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

The First Circuit affirmed Defendant's conviction of two counts of mailing threatening communications through the United States Postal Service, in violation of 18 U.S.C. 876(c), holding that the evidence was sufficient to support the verdict.After a jury found Defendant guilty of both counts of mailing threatening communications Defendant moved for a judgment of acquittal. The district court denied the motion, concluding that the evidence sufficed to permit a rational jury to find Defendant guilty of both counts. On appeal, Defendant challenged the sufficiency of the evidence with respect only to the third element of the offense. The First Circuit affirmed, holding that a rational jury could have found that Defendant knew his statements would be interpreted as true threats of physical harm. View "United States v. Oliver" on Justia Law

The First Circuit affirmed the judgment of the district court rejecting the claims of Plaintiffs John Doe and Ben Bloggs that their high school discipline was unconstitutional, holding that the district court properly entered judgment in favor of Hopkinton Public Schools on all counts.Following an investigation, Hopkinton High School determined that eight students on the school hockey team, including Plaintiffs, had bullied their fellow hockey team member, and suspended each hockey player for a number of days. In this appeal from the dismissal of their complaint, Plaintiffs argued that the discipline violated their First Amendment rights, the "emotional harm" prong of Mass. Gen. Laws ch. 71, 370 is unconstitutional, and that the punishment violated their student speech rights under Mass. Gen. Laws ch. 71, 82. The First Circuit affirmed the dismissal of the complaint, holding (1) the school did not violate Plaintiffs' First Amendment rights; (2) Plaintiffs' challenges to the "emotional harm" prong of the Massachusetts statute and school policy were moot; and (3) the school did not violate Plaintiffs' rights under the Massachusetts student speech statute. View "Doe v. Hopkinton Public Schools" on Justia Law

The First Circuit reversed the judgment of the district court granting Defendant's motion to dismiss this action seeking damages for injuries received in a boating accident, holding that this case was allowed to proceed in Plaintiffs' chosen forum.Plaintiffs were ferrying in a small boat when another boat, owned by Defendant, plowed into Plaintiffs' boat and sunk it. The crash also left one of the Plaintiffs with serious personal injuries. Plaintiffs filed suit against Defendant, a U.S. citizen, in Massachusetts, bringing claims for maritime negligence, loss of consortium, and property damages. Defendant moved to dismiss the complaint for forum non conveniens, arguing that Greece was the most appropriate venue for the case. The district court granted the motion and dismissed the case. The First Circuit reversed, holding that the district court abused its discretion in failing to hold Defendant to his burden of showing that the public and private interest factors displaced the presumption weighing in favor of Plaintiffs' initial forum of choice. View "Curtis v. Galakatos" on Justia Law

The First Circuit affirmed on a limited basis the district court's ruling that Plaintiffs suit must be dismissed for lack of personal jurisdiction, holding that dismissal was required.Plaintiff, a New York resident, brought this suit over a for-profit Israeli corporation that ranked the performance of United States investment analysts, claiming that that company defamed her in Massachusetts by posting a low rating of her professional performance. The district court dismissed the suit for lack of personal jurisdiction. The First Circuit affirmed, holding that Plaintiff failed to meet her burden to adduce evidence of specific facts sufficient to satisfy the requirements of constitutional due process for the exercise of personal jurisdiction. View "Lin v. TipRanks, Ltd." on Justia Law

The First Circuit vacated the judgment of the judgment of the district court granting a motion to compel arbitration filed by the personal representative of the estate of a famous American artist (Estate), dismissing an art publisher's (Publisher) motion for a preliminary injunction as moot, and eventually dismissing the case, holding that the district court erred.At issue was an agreement between the Estate and Publisher. Publisher asserted that the parties' original contract, which included an agreement to arbitration, was terminated and supplanted by a superseding contract that did not contain an arbitration provision. In question was whether the arbitrability of the parties' dispute about the newer contract's enforceability and impact on the earlier agreement to arbitrate should be decided by the court or by arbitrators. The district court concluded that the gateway question of arbitrability was for the arbitrators. The First Circuit reversed, holding that it is the court, and not the arbitrators, that must resolve the disagreement in this case. View "McKenzie v. Brannan" on Justia Law

