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

In this dispute between the Maine lobster industry and the National Marine Fisheries Service (the Agency) over a rule barring frequently employed methods of lobstering the First Circuit granted the Agency's motion for a stay pending appeal of the district court's issuance a permanent injunction, holding that the Agency was entitled to a stay.In 2021, the Agency issued a rule barring, from October to January each year, the most frequently employed methods of lobstering in an approximately 1,000-square-mile area of the Atlantic Ocean in order to reduce the risk that a right whale would become entangled in the ropes connecting lobster traps to buoys. Plaintiffs brought this action seeking to postpone enforcement of the new rule until the district court could finally decide whether the new rule was lawful. The district court granted Plaintiffs' preliminary request. The Agency appealed and asked the First Circuit to issue a stay of the district court order. The First Circuit granted the government's motion, holding the district court misapprended the record and erred in rejecting the Agency's arguments. View "District 4 Lodge of the International Ass'n v. Raimondo" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendants' joint motion to dismiss the charges against them on retrial, holding that the district court did not err.Defendants - Raymond Garraway and Cordwell Bennett - were convicted for possession with intent to distribute marijuana. Defendants moved for a mistrial. The district court granted the motion on the basis of the prosecution's improper arguments made at closing. When the prosecution began to retry them, Defendants filed a joint motion to dismiss for violation of the Double Jeopardy Clause. The district court denied the motion, finding that the prosecution did not intend to provoke a mistrial. The First Circuit affirmed, holding that the record amply supported the district court's decision. View "United States v. Garraway" on Justia Law

The First Circuit vacated the entry of summary judgment in this case brought by Plaintiff seeking relief from the termination of her benefits under the civil enforcement provision of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(1), holding that Defendant did not provide Plaintiff a full and fair review of her claim, and Plaintiff was prejudiced by Defendant's procedural violation.Plaintiff participated in a long-term disability plan sponsored by her employer and funded and administrated by Defendant. The Plan was subject to ERISA. When Defendant terminated Plaintiff's disability benefits, Plaintiff filed an internal appeal review. Defendant upheld the termination of benefits, relying in part on a report written by a doctor hired by Defendant to examine Plaintiff. Plaintiff was not given a copy of the doctor's report. Plaintiff sought relief under ERISA's civil enforcement provision, arguing that, in failing to provide her with an opportunity to respond to the doctor's report, Defendant failed to provide her with a full and fair review, as required by ERISA and its implementing regulation. The district court granted summary judgment for Defendant. The First Circuit vacated the summary judgment, holding that Defendant committed a procedural violation, and Plaintiff was prejudiced thereby. View "Jette v. United of Omaha Life Insurance Co." on Justia Law

The First Circuit reversed the order of the district court denying Lyft Inc.'s request to compel arbitration in this purported class action but affirmed the denials of preliminary injunctive relief, holding that the Federal Arbitration Act (FAA) applied.Plaintiffs were Massachusetts-based rideshare drivers who used the Lyft application and platform to find passengers. In their complaint, Plaintiffs claimed that Lyft misclassified them as independent contractors rather than employees. At issue on this appeal were rulings concerning Plaintiffs' requests for preliminary injunctive relief and the denial of Lyft's request to compel arbitration. The First Circuit reversed in part, holding (1) the FAA applies in this case; and (2) the district court did not err in denying Plaintiffs' requested injunction. View "Cunningham v. Lyft, Inc." on Justia Law

The First Circuit affirmed Defendant's conviction of intentionally causing damage to a protected computer and conspiring to do the same, holding that there was no error, plain or otherwise, in the proceedings below.Defendant committed a cyberattack against Boston Children's Hospital and Wayside Youth and Family Support Network causing both to lose their internet capabilities for several weeks. Defendant publicly admitted responsibility for the attacks. After an eight-day trial, Defendant was convicted for intentionally causing damage to a protected computer and conspiring to cause damage to a protected computer. The First Circuit affirmed (1) there was no violation of the Speedy Trial Act, 18 U.S.C. 3161-3174; (2) the district court did not err in denying Defendant's motion to suppress; (3) there was no abuse of discretion in the district court's denial of the four motions to withdraw that were filed by Defendant's trial counsel; (4) the district court did not err in precluding Defendant from raising a defense-of-others argument at trial; and (5) the trial judge did not err in denying three recusal motions Defendant made pro se after the verdict but before sentencing. View "United States v. Gottesfeld" on Justia Law

