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

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

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Plaintiffs filed a putative class action in the United States District Court for the District of Massachusetts, invoking federal diversity jurisdiction, alleging that Defendant, Raytheon Company, negligently exposed Plaintiffs and others similarly situated to beryllium. Plaintiffs’ principal theory of liability was that the beryllium exposure caused subcellular change. Plaintiffs alternatively argued that a cause of action for medical monitoring under Massachusetts law does not require a showing of subcellular or other physiological change. The district court granted summary judgment in favor of Defendant. The First Circuit affirmed, holding (1) because no named Plaintiff or any class member had as yet contracted beryllium sensitization, the first manifestation of subcellular change resulting from beryllium exposure, Plaintiffs’ first claim failed; and (2) Plaintiffs did not preserve a claim under their alternative theory. View "Genereux v. Raytheon Co." on Justia Law

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Plaintiffs, a class of investors, brought a securities fraud action against Genzyme Corporation, an international pharmaceutical company, and several of Genzyme’s executives, alleging that Defendants violated the Securities Exchange Act by making false or misleading statements to investors. The district court dismissed the complaint for failure to state a claim upon which relief could be granted and subsequently denied Plaintiffs’ post-judgment motion to amend the complaint. The First Circuit affirmed, holding (1) the district court did not err in concluding that the complaint failed to meet the formidable pleading standard for securities fraud claims; and (2) the district court did not abuse its discretion in denying Plaintiffs’ post-judgment motion to amend the complaint. View "Deka Int'l S.A. Luxembourg v. Genzyme Corp." on Justia Law

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The lawsuit underlying this action alleged that Glynis McCormack’s ward sexually and physically abused a younger boy. In this declaratory judgment action, the district court ruled that Metropolitan Property and Casualty Insurance Company, McCormack’s insurer, had a duty to defend McCormack in the underlying lawsuit. Metropolitan appealed, arguing that the alleged harmful conduct was excluded from coverage under the governing policy. The First Circuit affirmed, holding that, under the facts of this case, McCormack’s policy would cover the harm alleged in the complaint, and therefore, Metropolitan had a duty to defend McCormack in the underlying action. View "Metro. Prop. & Cas. Ins. Co. v. McCarthy" on Justia Law

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Appellant had worked for twenty-six years with the United States Postal Service as a letter carrier when he was charged with obstructing the mails in violation of 18 U.S.C. 1701. The statute provides that a defendant who “knowingly and willfully obstructs or retards the passage of mail” shall be fined or imprisoned. After a bench trial, the magistrate judge found Appellant guilty as charged. The district court affirmed. The First Circuit Court of Appeals affirmed, holding (1) even if the trial court’s definition of the term “willfully” was error, any error was harmless beyond a reasonable doubt; (2) the evidence of willful obstruction was sufficient; and (3) the magistrate judge did not deny Appellant due process by continuing the trial date. View "United States v. Marshall" on Justia Law

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Corizon, Inc. was a private independent contractor that provided healthcare services to inmates at Cumberland County Jail (CCJ) under a contract with the jail. After Paul Galambos, died from self-inflicted injuries that he sustained while he was a pretrial detainee at CCJ, Galambos’s estate brought a 42 U.S.C. 1983 action alleging that three employees of Corizon were deliberately indifferent to Galambos’s serious medical needs. Defendants moved for summary judgment, claiming that they were entitled to qualified immunity. The magistrate judge denied Defendants’ motions, concluding that material and disputed issues of fact existed that precluded the grant of immunity. Defendants appealed. The First Circuit dismissed the appeal for want of appellate jurisdiction under Johnson v. Jones because the district court’s denial of immunity turned on findings that there remained disputed issues of material fact and inference. View "Cady v. Cumberland County Jail" on Justia Law

