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

The First Circuit held that the Wire Act's prohibitions are limited to interstate wire communications related to bets or wagers on sporting events or contests, thus affirming the district court's grant of Plaintiffs' motions for summary judgment.In 2011, the Office of Legal Counsel (OLC) of the U.S. Department of Justice (DOJ) issued a legal opinion concluding that the Wire Act's prohibitions were uniformly limited to sports gambling. In 2018, the OLC issued an opinion, which was later adopted by the DOJ, that all prohibitions in the Wire Act, with one exception, applied to all forms of bets or waters. In 2019, the New Hampshire Lottery Commission and one of its vendors commenced this action seeking relief under the Administrative Procedure Act and the Declaratory Judgment Act. The district court granted relief, ruling that the Wire Act was limited to sports gambling. The First Circuit affirmed, holding (1) this controversy is justiciable; and (2) the Wire Act applies only to interstate wire communications related to sporting events or contests. View "New Hampshire Lottery Commission v. Rosen" on Justia Law

The First Circuit affirmed the decision of the district court refusing to enter Plaintiffs' requested preliminary injunction, holding that the district court correctly held that Plaintiffs failed to demonstrate a likelihood of success on the merits of their right to travel claim.Plaintiffs, three individuals who intended to travel from New Hampshire to Maine and certain businesses that relied on out-of-state customers, filed suit in response to an executive order issued by the Governor of Maine in response to the COVID-19 pandemic. The order required persons traveling to Maine to self-quarantine upon their arrival for fourteen days before going out in public. Plaintiffs sought a preliminary injunction prohibiting the requirement's enforcement, alleging that the self-quarantine requirement violated their constitutional rights to interstate travel and to procedural due process. The district court rejected the request. The First Circuit affirmed, holding that the district court correctly held that Plaintiffs failed to meet their burden to show that they had a likelihood of success on the merits. View "Bayley's Campground Inc. v. Mills" on Justia Law

In this dispute between a boat owner and his insurance company, the First Circuit affirmed the judgment of the district court in favor of the insurer, holding that the district court properly applied the doctrine of uberrimae fidei in this case.When Defendant applied for an insurance policy for his yacht from an entity later acquired by Plaintiff he failed to disclose that he had grounded a forty-foot yacht in Puerto Rico. Plaintiff later sought a declaratory judgment voiding the policy on the grounds that Defendant had failed to honor his duty of utmost good faith, known as uberrimae fidei in maritime law, in acquiring the policy and had therefore breached the warranty of truthfulness contained in the policy. The district court concluded that Plaintiff was entitled to void the policy. The First Circuit affirmed, holding that the district court correctly concluded that the uberrimae fidei doctrine entitled Plaintiff to a declaration that the policy was void. View "QBE Seguros v. Morales-Vazquez" on Justia Law

The First Circuit affirmed the district court's denial of Petitioner's petition under 28 U.S.C. 2255 to vacate his sentence on the basis that he received ineffective assistance of counsel regarding his rejection of a plea offer, holding that Petitioner failed to show prejudice from any deficient performance by counsel.After a jury trial, Petitioner was found guilty of several charges arising out of a drug enterprise operating in a public housing project. Acting pro se, Petitioner filed a timely petition for postconviction relief, claiming that he received ineffective assistance of counsel. The district court denied the petition. The First Circuit affirmed, holding (1) Petitioner's counsel's performance was deficient when counsel failed to give Petitioner sufficient time to consider a plea offer and failed to advise him of the exposure to a life sentence; but (2) Petitioner failed to satisfy the prejudice prong of Strickland v. Washington, 466 U.S. 668 (1984). View "Feliciano-Rodriguez v. United States" on Justia Law

The First Circuit affirmed the judgments of the lower courts dismissing Plaintiff's wrongful death and civil rights claims against the Superintendent of the Massachusetts State Police Colonel Timothy Alben for failure to state a claim and granting summary judgment for Massachusetts State Trooper Stephen Walker based on the qualified immunity doctrine, holding that there was no error.Walker shot and killed Wilfredo Justiniano, Jr. on the side of a highway. Plaintiff, Justiniano's sister and the personal representative of his estate, brought this suit alleging that Walker used excessive force against Justiniano in violation of his constitutional rights and that Alben was liable for, among other things, failure to train. The magistrate judge dismissed the claims against Alben and granted summary judgment for Walker. The First Circuit affirmed, holding (1) there was insufficient evidence to support a conclusion that Alben acted with deliberate indifference when he allegedly neglected to train Walker on how to interact with the mentally ill; and (2) Walker is qualifiedly immune. View "Justiniano v. Walker" on Justia Law