The First Circuit affirmed the judgment of the district court sentencing Defendant to seventy-two months of incarceration in connection with his plea of guilty to one count of unlawful possession of a firearm by a felon, holding that there was no error.On appeal, Defendant argued (1) the district court misapplied the Sentencing Guidelines when it imposed a four-level offense under U.S. Sentencing Guidelines Manual 2K2.1(b)(6)(B), and (2) the sentence was substantively unreasonable. The First Circuit affirmed, holding (1) the district court did not err in applying the four-level offense increase pursuant to section 2K2.1(b)(6)(B), and the sentence was otherwise procedurally reasonable; and (2) the sentence was plausible, defensible, and substantively reasonable. View "United States v. Rogers" on Justia Law

The First Circuit affirmed Defendant's conviction of one count of possession of child pornography, holding that none of Defendant's claims on appeal had merit.Defendant, an employee of U.S. Customs and Border Protection, came under investigation for downloading child pornography on his home computer. On appeal, Defendant argued that the district court erred in (1) refusing to suppress incriminating statements Defendant made when interviewed at his workplace by federal agents and (2) denying a post-trial motion seeking a Franks hearing to review an error in an affidavit used to secure the search warrant leading to the discovery of the incriminating evidence on Defendant's home computer. The First Circuit affirmed, holding that the district court (1) did not commit reversible error in finding that Defendant's interview was not custodial; and (2) did not err in denying Defendant's delayed request for a Franks hearing. View "United States v. O'Neal" on Justia Law

The First Circuit dismissed one of the claims in Petitioner's petition for review of the decision of the Board of Immigration Appeals (BIA) dismissing Petitioner's challenges to the denial of his asylum and withholding of removal claims and denied the others, holding that Petitioner was not entitled to relief.An immigration judge denied Petitioner's applications for asylum, withholding of removal, cancellation of removal, protection under the United Nations Convention Against Torture and voluntary departure. The BIA dismissed Petitioner's appeal. The First Circuit affirmed, holding (1) this Court lacked jurisdiction to consider Petitioner's first claim on appeal because Petitioner failed to exhaust his administrative remedies; (2) the BIA's decision on Petitioner's political opinion claim was supported by substantial evidence; and (3) Petitioner's withholding of removal claim failed because his asylum claim failed. View "Gomes v. Garland" on Justia Law

The First Circuit affirmed the judgment of the district court ordering that Plaintiff's breach of contract claim be dismissed for failure to state a plausible claim and granting summary judgment for Defendants on all remaining counts, holding that there was no error.Plaintiff sued the City of East Providence, Rhode Island, its School Department, and the School Superintendent, asserting claims arising from what she alleged were unlawful discriminatory employment actions taken against her. The First Circuit resolved all claims in favor of Defendants. The First Circuit affirmed, holding (1) Plaintiff failed to plead even a prima facie case of discrimination; and (2) Plaintiff's claim of retaliatory employment discrimination was not supported by admissible evidence that would warrant putting the case to a jury. View "Lima v. City of East Providence" on Justia Law

The First Circuit affirmed the ruling of the district court rejecting Defendant's request for a Franks hearing before Defendant entered a conditional guilty plea to one count of possession of a firearm by a prohibited person, holding that the district court did not err in denying Defendant a Franks hearing.Defendant was charged with one count of possession of a firearm by a prohibited person and one count of possession with the intent to distribute cocaine. Prior to trial, Defendant filed a motion to suppress evidence seized pursuant to search warrants and sought a Franks hearing on the basis of two alleged material omissions from the warrant affidavit. The district court denied both Defendant's Franks motion and his motion to suppress. The First Circuit affirmed, holding that the district court did not err in ruling that Defendant had failed to make the threshold showing necessary to obtain a Franks hearing. View "United States v. Leonard" on Justia Law