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

The First Circuit affirmed Defendants' convictions for securities fraud and conspiracy to commit securities fraud, holding that Defendants' claims of trial and sentencing error were unavailing.Defendants were two biostaticians employed by two publicly traded biopharmaceutical companies. The jury found Defendants guilty of conspiracy of commit securities fraud and all counts of securities fraud with which they were charged. The First Circuit affirmed, holding that the district court (1) did not err in denying Defendants' motions for judgments of acquittal as to the conspiracy and securities fraud convictions; (2) did not abuse its discretion in denying Defendants' motion to compel production of a letter from the Financial Industry Regulatory Authority; (3) imposed sentences that were without error; and (4) did not err in awarding restitution. View "United States v. Chan" on Justia Law

The First Circuit affirmed the judgment of the district court finding that Defendant had committed fraud in connection with a contract for dredging work to be performed in Massachusetts and in awarding Plaintiff $148,626 in damages, holding that the district court did not err.The jury's finding of fraud in this case was based on Massachusetts law. On appeal, Defendant argued that the court erred in determining at summary judgment that Massachusetts law applied to the fraud claim. The First Circuit affirmed, holding (1) the district court was plainly correct that Massachusetts law applied; (2) there was sufficient evidence to support the conviction; and (2) the arbitration clause in the contract between the parties' businesses did not bar this lawsuit. View "Hisert v. Haschen" on Justia Law

The First Circuit affirmed Defendant's sentence for violating the Racketeer Influenced and Corrupt Organization Act (RICO), 18 U.S.C. 1962(d), holding that the life without parole sentence imposed by the district court was not unconstitutional and that Defendant's remaining claims of error were unavailing.On appeal, Defendant, who was twenty years old at the time he committed the charged crime, sought to vacate his sentence of life imprisonment without the possibility of parole on Eighth Amendment grounds. The First Circuit affirmed, holding (1) Defendant failed to make the case for extending the Miller ban on life-without-parole sentences to offenders like Defendant who were in the eighteen-to-twenty range when they committed the crimes of conviction; (2) the district court did not err in determining that Defendant had twice committed the predicate offense of first-degree murder even where the jury had been instructed only on second-degree murder; and (3) Defendant's sentence was both procedurally and substantively reasonable. View "United States v. Gonzalez" on Justia Law

The First Circuit denied Petitioner's petition to review a decision of the Board of Immigration Appeals (BIA) denying his requests for asylum and withholding of removal under the Immigration and Naturalization Act and for protection under the Convention Against Torture (CAT), holding that substantial evidence supported the BIA's decision.Specifically, the First Circuit held (1) Petitioner failed to establish that he had been persecuted or had a well-founded fear of future persecution on account of race, religion, nationality, membership in a particular social group, or political opinion; and (2) the record did not compel a conclusion that state actors would be complicit in torturing him in the future. View "Celicourt v. Barr" on Justia Law

The First Circuit reversed the judgment of the district court granting Wilmington Savings Fund Society, FSB a declaratory judgment declaring invalid a home equity line of credit (HELOC) that had previously been granted to Nina Collart's father, Lucien, on property in Massachusetts and granting Wilmington an equitable lien in the property, holding that the court abused its discretion in granting Wilmington an equitable lien.Wilmington sued Nina in her individual capacity as trustee of the Lucien R. Collart, Jr. Nominee Trust and the Anne B. Collart Nominee Trust and also named as a defendant Thomas Mann, Jr., named in his capacity of the Nina B. Collart Trust. Wilmington sought a declaratory judgment that the HELOC was a valid encumbrance on the property and further sought an equitable lien on the property. The district court held that the HELOC was invalid and that Wilmington was entitled to an equitable lien against the property. The First Circuit reversed, holding that the lien was based on an error of law and that the defendants should have had judgment entered in their favor. View "Wilmington Savings Fund Society v. Collart" on Justia Law

