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

The First Circuit reversed the judgment of the district court in this dispute between the International Brotherhood of Electrical Workers, Local 103 (the Union) and Johnson Controls Security Solutions, LLC over Johnson Controls' compliance with the terms of the parties' collective bargaining agreement (CBA), holding that the district court erred by failing to order arbitration as called for by a clause in the CBA.Johnson Controls' Norwood, Massachusetts facility entered into a CBA with the Union, a labor organization that represented employees of the company, that contained an arbitration clause. The Union filed a grievance concerning Johnson Controls' reduction in its matching contribution to the company's 401(k) plan, which Johnson Controls denied. When the Union filed a demand for arbitration Johnson Controls brought this lawsuit seeking a declaratory judgment that the dispute was not arbitrable under the CBA. The district court concluded that the dispute was not arbitrable. The First Circuit reversed, holding that nothing in the record showed that the parties intended to exclude this type of dispute from the scope of the arbitration clause. View "Johnson Controls Security Solutions, LLC v. Int'l Brotherhood of Electrical Workers, Local 103" on Justia Law

The First Circuit affirmed the judgment of the district court ordering compliance with an administrative subpoena issued to Appellant by the United States Drug Enforcement Administration (DEA) pursuant to 21 U.S.C. 876, to produce certain prescription drug records of an individual, holding that there was no error.The instant subpoena was issued by the DEA pursuant to 21 U.S.C. 876 to produce the prescription drug records kept by New Hampshire's Prescription Drug Monitoring Program (the PDMP) of an individual. The district court ordered Appellant, who was then the PDMP program manager, to comply with the subpoena. The First Circuit affirmed, holding (1) the district court did not abuse its discretion in concluding that the subpoena was enforceable under 21 U.S.C. 876(c); and (2) the third-party doctrine applied to this case. View "U.S. Dep't of Justice v. Jonas" on Justia Law

The First Circuit affirmed Defendant's twelve-month prison sentence that was imposed after he committed and admitted to multiple supervised release violations, holding the sentence was neither procedurally nor substantively unreasonable.The government argued that Defendant's appeal was moot because he had been released from incarceration, even though he was still serving his term of supervised release. The First Circuit held (1) this case was not mooted as a result of Defendant's release from incarceration; and (2) the sentence imposed in this case was defensible, and its duration was not an abuse of discretion. View "United States v. Reyes-Barreto" on Justia Law

In this interlocutory appeal, the First Circuit affirmed the judgment of the district court denying Defendants' claims that their prosecutions ran afoul of the prohibition in a congressional appropriations rider against spending federal funds to prosecute criminal defendants for marijuana-related offenses, holding that there was no error.The appropriations rider at issue placed a practical limit on federal prosecutors' ability to enforce the Controlled Substances Act, 21 U.S.C. 801 et seq., with respect to certain conduct involving medical marijuana. Defendants - two individuals and three companies - were indicted for marijuana-related offenses. Defendants moved to enjoin their prosecutions pursuant to the appropriations rider. The district court denied the motion. The First Circuit affirmed, holding that the appropriations rider did not bar the pending federal prosecution against Defendants. View "United States v. Bilodeau" on Justia Law

The First Circuit affirmed Defendant's conviction, entered following his guilty plea, for aiding and abetting the possession of a firearm in furtherance of a drug-trafficking crime and aiding and abetting the possession of cocaine with intent to distribute, holding that there was no error.Following his guilty plea, the district court sentenced Defendant to serve an eighteen-month term of immurement on the drug-trafficking count and a consecutive 144-month term of immurement on the firearms count. The Supreme Court affirmed the convictions and sentence, holding (1) Defendant failed to demonstrate that the plea agreement was unenforceable because one section of the agreement lacked his signature; and (2) Defendant's sentence on the firearms count was both procedurally and substantively reasonable. View "United States v. Merced-Garcia" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing a relator's qui tam action brought under the False Claims Act (FCA), 31 U.S.C. 3729 through 3733, holding that the district court did not err in dismissing the action.At issue before the First Circuit was the function of the hearing provided by statute when the government files a motion to dismiss a relator's FCA qui tam action over the relator's objections. The Court held (1) the government must provide its reasons for seeking dismissal such that the relator can attempt to convince the government to withdraw its motion at the hearing; (2) if the government does not agree to withdraw its motion, the district court should grant the motion unless the relator can show that, in seeking dismissal, the government is transgressing constitutional limitations or perpetrating a fraud on the court; and (3) the district court properly granted the government's motion to dismiss this case. View "Borzilleri v. Bayer AG" on Justia Law

