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

Investors in a major drug-development company alleged that the company and two of its officers misled them about the integrity of the company’s overseas supply chain for long-tailed macaques, which are essential for its business. After China halted exports of these monkeys due to the COVID-19 pandemic, the company shifted to suppliers in Cambodia and Vietnam, some of which were later implicated in a federal investigation into illegal wildlife trafficking. Despite public signs of the investigation and seizures of shipments, the company’s CEO assured investors that its supply chain was unaffected by the federal indictment of certain suppliers, and that the indicted supplier was not one of its own. However, evidence suggested that the company was, in fact, sourcing macaques from entities targeted by the investigation, either directly or through intermediaries.The United States District Court for the District of Massachusetts dismissed the investors’ class action complaint, finding that the plaintiffs failed to allege any false or misleading statements or scienter (intent or recklessness), and therefore did not reach the issue of loss causation. The court also dismissed the derivative claim against the individual officers.The United States Court of Appeals for the First Circuit reviewed the dismissal de novo. The appellate court held that the investors plausibly alleged that the company and its CEO knowingly or recklessly misled investors in November 2022 by assuring them that the company’s supply chain was not implicated in the federal investigation, when in fact it was. The court found these statements actionable, but agreed with the lower court that other statements about “non-preferred vendors” were not independently misleading. The First Circuit reversed the district court’s dismissal as to the November 2022 statements and remanded for further proceedings, including consideration of loss causation. Each party was ordered to bear its own costs on appeal. View "State Teachers Retirement System of Ohio v. Charles River Laboratories International, Inc." on Justia Law

A police officer with the Cambridge Police Department, who had served in both patrol and special investigations roles, posted a comment on his personal Facebook page criticizing the naming of a federal police reform bill after George Floyd. In his post, he referred to Floyd as a "career criminal, a thief and druggie," and expressed pessimism about the country's future. The post was made from home, visible only to his Facebook friends, but was quickly screenshotted and shared with community members, including the local NAACP. The police commissioner was alerted, and the department initiated an internal investigation. The officer was placed on administrative leave and, after the investigation concluded that his post violated department policies on courtesy and professionalism, he was suspended without pay for four days.The officer filed suit in the United States District Court for the District of Massachusetts, alleging that his suspension was unconstitutional retaliation for exercising his First Amendment rights. Both parties moved for summary judgment. The district court granted summary judgment in favor of the department, finding that the department’s interest in maintaining public trust and effective service outweighed the officer’s and the public’s interest in his speech, particularly given the context of heightened scrutiny and protest following George Floyd’s death.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s decision de novo. The First Circuit held that, while the officer’s speech addressed a matter of public concern, its mocking and disparaging nature diminished its First Amendment value. The court further held that the department’s prediction that the post could undermine public trust was reasonable, especially in the context of ongoing public unrest and the department’s need to maintain community confidence. The court found no evidence of impermissible viewpoint discrimination. The First Circuit affirmed the district court’s grant of summary judgment for the department. View "Hussey v. City of Cambridge" on Justia Law

In this case, the plaintiff, Robert Arias, sued several federal Drug Enforcement Administration (DEA) agents for damages, alleging that they violated his Fourth Amendment rights during his arrest in a shopping center parking lot in September 2016. Arias claimed that some agents used excessive force against him, while others failed to intervene to prevent that force. He based his claims on the implied cause of action for damages under the Fourth Amendment recognized by the Supreme Court in Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics.The United States District Court for the District of New Hampshire granted summary judgment to the defendants. The court reasoned that, due to the 1988 amendment to the Inspector General Act (IGA), which created an administrative mechanism for reporting federal law enforcement misconduct, Arias’s claims arose in a “new context” compared to Bivens. The District Court concluded that the existence of this alternative remedial scheme counseled against extending the Bivens remedy, thus precluding Arias’s excessive force and failure-to-intervene claims.On appeal, the United States Court of Appeals for the First Circuit reviewed the District Court’s decision. The First Circuit held that the IGA’s administrative remedy, by itself, does not make the context of Arias’s excessive force claims meaningfully different from Bivens. The court found that Arias’s excessive force claims arise in the same context as Bivens, so the Bivens remedy remains available. However, the court affirmed summary judgment on Arias’s failure-to-intervene claims, as he did not show that those claims arise in the same context as Bivens or justify extending Bivens to that context. The First Circuit thus reversed the District Court’s judgment on the excessive force claims and remanded for further proceedings, while affirming the judgment on the failure-to-intervene claims. View "Arias v. Herzon" on Justia Law