The First Circuit affirmed the grant of summary judgment to Ocwen Loan Servicing, LLC in Josephine Donahue's suit against Ocwen and the Government National Mortgage Association (GNMA), holding that summary judgment was properly granted on the only claim at issue here.Donahue executed a mortgage for her home that was assigned to Ocwen. Donahue later defaulted on the mortgage. Ocwen held a foreclosure auction and was the highest bidder. Donahue subsequently field suit against GNMA and Ocwen, alleging three counts. The district court granted summary judgment to Ocwen on all claims but did not address Donahue's still-pending claims against GNMA. Donahue appealed, seeking review of only the grant of summary judgment to Ocwen on Count III of her complaint. Donahue subsequently dismissed her claims against GNMA. The First Circuit affirmed, holding (1) the prudent course is to assume appellate jurisdiction, despite the parties' disagreement as to whether this Court has appellate jurisdiction, given how clear the merits are; and (2) there was no disputed fact precluding summary judgment on the only claim at issue here. View "Donahue v. Federal National Mortgage Ass'n" on Justia Law

The First Circuit held that Students for Fair Admissions, Inc. (SFFA) had associational standing to bring its claims against the President and Fellows of Harvard College and the Board of Overseers (collectively, Harvard) and that Harvard's race-conscious undergraduate admissions program does not violate Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d et seq.In its suit, SFFA alleged that Harvard's race-conscious admissions processed violated Title VI by discriminating against Asian American applicants in favor of white applicants. SFFA sought a declaratory judgment, injunctive relief, attorneys' fees and costs. The district court denied Harvard's motion to dismiss for lack of standing and then found that Harvard had met its burden of showing its admissions process did not violate Title VI. The First Circuit affirmed, holding (1) SFFA had associational standing to bring its claims; and (2) under governing Supreme Court law, Harvard's admissions program does not violate Title VI. View "Students for Fair Admissions v. President & Fellows of Harvard College" on Justia Law

The First Circuit affirmed Defendant's conviction for conspiracy to possess with intent to distribute heroin, entered pursuant to a guilty plea, holding that the district court did not err in accepting Defendant's plea.On appeal, Defendant argued that the district court failed to determine that there was a factual basis for his guilty plea, as required by Fed. R. Crim. P. 11(b)(3). The First Circuit disagreed, holding that Defendant's admission to participating in a conspiracy that involved at least one other person provided a reasoned basis to believe that he was guilty of conspiracy and that Defendant could not show that the district court's acceptance of his plea prejudiced him. View "United States v. Delarosa Arias" on Justia Law

The First Circuit denied Petitioner's petition for review of the final decision of the Federal Motor Carrier Safety Administration (the FMSCA) determining that Sorreda Transport, LLC's business safety rating was unsatisfactory, holding that the the FMSCA's findings and conclusions were supported by substantial evidence in the record and its decision denying Sorreda's petition for review was not arbitrary or capricious.After the FMSCA, an agency within the United States Department of Transportation that regulates the trucking industry, used a notice informing Sorreda of its proposed unsatisfactory rating, Sorreda appealed. The FMSCA issued a final order denying Sorreda's petition for administrative review. Sorreda then filed a timely petition for review in the First Circuit. The First Circuit denied the petition, holding that the FMSCA's findings were supported by substantial evidence and that its determination that Sorreda's business safety rating was unsatisfactory was neither arbitrary nor capricious under the applicable regulations. View "Sorreda Transport, LLC v. United States Department of Transportation" on Justia Law

In this case, the First Circuit held that a viable substantive due process state-created danger claim was presented against two Maine State Police officers and that the district court erred in granting the officers' summary judgment motion on qualified immunity grounds.This 42 U.S.C. 1983 action arose out of the attacks, murder, and rapes committed in 2015 by Anthony Lord against Brittany Irish and those close to her (Plaintiffs) after actions and inactions by the defendant officers. Plaintiffs sought relief based on the state-created substantive due process danger doctrine, under which officers may be held liable for failing to protect plaintiffs from danger created or enhanced by their affirmative acts. The district court granted summary judgment to the officers on the grounds of qualified immunity. The First Circuit (1) affirmed the district court's ruling that a jury could find that the officers violated Plaintiffs' substantive due process rights; and (2) reversed the grant of Defendants' summary judgment motion on qualified immunity grounds, holding that a reasonable jury could conclude that the facts of this case could give rise to a constitutional violation under the state-created danger doctrine. View "Irish v. Fowler" on Justia Law