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

Steven Fustolo purchased a rental investment unit in Boston, Massachusetts, in 2009, taking out a mortgage with Mortgage Electronic Registration Systems, Inc. (MERS) as nominee for Union Capital Mortgage Business Trust. The mortgage was reassigned six times, and Fustolo defaulted on the loan. He sought a declaratory judgment that the current holders, Federal Home Loan Mortgage Corporation as Trustee of SCRT 2019-2 (the Trust) and Select Portfolio Servicing, Inc. (SPS), had no right to foreclose because they did not validly hold the mortgage or the accompanying promissory note. Fustolo also claimed defamation, slander of title, unfair business practices, violation of Massachusetts's Debt Collection Act, and a violation of Regulation X of the Real Estate Settlement Procedures Act (RESPA) by SPS.The United States District Court for the District of Massachusetts dismissed Fustolo's claims, except for one count challenging the adequacy of a notice letter, which was later settled. The court found that the Trust validly held both the mortgage and the note, and that Fustolo's state law claims hinged on the incorrect assertion that the Trust did not have the right to foreclose. The court also dismissed the RESPA claim, stating that Fustolo failed to specify which provision of RESPA was violated and that SPS had responded to his notice of error.The United States Court of Appeals for the First Circuit affirmed the district court's dismissal. The appellate court held that the Trust validly held the mortgage and the note, as the note was indorsed in blank and in the Trust's possession. The court also found that MERS had the authority to assign the mortgage despite Union Capital's dissolution. Additionally, the court ruled that Fustolo's RESPA claim failed because challenges to the merits of a servicer's evaluation of a loss mitigation application do not relate to the servicing of the loan and are not covered errors under RESPA. View "Fustolo v. Select Portfolio Servicing, Inc." on Justia Law

Jorge Baez sued BayMark Detoxification Services, Inc., alleging disability discrimination under Massachusetts law, claiming BayMark Detox was his former employer. Baez was repeatedly informed that he had sued the wrong party but did not amend his complaint in time. BayMark Detox moved for summary judgment, asserting it was never Baez's employer. Baez then requested to amend his complaint to name the correct employer, but the district court granted summary judgment to BayMark Detox, denied Baez's Rule 60(b) motion for relief, and ordered Baez to pay costs.Baez initially worked for Community Health Care, Inc. (CHC), which was acquired by BayMark Health Services, Inc. (BHS). During the COVID-19 pandemic, Baez worked from home but was later terminated after an audit revealed billing errors. Baez filed a discrimination complaint against BayMark Detox, which was removed to federal court. BayMark Detox, a separate entity from CHC, stated it never employed Baez. The district court set a deadline for amending pleadings, which Baez missed.The United States District Court for the District of Massachusetts granted summary judgment to BayMark Detox, finding no evidence that BayMark Detox was Baez's employer. The court denied Baez's request to amend his complaint, citing his failure to show good cause for the delay. The court also denied Baez's Rule 60(b) motion, rejecting the argument that Massachusetts procedural rules should apply. The court awarded costs to BayMark Detox.The United States Court of Appeals for the First Circuit affirmed the district court's rulings, agreeing that Baez failed to name the correct employer and did not demonstrate good cause for amending his complaint late. The court also upheld the award of costs to BayMark Detox. View "Baez v. BayMark Detoxification Services, Inc." on Justia Law

Renee Sevelitte and the Estate of Joseph F. Sevelitte dispute the entitlement to the proceeds of a life insurance policy Joseph purchased during his marriage to Renee. Massachusetts law automatically revokes a spouse's beneficiary status upon divorce unless specific exceptions apply. The life insurance policy named Renee as the beneficiary, but the policy did not address the effect of divorce on beneficiary status. Renee and Joseph's divorce agreement included provisions about life insurance policies but did not explicitly state that Renee would remain the beneficiary of the policy in question.The United States District Court for the District of Massachusetts granted summary judgment to the Estate, determining that Renee could not establish that any exceptions to the automatic revocation applied. Renee appealed, arguing that the district court erred in its decision.The United States Court of Appeals for the First Circuit reviewed the case. The court noted that its previous decision did not determine that the divorce agreement satisfied the statutory exceptions but only that it was plausible. The court emphasized that Renee needed to provide evidence to support her claim that the divorce agreement intended to maintain her beneficiary status. The Estate presented evidence, including an affidavit from Joseph's divorce attorney and an expert report, indicating that the divorce agreement did not intend to retain Renee's beneficiary status.The First Circuit affirmed the district court's decision, concluding that Renee failed to present any evidence to create a genuine dispute about the intended meaning of the divorce agreement. Therefore, the court held that the Estate was entitled to the proceeds of the life insurance policy. View "Sevelitte v. The Guardian Life Insurance Company of America" on Justia Law

