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

The First Circuit denied Plaintiff's motion for an injunction preventing the implementation of a plan promulgated by the Boston Public Schools for admitting students to Boston Latin School, Boston Latin Academy, and John D. O'Bryant School of Mathematics and Science for the 2021-2022 school year, holding that Plaintiff did not show it was not entitled to the injunction.Plaintiff, a corporation acting on behalf of fourteen parents and children residing in Boston, asserted that the 2021-2022 admissions plan violated the Equal Protection Clause of the Fourteenth Amendment and Mass. Gen. Laws ch. 76, 5. The district court entered judgment in Defendants' favor. Plaintiff appealed and moved for an order under Fed. R. Civ. P. 62(d) enjoining Defendants from implementing the plan during the pendency of this appeal. The First Circuit denied the motion, holding that Plaintiff failed to show a strong likelihood that it would prevail on the merits. View "Boston Parent Coalition for Academic Excellence Corp. v. School Committee of City of Boston" on Justia Law

The First Circuit affirmed the decision of the Bankruptcy Appellate Panel for the First Circuit (BAP) affirming the judgment of the bankruptcy court finding that Debtor defaulted on his obligation and refusing to grant him a discharge, holding that Debtor's assignments of error were unavailing.Debtor filed a petition for Chapter 13 bankruptcy in the District of Massachusetts. The case was subsequently converted to a Chapter 7 case. After Debtor failed to file any of the documents mandated by court orders the court entered a further order requiring Debtor to file the overdue documents by a certain date. Debtor did not heed the order. After a show cause hearing, the bankruptcy court denied Debtor a discharge and dismissed his petition for failing to ignore the court's orders. The BAP affirmed. The First Circuit affirmed, holding that Debtor received the constitutional protections to which he was entitled and that, due to Debtor's conduct, the bankruptcy court's denial of a discharge was within its discretion. View "Francis v. Desmond" on Justia Law

The First Circuit affirmed Defendant's conviction of conspiracy to commit various financial crimes, conspiracy to commit money laundering, and converting government property, holding that Defendant was not entitled to relief as to any of his assignments of error.This case arose from Defendant's participation, along with several coconspirators, in a scheme to defraud the federal government by falsifying tax returns. A jury convicted him of multiple counts, and the judge sentenced him to eighty-four months in jail. The First Circuit affirmed, holding (1) Defendant's claims of error in the trial judge's evidentiary rulings were unavailing; and (2) the judge properly applied two sentencing enhancements. View "United States v. Grullon" on Justia Law

The First Circuit affirmed in part and reversed in part the judgment of the district court granting summary judgment in favor of Defendants and dismissing Blackstone Headwaters Coalition, Inc.'s complaint alleging that Defendants had violated the Federal Clean Water Act (CWA), 33 U.S.C. 1251 et seq., holding that the district court erred by granting summary judgment on Count I of the complaint.Plaintiff, a non-profit environmental organization, sued two companies and two individuals involved in the development of a residential construction site in Massachusetts. In Count I of the complaint, Plaintiff alleged that three defendants had violated the Federal CWA by failing to obtain from the EPA a construction general permit. Count II alleged that all four defendants had violated the Federal CWA by failing to prevent sediment-laden stormwater discharges from flowing from that construction site into waters leading to the Blackstone River. The district court granted summary judgment for Defendants. The First Circuit reversed in part, holding that nothing supported Defendants' argument that a citizen suit under the Federal CWA cannot be brought against an entity that is alleged to be an operator of a construction site that is unlawfully discharging pollutants into federal waters long as another entity controlled by the same individuals has such permit coverage. View "BBlackstone Headwaters Coalition, Inc. v. Gallo Builders, Inc." on Justia Law

In this property dispute leading to a bankruptcy filing, the First Circuit held that a probate court's contempt proceedings and resultant penalties were excepted from an automatic stay and that the bankruptcy court did not abuse its discretion in partially lifting the stay.Donald Kupperstein rented certain property that he did not own to various tenants. The property belonged to the Estate of Fred Kuhn, now managed by Irene Stall. The Estate owed money to Massachusetts Office of Health and Human Services (MassHealth). When Kupperstein would not relinquish his claim to the property, the parties ended up in several Massachusetts courts. The probate court voided the property's transfer and ordered Kupperstein to pay to rents collected from the property to MassHealth. Kupperstein subsequently filed for bankruptcy, and the court held him in contempt. Schall and MassHealth filed motions in the bankruptcy court to lift the automatic stay as it applied to state court actions so the cases could proceed. The court lifted the stay and denied Kupperstein's motion to hold MassHealth in contempt and to impose sanctions. The district court affirmed. The First Circuit affirmed, holding that the district court did not err in denying relief. View "Kupperstein v. Schall" on Justia Law

