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

The First Circuit affirmed Defendant's prison sentence for possessing with intent to distribute cocaine base, in violation of 21 U.S.C. 841(a), holding that Defendant invited any error in regards to his challenge to the determination of his criminal history category.Pursuant to a plea agreement, Defendant pled guilty to possessing with intent to distribute cocaine base. At the sentencing hearing, the district court acknowledged that the parties recommended a statutory minimum sentence of sixty months' imprisonment. The district court proceeded to impose an eighty-four-month prison sentence to be followed by five years of supervised release. On appeal, Defendant argued that the district court erred in applying the "intervening arrest" rule in section 4A1.2(a)(2) of the United States Sentencing Guidelines when determining his criminal history. The First Circuit affirmed, holding that, through his counsel, Defendant invited any error in that respect. View "United States v. Miranda-Carmona" on Justia Law

The First Circuit affirmed the judgment of the district court holding that the Federal National Mortgage Association (Fannie Mae) and the Federal Housing Finance Agency (FHFA) were not subject to Appellants' Fifth Amendment claims, holding that there was no error.Appellants obtained loans secured by mortgages on their real property in Rhode Island. The loans and mortgages were later sold to Fannie Mae while the FHFA was acting as Fannie Mae's conservator. Consistent with Rhode Island law, when Appellants defaulted on their loans Fannie Mae conducted nonjudicial foreclosure sales of the mortgaged properties. Appellants brought suit in a federal district court, arguing that the nonjudicial foreclosure sales violated their procedural due process rights under the Fifth Amendment. The district court dismissed those claims. The First Circuit affirmed, holding that FHFA and Fannie Mae were not government actors subject to Appellants' due process claims. View "Montilla v. Federal National Mortgage Ass'n" on Justia Law

The First Circuit affirmed Defendant's convictions and sentence for one count of conspiracy to distribute and to possess with intent to distribute heroin and one count of distribution of heroin, holding that Defendant was not entitled to relief on her allegations of error.For the convictions, the district court imposed a downward variant sentence of forty-eight months' imprisonment followed by two years of supervised release. The First Circuit affirmed, holding (1) the district court did not abuse its discretion by finding certain coconspirator statements were non-hearsay under Fed. R. Evid. 801(d)(2)(E) and admitting the statements into evidence; (2) Defendant waived her claim of error regarding the propriety of the jury instructions about the elements of the offenses; and (3) the district court did not clearly err by applying a three-level mitigating role reduction under U.S.S.G. 3B1.2 rather than a four-level minimal role reduction. View "United States v. Ruiz" on Justia Law

The First Circuit vacated the judgment of the district court imposing a five-year prison sentence upon Defendant for committing a federal firearms offense, holding that the district court erred in resolving what constitutes a "controlled substance" within the meaning of section 2K2.1(a)(2) of the United States Sentencing Guidelines.On appeal, Defendant argued that the district court erred in applying at his sentencing the enhancement set forth in section 2K2.1(a)(2), which subjects a defendant who has been convicted of a 18 U.S.C. 922(g) offense to a higher base offense level under the Guidelines if he committed the offense "subsequent to sustaining at least two felony convictions of either a crime of violence or a controlled substance offense." Specifically, Defendant argued that his prior Massachusetts conviction for possession with intent to distribute "marihuana" did not qualify as a conviction of a "controlled substance offense" under section 2K2.1(a)(2). The First Circuit vacated the judgment below, holding that Defendant's Massachusetts conviction was not a conviction of a "controlled substance offense" within the meaning of that term as it was used in the version of section 2K2.1(a)(2) that was applicable at Defendant's sentencing. View "United States v. Abdulaziz" on Justia Law

The First Circuit affirmed Defendant's convictions for possessing and aiding and abetting the possession of drugs with intent to distribute them and possessing and aiding and abetting the possession of a gun in furtherance of a drug-trafficking crime, holding that Defendant was not entitled to reversal of his convictions.On appeal, Defendant challenged four of the trial judge's evidentiary rulings and three jury instructions. The First Circuit affirmed, holding (1) any error in the district court's evidentiary rulings was harmless; and (2) the district court committed no reversible error in its instructions to the jury. View "United States v. Rivera-Galindez" on Justia Law