In 2016, Rhode Island enacted the RhodeWorks Act, which imposed tolls on tractor-trailers crossing thirteen bridges within the state. The toll revenue was intended for the replacement, reconstruction, operation, and maintenance of these bridges. The tolls were subject to three statutory caps: a truck could not pay more than once in each direction, more than $40 per day, or more than $20 for a single through trip from Connecticut to Massachusetts. The American Trucking Associations and several trucking companies challenged the tolls, arguing they violated the dormant Commerce Clause by discriminating against interstate commerce and failing to fairly approximate use of the bridges.The U.S. District Court for the District of Rhode Island permanently enjoined the tolls, finding that they discriminated against interstate commerce and did not fairly approximate use. The court concluded that the tolls' application solely to tractor-trailers and the statutory caps each violated the dormant Commerce Clause.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed that the statutory caps on tolls were unconstitutional because they disproportionately benefited in-state over out-of-state tractor-trailers, thus discriminating against interstate commerce. However, the court held that the tolls' application solely to tractor-trailers did not violate the fair-approximation test, as it was not wholly unreasonable for Rhode Island to rely on studies showing that tractor-trailers caused the most damage to the bridges.The First Circuit concluded that the unconstitutional caps were severable from the rest of the statute. Therefore, the court affirmed the district court's judgment in part, reversed it in part, and remanded the case for the entry of judgment consistent with its opinion. View "American Trucking Associations, Inc. v. Rhode Island Turnpike and Bridge Authority" on Justia Law

In this case, the appellant, Elvin Torres-Estrada, was charged in a superseding indictment with conspiring to distribute controlled substances and other related offenses. Plea negotiations began, and the government offered a plea deal allowing Torres-Estrada to request a 188-month sentence. However, one of his attorneys, Ramón Garcia, advised him to counteroffer for a lower sentence and assured him that he could negotiate a better deal. This advice conflicted with the recommendations of Torres-Estrada's other attorneys, who believed the government's offer was favorable and urged him to accept it promptly.The United States District Court for the District of Puerto Rico initially handled the case. Torres-Estrada followed Garcia's advice, leading to a series of counteroffers and negotiations that ultimately did not result in a more favorable plea deal. Instead, Torres-Estrada later signed a consolidated plea agreement for a 264-month sentence, with the government allowed to argue for 288 months. The district court sentenced him to 288 months. Torres-Estrada filed a motion under 28 U.S.C. § 2255, claiming ineffective assistance of counsel, which the district court denied.The United States Court of Appeals for the First Circuit reviewed the case. The court examined whether Garcia's advice and actions constituted ineffective assistance of counsel under the standards set by Missouri v. Frye and Lafler v. Cooper. The court found that while Garcia's conduct was problematic, it did not meet the threshold for constitutionally deficient performance. Additionally, the court concluded that Torres-Estrada failed to demonstrate that he would have accepted the government's original plea offer but for Garcia's advice. Therefore, the First Circuit affirmed the district court's denial of sentencing relief. View "Torres-Estrada v. United States" on Justia Law

Plaintiffs Luther C. Parente and Eric L. Stewart sued the Rhode Island Department of Corrections (RIDOC) and its staff for failing to properly treat their preexisting medical conditions. They alleged various federal and state constitutional, statutory, and common law bases for relief, including a claim under the Rhode Island Civil Rights Act of 1990 (RICRA). The plaintiffs claimed that RIDOC's medical and correctional staff failed to meet their medical needs, resulting in harm and discrimination.The United States District Court for the District of Rhode Island denied RIDOC's motion for summary judgment on Eleventh Amendment grounds as to the RICRA claim. The district court held that Rhode Island's general waiver of sovereign immunity under the State Tort Claims Act applied to RICRA claims, reasoning that discrimination actions under RICRA sounded in tort. RIDOC appealed this decision, arguing that the district court erred in holding that violations of civil rights under RICRA were subject to the general waiver of Eleventh Amendment immunity.The United States Court of Appeals for the First Circuit reviewed the case and determined that there was a "special reason" to certify the underlying state-law issue to the Rhode Island Supreme Court. The appellate court noted that the question of whether RICRA claims are "actions of tort" under the State Tort Claims Act is a matter of state law that has not been definitively resolved by the Rhode Island Supreme Court. Therefore, the First Circuit certified the question to the Rhode Island Supreme Court to determine whether discrimination claims under RICRA are covered by the general waiver of sovereign immunity under the State Tort Claims Act. The First Circuit retained jurisdiction over the issue pending resolution of the certified question. View "Parente v. Lefebvre" on Justia Law

Jose Rodolfo Escobar Larin, a native and citizen of El Salvador, sought review of a Board of Immigration Appeals (BIA) decision that affirmed the denial of his claims for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). Escobar also petitioned for review of a separate BIA ruling that denied his motion to reopen his removal proceedings. The Department of Homeland Security (DHS) had issued Escobar a Notice to Appear, charging him with removability for being present in the U.S. without being admitted or paroled. Escobar filed an application for asylum and withholding of removal, claiming a well-founded fear of persecution in El Salvador due to his mental illness and opposition to gang authority.The Immigration Judge (IJ) found Escobar credible but denied his claims, determining that his asylum application was untimely and that he failed to meet the requirements for withholding of removal and CAT protection. The BIA affirmed the IJ's decision, agreeing that Escobar did not demonstrate extraordinary or changed circumstances to excuse the late filing of his asylum application. The BIA also found that Escobar did not establish a likelihood of persecution or torture if returned to El Salvador.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the BIA erred in its interpretation of the changed-circumstance exception to the one-year filing deadline for asylum applications. The court vacated and remanded the BIA's ruling on Escobar's asylum claims, withholding of removal claims, and CAT claim for further proceedings. The court also affirmed the denial of Escobar's motion to reopen, concluding that the BIA did not abuse its discretion in that decision. View "Escobar Larin v. Garland" on Justia Law

