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

The First Circuit denied the petition filed by Petitioner, a Salvadoran national, seeking judicial review of a decision of the Board of Immigration Appeals (BIA) upholding an adverse decision by an immigration judge (IJ) denying Petitioner's application for withholding of removal, holding that Petitioner was not entitled to relief.Specifically, the First Circuit held (1) substantial evidence in the record supported the agency's determination that Petitioner failed to show an entitlement to withholding of removal based on a clear probability of either past or future religious persecution; (2) Petitioner waived his argument that the BIA erred in rejecting his "social group" claim; and (3) the BIA did not abuse its discretion by not remanding the case to the IJ for further proceedings. View "Sanchez-Vasquez v. Garland" on Justia Law

The First Circuit vacated Defendant's convictions on six counts relating to public corruption in the Commonwealth, holding that the district court's refusal to sever Defendant's trial from that of one of her codefendants was an abuse of discretion.Defendant worked as the administrator of the Puerto Rico Workforce Development Administration (ADL) for two years before she was charged with various federal offenses relating to public corruption. Defendant was tried jointly with three other individuals who were also charged in the indictment and convicted of all six counts that she faced. The First Circuit vacated the convictions, holding (1) there was sufficient evidence in the record supporting the convictions; but (2) the district court abused its discretion in declining to sever Defendant's trial from that of her codefendant, and the resulting prejudice was such that the matter must be remanded for a new trial. View "United States v. Lopez-Martinez" on Justia Law

The First Circuit affirmed Defendant's conviction for conspiring to commit drug trafficking offenses but remanded the case for resentencing, holding that the district court erred in imposing a two-level enhancement to Defendant's base offense level.A jury convicted Defendant of conspiracy to possess with intent to distribute a controlled substance and conspiracy to import narcotics into the United States, and the district court imposed a sentence of approximately 224 months, reflecting a sentence at the lowest end of the recommended range. The First Circuit affirmed, holding (1) the trial court erred in permitting the government to solicit "overview" testimony and in allowing the government to present evidence relating to a previous cocaine seizure, but both errors were harmless; and (2) while Defendant's claim that there was an unwarranted disparity between his sentence and those of his codefendants lacked merit, the district court erred by imposing a supervisory role enhancement without identifying evidence that Defendant played a supervisory role in the conspiracy. View "United States v. Garcia-Sierra" on Justia Law

The First Circuit affirmed the order of the district court imposing a sanction against Appellant under Fed. R. Civ. P. 11, holding that the district court did not abuse its discretion.Appellant was a Massachusetts lawyer who brought suit on behalf of Gerald Alston, a black man who formerly worked as a firefighter. Defendant Stanley Spiegel eventually moved to dismiss and for sanctions. The magistrate judge recommended that the district court dismiss the claims against Spiegel with prejudice and ruled that sanctions were in order. The First Circuit affirmed, holding that because Appellant persisted in pursuing claims against Spiegel without an adequate basis in law or fact and despite a warning from the magistrate judge, sanctions were in order. View "Ames v. Spiegel" on Justia Law

The First Circuit denied Petitioner's petition for review of an order of the Board of Immigration Appeals (BIA) denying Petitioner's motion to reopen the BIA's decision denying Petitioner's application for cancellation of his removal, holding that any error was harmless.After Petitioner, a citizen of Guatemala, was issued a notice to appear Petitioner applied for cancellation of his removal under 8 U.S.C. 1229b(b)(1). The immigration judge denied the application, and the Board of Immigration Appeals (BIA) affirmed. Petitioner later filed a motion to reopen the BIA decision, arguing that his prior counsel provided ineffective assistance. The BIA denied the motion. The First Circuit affirmed, holding that equitable tolling did not apply to toll the statutory deadline for filing the motion. View "Quiroa-Motta v. Garland" on Justia Law

The First Circuit affirmed Defendant's conviction of one count of possession with intent to distribute various controlled substance and one count of possession of a firearm in furtherance of a drug-trafficking crime, holding that the district court did not err in denying Defendant's motion to suppress.Defendant sought to suppress drug evidence and a firearm seized pursuant to a search warrant for the car he was driving when he was arrested on an outstanding federal warrant. In his motion, Defendant argued that the search warrant for the car was invalid because it was issued based on an unlawful inventory search. The First Circuit affirmed the denial of Defendant's motion to suppress, holding that the district court did not err in concluding that (1) the officers had an objectively reasonable non-investigatory purpose; and (2) the inventory search of the car was unlawful. View "United States v. Sylvester" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of CVS Pharmacy, Inc. and dismissing this complaint involving a pharmacist's dispensation of a prescription that triggered the pharmacy's internal warning system, holding that the district court did not err.Plaintiff brought this action alleging that he sustained permanent ocular damages as a result of a medication dispensed by CVS. Plaintiff brought a claim for negligence, a claim under Mass. Gen. Laws ch. 93A, and a claim for product liability. The district court granted summary judgment for CVS. The First Circuit affirmed, holding that Plaintiff did not provide any adequate basis for reversing the district court's decisions. View "Carrozza v. CVS Pharmacy, Inc." on Justia Law

The First Circuit affirmed the sentence imposed on Defendant after he pled guilty to unlawfully possessing a machine-gun, 18 U.S.C. 922(o), and being a felon in possession of a firearm, 18 U.S.C. 922(g)(1), holding that the sentence was reasonable.Defendant's Guidelines Sentencing Range was sixty-three to seventy-eight months. The district judge, however, sentenced Defendant to 100 months' imprisonment and two years of supervised release. The First Circuit affirmed the sentence, holding (1) where it was ambiguous whether the district court imposed a variance or departure, any error was harmless; and (2) the court's focus on Defendant's past convictions did not take the sentence out of the range of reasonable sentences, and the court did not consider Defendant's history of drug use. View "United States v. Laboy-Nadal" on Justia Law

The First Circuit reversed the decision of the district court refusing to enforce arbitration clauses in the employment agreement between New York Life Insurance Company and Ketler Bosse, which expressly required that any disputes about arbitrability be referred to the arbitrator, holding that the district court abused its discretion.After New York Life terminated its business relationship with him Bosse brought this action alleging race discrimination in violation of 42 U.S.C. 1981 and 1985 and other state law claims. New York Life asked the court to compel arbitration and stay or dismiss the lawsuit, but the district court refused. The First Circuit reversed, holding (1) the district court's analysis contravened the Supreme Court's holdings in Henry Schein, Inc. v. Archer & White Sales, Inc., 139 S. Ct. 524 (2019), First Options of Chicago, Inc. v. Kaplan, 514 U.S. 938 (1995) and other cases; and (2) the arbitration clause was clear, unmistakable, and unambiguous and should have been enforced on those terms. View "Bosse v. New York Life Insurance Co." on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment in favor of Novo Nordisk Inc. and dismissing Plaintiffs' age discrimination claims, holding that the district court did not err.During a global reorganization, Novo Nordisk terminated Plaintiffs from their jobs based in Puerto Rico and did not select Plaintiffs for post-reorganization positions. Plaintiffs brought this complaint alleging that Novo Nordisk violated Puerto Rico's statutes prohibiting age discrimination in employment and penalizing termination without just cause. The district court granted summary judgment in favor of Novo Nordisk on all of Plaintiffs' claims. The First Circuit affirmed, holding that summary judgment was properly granted. View "Puig Martinez v. Novo Nordisk Inc." on Justia Law