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In 2011, drugs found in Appellant’s possession were sent to a Massachusetts testing laboratory, where Annie Dookhan, a chemist, certified that the drugs were crack cocaine. Appellant was subsequently indicted in federal court for possessing crack cocaine with the intent to distribute. Appellant pleaded guilty to the offense and went to prison. In 2012, it was discovered that Dookhan had falsely certified countless drug-test results. Although there was no direct evidence that Dookhan had committed misconduct in this case, Appellant filed a motion to set aside his conviction and vacate his guilty plea based on the scandal. The district court denied Appellant’s motion. The First Circuit affirmed, holding that Appellant did not meet his burden of proving that there was a reasonable probability that he would not have pleaded guilty had he known of Dookhan’s transgressions. View "Wilkins v. United States" on Justia Law

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Appellant pleaded guilty to two counts related to his involvement in a drug ring. After a plea colloquy, the district judge sentenced Appellant to 327 months on count one and life imprisonment on count two, to run consecutively. Thereafter, the district judge twice resentenced Appellant. The last sentence imposed on Appellant was a total aggregate sentence of 405 months. Appellant appealed, contending that his first judgment should be vacated because of flaws in the initial plea colloquy and because the district court lacked authority for actions taken after entry of the first sentence. The First Circuit affirmed the initial guilty plea and original sentence and vacated all subsequent judgments and orders of the district court, holding (1) the first sentence was not unreasonable, and although the initial plea colloquy was flawed, the imperfections did not justify setting aside the first judgment; and (2) the district judge lacked statutory authority to act after he entered the original sentence, and therefore, the first and most severe sentence imposed by the district judge stands. View "United States v. Sevilla-Oyola" on Justia Law

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At issue in this appeal was a tax credit that offset federal tax owed on income earned in the operation of a business in Puerto Rico. The credit remained available to taxpayers under section 936 of the Internal Revenue Code during the ten-year transition period after section 936 was repealed. During the transition period, the taxable income an eligible claimant could claim in computing its credit was capped at an amount approximately equal to the average of the amounts it had previously claimed, but the cap could be adjusted for a taxpayer’s purchases and sales of businesses that had generated credit-eligible income. In this case, Appellant-corporation, a U.S. taxpayer, sold a line of businesses in Puerto Rico to a foreign corporation that did not pay U.S. corporate income taxes. Appellant argued it was not required to reduce its cap because the buyer had no credit cap to increase. The district court granted summary judgment for the government. The First Circuit reversed, holding (1) the reduction in a seller’s cap as a result of the sale of a business line is appropriate only in the event of a corresponding increase in the buyer’s cap; and (2) therefore, the transfers did not reduce Appellant’s credit cap. View "OMJ Pharms., Inc. v. United States" on Justia Law

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Plaintiff worked in a luggage factory in France that was owned by Samsonite. Samsonite was controlled by an investment group led by Bain Capital, LLC. Bain wanted to shut down the factory, and to avoid paying millions of dollars in post-termination benefits to the laid-off employees of the factory, Bain and Samsonite hired a third party, HB Group, to buy the factory. In 2007, a French court ordered the judicial liquidation of the factory. Because HB Group had no resources to pay Plaintiff and her coworkers, Plaintiff commenced this putative class action in 2012 seeking to hold Bain liable for losses suffered by the factory’s workers as a result of the sale and liquidation. The district court dismissed the complaint as untimely under the relevant three-year statute of limitations. The First Circuit affirmed, holding that there was no basis to conclude that the statute of limitations was tolled in this case. View "Abdallah v. Bain Capital, LLC" on Justia Law

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After a jury trial, Petitioner was found guilty of second degree murder and unlawful possession of a firearm. Petitioner appealed his conviction, contending that the Commonwealth used its peremptory challenges to exclude young African Americans in violation of the equal protection principles laid down in Batson v. Kentucky. The Massachusetts Appeals Court (MAC) concluded that Petitioner had failed to make a prima facie showing that the Commonwealth’s use of peremptory challenges was likely motivated by the jurors’ race. Petitioner failed to obtain relief on appeal in the Massachusetts courts and subsequently sought a writ of habeas corpus from the United States District Court. The district court denied the petition. The First Circuit vacated the judgment of the district court, holding that the MAC’s application of the first Batson prong was clear error and represented an objectively unreasonable application of clearly established federal law. Remanded to the district court to conduct an evidentiary hearing and to complete the Batson inquiry. View "Sanchez v. Roden" on Justia Law