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

The First Circuit affirmed the decision of the district court dismissing Plaintiff's breach of contract lawsuit against the City of Santa Isabel, a Puerto Rico municipality, holding that the district court did not abuse its discretion.This case arose from services that Plaintiff provided to the City of Santa Isabel following Hurricane Maria. When the City failed to pay Plaintiff for its services, Plaintiff brought this breach of contract action seeking almost $368,880. The district court granted the City's motion to dismiss, concluding that Plaintiff failed to show that it met the requirements for forming an enforceable contract with a Puerto Rico municipality such as the City. The First Circuit affirmed, holding that the district court (1) correctly found that the documents Plaintiff filed did not constitute a written contract; and (2) did not err by denying Plaintiff's motion for reconsideration. View "Disaster Solutions LLC v. City of Santa Isabel" on Justia Law

The First Circuit affirmed the decision of the district court denying Defendant's motion for unconditional discharge, holding that there was no reversible error in the district court's decision.In 2009, Defendant was civilly committed under the Adam Walsh Child and Protection and Safety Act, 120 Stat. 587. In 2012, Defendant was discharged from his civil commitment under conditions, including that he received supervised probation and mental health treatment. In 2018, Defendant moved for an unconditional discharge. The district court denied the motion but did remove many of Defendant's conditions. The First Circuit affirmed, holding (1) the district court did not err in concluding that Defendant had failed to show he would not be sexually dangerous to others if released unconditionally; and (2) the district court did not err in finding that Defendant had failed to meet his burden to show that he would not have "serious difficulty in refraining from sexually violent conduct." View "United States v. Hunt" on Justia Law

The First Circuit affirmed Defendant's sentence of eighty-four months' imprisonment imposed in connection with his plea of guilty to being a felon in possession of a firearm, holding that the sentence was neither procedurally nor substantively unreasonable.On appeal, Defendant argued, among other things, that the district court erred by quashing subpoenas issued to victims and by imposing a sentence that Defendant argued was both procedurally and substantively unreasonable. The First Circuit affirmed, holding (1) the district court's quashing of the subpoenas did not violate Defendant's due process rights; and (2) the upwardly variant sentence was both procedurally and substantively reasonable. View "United States v. Hernandez-Negron" on Justia Law

The First Circuit denied the petition filed by Petitioner, a native and citizen of Haiti, seeking review of an order of the Board of Immigration Appeals (BIA) that affirmed the denial of Petitioner's application for protection under the Convention Against Torture (CAT), holding that Petitioner's claims failed.After Petitioner was served with a notice to appear alleging that he was subject to removal, Petitioner filed an application for asylum, withholding of removal, and protection under the CAT. An immigration judge (IJ) denied Petitioner's application. The BIA affirmed and adopted the IJ's determination. The First Circuit affirmed, holding that the lower courts did not err in finding that Petitioner failed to show that it was more likely than not that he would be tortured in Haiti if he returned. View "Bonnet v. Garland" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motion for compassionate release, alleging "extraordinary and compelling" reasons pursuant to 18 U.S.C. 3582(c) 3582(c)(1)(A), as amended by the First Step Act, holding that the district court did not abuse its discretion when it denied Defendant's motion for compassionate release.Defendant admitted that he had violated the conditions of his supervised release, and the district court imposed a thirty-month revocation sentence to be served consecutively to any other term of imprisonment. Defendant later filed the instant motion for compassionate release, alleging, among other things, that his pre-existing medical infirmities, along with the conditions of his confinement, posed a substantial risk of severe illness if should contract COVID-19. The district court denied the motion. The First Circuit affirmed, holding that the district court did not abuse its discretion in denying Defendant's compassionate release motion. View "United States v. Canales-Ramos" on Justia Law

The First Circuit vacated the amended judgment of the district court amending the restitution portion of Defendant's sentence, holding that the district court was divested of jurisdiction over the restitution order once the order was entered as part of Defendant's final criminal judgment.In 2011, the district court imposed a criminal sentence against Defendant. The original sentence included a restitution order to the corporate victim payee. In 2020, the district court amended the restitution portion of the sentence to substitute the receiver of the corporate victim as the restitution recipient. The First Circuit reversed the amended restitution order, holding (1) the district court invoked Fed. R. Crim. P. 36 for an amendment that could not be properly made under it; and (2) therefore, the district court acted without jurisdiction. View "United States v. Harvey" on Justia Law

The First Circuit reversed the judgment of the district court granting Defendant's motion to suppress evidence seized during a protective search of a car, holding that the actual-fear analysis set forth in United States v. Lott, 870 F.2d 778 (1st Cir. 1989), is no longer controlling.In Lott, the First Circuit held that officers cannot do a frisk for weapons where the officers were not actually concerned for their safety. The district judge in this case granted Defendant's motion to suppress after finding that while officers had an objectively reasonable basis to search the car, they had no subjective concerns for their safety. The First Circuit reversed the judge's evidence suppression and remanded the case for further proceedings, holding that Lott is abrogated to the extent that it is inconsistent with the opinion in this case. View "United States v. Guerrero" on Justia Law

The First Circuit affirmed the order of the district court dismissing Plaintiff's federal claims seeking to hold private parties liable as state actors under 42 U.S.C. 1983, holding that the district court did not err in granting Defendants' Fed. R. Civ. P. 12(b)(6) motion to dismiss.In this case arising from eviction proceedings, Plaintiff brought this suit against Management Administration Services Corporation and its administrator, alleging violations of the Fourth and Fourteenth Amendments related to a search of her apartment, violations of due process related to rent-adjustment negotiations and eviction proceedings, and pendant claims for emotional distress. In response to Defendants' motion to dismiss Plaintiff argued that Defendants were performing a function traditionally and exclusively reserved to the state. The district court dismissed the complaint. The First Circuit affirmed, holding that the complaint failed to allege sufficient facts to ground a plausible conclusion that the function Defendants performed was, by tradition, an exclusive prerogative of the state. View "Cruz-Arce v. Management Administration Services Corp." on Justia Law

The First Circuit affirmed Defendant's conviction for attempted illegal reentry into the United States, holding that the district court did not err in refusing Defendant's preferred jury instructions and did not abuse its discretion in refusing to allow presentation of a duress defense.On appeal, Defendant argued that the trial court erred in denying his requested jury instructions as to the requisite level of intent and in refusing to admit his petition for asylum into evidence. The First Circuit affirmed, holding (1) because Defendant did not make a threshold showing of duress the district court the district court did not err in refusing to instruct the jury on this affirmative defense; and (2) the district court did not abuse its discretion in refusing to allow Defendant to present a duress defense. View "United States v. Florentino-Rosario" on Justia Law

The First Circuit affirmed Defendant's conviction and sentence for conspiracy to commit Hobbs Act robbery, robbery, and discharging and brandishing a firearm during and in relation to a crime of violence, holding that there was no error in Defendant's convictions or sentence.On appeal, Defendant argued that the district court erred in admitting hearsay evidence and erred in instructing the jury on vicarious liability. Defendant further argued that the district court erroneously applied the official-victim adjustment in United States Sentencing Guidelines 3A1.2. The First Circuit affirmed, holding (1) any impermissible inference of guilt drawn from the contested statements was harmless; (2) the district court's jury instructions were not incorrect or misleading as to the two theories of vicarious liability; and (3) there was no error in the district court's Sentencing Guidelines calculation. View "United States v. Carter" on Justia Law