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

The First Circuit affirmed the judgment of the district court revoking Defendant's supervised release after he was acquitted of a criminal assault charge arising from the same incident leading to his revocation, holding that the evidence supported a finding of revocation and that the sentence imposed was reasonable.The probation office petitioned for the arrest of Defendant for violating his supervised release by committing the offense of assaulting a U.S. Probation Office employee. A criminal complaint was also issued for the alleged assault. A jury acquitted Defendant of the criminal assault charge. The district judge proceeded to revoke Defendant's supervised release on the basis of the same conduct and sentenced him to twenty-four months' imprisonment followed by eight months of supervised release. The Supreme Court affirmed, holding (1) acquitted conduct can be used to revoke supervised release due to the differing burdens of proof; (2) the evidence was sufficient to prove that Defendant committed an assault; and (3) Defendant's sentence was substantively and procedurally reasonable. View "United States v. Frederickson" on Justia Law

The First Circuit affirmed Defendant's conviction and sentence imposed after he pled guilty to six counts stemming from a robbery of a federal confidential informant during a guns-for-cash deal, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the First Circuit held (1) Defendant's challenge based on Rehaif v. United States, 139 S. Ct. 2191 (2019), to his conviction for possession of a firearm by a felon, in violation of 18 U.S.C. 922(g), was without merit; (2) Defendant's challenge to the plea colloquy failed; (3) Defendant's challenge based upon United States v. Davis, 139 S. Ct. 2319 (2019), to the acceptance of his plea to aiding and abetting the use of a firearm during and in relation to a crime of violence, in violation of 18 U.S.C. 2, 924(c), failed on plain error review; (4) the prosecutor did not breach plea agreement; and (5) Defendant's sentence of 198 months' imprisonment was neither procedurally nor substantively unreasonable. View "United States v. Farmer" on Justia Law

In this appeal concerning the scope and reach of 28 U.S.C. 1963 - a statute permitting the registration of certain judgment in a federal district court - the First Circuit affirmed the district court's judgment concluding that the New York state court judgment proffered by Plaintiff did not come within the statutory sweep and that no other cognizable basis for federal subject-matter jurisdiction had been shown, holding that the district court did not err.Plaintiff sought recognition of a Korean judgment in New York. A New York court recognized the Korean judgment and entered a judgment in Plaintiff's favor for more than $13 million. When the New York judgment went unpaid, Plaintiff filed the judgment in the United States District Court for the District of Massachusetts. Defendants moved to quash, arguing that the district court lacked subject-matter jurisdiction because 28 U.S.C. 1963 only authorized district courts to register judgments of other federal courts and not state court judgments. The district court agreed and dismissed the matter for want of subject-matter jurisdiction. The First Circuit affirmed, holding (1) section 1963 does not authorize federal courts to register state-court judgments; and (2) there were no independent grounds for federal jurisdiction here. View "Woo v. Spackman" on Justia Law

In this appeal and cross-appeal stemming from litigation that followed the termination of an almost forty-year business relationship between a company that manufactured and supplied soup base products (Manufacturer) and a company that distributed them (Distributor), the First Circuit reversed in part and vacated in part Distributor's appeal and affirmed in Manufacturer's cross appeal, holding that the district court erred in part.Following a trial, the jury awarded Distributor $255,000 in damages for its state law breach of contract and tortious interference with business relationships claims against Manufacturer. The district court granted summary judgment to Manufacturer on Distributor's claim against it under Mass. Gen. Laws ch. 93A and to Manufacturer on its counterclaim for breach of contract, for which the court awarded Manufacturer $97,843 in damages. The First Circuit held that the district court (1) erred in granting summary judgment on the Chapter 93A claim; (2) erred in striking as duplicative the jury's damages award on Distributor's breach of contract claim; (3) erred in denying Distributor prejudgment interest on the damages award it received on the tortious interference with business relations claim; and (4) erred in denying Distributor's offset request. View "Primarque Products Co. v. Williams West & Witt's Products Co." on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Employer and dismissing Employee's claims for retaliation in violation of the Family and Medical Leave Act (FMLA), 29 U.S.C. 2612, and disability discrimination in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213, and the Rhode Island Fair Employment Practices Act, R.I. Gen. Laws 28-5-7, holding that the district court did not err.Employee took leave from Employer under the FMLA to undergo preventive surgery and then took a second leave for a related surgery that same year. The following year, Employer eliminated Employee's position. As an alternative to termination, Employer offered Employee a newly created, lower level position with a lower salary. Employee declined the position, and Employer terminated her employment. Plaintiff then brought this action. The district court granted summary judgment in favor of Employer. The First Circuit affirmed, holding that summary judgment was properly granted. View "O'Rourke v. Tiffany & Co." on Justia Law