The case involves the approval process for a large-scale commercial offshore wind energy facility located on the Outer Continental Shelf, fourteen miles south of Martha's Vineyard and Nantucket. The plaintiffs, consisting of commercial fishing entities and a nonprofit organization, challenged the federal government's approval of the project, citing violations of the Administrative Procedure Act (APA), the National Environmental Policy Act (NEPA), the Endangered Species Act (ESA), the Marine Mammal Protection Act (MMPA), the Clean Water Act (CWA), and the Outer Continental Shelf Lands Act (OCSLA).The United States District Court for the District of Massachusetts granted summary judgment in favor of the defendants, which included various federal departments and agencies, as well as the business entity responsible for the wind project. The court found that the plaintiffs' ESA claims were non-justiciable due to lack of standing and mootness, as the initial biological opinion had been superseded by a new one. The court also ruled that the plaintiffs were outside the zone of interests protected by the NEPA and the MMPA, and that the Alliance had failed to show that the Corps' issuance of the CWA Section 404 permit was arbitrary or capricious.The United States Court of Appeals for the First Circuit reviewed the district court's rulings de novo. The appellate court affirmed the district court's judgments, agreeing that the plaintiffs lacked standing for their ESA claims and that the claims were moot. The court also upheld the district court's zone-of-interests rulings regarding the NEPA and MMPA claims. Additionally, the court found that the Corps' decision to issue the CWA permit was not arbitrary or capricious and that the BOEM's approval of the project under the OCSLA was lawful. The appellate court concluded that the plaintiffs' arguments did not demonstrate that the BOEM had acted arbitrarily or capriciously in approving the project. View "Seafreeze Shoreside, Inc. v. Department of the Interior" on Justia Law

Beijing Abace Biology Co., Ltd. (Abace) filed a lawsuit against Dr. Chunhong Zhang and MtoZ Biolabs, Inc. (MtoZ) after Dr. Zhang, a former employee, co-founded MtoZ, a company providing similar services to Abace. Abace claimed that Dr. Zhang breached her contract and fiduciary duty, and that MtoZ tortiously interfered with Abace's business. Dr. Zhang had signed several employment-related agreements, including non-compete clauses, while working for Abace. The dispute centered on whether these non-compete agreements were enforceable under Chinese law.The United States District Court for the District of Massachusetts granted summary judgment in favor of Dr. Zhang and MtoZ, concluding that Dr. Zhang did not fall within the categories of employees subject to non-compete agreements under Chinese law. The court found that Dr. Zhang was neither senior management nor senior technical personnel, and did not have access to trade secrets or confidential information that would justify a non-compete restriction.The United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court agreed that under Chinese law, non-compete agreements are enforceable only against senior management, senior technical personnel, or employees with access to trade secrets. The court found no evidence that Dr. Zhang held a senior management or technical role, or that she had access to trade secrets. Consequently, the non-compete agreements were unenforceable, and the summary judgment in favor of Dr. Zhang and MtoZ was upheld. View "Beijing Abace Biology Co., Ltd. v. Zhang" on Justia Law

The defendant, Ronald Andruchuk, purchased 169 firearms over five months in 2021 while struggling with drug addiction. He falsely attested on federal forms that he did not use illicit drugs. Neighbors complained about bullets flying dangerously close to their homes, and on February 24, 2022, police witnessed bullets flying above their heads from Andruchuk's property. He was arrested for violating a state law against firing ammunition in a compact area. A federal investigation led to a search of his home, where agents found 219 unsecured firearms, gun paraphernalia, and over 25,000 rounds of ammunition. Andruchuk was charged with making false statements during firearms purchases and possession of a firearm by an unlawful user of a controlled substance.The United States District Court for the District of Rhode Island accepted Andruchuk's guilty plea to two counts of making false statements and one count of possession of a firearm by an unlawful user of a controlled substance. In exchange, the government agreed to dismiss the remaining charges and recommend a sentence at the low end of the guideline range. Andruchuk waived his right to appeal if the sentence was within or below the guideline range determined by the court. The court calculated a guideline range of sixty-three to seventy-eight months and sentenced him to sixty-three months.The United States Court of Appeals for the First Circuit reviewed the case. Andruchuk argued that the district court erred in calculating the guideline range and that this error invalidated his appellate waiver. The Court of Appeals upheld the waiver, finding it was knowing and voluntary, and dismissed the appeal. The court also dismissed Andruchuk's ineffective assistance of counsel claim as premature, noting it could be raised in a collateral proceeding under 28 U.S.C. § 2255. View "United States v. Andruchuk" on Justia Law