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

The First Circuit affirmed the judgment of the district court in favor of Defendants, denying Plaintiff's motion for class certification, and denying Plaintiff's motion to file a third amended complaint, holding that Defendant sufficiently warned investors about the vulnerability of its manufacturing infrastructure so that Plaintiff knew of the investment risks when he purchased his shares.Plaintiff was an investor who lost money when he bought stock in Keryx Biopharmaceuticals, Inc. and watched the value plummet soon after that purchase. Plaintiff sued Keryx and its executives, alleging that Keryx's inadequate disclosures about its manufacturing defects amounted to securities fraud. The district court allowed Defendants' motion for judgment on the pleadings. The First Circuit affirmed, holding that Plaintiff failed to state a claim under section 10(b) of the Securities Exchange Act. View "Karth v. Keryx Biopharmaceuticals, Inc." on Justia Law

The First Circuit affirmed the order of the district court dismissing Plaintiff's suit brought against Defendant, his employer, asserting claims of age-based discrimination under the Age Discrimination in Employment Act (ADEA) and Puerto Rico's statutory analog, holding that this Court will not adopt any version of the single filing rule that would excuse the procedural failings associated with Plaintiff's suit.In moving to dismiss the complaint, Defendant asserted that Plaintiff neglected to first file a complaint with the Equal Employment Opportunity Commission and therefore failed to exhaust his administrative remedies before filing suit. Plaintiff argued in response that the district court should adopt and apply the "single filing rule," otherwise known as the "piggyback rule," which would allow him to vicariously satisfy his exhaustion obligation by relying upon a timely-filed administrative complaint against his employer made by a similarly-situated plaintiff. The district court declined to adopt the single filing rule, dismissed Plaintiff's ADEA claims, and declined to exercise supplemental jurisdiction over his Puerto Rico law claims. The First Circuit affirmed, holding that the district court correctly dismissed the complaint. View "Perez-Abreu v. Metropol Hato Rey LLC" on Justia Law

The First Circuit affirmed the judgment of the district court sentencing Defendant to a 130-month term of immurement and refusing to grant him an offense-level reduction for acceptance of responsibility, holding that there was no error or abuse of discretion.Defendant pleaded guilty to conspiracy to distribute and to possess with intent to distribute controlled substances and to petit larceny. The district court imposed a downwardly variant sentence of 130 months' imprisonment. The First Circuit affirmed, holding (1) the district court did not clearly err in denying Defendant an offense-level reduction for acceptance of responsibility; and (2) Defendant's sentence was not substantively unreasonable. View "United States v. DeJesus" on Justia Law

In this en banc decision involving a real property dispute, the First Circuit affirmed the judgment of the district court holding that the "Penobscot Indian Reservation" (the Reservation) does not include the waters and submerged lands constituting the riverbed of the six-mile stretch of the Penobscot River known as the Main Stem, holding that the district court did not err.The Penobscot Nation sued the State of Maine and various state officials seeking a declaratory judgment that the Nation had exclusive regulatory authority over the Main Stem and a declaratory judgment that the Nation had sustenance fishing rights in the Main Stem. The district court declared that the Reservation does not include the waters of the Main Stem or the submerged lands of the riverbed beneath it but that the Nation had sustenance fishing rights in the Main Stem. A divided panel of the First Circuit affirmed in part and vacated in part. The First Circuit subsequently vacated the panel opinion and granted rehearing en banc. The Court then held (1) the Reservation does not include the waters and submerged lands constituting the riverbed of the Main Stem; and (2) as to the Nation's claim that Maine infringed on its fishing rights, the claim was not ripe and the Nation lacked standing. View "United States v. Frey" on Justia Law

The First Circuit affirmed the federal convictions and sentences of Defendants - Herzzon Sandoval, Edwin Guzman, Erick Argueta Larios, and Cesar Martinez - stemming from a federal criminal investigation into La Mara Salvatrucha, a transnational criminal organization, in Massachusetts, holding that there was no prejudicial error.Specifically, the First Circuit held (1) Defendants' sufficiency of the evidence challenges to their respective convictions were without merit; (2) there was no merit to Defendants' claims that the district court erred in denying a motion for a continuance due to pretrial publicity or in denying their motion for a mistrial; (3) Defendants' challenges to the court's evidentiary rulings failed; (4) challenges concerning purported misstatements of the evidence in the government's closing argument and purported instructional errors provided no basis for overturning Defendants' convictions; and (5) Defendants' challenges to their sentences failed. View "United States v. Sandoval" on Justia Law