The First Circuit denied Petitioner's petition for judicial review seeking to set aside the decision of the Board of Immigration Appeals (BIA) affirming the denial of his application for asylum, withholding of removal, and other relief, holding that the BIA's decision must be upheld.On appeal, Petitioner's principal assignment of error challenged the denial of his asylum claim. Petitioner specifically argued against the adverse credibility determination of the immigration judge (IJ), which the BIA upheld. The First Circuit denied the petition for review, holding (1) the IJ's adverse credibility determination was supported by substantial evidence in the record, and therefore, the BIA's denial of Petitioner's asylum claim must be upheld; (2) because Petitioner failed to satisfy the standard required for asylum, his claim for withholding of removal necessarily failed; and (3) Petitioner's claim for CAT protection is deemed abandoned. View "Zaruma-Guaman v. Wilkinson" on Justia Law

In this civil action brought by plaintiffs seeking to enjoin policies governing searches of electronic devices at the United States' borders, the First Circuit found no violations of either the Fourth Amendment or the First Amendment.The border search policies challenged her allow border agents to perform basic searches of electronic devices without reasonable suspicion and advanced searches with reasonable suspicion. The First Circuit joined the Eleventh Circuit in holding that advanced searches of electronic devices at the border do not require a warrant or probable cause and joined the Ninth and Eleventh Circuits in holding that basic border searches of electronic devices are routine searches that may be performed without reasonable suspicion. The Court then affirmed in part, reversed in part and vacated in part the judgment of the district court, holding that the court erred in narrowing the scope of permissible searches of electronic devices at the border. View "Alasaad v. Wolf" on Justia Law

In these three consolidated appeals arising out of the Title III debt-restructuring proceedings brought by the Financial Oversight and Management Board (Board) for Puerto Rico on behalf of the Puerto Rico Sales Tax Financing Corporation (COFINA) under the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA) the First Circuit held that certain appeals were equitably moot and another claim was properly dismissed.The Title III court approved a plan of adjustment (the Plan) proposed by the Board resolving disputes between the Commonwealth of Puerto Rico and COFINA and between the junior and senior holders of COFINA's outstanding debt. The Elliott and Pinto-Lugo groups objected to the Plan, arguing, among other things, that it unlawfully abrogated their rights as junior COFINA bondholders. Peter Hein, an individual creditor, challenged the dismissal of his proof of claim against COFINA. The Title III court dismissed Hein's challenges and overruled the objections to the Plan. On Appeal, the First Circuit (1) dismissed the Elliott and Pinto-Lugo appeals as equitably moot; and (2) affirmed the dismissal of Hein's claims against COFINA. View "Pinto Lugo v. Commonwealth of Puerto Rico" on Justia Law

The First Circuit affirmed the judgment of the district court upholding the jury verdict awarding Plaintiff compensatory on his claims of failure to accommodate his disability at work but remitting the jury's punitive damages award, holding that Defendants' claims on appeal failed.Specifically, the First Circuit held (1) the district court did not err in denying Defendants' post-trial motions for judgment as a matter of law because Plaintiff sufficiently proved his case under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101, and Maine Human Rights Act (MHRA), Me. Stat. tit. 5, 4571; (2) the district court's rulings denying Defendants' motion for a new trial were not an abuse of discretion; and (3) the district court did not abuse its discretion in denying Defendants' motion for remittitur because Defendants' arguments in support of the motion were misplaced and unsupported by the record. View "Burnett v. Ocean Properties, Ltd." on Justia Law

The First Circuit granted Petitioner's petition for review of the Board of Immigration Appeals' (BIA) denial of his motion to reopen his removal proceedings and to remand to the immigration judge (IJ) for further consideration, holding that the BIA abused its discretion.Petitioner sought reconsideration due to the fact that he had been placed on a waiting list by the United States Citizenship and Immigration Services (USCIS) for a U-1 nonimmigrant visa pursuant to the Victims of Trafficking and Violence Protection Act (VTVPA), 8 U.S.C. 1101(a)(15)(U). In denying Petitioner's motion to reopen his removal proceedings, the BIA gave two reasons for its denial. The First Circuit reversed and remanded the case, holding that the BIA abused its discretion because it failed to render a reasoned decision that accords with its own precedent and policies and failed to consider the position of the Immigration and Customs Enforcement. View "Benitez v. Wilkinson" on Justia Law