual intention to negotiate and contained a choice-of-law provision directing the application of Washington law. After the transaction fell through, Plaintiff sued Defendant in Massachusetts state court, seeking, inter alia, a declaration that the LOI was an enforceable contract and pecuniary damages for breach of contract. Defendant removed the case to federal court. The district court granted Defendant's motion to dismiss for failure to state a claim, concluding that Washington would not recognize contracts to negotiate as enforceable. The First Circuit Court of Appeals vacated the district court's judgment in its entirety, holding (1) the Washington Supreme Court would, in all probability, recognize the enforceability of contracts to negotiate; and (2) the complaint plausibly stated a cause of action for breach of a contract to negotiate. View "Butler v. Balolia" on Justia Law

In 2006, Appellant pled guilty to possession of cocaine with intent to distribute. Appellant was sentenced to a prison term plus supervised release, but the district court later revoked Defendant's term of supervised release and imposed a new supervised release term. While serving his second term of supervised release, Appellant pled guilty to three supervised release violations. Following a hearing, the district court revoked the extant term of supervised release and sentenced Appellant to a flat incarcerative term. Appellant appealed, arguing primarily that the district court violated Fed. R. Crim. P. 32(i)(3)(B) by failing to make rulings on controverted issues of fact raised at sentencing. The First Circuit Court of Appeals affirmed the sentence without deciding whether Rule 32 applies to a sentencing proceeding that follows the revocation of a term of supervised release, holding that Appellant failed to make out a viable claim under Rule 32(i)(3)(B). View "United States v. Gonzalez" on Justia Law

Because Munce's Superior Petroleum Products, Inc. (MSPP) failed to comply with a state court order compelling it to bring its facilities into compliance with New Hampshire environmental law, $194,220 in contempt fines was levied against MSPP. The state court orders were issued after MSPP filed a Chapter 11 bankruptcy petition, although the violations of New Hampshire law began before MSPP filed its Chapter 11 petition. The New Hampshire Department of Environmental Services filed a motion to give the fines administrative expense priority, which the bankruptcy court granted. The district court affirmed. The First Circuit Court of Appeals affirmed, holding that, under the circumstances of this case, the post-petition contempt fine assessed by the New Hampshire state court against MSPP, a debtor-in-possession, was entitled to administrative expense priority. View "Munce's Superior Petroleum Prods., Inc. v. N.H. Dep't of Envtl. Servs." on Justia Law

Under the Workforce Investment Act of 1998 (WIA), Maine obtained federal funding to strengthen local workforces. Plaintiff was the executive director of the Local Area I Workforce Investment Board (LWIB). Plaintiff reported to and received her salary from Aroostook County, and the County used WIA funds for this purpose. Federal monitors from the Department of Labor undertook a compliance review of the LWIB and found that Plaintiff's job description was not in compliance with federal program requirements because, absent an express agreement between the LWIB and the County, the County could not be Plaintiff's employer. Plaintiff transmitted results of the federal monitoring visit but did so as part of her job responsibilities. The Northern Maine Development Commission, Inc. (NMDC) was later designated as the fiscal agent for the LWIB, and Plaintiff's employment was terminated. Plaintiff applied for NMDC's director of workforce development petition was not hired. Plaintiff then filed this Maine Whistleblowers' Protection Act (MWPA) action against NMDC for violating the whistleblower law. The district court granted summary judgment for NMDC. The First Circuit Court of Appeals affirmed, holding that, on the undisputed facts, Plaintiff was not a whistleblower under the MWPA and so had no claim against NMDC. View "Winslow v. Aroostook County" on Justia Law

