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

The First Circuit vacated the entry of an amended judgment entered in this medical malpractice case, holding that the district court erred in granting judgment as a matter of law.Plaintiffs, a couple and their minor child, sued Defendants, a hospital and a medical doctor, seeking damages for the brain damage that the child suffered at his birth. The jury entered a verdict of just under $5 million in favor of Plaintiffs. The hospital subsequently filed two post-trial motions - a renewed motion for judgment as a matter of law under Fed. R. Civ. P. 50(b). In granting the motion, the district court reconsidered its position at trial and struck the testimony of the only expert on future costs. The court then entered an amended judgment setting aside just over $3 million of the judgment. The First Circuit vacated the judgment below, holding that the district court erred. View "Santos-Arrieta v. Hospital Del Maestro, Inc." on Justia Law

The First Circuit affirmed Defendants' convictions of one count each of conspiracy to possess with intent to distribute and to distribute one hundred grams or more of heroin and one count each of possession with intent to distribute and distribution of heroin, holding that there was no error.Specifically, the First Circuit held (1) the district court did not err in denying Defendants' pre-trial rulings denying their motions to suppress evidence that resulted from the search of their vehicle, including their statements made during the stop; (2) the district court did not impermissibly limit the questioning of Gutierrez in violation of the Confrontation Clause; (3) the prosecutor improperly made a statement during closing argument that referred to facts not in evidence, but the statement was harmless; (4) the district court properly instructed the jury in response to a question asked during deliberations; and (5) the district court did not err in applying the mandatory minimum sentence under 21 U.S.C. 841(b)(1)(B)(i). View "United States v. Cruz-Rivera" on Justia Law

The First Circuit affirmed the decision of the district court rejecting Appellants' facial challenge to the Rhode Island comprehensive statutory scheme designed to increase transparency in regard to election-related spending, holding that there was no error.The law at issue required limited disclosure of funding sources responsible for certain independent expenditures and electioneering communications. Appellants challenged the disclosure an disclaimer provisions, arguing that the provisions did not withstand the required degree of scrutiny and infringed on constitutionally protected free-speech, privacy, and associational rights. The trial court dismissed the complaint. The First Circuit affirmed, holding that the challenged aspects of Rhode Island's disclosure and disclaimer regime were constitutional. View "Gaspee Project v. Mederos" on Justia Law

The First Circuit reversed the ruling of the district court suppressing blood alcohol content evidence from a warrantless blood draw because no exigent circumstances were present, holding that the district court misapplied the law to the facts in this case.After a car accident that killed three people, a police officer ordered a warrantless blood of Defendant's blood without Defendant's consent and without exigent circumstances. The government charged Defendant with three counts of manslaughter and other intoxicated-driving crimes. Defendant filed a motion to suppress evidence from the warrantless blood draw, which the district court granted. The First Circuit reversed, holding that the government met its burden to show it was reasonable for the police officer to think exigent circumstances existed when he took the blood draw. View "United States v. Manubolu" on Justia Law

The First Circuit affirmed Defendants' cross-motions for summary judgment in this action challenging the denial of Plaintiff's application for a "permit to purchase" a firearm, holding that Defendant provided no basis on appeal for overturning the district court's grant of summary judgment to Defendants.William Lyver, the chief of police for Northborough, Massachusetts, denied Plaintiff a permit to purchase based on Plaintiff's criminal history - specifically, his two out-of-state firearms-related convictions. Plaintiff subsequently brought this action pursuant to 42 U.S.C. 1983 seeking a declaratory judgment that Mass. Gen. Laws ch. 140, 131(d)(ii)(D) violated the Second and Fourteenth Amendments to the United States Constitution. The district court upheld the provisions on the ground that they were substantially related to an important governmental interest. The First Circuit affirmed, holding that Plaintiff provided no ground for overturning the district court's grant of summary judgment to Defendants. View "Morin v. Lyver" on Justia Law