In this appeal from the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA) Title III court in Puerto Rico the First Circuit affirmed the dismissal of Petitioner's mandamus petition for failure to state a claim, holding that the Title III court correctly dismissed the petition for writ of mandamus.The petition at issue alleged that when the Puerto Rico Electric Power Authority (PREPA) announced that it would increase some medical co-pays while decreasing others in order to comply with its certified fiscal plan PREPA violated two provisions of a Puerto Rican statute. Petitioner, which represented the employees of PREPA, sought to compel PREPA to comply with the savings and pre-existing conditions provisions of Act No. 26-2107, P.R. Laws Ann. tit. 3, 9461 et seq. The Title III court denied mandamus relief, concluding that Petitioner did not meet its burden of showing that there were no adequate alternative remedies. The First Circuit affirmed, holding that the petition was correctly dismissed because Petitioner did not demonstrate that there was no adequate alternative remedy available for its members to recover from PREPA. View "Union de Trabajadores de la Industria Electrica y Riego v. Ortiz Vazquez" on Justia Law

The First Circuit affirmed the decisions of the district court in these appeals challenging the court's discretionary rulings in connection with a request under 28 U.S.C. 1782 to conduct court-ordered discovery for use in a foreign proceeding, holding that the district court did not err or abuse its discretion.The foreign proceeding at issue was one of approximately 200 separate securities fraud actions brought in 2016 against Porsche Automobile Holding SE in Germany. The actions stemmed from Porsche's alleged malfeasance in connection with "defeat devices" employed to circumvent emissions testing in certain diesel vehicles manufactured by Volkswagen AG. The district court granted in part Porsche's request for discovery in the United States from affiliates of John Hancock funds who were plaintiffs in the German actions. The First Circuit affirmed the district court's orders denying the Hancock plaintiffs' motion to intervene and denying in part the Hancock affiliates' motion to quash, holding that the district court did not abuse its discretion. View "Porsche Automobile Holding SE v. John Hancock Life Insurance Co." on Justia Law

The First Circuit affirmed the district court's order granting the government's request to garnish Appellant's husband's 401(k) account and apply the proceeds to his nearly four million dollar criminal restitution obligations, holding that Appellant had no vested legal interest in her husband's account.Appellant's husband (Husband) pleaded guilty to eight counts of wire fraud, money laundering, and unlawful monetary transactions. The district court sentenced him to a term of incarceration and ordered him to pay $3,879,750 in restitution. The government later asked the district court for a writ of garnishment directed at Husband's 401(k) plan, which Husband held individually in his own name. The district court rejected Appellant's objections and issued a garnishment order. The First Circuit affirmed, holding (1) Massachusetts law did not give Appellant a vested legal interest in Husband's 401(k) account; and (2) it was not plain error for the district court to issue the writ of garnishment without compensating Appellant for her contingent death benefit under the policy. View "United States v. Abell" on Justia Law

In this appeal arising out of a lawsuit for damages that Plaintiff brought against three defendants in connection with the drowning deaths of her husband and son, the First Circuit reversed the judgment of the district court dismissing the suit based on the doctrine of forum non conveniens, holding that dismissal was not warranted.Plaintiff named as defendants Marriott International, Inc.; Marriott Worldwide Corporation; and Reluxicorp, Inc., the Marriott franchisee in Montreal where the drowning occurred. The United States District Court for the District of Massachusetts found personal jurisdiction over Defendants but dismissed it based on the doctrine of forum non conveniens, concluding that an adequate alternative forum was available in Canada. The First Circuit reversed in part, holding (1) the district court correctly denied Defendants' motion to dismiss for lack of personal jurisdiction; but (2) the district court erred in granting Defendant's motion to dismiss on forum non conveniens grounds. View "Nandjou v. Marriott International, Inc." on Justia Law

The First Circuit affirmed Defendant's sentences imposed in connection with his guilty plea to being a felon in possession of a firearm, holding that the sentences were procedurally and substantively reasonable.Defendant pleaded guilty to being a felon in possession of a firearm. Defendant was sentenced to sixty months' imprisonment for that offense and to eighteen months' imprisonment for violating the conditions of his supervised release. Defendant appealed, challenging both the procedural and substantive reasonableness of his sentences, which were above the United States Sentencing Guidelines range. The First Circuit affirmed, holding that Defendant's variant sentences were both procedurally and substantively reasonable. View "United States v. Flores-Quinones" on Justia Law