The First Circuit reversed in part and affirmed in part the judgment of the district court dismissing Plaintiff's complaint filed in connection with mother's estate, holding that the district court erred in granting the motion to dismiss as it pertained to count two.Plaintiff brought this suit against Defendants, her two sisters, who were appointed as co-executors of the estate upon the death of the mother. Count one set forth a number of state law tort claims relating to Defendants' actions with respect to actions that Plaintiff contended should have been part of the estate. Count two set forth Massachusetts law claims relating to the discharge of a mortgage that the motion held on Plaintiff's Massachusetts condominium. Defendants and the mother were all New Jersey residents. The district court granted Defendants' motion to dismiss, finding a lack of personal jurisdiction conclusive of this case. The First Circuit reversed in part, holding (1) the district court erred in ruling that there was no federal subject matter jurisdiction over Plaintiff's count two claims; and (2) the district court properly dismissed Plaintiff's count one claims. View "Mojtabai v. Mojtabai" on Justia Law

In this complaint alleging violations of the Clean Water Act (CWA), 33 U.S.C. 1251 et seq., and the Resource Conservation and Recovery Act (RCA), 42 U.S.C. 6901 et seq., the First Circuit vacated the order of the district court granting a motion to stay the proceedings under the so-called doctrine of primary jurisdiction, holding that the district court improperly stayed the case.Conservation Law Foundation, a not-for-profit organization, brought this suit against ExxonMobil Corporation, ExxonMobil Oil Corporation, and ExxonMobil Pipeline Company (collectively, ExxonMobil), alleging unlawful violations at ExxonMobil's petroleum storage and distribution terminal in Everett, Massachusetts. After the district court denied ExxonMobil's motion to dismiss, ExxonMobil moved to stay the case under the doctrine of primary jurisdiction until the Environmental Protection Agency (EPA) issued a decision on ExxonMobil's pending permit renewal application for the Everett terminal. The First Circuit vacated the stay order, holding that the district court erred in granting a stay under the doctrine of primary jurisdiction until EPA issues a new permit for ExxonMobil's Everett terminal. View "Conservation Law Foundation v. ExxonMobil Corp." on Justia Law

The First Circuit vacated the judgment of the district court dismissing this action against the Puerto Rico Aqueduct and Sewer Authority (PRASA) under the citizen enforcement provision of the federal Clean Water Act (CWA), 33 U.S.C. 1365(a), holding that Plaintiff alleged sufficient facts to survive a motion to dismiss.In his complaint, Plaintiff claimed that PRASA was violated the CWA by discharging raw sewage that flowed into a creek near her home in San Juan. The district court dismissed the complaint for failure to state a claim, finding that a citizen suit was barred because the Environmental Protection Agency (EPA) was prosecuting a case it previously filed against PRASA addressing the same violations. The First Circuit vacated the order, holding (1) the district court failed to follow the correct standard for evaluating a motion to dismiss; and (2) Plaintiff's complaint stated a plausible claim that the EPA was not diligently persecuting certain violations. View "Cebollero-Bertran v. Puerto Rico Aqueduct & Sewer Authority" on Justia Law

The First Circuit affirmed the judgment of the district court denying Petitioner's petition for a writ of habeas corpus under 28 U.S.C. 2254, as amended by the Antiterrorism and Effective Death Penalty Act (AEDPA), holding that the district court did not err in denying the petition.In his habeas petition, Petitioner alleged that the trial court violated his constitutional rights to a complete defense and to have effective assistance of counsel. The district court denied the petition. The First Circuit affirmed, holding (1) the exclusion of certain medical evidence, even if error, was harmless beyond a reasonable doubt; and (2) trial counsel was not constitutionally deficient for not consulting or calling a child abuse expert who could testify to the effects of Munchausen Syndrome by Proxy on fathers like Petitioner. View "Strickland v. Goguen" on Justia Law

The First Circuit affirmed the drug conspiracy and distribution convictions of five members of a drug trafficking organization, holding that none of the issues raised by the five defendants translated into reversible error warranting vacatur of their convictions or sentences.Fifty-five individuals were indicted on charges of conspiracy to distribute heroin, cocaine, cocaine base, marijuana, and prescription pills. By the time a jury trial began most of the defendants had pleaded guilty. Five of the defendants who were ultimately convicted appealed their convictions, and some of them appealed their sentences. The defendants were Joel Rivera-Alejandro, Carlos Rivera-Alejandro, Juan Rivera-George, Suanette Ramos- Gonzalez, and Idalia Maldonado-Pena. The First Circuit affirmed the judgments in their entirety, holding that there was no reversible error in this case. View "United States v. Maldonado-Pena" on Justia Law