The First Circuit affirmed the judgment of the district court denying Petitioner's petition for a writ of habeas corpus seeking to overturn his 2010 New Hampshire conviction for aggravated felonious sexual assault, holding that the district court properly rejected Petitioner's Sixth Amendment claim.In his habeas petition, Petitioner asserted that his Sixth Amendment right to autonomy to determine the objectives of his defense when his counsel took certain actions to present a defense at trial, despite Petitioner's instructions not to do so. The district court denied the petition. The First Circuit affirmed, holding that Petitioner was not denied autonomy to direct the objectives of his defense when his trial counsel presented an active defense contrary to Petitioner's express wishes. View "Kellogg-Roe v. Gerry" on Justia Law

In this vaccination dispute, the First Circuit denied the motion brought by Appellants seeking an injunction pending appeal, holding that Appellants were not entitled to the injunction.Appellants, eight employees of Mass General Brigham, Inc. (MGB), challenged MGB's application of its mandatory vaccination policy to them individually. The policy was issued in June 2021 requiring all MGB employees to be vaccinated against COVID-19 unless they qualified for a medical or religious exemption. After Appellants' requests for exemptions were denied and they still refused to get vaccinated, MGB placed them on unpaid leave. Appellants sued under Title VII of the Civil Rights Act and the Americans with Disabilities Act, arguing that MGB unlawfully denied their individual exemption requests. The district court denied Appellants' motion for a preliminary injunction, which would have required Appellants' reinstatement from unpaid leave status. The First Circuit denied Appellants' motion for injunction pending appeal, holding that adequate legal remedies foreclosed injunctive relief. View "Together Employees v. Mass General Brigham Inc." on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's motion to suppress evidence recovered during a traffic stop, holding that the district court did not err when it denied the motion to suppress.Appellant entered a conditional guilty plea to possession of a controlled substance with the intent to distribute, reserving the right to appeal the district court's denial of his motion to suppress both statements he made at the scene of his traffic stop and the physical evidence obtained during the stop. In denying the motion to suppress, the district court concluded that the law enforcement officer had reasonable suspicion to stop Defendant's car. The First Circuit affirmed, holding that the officer had a reasonable basis to believe Appellant had committed a traffic infraction and thus to perform a traffic stop. View "United States v. Miles" on Justia Law

The First Circuit granted in part and denied in part Petitioner's petition for review of the decisions of the Board of Immigration Appeals (BIA) determining that Petitioner's previous conviction constituted a "particularly serious crime" making him ineligible for withholding of removal and denying his application for deferral of removal under the Convention Against Torture (CAT), holding that the BIA erred in part.The lower agencies found that Petitioner's conviction for possession of oxycodone with intent to distribute in violation of Mass. Gen. Laws ch. 94C, 32A(a) was a particularly serious crime rendering him ineligible for withholding of removal and denied his application for deferral of removal under the CAT. The First Circuit denied Petitioner's petition for review insofar as he sought CAT relief but granted the petition in part because the immigration judge informed Petitioner that he was eligible for potential relief only under the CAT and treated Petitioner's conviction for drug trafficking as if it were a per se bar to withholding of removal. The First Circuit remanded the case to the BIA with instructions to give Petitioner a new hearing to determine whether he was entitled to withholding of removal. View "De Carvalho v. Garland" on Justia Law

The First Circuit affirmed the judgment of the district court granting two summary judgment motions in favor of Defendants in this class action lawsuit, holding that Defendants' actions in this case could not support a claim under the Racketeer Influenced and Corrupt Organizations Act (RICO).In granting the two summary judgment motions at issue, one filed on behalf of all Defendants and on filed behalf of certain Defendants, the district court adopted the findings of law of the Court of Appeals of Puerto Rico in Collazo Burgos v. La Asociación de Suscripción Conjunta del Seguro de Responsabilidad Obligatorio, No. K AC2010-0179, 2017 WL 6884428 (P.R. Cir. Nov. 30, 2017). The court further held that Defendants' actions were required under Puerto Rico law and thus could not support a RICO claim. The First Circuit affirmed, holding that the district court did err under the Erie doctrine in adopting the reasoning of the court of appeals in Collazo Burgos. View "Torres-Ronda v. Nationwide Mutual Insurance Co." on Justia Law