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

The First Circuit vacated the judgment of the Board of Immigration Appeals (BIA) dismissing Appellant's appeal from a decision of an immigration judge (IJ) ordering him removed from the United States, holding that the BIA failed to address Appellant's request to apply equitable tolling in assessing whether her appeal was timely.Appellant, a native and citizen of Jamaica, applied for asylum, withholding of removal, and protection under the United Nations Convention Against Torture. The IJ denied Appellant's requests for relief and ordered her removed to Jamaica. In the midst of the newly-announced health emergency occasioned by the COVID-19 pandemic, Appellant missed the deadline to appeal the IJ's removal order. The BIA summarily dismissed Appellant's appeal as untimely. The First Circuit vacated the BIA's order of dismissal, holding that the BIA erred by failing to consider Appellant's request for equitable tolling in deciding whether her appeal was timely. View "James v. Garland" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motion under the First Step Act (codified as amended in scattered sections of 18 U.S.C., 21 U.S.C., and 34 U.S.C.) to reduce his sentence for a more than decade-old federal drug offense, holding that the motion was moot.In 2000, Defendant received a sentence for his convictions and was sentenced to a term of imprisonment followed by supervised release. While Defendant's supervised release from prison began in 2007, Defendant thrice violated the terms of his supervised release and was sentenced in 2010 to six months' imprisonment. In 2019, Defendant moved to have his fully-served sentence reduced under the First Step Act. The district court denied the motion as moot. The First Circuit affirmed, holding that the district court did not err in dismissing Defendant's First Step Act motion as moot. View "United States v. Melendez" on Justia Law

The First Circuit vacated the district court's damages award and certain of its other rulings in this dispute between sophisticated parties concerning intellectual property rights, holding that the district court erred in applying the pertinent principles to the documents at issue.Plaintiffs brought suit alleging that Defendants violated the terms of a license by failing to pay certain royalties and sublicensing fees. The district court granted partial summary judgment for Plaintiffs. The First Circuit vacated the judgment in favor of Plaintiffs as to the breach of contract claim and directed the district court to enter judgment granting Defendants' motion to dismiss that claim and vacated the judgment as to audit-and-account and reformation claims without prejudice, holding that the district court erred. View "General Hospital Corp. v. Esoterix Genetic Laboratories, LLC" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant of three drug trafficking offenses after law enforcement officers discovered cocaine and heroin inside of his vehicle, holding that the district court did not err in denying Defendant's motion to suppress.In his motion to suppress, Defendant argued that the officers stopped his vehicle without reasonable suspicion, in violation of the Fourth Amendment, and therefore, the drugs found inside of the vehicle were inadmissible as evidence. The district court denied Defendant's motion to suppress. The First Circuit affirmed, holding that the officers had probable cause to arrest Defendant when they conducted the vehicle containment in this case. View "United States v. Gonzalez" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellants' request for a preliminary injunction to prevent enforcement of a regulation promulgated by Maine's Center for Disease Control requiring all workers in licensed healthcare facilities to be vaccinated against COVID-19, holding that the district court did not err.Under Maine law, a healthcare worker may claim an exemption from the vaccination requirement only if a medical practitioner certifies that vaccination "may be medically inadvisable." Appellants - several Maine healthcare workers and a healthcare provider - brought this action alleging that the vaccination requirement violated their rights under 42 U.S.C. 1985 and the Free Exercise Clause, Supremacy Clause, and Equal Protection Clause of the United States Constitution. The district court denied Appellants' motion for a preliminary injunction. The First Circuit affirmed, holding that the district court did not err in concluding that Appellants were unlikely to succeed on the merits of their claims. View "Does v. Mills" on Justia Law

The First Circuit vacated the order of the Board of Immigration Appeals (BIA) that affirmed the denial of Appellant's application for withholding of removal and protection under the Convention Against Torture (CAT), holding that the BIA's affirmance of the immigration judge's (IJ) finding of adverse credibility did not hold up.After a hearing, the IJ issued an oral decision denying Appellant's claims, finding that Appellant was not a credible witness in terms of crucial aspects of his claim and his lack of credibility was ultimately fatal to his argument that he had suffered past persecution. The BIA affirmed. The First Circuit vacated the BIA's order, holding that the BIA's affirmance of the IJ's adverse credibility finding could not be sustained, and therefore, the BIA's rulings could also not be sustained. View "Lopez Troche v. Garland" on Justia Law

The First Circuit affirmed the rulings of the district court dismissing Plaintiff's claims alleging that his termination violated 42 U.S.C. 1983 and Titles VI and VII of the Civil Rights Act of 1964, holding that there was no merit to Plaintiff's challenges on appeal.On appeal, Plaintiff challenged the district court's grant of summary judgment to Defendant on his Title VII retaliation claim, its dismissal of Plaintiff's Title VII hostile work environment claims for his failure to exhaust administrative remedies, and its denial of Plaintiff's motion for leave to amend his complaint to add a claim of disability discrimination. The First Circuit affirmed, holding that the district court did not err in granting summary judgment on the retaliation claim, its dismissal of the hostile work environment claim, and its denial of Plaintiff's motion to amend his complaint. View "Jenkins v. Housing Court Department" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing this action for want of subject matter jurisdiction, holding that the district court did not err.AMTAX Holdings 227 LLC, joined by Tax Credit Holdings III, LLC, sued Tenants' Development Corporation (TDC) and Tenants' Development II Corporation (TD II) in the United States District Court for the District of Massachusetts seeking a declaratory judgment concerning the validity of an agreement that embodied a right of first refusal. TDC and TD II moved to dismiss the suit for want of federal subject-matter jurisdiction. The district court dismissed the suit. The First Circuit affirmed, holding that the district court did not err in concluding that the complaint in this case failed to trigger embedded federal question jurisdiction. View "AMTAX Holdings 227, LLC v. Tenants' Development II Corp." on Justia Law

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