In this case arising from what the Social Security Administration (SAA) did to Appellants, Marie Pagan-Lisboa and Daniel Justiniano-Ramirez, after Jose Hernandez-Gonzalez and Samuel Torres-Crespo admitted to fraudulently helping people get disability-insurance benefits from the SAA, the First Circuit held that Appellants were entitled to a new redetermination proceeding.With the help of Hernandez-Gonzalez and Torres-Crespo, Pagan-Lisboa applied for and started getting disability benefits from the SAA. An ALJ determined that Pagan-Lisboa did not have sufficient evidence to support her initial benefits claim and terminated her benefits. An ALJ also canceled Justiniano-Ramirez's benefits benefits on the grounds that Hernandez-Gonzalez had provided fraudulent evidence in support of the benefits. Thereafter, Appellants sued a putative class action, arguing that the SAA could not terminate their benefits without letting them contest the existence of fraud in their cases. The court of appeals affirmed the ALJ's decision in Justiniano-Ramírez's case and remanded Pagan-Lisboa's case back to the agency. The First Circuit held (1) the judge erred in not accepting Justiniano-Ramírez's amended complaint, which showed that he had exhausted his administrative remedies; and (2) the judge did not wrongly dismiss Appellants' policy challenges to the redetermination procedure. View "Pagan-Lisboa v. Social Security Administration" on Justia Law

The First Circuit reversed the judgment of the district court dismissing and this medical malpractice claim, holding that the lawsuit was timely filed and not outside the statute of limitations.The district court set aside a jury verdict for Plaintiffs, granted Defendants' motion for judgment as a matter of law, and dismissed this case as untimely, finding that a reasonable jury could not have concluded that this suit was not time barred. On appeal, Plaintiffs argued that even with the exercise of proper diligence they could not have had the requisite knowledge to file suit against Defendant more than one year before they did. The First Circuit agreed and reversed, holding that a reasonable jury could have found that Plaintiffs did not obtain the necessary knowledge to sue until sometime after one year prior to filing suit. View "Melendez-Colon v. Rosado-Sanchez" on Justia Law

The First Circuit affirmed the judgment of the district court sentencing Defendant in connection with his plea of guilty to the federal crime of carjacking, 18 U.S.C. 2119, holding that the sentence was reasonable.Prior to Defendant's guilty plea he entered into a plea agreement with the government stipulating a total offense level (TOL) but not a criminal history category (CHC). At sentencing, the district court calculated a higher TOL than the one in the plea agreement. Together with the court's CHC calculation, the calculated TOL resulted in a higher sentencing range than that set out in the plea agreement. The First Circuit affirmed the sentence, holding (1) the district court committed no procedural errors during sentencing; and (2) Defendant's sentence was substantively reasonable. View "United States v. Pupo" on Justia Law

The First Circuit affirmed the district court's grant of summary judgment in favor of Defendants - the City of Framingham and Chief of the Framingham Police Department - in this Garcetti speech-retaliation and Massachusetts Whistleblower Act action brought by Plaintiff, an FPD detective, holding that the district court did not err.Plaintiff brought this lawsuit challenging allegedly retaliatory employment actions, including a five-day suspension and his being put on paid administrative leave during an investigation. The district court granted summary judgment for Defendants, concluding that Defendants met their burden to show that the adverse employment decisions would have occurred despite Plaintiff's protected speech. The First Circuit affirmed, holding that Defendants met their burden to prove an independent non-retaliatory basis for Plaintiff's discipline. View "Gutwill v. City of Framingham" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing the claims brought by two unions, which represented public employees in Puerto Rico, and one of their members against the United States, the Financial Oversight and Management Board, and the Commonwealth, holding that Plaintiffs lacked standing.In their complaint, Plaintiffs raised a range of claims under federal constitutional and international law concerning the legal status of Puerto Rico. The district court dismissed Plaintiffs' claims for declaratory relief for lack of subject matter jurisdiction, concluding that Plaintiffs failed to allege concrete and particularized injuries that their requested relief could redress. The First Circuit affirmed, holding that Plaintiffs did not meet their burden to satisfy the federal constitutional requirements for standing. View "UECFSE v. United States" on Justia Law