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

The First Circuit affirmed in part and reversed in part the district court's grant of summary judgment in favor of Defendant on Plaintiff's federal and Massachusetts state law employment discrimination claims, holding that that court erred in granting summary judgment as to several of Plaintiff's claims.Plaintiff, a former employee of Defendant, an online home furnishings company with a principal place of business in Massachusetts, sued Defendant bringing claims under both Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq., and Mass. Gen. Laws ch. 151B, 4.1, 4.4, and 4.4A. The district court granted summary judgment for Defendant on all claims. The First Circuit reversed in part, holding that the district court (1) correctly granted summary judgment to Defendant on Plaintiff's state and federal claims for failing to remedy sexual harassment; and (2) erred in granting summary judgment to Defendant on Plaintiff's remaining claims. View "Forsythe v. Wayfair, LLC" on Justia Law

The First Circuit reversed the order of the district court ordering the release of sealed archival records of certain grand jury proceedings and its judgment in favor of historian and Petitioner Jill Lepore, holding that the federal court did not have the authority to order the release of the grand jury records.As research on a book she was writing, Petitioner filed a Freedom of Information Act request seeking the release of sealed archival records of grand jury proceedings from 1971 that were held to consider possible criminal charges arising out of the publication of excerpts from the "Pentagon Papers," a government study of the Vietnam War. The district court ultimately ordered the records released. The First Circuit reversed, holding that the court erred in holding that it had the authority to order the release of grand jury records based upon its finding that historical interest in the records outweighed any countervailing considerations. View "Lepore v. United States" on Justia Law

The First Circuit dismissed Defendants' appeals from the trial court's refusal to dismiss their indictments, holding that this Court lacked jurisdiction to review before final judgment the district court's order denying Defendants' motions to dismiss.A United States Attorney for the District of Massachusetts charged Massachusetts state district court judge Shelley Joseph and Wesley MacGregor, her courtroom deputy, for allegedly interfering with the enforcement of federal immigration law. Defendants filed motions to dismiss their indictments based on Judge Joseph's claim of absolute judicial immunity and on their contention that their prosecution was unconstitutional. The district court denied the motions to dismiss, and Defendants appealed. The First Circuit dismissed the appeals as premature, holding that, at this stage in the proceedings, this Court had no jurisdiction to review the merits of the district court's rulings. View "United States v. Joseph" on Justia Law

The First Circuit denied Petitioner's petition for review of a final order of removal issued by the Board of Immigration Appeals (BIA), holding that the immigration judge (IJ) and BIA properly concluded that Petitioner's Massachusetts conviction for accessory after the fact rendered him removable as an aggravated felon.The U.S. Department of Homeland Security initiated removal proceedings against Petitioner. An IJ held that Petitioner was removable under the Immigration and Nationality Act, 8 U.S.C. 1227(a)(2)(A)(iii) for having committed an aggravated felony, as defined under 8 U.S.C. 1101(a)(43). As relevant to this appeal, the IJ held that Petitioner's Massachusetts accessory-after-the-fact conviction was categorically an offense relating to obstruction of justice and so was a proper ground for removal as an aggravated felony. The BIA denied Petitioner's appeal. The First Circuit denied Petitioner's petition for review, holding that the BIA did not err in determining that Petitioner's Massachusetts conviction rendered him ineligible for withholding of removal. View "Silva v. Garland" on Justia Law

The First Circuit vacated the order of the district court dismissing Plaintiffs' action seeking damages for medical malpractice, holding that the district court abused its discretion by failing to apply the requisite exceptional-circumstances test.Plaintiffs commenced this civil action in federal court alleging negligence under Puerto Rico law leading to the death of their mother. Approximately one month earlier, a larger group of plaintiffs brought a similar medical malpractice suit in the superior court of Puerto Rico also arising from the decedent's death. A defendant in both cases filed a motion in federal court to stay or dismiss the federal court proceeding. The district court granted the motion, finding the "prior pending action" doctrine applicable. The First Circuit vacated the order below, holding that the district court erred in applying the "prior pending action" doctrine in lieu of the test set forth in Colorado River Water Conservation District v. United States, 424 U.S. 800 (1976) and its progeny. View "Maldonado-Cabrera v. Anglero-Alfaro" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment ruling in favor of Defendant, a marketing company, holding that district court correctly concluded that Plaintiffs, who worked as "brand representatives" for Defendant, qualified as outside salespeople under governing law.Plaintiffs sued Defendant on behalf of themselves and other brand representatives, seeking to recover unpaid overtime wages under the Fair Labor Standards Act (FLSA) and analogous state wage laws, alleging that they failed to receiver overtime wages for working over forty hours per week. The district court granted summary judgment in favor of Defendant, concluding that Plaintiffs fell within the FLSA's outside sales exemption and thus were not entitled to overtime compensation. The First Circuit affirmed, holding that Plaintiffs fell within the outside sales exemption, 29 U.S.C. 213(a)(1). View "Modeski v. Summit Retail Solutions, Inc." on Justia Law

