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

The First Circuit affirmed Defendant's sentence imposed in connection with his conviction of possession of a firearm and ammunition by a convicted felon, holding that the sentencing outcome was defensible.Defendant pled guilty to possession of a firearm and ammunition by a convicted felon. The district court concluded that a forty-six-month term of immurement was an appropriate punishment and sentenced him to an incarcerative sentence of that length. Defendant appealed, arguing that, in fashioning his sentence, the district court overemphasized aggravating factors and overlooked mitigating factors. The First Circuit affirmed, holding that Defendant's sentence was neither procedurally nor substantively unreasonable. View "United States v. Ruperto-Rivera" on Justia Law

The First Circuit affirmed the judgment of the district court ruling against defendant Massachusetts Mutual Life Insurance Company (MassMutual) and against Plaintiff's class action claims in this insurance dispute, holding that the district court did not err.In 2003, MassMutual decided to cut the minimum guaranteed interest rates paid to purchasers of some of its annuities. MassMutual chose to change the interest rate by an endorsement that its staff warned would result in consumer confusion and introduce ambiguity into its annuity certificate. Plaintiff in this case believed that he had bought an annuity that guaranteed him three percent annual interest, but MassMutual claimed that it promised only 1.5 percent annual interest. The district court ruled against MassMutual and against Plaintiff's class action claims. The First Circuit affirmed, holding (1) the annuity did not unambiguously set the minimum guaranteed interest rate at 1.5 percent; (2) the district court did not err in denying Plaintiff's motion for class certification; and (3) MassMutual waived its challenge to prejudgment interest. View "Aronstein v. Massachusetts Mutual Life Insurance Co." on Justia Law

The First Circuit affirmed Defendants' convictions of multiple counts of introducing through their work at the New England Compounding Center (NECC) "misbranded" drugs into interstate commerce with the intent to defraud or mislead, holding that there was no error or abuse of discretion.Defendants Kathy Chin and Michelle Thomas worked at NECC, a compounding pharmacy that distributed a contaminated medication that led to illnesses and deaths of patients across the country. Defendants were among fourteen individuals affiliated with NECC who were charged with criminal offenses related to the contaminated medication. A jury found Defendants guilty of the counts that each faced. The First Circuit affirmed, holding (1) Defendants' convictions were supported by sufficient evidence; (2) the statute setting forth the underlying offense was not void for vagueness as applied to Defendants; and (3) none of Defendants' grounds for overturning the district court's rulings under Fed. R. Crim. P. 33 had merit. View "United States v. Chin" on Justia Law

The First Circuit affirmed the judgment of the district court awarding to the Commonwealth a letter written by Alexander Hamilton to the Marquis de Lafayette on July 21, 1780 that was the subject of a civil forfeiture action, holding that there was no error.The letter at issue was seized pursuant to a judicial warrant by the Federal Bureau of Investigations from a fine antiques auctions house in Virginia. The government filed a verified complaint for forfeiture in rem against the letter, alleging that the letter was subject to forfeiture as property traceable to a violation of statutes that criminalize interstate transport of and trade in stolen goods valued over $5,000. The Commonwealth and the Estate of Stewart Crane filed claims to the letter. The district court struck the Estate's claim and concluded that the Commonwealth was the only entity that could own the letter. The First Circuit affirmed, holding that the district court did not err in honoring the Commonwealth's claim of entitlement to the letter. View "United States v. Boss" on Justia Law

The First Circuit dismissed this appeal from the district court's denial of Plaintiff's request for injunctive relief, holding that Plaintiff's claims were moot.During the initial stages of COVID-19 vaccine distribution, the State of New Hampshire implemented a plan to allocate its supply. The overall plan earmarked up to ten percent of vaccines to an "equity plan" to reach certain vulnerable individuals. Before he obtained a vaccine appointment, Plaintiff sued to challenge the equity plan, arguing that the plan illegally discriminated on the basis of race. The district court denied Plaintiff's request for a preliminary injunction, and Plaintiff appealed. The First Circuit dismissed the appeal, holding that where Plaintiff no longer had any stake in how New Hampshire allocates its abundant supply of vaccines, his request for a preliminary injunction was moot. View "Pietrangelo v. Sununu" on Justia Law