The First Circuit affirmed Defendant's conviction of possession of child pornography involving a minor who had not yet attained twelve years of age and sentence of twenty-eight months' imprisonment followed by a sixty-month term of supervised release, holding that Defendant's claims of error were unavailing.Specifically, the First Circuit held (1) the government's evidence was sufficient to sustain a finding of guilt beyond a reasonable doubt; (2) there was no plain error in the district court's procedure for entertaining juror questions; and (3) Defendant waived any objection to the district court's jury instruction on the definition of "knowingly." View "United States v. Levin" on Justia Law

In these cross-appeals, the First Circuit vacated the district court's opinion and order entered on September 30, 2017 and part of the amended judgment entered on September 19, 2019 and directed the entry of an amended judgment in favor of a playwright on his claim of copyright infringement, holding that the district court erred.At issue was whether Editorial Cultural, Inc. was liable for copyright infringement after it printed and sold 20,000 copies of the theatrical adaptations of two novels written by Puerto Rico author Enrique Laguerre. Plaintiffs - Laguerre's heirs and Roberto Ramos Perea, the playwright who adopted the novels for the stage - sued Editorial Cultural, claiming that Ramos owned the copyrights to both adaptations and that Editorial Cultural infringed those copyrights. The district court dismissed Ramos as the copyright owner and entered judgment against Editorial Cultural, awarding damages to Laguerre's heirs. The First Circuit eliminated Ramos as the copyright owner and awarded damages to Laguerre's heirs. The First Circuit directed the entry of amended judgment in favor of Ramos, holding that the district court erred in concluding that Laguerre retained the right to print the adaptations at issue here. View "Perea v. Editorial Cultural, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court denying, without a hearing, Defendant's motion seeking a reduction of his sentence per the terms of the Fair Sentencing Act, Pub. L. No. 111-220, 2, 124 Stat. 2372, and the First Step Act of 2018, Pub. L. No. 115-391, 231 Stat. 5194, holding that the district court did not err.In 2008, Defendant was convicted by a jury of distributing more than five grams of cocaine base and sentenced to eighteen years in prison. After Congress passed the Fair Sentencing Act and the First Step Act, Defendant filed a motion in district court seeking a reduction in his sentence per the terms of those statutes. The district court summarily denied the motion. The First Circuit affirmed, holding that the district court did not err in declining to modify Defendant's sentence. View "United States v. Fields" on Justia Law

The First Circuit vacated Defendant's conviction of attempted enticement of a minor for unlawful sexual activity, holding that the district court committed plain error in failing to give a jury instruction on the entrapment defense.Defendant was apprehended through a sting operation in which a government agent created a profile on a dating application and, after being contact by Defendant, offered to arrange a sexual encounter with the agent's "minor boyfriend." On appeal, Defendant argued, among other things, that the district court erred in rejecting his request for an entrapment instruction. The First Circuit agreed and remanded the case for a new trial, holding that the trial court committed clear or obvious error in refusing Defendant's entrapment defense, and the error affected Defendant's substantial rights and undermined the fundamental fairness of his trial. View "United States v. Perez-Rodriguez" on Justia Law

The First Circuit vacated the judgment of the district court against Bais Yaakov of Spring Valley, a small private high school on its action seeking injunctive relief and statutory damages against ACT, Inc., a non-profit entity that develops and administers the ACT college admissions test, holding that the district court erred in finding that Bais Yaakov's individual claim was rendered moot.In its complaint, Bais Yaakov claimed that three one-page faxes sent by ACT in 2012 were unsolicited advertisements sent in violation of the Telephone Consumer Protection Act (TCAP, 47 U.S.C. 227(b)(1)(C) and seeking injunctive relief and statutory damages in the amount of approximately $400 million dollars. After extended litigation, the district court concluded that class certification was unwarranted and that Bais Yaakov's individual claim was rendered moot by ACT's offer to pay the full amount of that claim and a promise not to sent further faxes to the high school. The First Circuit affirmed the denial of class certification and the dismissal of the claim for injunctive relief but otherwise vacated the judgment, holding (1) the district court did not abuse its discretion in finding that the proposed classes could not be certified or in denying injunctive relief; and (2) Bais Yaakov's damage claim was not moot. View "Bais Yaakov of Spring Valley v. ACT, Inc." on Justia Law