The First Circuit granted in part one of Petitioner's petitions for review of the decision of the Board of Immigration Appeals (BIA) ordering Petitioner removed, holding that remand was required.The same day the denial of Petitioner's I-751 petition to remove the conditions of his residency was issued, the Department of Homeland Security (DHS) initiated removal proceedings against Petitioner. Petitioner subsequently divorced his former wife and married anew. Petitioner's new wife filed an application for adjustment of Petitioner's status on the basis of their marriage and an I-751 waiver petition. Petitioner was subsequently indicted for kidnapping and two counts of sexual assault. The IJ granted Petitioner's application for adjustment of status. The BIA sustained the DHS's appeal and ordered Petitioner removed without acknowledging that Petitioner had a pending I-751 waiver. The First Circuit held (1) the BIA abused its discretion in denying Petitioner's motion to reconsider based on two clear-error-standard violations; and (2) remand was required for consideration of the effect, if any, of the final denial of the I-751 waiver on Petitioner's motions. View "Adeyanju v. Garland" on Justia Law

In this medical malpractice action the First Circuit affirmed the judgment of the district court entering judgment in accordance with the jury's verdict finding Doctors' Center Hospital (Manati), Inc. (Doctors' Center) liable for eight percent of a more than $14 million total award, holding that there was no error.This lawsuit stemmed from obstetric care provided to Plaintiff, Jeanette Rodriguez-Valentin in connection with the birth of her son, DALR. The jury found Doctors' Center liability and awarded damages. The jury apportioned ninety-two percent of that liability to two treating physicians with whom Plaintiff settled prior to trial and apportioned to Doctors' Center the remaining amount of $1,143,680. The First Circuit affirmed, holding that the district court (1) did not err or abuse its discretion in deferring to the jury's evaluation of the evidence; and (2) did not err in denying Doctors' Center's motions for judgment as a matter of law, for a new trial, or for remittitur. View "Rodriguez-Valentin v. Doctors' Center Hospital (Manati), Inc." on Justia Law

The First Circuit affirmed the ruling of the Board of Immigration Appeals (BIA) denying Petitioner's application for asylum, withholding of removal, protection under the Convention Against Torture (CAT), and voluntary departure, holding that the BIA's determination was supported by substantial evidence.Petitioner, a native and citizen of Guatemala, was charged with removability. Petitioner conceded removability and applied for asylum, withholding of removal, protection under the CAT, and post-conclusion voluntary departure. The immigration judge (IJ) found that Petitioner's asylum claim failed on the merits and that Petitioner was not entitled to relief on his remaining arguments for relief. The BIA affirmed. The First Circuit affirmed, holding that substantial evidence supported the decisions of the IJ and the BIA. View "Lopez-Perez v. Garland" on Justia Law

The First Circuit affirmed the decision of the district court granting judgment to Defendants and denying a declaration requested by Plaintiffs that the Massachusetts Bureau of Special Education Appeals (BSEA) erred in determining that Swampscott Public Schools had provided their daughter, G.D., with a free appropriate public school education as required under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. §§ 1400 et seq., holding that there was no error.Plaintiffs sought a determination from the BSEA that G.D.'s Individualized Education Program (IEP) was not reasonably calculated to provide her with a free appropriate public education (FAPE) and further sought reimbursement from Swampscott Public Schools associated with Plaintiffs' unilateral placement of G.D. at a nearby private school. After the BSEA denied the claims Plaintiffs filed suit against the school district and the BSEA. The district court determined that G.D.'s IEP was reasonably calculated to provide her with a FAPE and entered judgment for Defendants. The First Circuit affirmed, holding that Plaintiffs were not entitled to relief as to any of their allegations of error. View "G.D. v. Swampscott Public Schools" on Justia Law