The First Circuit affirmed the district court's entry of summary judgment on Count I of Plaintiff's complaint seeking damages under 42 U.S.C. 1983 but reversed the entry of summary judgment on Count IX, holding that unconstitutional conduct of police officers violated the clearly established law of the Supreme Court, as set forth in Florida v. Jardines, 569 U.S. 1, 6 (2013).Plaintiff brought this complaint against the Town of Orono, the chief of the Orono Police Department, and four police officers with whom he interacted during two encounters in 2016 - one in February and one in September - both of which resulted in his being arrested without a warrant on charges that were subsequently dropped. The district court granted summary judgment in favor of Defendants. The First Circuit affirmed in part and reversed in part, holding that the district court (1) correctly granted summary judgment on Count I relating to the February incident; but (2) erred in granting summary judgment on Count IX relating to the September incident. View "French v. Merrill" on Justia Law

In this appeal arising out of an adversary action filed in a Chapter 11 proceeding in the Bankruptcy Court for the District of Massachusetts the First Circuit affirmed the judgment of the bankruptcy court allowing the debtor to avoid a mortgage, holding that there was no error in the bankruptcy court's judgment.After Debtor filed for Chapter 11 bankruptcy Debtor commenced an adversary proceeding against U.S. Back seeking to "avoid" the mortgage because her name was missing from the certificate of acknowledgment. The district court granted Debtor's motion. The district court affirmed. The First Circuit affirmed, holding that summary judgment was properly granted for Debtor because the omission of Debtor's name from the certificate of acknowledgment was a material defect under Massachusetts law. View "U.S. Bank, N.A. v. Desmond" on Justia Law

The First Circuit affirmed Defendant's consecutive upwardly variant sentences imposed in two criminal cases, holding that both sentences were procedurally and substantively reasonable.While on bail pending trial for drug and firearm-related charges, Defendant was arrested and charged in a separate case with receipt of a firearm while under indictment for a felony. Defendant pleaded guilty to the firearm offenses in both cases and requested to be sentenced for both counts of conviction in a single proceeding. The district court granted the requested and sentenced Defendant to upwardly variant sentences. The First Circuit affirmed, holding that Defendant's sentences in both cases were procedurally reasonable and substantively reasonable. View "United States v. Vargas-Martinez" on Justia Law

The First Circuit affirmed the judgment of the district court granting Defendants' motion for summary judgment and dismissing Plaintiff's action against a police officer, police chief, and town alleging a violation of his federal and state civil rights for being arrested without probable cause, holding that the district court erred.During a domestic relations dispute, police officers arrested Plaintiff for domestic abuse assault. The charges were later dropped. Plaintiff then brought this action arguing that he had used justifiable force during the incident under state law to defend himself and his property. The district court granted summary judgment for Defendants, concluding that the officer had probable cause to arrest Plaintiff. The First Circuit affirmed, holding that there was probable cause under federal common law supporting Plaintiff's arrest for domestic violence assault. View "Karamanoglu v. Town of Yarmouth" on Justia Law

In this eviction action that was removed from a Massachusetts state court the First Circuit reversed the order of the district court ordering a remand in this case and directed the district court to retrieve the removed action and resume jurisdiction, holding that the district court erred.The action in this case sought both to evict Defendant for nonpayment of rent and to recover rent arrearages. Defendant removed the action to the federal district court on the grounds of diversity jurisdiction. In response, Plaintiff argued that the federal district court was entitled to abstain from adjudicating the action under the abstention principles set forth in Burford v. Sun Oil Co., 319 U.S. 315 (1943). The district court granted Plaintiff's motion to remand, concluding that abstention was appropriate. The First Circuit reversed, holding that the court's remand order was in error. View "Forty Six Hundred, LLC v. Cadence Education, LLC" on Justia Law