A former college track and field coach used his position to obtain nude and semi-nude photographs from female student-athletes. While coaching at a university, he would ask athletes for their phones under the pretense of filming their form, then search for and secretly send intimate images to himself. After leaving the university, he created anonymous social media accounts to contact former athletes, falsely claiming he found their photos online and offering to help remove them, while actually using the images he had previously stolen. He also created fake online personas to solicit additional images under the guise of a body development study and conspired with others to hack into women’s Snapchat accounts, obtaining more private images. In total, he obtained images from fifty-one women and attempted to obtain them from at least seventy-two others.A grand jury indicted him on multiple counts, including wire fraud, cyberstalking, and computer fraud. He was released pending trial with conditions, but violated them by again soliciting images online. The United States District Court for the District of Massachusetts calculated a guideline sentencing range of twenty-seven to thirty-three months, but imposed an upwardly variant sentence of sixty months, citing the number of victims, the nature of the offenses, the abuse of trust, and his conduct while on release. The court rejected the government’s request for an even higher sentence.On appeal, the United States Court of Appeals for the First Circuit reviewed the procedural and substantive reasonableness of the sentence. The court held that the district court did not commit procedural error, adequately considered the relevant sentencing factors, and provided a plausible and defensible rationale for the upward variance. The First Circuit affirmed the sixty-month sentence, finding it reasonable in light of the seriousness of the offenses, the impact on the victims, and the risk of recidivism. View "United States v. Waithe" on Justia Law

Dinelson Hernandez-Rodriguez was stopped by a Connecticut state trooper while driving a vehicle that was under surveillance by the Drug Enforcement Administration (DEA) as part of a lengthy investigation into a Boston-based drug trafficking operation. The DEA had linked the vehicle and its occupants to the transport of cocaine from New York to Boston and the return of drug proceeds to New York. On the day of the stop, DEA agents observed Hernandez-Rodriguez interacting with suspected co-conspirators and driving the vehicle away from a location associated with drug activity. After the stop, a search of the vehicle uncovered $240,240 in a hidden compartment.The United States District Court for the District of Massachusetts denied Hernandez-Rodriguez’s motion to suppress the cash, finding that the warrantless search was justified under the automobile exception to the Fourth Amendment because there was probable cause to believe the vehicle contained evidence of a crime. The court found that the DEA’s extensive investigation, surveillance, and intercepted communications provided sufficient grounds for probable cause. Following a jury trial, Hernandez-Rodriguez was convicted of conspiracy to distribute cocaine and sentenced to sixty-eight months in prison.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s factual findings for clear error and its legal conclusions de novo. The appellate court held that the collective knowledge of the DEA agents, imputed to the state trooper who conducted the stop, established probable cause to search the vehicle under the automobile exception. The court rejected the argument that the search was based on a mere “hunch,” finding that the facts supported a fair probability that evidence of a crime would be found. The First Circuit affirmed the district court’s denial of the motion to suppress. View "United States v. Hernandez-Rodriguez" on Justia Law

A coastal town in Maine, known for its small population and proximity to a national park, experienced a significant increase in cruise ship tourism, with large vessels bringing thousands of passengers daily. In response to concerns about congestion, public safety, and the impact on local amenities, residents approved an ordinance capping the number of cruise ship passengers who could disembark in the town to 1,000 per day. The ordinance imposed fines for violations and was intended to address issues primarily at the waterfront and, to a lesser extent, in the downtown area.Several local businesses, a business association, and a pilots’ association challenged the ordinance in the United States District Court for the District of Maine. They argued that the ordinance was preempted by federal and state law, violated the Commerce Clause (including its dormant aspect), and infringed on due process rights. After a bench trial, the District Court largely ruled in favor of the town and an intervening resident, rejecting most claims but finding that the ordinance was preempted by federal regulations only to the extent it restricted crew members’ shore access. The court declined to enjoin the ordinance, noting the town’s intent to address this issue through further rulemaking.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s rejection of the state law preemption, federal preemption (except for the now-moot crew access issue), and due process claims. The First Circuit also affirmed the dismissal of discrimination-based Dormant Commerce Clause claims, finding no similarly situated in-state and out-of-state competitors. However, the court vacated and remanded the District Court’s dismissal of the Pike balancing Dormant Commerce Clause claim, instructing further analysis of whether the ordinance’s burdens on interstate commerce are clearly excessive in relation to its local benefits. The court dismissed as moot the appeals related to the crew access issue. View "Ass'n to Preserve and Protect Local Livelihoods v. Town of Bar Harbor" on Justia Law

In October 2016, parents sought emergency medical care for their nineteen-month-old son, who was experiencing convulsions and seizures. The child was treated at three different medical facilities in Puerto Rico, including by Dr. Fernando Vega-Moral at HIMA San Pablo Bayamón hospital. After being transferred between hospitals, the child suffered cardiac arrest and died. The parents, along with other family members, initially filed a medical malpractice and negligence suit in Puerto Rico Commonwealth court against the medical centers and unnamed doctors, but did not specifically name Dr. Vega. That case was dismissed without prejudice in May 2018.Subsequently, in May 2019, the parents filed a new lawsuit in the United States District Court for the District of Puerto Rico, this time naming Dr. Vega and others as defendants and asserting claims under Puerto Rico’s tort statutes. The district court dismissed some defendants and granted summary judgment to Dr. Vega, finding that the claims against him were time-barred. The court determined that, although the parents’ initial Commonwealth complaint was timely due to extensions following Hurricane María, the federal complaint did not toll the statute of limitations as to Dr. Vega because he was not named in the earlier suit. The court also denied the parents’ motion for reconsideration, holding that their new arguments and evidence should have been presented earlier.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s rulings. The First Circuit held that Dr. Vega properly raised the statute of limitations defense and that, under Puerto Rico law, the burden shifted to the parents to show that the limitations period was tolled as to Dr. Vega. The parents failed to provide competent evidence to meet this burden. The court also found no abuse of discretion in denying reconsideration, as the parents’ new arguments and evidence were untimely. View "Cruz-Cedeno v. Vega-Moral" on Justia Law

