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

The First Circuit reversed the judgment of the district court dismissing Plaintiffs' securities fraud class action alleging that Carbonite, Inc. and certain current and former officers misled investors by touting a new product that they knew did not work, holding that the complaint sufficiently pleaded a claim.Plaintiffs, the Construction Industry and Laborers' Joint Pension Trust and other holders of Carbonite's common stock, brought this complaint seeking recovery under sections 10(b) and 20(a) of the Securities Exchange Act. Defendants filed a motion to dismiss, which the district court allowed. The First Circuit reversed, holding that the complaint sufficiently pled that Defendants' statements were material misrepresentations made with scienter. View "Construction Industry & Laborers Joint Pension Trust v. Carbonite, Inc." on Justia Law

The First Circuit reversed the judgment of the district court requiring the parties to arbitrate their dispute in this case, holding that the district court erred in compelling arbitration.In 2000, Air-Con signed a written distribution agreement with Daikin Industries, LTD to be an authorized distributor in Puerto Rico of air conditioning and refrigeration equipment. The agreement contained an arbitration provision requiring the parties to arbitrate any disputes in Japan. Also in 2000, Air-Con established a distribution relationship with Daikin Applied Latin America, LLC, Daikin Industries' subsidiary. In 2018, Air-Con filed suit against Daikin Applied seeking injunctive relief and damages under Puerto Rico's Dealer Protection Act. After the case was removed to federal court Daikin Applied filed a motion to compel arbitration, arguing that the written agreement between Air-Con and Daikin Industries governed Daikin Applied's relationship with Air-Con. The district court agreed with Daikin Applied. The First Circuit reversed, holding that the district court erred in concluding that Air-Con agreed to arbitrate the claims at issue in this case. View "Air-Con, Inc. v. Daikin Applied Latin America, LLC" on Justia Law

The First Circuit affirmed Defendant's upwardly variant sentence imposed in connection with his conviction for possessing a firearm in furtherance of a drug-trafficking crime, holding that the sentence was neither procedurally nor substantively unreasonable.Defendant entered a straight guilty plea to two counts of possession of drugs with intent to distribute and one count of possession of a firearm in furtherance of a drug-trafficking crime. The district court imposed an aggregate incarcerate sentence of eighty-eight months. On appeal, Defendant argued, among other things, that the sentencing court erred in imposing an upwardly variant sentence without providing adequate justification. The First Circuit affirmed, holding (1) there was no procedural error; and (2) the sentence was substantively reasonable. View "United States v. Valle-Colon" on Justia Law

The First Circuit affirmed the decision of the Massachusetts Department of Environmental Protection (DEP) reaffirming the issuance of an air permit to Algonquin Gas Transmission, LLC for a natural gas compressor station in Weymouth, Massachusetts, holding that the agency's actions were not arbitrary or capricious.DEP had previously approved Algonquin's plans to power the Weymouth station using a natural gas-fired turbine, which emitted nitrogen oxides. In a prior appeal, the City of Quincy, the Towns of Braintree and Hingham, and a group of citizens (collectively, the City) and other petitioners established that the DEP did not follow its own procedures when it eliminated an electric motor as a possible alternative to the gas-fired turbine, and the First Circuit remanded the case. On remand, DEP again concluded that an electric motor was not what Massachusetts regulations call the "best available control technology" (BACT) for the new compressor station and reaffirmed the air permit at issue. The First Circuit affirmed the DEP's decision after remand, holding that substantial evidence supported the decision and that the agency's determination was not arbitrary and capricious. View "City of Quincy v. Massachusetts Department of Environmental Protection" on Justia Law

The First Circuit affirmed the district court's judgment denying Defendant's motion to suppress evidence obtained during the execution of a no-knock search warrant at the apartment where he and his girlfriend lived, holding that the district court did not err.On appeal, Defendant argued that the district court erred by failing to suppress evidence obtained from the search of his backpack because his backpack was not properly subject to search and erred in failing to find that there was insufficient justification for the no-knock provision of the warrant. The First Circuit affirmed, holding (1) there was nothing improper about the search; and (2) the district court did not commit plain error by not ruling that the no-knock provision was unsupported. View "United States v. Congo" on Justia Law

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