Defendant was indicted in 2012 for possession of a firearm by a felon based on his prior predicate conviction in 1995 of a state felony. Defendant moved to dismiss the count, arguing that he could not be classified as a felon under 18 U.S.C. 922(g)(1) because he had his civil rights to sit on a jury and to hold public office restored as a matter of New Hampshire state law. At issue was whether Defendant's right to serve on a New Hampshire jury was restored before the date of the federal offense. The district court adopted Defendant's reading of New Hampshire's juror eligibility statutes and dismissed the felon in possession charge. The First Circuit Court of Appeals certified to the New Hampshire Supreme Court the question of law of whether Defendant's right to serve on a New Hampshire jury was restored as of the date of the federal crime under the New Hampshire Revised Statutes. View "United States v. Howe" on Justia Law

Petitioners, natives and citizens of Russia, overstayed their visas and applied for asylum, withholding of removal, and relief under the Convention Against Torture (CAT). An immigration judge (IJ) denied Petitioners' applications but granted them voluntary departure. In regards to Petitioners' asylum application, the IJ found that Petitioner Pavel Ivanov's testimony about mistreatment he experienced because of his Pentecostal faith was credible and consistent, but that the persecution Ivanov experienced in Russia was not "on account of" his Pentecostal faith. The Board of Immigration Appeals (BIA) summarily affirmed the IJ's asylum determination. The First Circuit Court of Appeals vacated the order of the BIA affirming the IJ's decision and remanded for further proceedings, holding that Ivanov established his eligibility for asylum. View "Ivanov v. Holder" on Justia Law

This case concerned a plumbers and pipefitters union ("the Union"), which established employee benefits plans. Among the pension benefits promised to Union employees were "banked hour" benefits, which were retroactively conferred during the course of employment. The Pension Trust sought to eliminate the benefits in an attempt to meet its obligations to a larger group of plan participants. Plaintiffs, now-retired union employees, filed this action against the Trustees, alleging that the cuts, which were effectuated through a plan amendment, violated the anti-cutback provisions ERISA, which protects "accrued benefits" against reduction by amendment. The district court entered summary judgment for Plaintiffs. The First Circuit Court of Appeals affirmed, holding that Plaintiffs' benefits were in fact "accrued" and that the plan amendment, if implemented, would violate the anti-cutback provisions of ERISA. View "Bonneau v. Plumbers & Pipefitters Local Union 51 Pension Trust Fund" on Justia Law

After a thirty-seven-day jury trial, Appellant was convicted of four terrorism-related counts and three counts premised on allegedly false statements and sentenced to a 210-month term of immurement. Defendant appealed, challenging, inter alia, his convictions on the four terrorism-related counts on the grounds that they were neither supported by the evidence nor constitutionally permissible. The First Circuit Court of Appeals affirmed, holding (1) the evidence was sufficient to convict Defendant on the four terrorism-related counts and on the false statement counts; (2) the trial court did not prejudicially err in its evidentiary rulings; (3) Defendant's convictions were constitutional; and (4) the district court did not err in sentencing Defendant. View "United States v. Mehanna" on Justia Law

Cadlerocks Centennial Drive, LLC entered into a loan secured by a mortgage on its property. Daniel Cadle executed a personal guaranty on the loan. The original lender subsequently assigned the mortgage and related documents to Wells Fargo Bank as trustee for registered holders ("Trust"). ORIX Capital Markets, LLC was the special servicer of the Trust and began servicing the loan. Cadlerocks later defaulted on its loan, after which the Trust commenced foreclosure proceedings. ORIX then filed this lawsuit against Cadlerocks and Cadle, alleging breaches of the various agreements related to the loan. Among those documents was an indemnity agreement, under which Cadle and Cadlerocks agreed to indemnify the original lender and its assignees for liabilities "sought from or asserted against" the indemnitees connected with the presence of hazardous material on or around the property. ORIX conducted environmental tests on the property, and the district court held that ORIX was entitled to recover the majority of the costs associated with the environmental testing under the indemnity agreement. The First Circuit Court of Appeals reversed the part of the district court's order awarding costs associated with environmental testing, holding that the cost of the tests that ORIX conducted fell outside the scope of the indemnity agreement. Remanded. View "ORIX Capital Markets, LLC v. Cadlerocks Centennial Drive, LLC" on Justia Law