While serving a ten-year sentence in Rhode Island Department of Corrections (RIDOC) custody, Jerry Cintron, who suffers from opioid use disorder, relapsed and overdosed on a fentanyl-laced pill. After the incident, RIDOC officials sanctioned him with a total of 450 days in solitary confinement for various infractions related to the overdose and alleged trafficking. During this period, Cintron experienced severe mental and physical deterioration, including significant weight loss, self-injurious behavior, and psychiatric symptoms. He repeatedly informed RIDOC officials of his worsening condition and requested relief, but his pleas were denied or ignored, and his conditions remained unchanged.Cintron filed a lawsuit in the United States District Court for the District of Rhode Island under 42 U.S.C. § 1983, alleging violations of his Eighth Amendment rights due to deliberate indifference by RIDOC officials. The defendants moved for judgment on the pleadings, arguing that Cintron’s claims failed on the merits and that they were entitled to qualified immunity. The district court denied the motion as to the Eighth Amendment claim, allowing it to proceed against all defendants, and the defendants appealed.The United States Court of Appeals for the First Circuit reviewed the case and held that Cintron’s complaint plausibly alleged an Eighth Amendment violation by three RIDOC officials—Aceto, Corry, and Kettle—who were aware of his deterioration and had authority to intervene but failed to do so. The court found that, as of 2019, it was clearly established that prolonged social, sensory, and sleep deprivation in solitary confinement could constitute cruel and unusual punishment, and that officials could not respond with deliberate indifference. The court affirmed the district court’s denial of qualified immunity for these three officials, reversed as to the other defendants, and remanded for further proceedings on declaratory and injunctive relief. View "Cintron v. Bibeault" on Justia Law

In February 2023, police officers arrested Charlie Vick for domestic assault and battery involving a firearm. After his arrest, officers discovered that the car he had been driving was uninsured, unregistered, and had invalid license plates. They waited until Vick's uncle attempted to drive the car away and then stopped him shortly after he exited the parking lot. The officers impounded the car and conducted an inventory search, which revealed a gun. Vick was subsequently charged with being a felon in possession of a firearm.The United States District Court for the District of Massachusetts ruled that the officers had staged the impounding and that their sole motive for the search was investigatory. Consequently, the court ordered the suppression of the evidence found during the search. The government appealed, arguing that the district court should not have considered the officers' subjective motives and that the court's finding of a sole investigatory motive was clearly erroneous.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed with the government that the district court's finding of a sole investigatory motive was clearly erroneous. The appellate court noted that the officers had an objectively reasonable basis for impounding the car, as it was unregistered, uninsured, and had invalid plates, making it a safety hazard. The court also found that the officers' decision to impound the car was lawful under the community caretaking exception to the Fourth Amendment's warrant and probable cause requirements. Consequently, the appellate court reversed the district court's grant of the motion to suppress and remanded the case for further proceedings. View "US v. Vick" on Justia Law

Two cousins, Jairo Huertas-Mercado and Erick Pizarro-Mercado, were involved in a series of violent crimes in Puerto Rico, including six carjackings and two kidnappings, one of which resulted in death. The crimes occurred between May and June 2018, and involved the use of firearms and threats of violence. The victims included a security guard, a family on a road trip, a surfer, a couple, a churchgoer, and a well-known local singer, Bryant Myers, who was kidnapped along with his mother.The case was first brought to the United States District Court for the District of Puerto Rico, where Huertas was initially indicted in July 2018. Over time, the indictment was superseded three times, adding more charges and defendants, including Pizarro. The pretrial process was prolonged due to ongoing investigations, plea negotiations, and the COVID-19 pandemic. The death penalty review process also contributed to the delay. Ultimately, the trial began in September 2022, more than four years after the initial indictment.The United States Court of Appeals for the First Circuit reviewed the case. Huertas argued that his constitutional right to a speedy trial was violated due to the 51-month delay between his indictment and trial. The court applied the Barker v. Wingo balancing test and found that while the delay was lengthy, it was justified by valid reasons, including the complexity of the case, the need for thorough investigation, and the impact of the pandemic. Huertas' failure to assert his right to a speedy trial and the lack of demonstrated prejudice to his defense also weighed against him.Both defendants challenged the sufficiency of the evidence for their convictions, particularly the carjacking charges. The court found that the evidence, including witness testimonies and admissions by Huertas, was sufficient to support the jury's verdict. The court also rejected Huertas' double jeopardy claim, noting that the lesser included offense was dismissed before sentencing.Finally, Pizarro's argument that his life sentence was unreasonable was reviewed. The court found that the sentence was within the guideline range and justified by the severity of the crimes, affirming the district court's decision. The appeals court ultimately affirmed the convictions and sentences of both defendants. View "US v. Huertas-Mercado" on Justia Law