The First Circuit affirmed Defendants' convictions for conspiring to distribute twenty-eight grams or more of cocaine base, holding that neither Defendant was entitled to relief on his claims of error.Defendants Juan Pena and Rosnil Ortiz were convicted for conspiring to distribute twenty-eight grams or more of cocaine base. On appeal, Defendants argued that the district court erred in allowing the jury to consider certain video recordings and the "out-of-court" statements captured therein. The First Circuit affirmed, holding that the district court (1) did not commit reversible error in admitting certain portions of two videos and the audio statements therein; (2) did not deny Defendants' constitutional rights to confront witnesses and to present a complete defense by excluding certain statements, as Defendants intended to use them; and (3) did not deprive Defendants of their right to an impartial tribunal by instructing the jury mid-cross-examination that it was proper for law enforcement agents to use confidential informants and to take drug weight into account when directing controlled drug purchases. View "United States v. Pena" on Justia Law

The First Circuit affirmed Defendant's convictions on six counts covering a range of federal crimes that stemmed from Defendant's use of a social security number assigned to another person, holding that there was no error in the proceedings below.On appeal, Defendant argued that the district court erred in admitting into evidence a form that he submitted to the Social Security Administration in 2014 and wrongly permitted a former immigration officer to testify to the answers that Defendant gave in response to questioning at the Miami Intentional Airport. The First Circuit affirmed, holding that the district court (1) did not err by rejecting Defendant's objection to the admission of the form; and (2) did not err in denying Defendant's motion to suppress the testimony of the former immigration official. View "United States v. Doe" on Justia Law

The First Circuit affirmed Defendant's conviction of one count of conspiracy to possess with intent to distribute and to distribute 500 grams or more of cocaine, in violation of 21 U.S.C. 846, and one count of possession with intent to distribute 500 grams or more of cocaine, in violation of 21 U.S.C. 841(a)(1), holding that there was no error.Specifically, the First Circuit held (1) the district court did not err in denying Defendant's motion to suppress evidence obtained during a traffic stop and admitting items seized from the vehicle at trial; (2) the district court did not manifestly abuse its discretion in admitting certain statements of lay witnesses; (3) the proceedings did not contravene Defendant's constitutional right to a speedy trial; and (4) Defendant's absence at certain pre-trial proceedings did not violate his statutory or constitutional presence rights. View "United States v. Reyes" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment for Defendants in this personal injury action, holding that the district court properly granted summary judgment as to all claims.This case arose from a car accident in Rhode Island involving Horace Johnson, the driver, and Carlton Johnson, a passenger. Carlton and his mother sued to recover damages for Carlton's injuries. The district court granted summary judgment for Defendants - Horace, his insurer, and the company from which Horace had leased the vehicle. The First Circuit ultimately certified to the Rhode Island Supreme Court a question regarding the definition of "civil action" in Rhode Island's Rejected Settlement Offer Interest Statute, R.I. Gen. Laws 27-7-2.2. After the Rhode Island Supreme Court supplied its answer, this Court affirmed the district court's judgment in its entirety, holding that the district court (1) correctly concluded that section 27-7-2.2 was inapplicable; (2) properly concluded that an enforceable settlement agreement existed; and (3) was right to grant summary judgment as to Carlton's insurer bad faith claims. View "Johnson v. Johnson" on Justia Law