The First Circuit vacated the judgment of the district court granting summary judgment in favor of Defendant in this case alleging a violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., holding that genuine issues of material fact precluded summary judgment.Plaintiff, who was Black, sued Bridgewater State university's Board of Trustees and Office of Equal Opportunity and a University administrator (collectively, Defendants) alleging that she was not hired for a University position because of her race. The district court granted summary judgment in favor of Defendants. The First Circuit reversed, holding that Plaintiff's aggregate package of proof sufficed to survive Defendants' motion for summary judgment. View "Taite v. Bridgewater State University" on Justia Law

The First Circuit dismissed Plaintiffs' appeal for want of jurisdiction, holding that the Federal Rules of Bankruptcy Procedure (the bankruptcy rules), and not the Federal Rules of Civil Procedure (the civil rules), govern cases that have come within the federal district court's jurisdiction as cases "related to" a pending bankruptcy proceeding. 28 U.S.C. 1334(b).In this case arising from the derailment and explosion in Lac-Megantic, Canada, Plaintiffs brought thirty-nine separate suits against several defendants. The derailment occurred on the watch of Montreal, Maine and Atlantic Railway (MMA). MMA sought the protection of the bankruptcy court. Plaintiffs' suits were removed to federal district court. Plaintiffs subsequently joined Canadian Pacific Railway Company as an additional defendant. The suits were centralized in the District of Maine. The district court later granted Plaintiffs' request to dismiss their claims against all defendants except Canadian Pacific pursuant to a settlement agreement that was part of MMA's plan of liquidation. The district court entered judgment for Canadian Pacific. Plaintiffs moved for reconsideration of their motion to file an amended complaint. The district court denied the motion as untimely. The First Circuit dismissed Plaintiffs' appeal, holding that the Bankruptcy Rules governed the procedural aspects of this case, Plaintiffs' motion to reconsider was untimely, and the attempted appeal was untimely. View "Roy v. Canadian Pacific Railway Co." on Justia Law

The First Circuit reversed the order of the district court excluding two documents from the summary judgment record and granting summary judgment for Defendant on all of Plaintiff's claims, holding that the district court erred in excluding the two documents from the summary judgment record.Defendant terminated Defendant's employment after he had been employed for thirty-three years. Plaintiff brought this lawsuit alleging wrongful termination of his employment under state law and age discrimination under federal and state law. Defendant moved to strike two of Plaintiff's documents on the grounds that they had been produced after the discovery cut-off date and that they were not properly authenticated. The district court granted the motion to strike the documents and then granted Defendant's motion for summary judgment. The First Circuit reversed the order excluding the documents and vacated the entry of summary judgment, holding that the court erred in striking the documents and that material issues of fact precluded summary judgment. View "Zampierollo-Rheinfeldt v. Ingersoll-Rand de Puerto Rico, Inc." on Justia Law

The First Circuit vacated the judgment of the district court granting summary judgment in favor of Bautista Cayman Asset Company in its action for collection of monies and foreclosure of collateral against Fountainebleu Plaza, S.E., Edwin Loubriel Ortiz, and Sedcorp, Inc., holding that remand was required for the sole purpose of better determining the amount due.Fountainebleu and Loubriel (collectively, Appellants) appealed the district court's judgment, arguing that the district court lacked subject matter jurisdiction over the case and that, alternatively, genuine issues of material fact precluded summary judgment. The First Circuit vacated the judgment, holding that because the record failed to account for payments made to Bautista's predecessor, the case must be remanded for the sole purpose of better determining the amount due. View "Bautista Cayman Asset Co. v. Fountainebleu Plaza, S.E." on Justia Law

The First Circuit affirmed the judgment of the Title III court holding that Claimants, who invested in mutual funds that owned bonds issued by the Commonwealth of Puerto Rico and filed proofs of claim in the Commonwealth's Title III case, lacked standing to recover damages directly from the Commonwealth for losses suffered by the mutual funds, holding that there was not a basis in law for this lawsuit.The Claimants alleged that they had a right to recover damages directly from the Commonwealth for losses suffered by the mutual funds in those investments. The title III court concluded that Claimants lacked standing because they did not own any bonds issued by the Commonwealth and that the Claimants' ownership interest in the mutual funds did not give them a right to recover against the Commonwealth. The Title III court subsequently denied the Claimants' motions for reconsideration. The First Circuit affirmed, holding that the Title III court did not err in its standing analysis, either in its initial decision disallowing the Claimants' claims or in its consideration of the two motions for reconsideration. View "Diaz Mayoral v. Financial Oversight & Management Board for Puerto Rico" on Justia Law