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

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Defendants, the Town of Marblehead and its buildings commissioner, and dismissing this lawsuit brought under the Religious Land Use and Institutionalized Persons Act (RLUIPA), holding that the district court did not err.St. Paul's Foundation and the Shrine of St. Nicholas the Wonderworker, Patron of Sailors, Brewers and Repentant Thieves (collectively, St. Paul's), brought this action alleging that Defendants substantially burdened St. Paul's religious exercise. Specifically, St. Paul's sought to reinstate a building permit that it had secured for the redevelopment of a site on which the Shrine of St. Nicholas was located but that had been suspended prior to the completion of that construction. The district court granted summary judgment in favor of Defendants. The First Circuit affirmed, holding that St. Paul's did not successfully advance a basis for reversing the summary judgment in this case. View "St. Paul's Foundation v. Ives" on Justia Law

The First Circuit vacated the order of the district court denying in part Plaintiffs' motion for summary judgment and granting in part Defendants' motion for summary judgment, holding that the case must be dismissed for failure to exhaust administrative remedies.Parents brought this case alleging dissatisfaction with the individualized education plan offered to their son by the Puerto Rico Department of Education. Rather than file an administrative appeal, which was available to them, Parents brought suit in the United States District Court for the District of Puerto Rico. After issuing orders during a period of several years the district court issued an amended opinion and order denying in part Plaintiffs' motion for summary judgment and granting in part Defendants' motion for summary judgment. The First Circuit vacated the district court's judgment and remanded the case with instructions to dismiss, holding that the district court erred in finding that Parents did not need to exhaust their administrative remedies. View "Valentin-Marrero v. Commonwealth of Puerto Rico" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant, pursuant to a jury verdict, of conspiracy to commit a robbery, committing the robbery, and discharging a firearm in relation to a crime of violence resulting in death, holding that none of Defendant's challenges on appeal had merit.After a jury found Defendant guilty of all counts the district court sentenced him to thirty years in prison. The First Circuit affirmed the judgment, holding (1) there was sufficient evidence to support the convictions; (2) Defendant failed to preserve any objection to the use of a Pinkerton instruction; and (3) Defendant's evidentiary challenges were unavailing. View "United States v. Serrano-Delgado" on Justia Law

The First Circuit vacated Defendant's sentence imposed in connection with his plea of guilty to illegally possessing a machine gun and remanded the case for resentencing, holding that the judge's sentence "explanation" was reversible error.The crime for which Defendant was convicted carried a top prison term of ten years. Defendant sought a term of twenty-four months, and the government sought thirty months. The judge varied the sentence to sixty months because, in part, Defendant had a track record of engaging in drug offenses and weapon violations. Defendant appealed, challenging the procedural and substantive reasonableness of the judge's decision. The First Circuit vacated the sentence, holding that because the trial judge gave "weight" to arrests not backed by "convictions or independent proof of conduct," Defendant's sentence could not stand. View "United States v. Torres-Melendez" on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment in favor of Defendant, his former employer, and dismissing Plaintiff's complaint alleging that Defendant terminated his employment because of his age and because he received a liver transplant, holding that the district court did not err.Plaintiff filed a complaint alleging disability discrimination under the Americans With Disabilities Act (ADA) and age discrimination under the Age Discrimination in Employment Act (ADEA). The district court granted summary judgment for Defendant and dismissed the complaint. The First Circuit affirmed, holding that the evidence on the record did not support either Plaintiff's ADA claim or his ADEA claim. View "Lahens v. AT&T Mobility Puerto Rico, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court granting the separate post-verdict motions for judgment of acquittal filed by the two defendants in this case, Eddie Guerrero-Narvaez and Kayvan Cartagena-Suarez, holding that there was no error.After a jury trial, Defendants were convicted of aiding and abetting each other in the commission of a carjacking. Defendants subsequently filed separate post-verdict motions for judgment of acquittal. The district court granted Guerrero-Narvaez's motion, ruling that no reasonable trier of fact could find from the evidence presented at trial that Guerrero-Narvaez possessed the requisite specific intent to violate the federal carjacking statute. The court then granted Cartagena-Suarez's motion as well. The government appealed. The First Circuit affirmed, holding that the evidence did not support the jury's conclusion that Cartagena-Suarez possessed the necessary intent. View "United States v. Guerrero-Narvaez" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Plaintiff's defamation complaint, holding that the district court properly dismissed the complaint.Plaintiff brought this action against Defendant, a moderator of of a neighborhood online forum who had copied the forum's discussion threats and reposted them to a new online platform. Plaintiff sued for defamation under Massachusetts law and copyright infringement. The district court granted Defendant's motion to dismiss for failure to state a claim. The First Circuit affirmed, holding that the district court properly ruled that Defendant established two affirmative defenses to Plaintiff's claims: (1) as to the defamation claim, immunity from liability under section 230 of the Communications Decency Act; and (2) as to the copyright claim, fair use. View "Monsarrat v. Newman" on Justia Law

The First Circuit affirmed the order of the district court entering summary judgment in favor of Defendant and dismissing Plaintiff's claims for fraud, civil conspiracy, breach of fiduciary duty, and unjust enrichment, holding that Plaintiff failed to make a sufficient showing on essential elements of her case.In 2014, Plaintiff sold her special limited partnership interests in an affordable housing property for $1.5 million. In 2016, the property sold for $11.7 million. Plaintiff brought this lawsuit alleging claims for civil conspiracy, fraud, unjust enrichment, and breach of fiduciary duty, alleging that she was fraudulently led to believe that Defendant had power over the property and would block any attempt to sell or refinance it. The district court entered summary judgment for Defendant. The First Circuit affirmed, holding (1) Plaintiff failed to establish that Defendant intentionally misrepresented the value of the property and Plaintiff's special interest; and (2) Plaintiff's remaining causes of action were unsuccessful in the absence of wrongdoing or foreseeable damages. View "Katz v. Belveron Real Estate Partners, LLC" on Justia Law

The First Circuit affirmed Appellant's plea of guilty to one count of investment adviser fraud, four counts of wire fraud, and one count of aggravated identity theft, holding that there was no prejudicial error in the proceedings below.On appeal, Appellant argued that her plea was not knowing and voluntary, that the evidence was insufficient to convict her of wire fraud and aggravated identity theft, that several sentencing enhancements were improperly applied, and that her counsel was ineffective. The First Circuit affirmed, holding (1) there was no error in the district court's acceptance of Appellant's guilty plea; (2) Appellant's conduct clearly satisfied the statutory requirements for wire fraud and aggravated identity theft; and (3) Appellant's challenges to several aspects of her sentence were unavailing. View "United States v. Kitts" on Justia Law

The First Circuit affirmed Defendant's sentence for being a felon in possession of a firearm, holding that the district court did not err in its application of the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e)(1) and in its imposition of a mandatory fifteen-year sentence.Defendant pled guilty to a felon in possession charge. The district court concluded that, due to his four prior Maine burglary convictions, Defendant qualified for the ACCA's enhanced mandatory minimum penalty, and sentenced Defendant to fifteen years' imprisonment. The First Circuit affirmed, holding (1) the district court did not err in applying the ACCA to Defendant based on his prior burglary convictions in Maine; and (2) this Court declines to overturn its prior decision in United States v. Duquette, 778 F.3d 314 (1st Cir. 2015), and its application of the categorical approach to the statute at issue here. View "United States v. Bowers" on Justia Law