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

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

The First Circuit affirmed the decision of the district court granting the government's motion in limine to admit a recording of a 911 call placed by Defendant's girlfriend, holding that the Confrontation Clause was not implicated and that the district court did not abuse its discretion in applying a hearsay exception.Defendant was indicted for possessing a stolen firearm and being a felon in possession of a firearm. Prior to trial, the government filed a motion in limine seeking to introduce the 911 recording without calling Defendant's girlfriend as a witness. The district court granted the motion. Defendant then entered a conditional guilty plea, reserving his right to appeal the district court's order granting the motion. The First Circuit affirmed, holding that the Confrontation Clause was not implicated by the non-testimonial statements and that the district court did not abuse its discretion in admitting the 911 recording. View "United States v. Estes" on Justia Law

In these consolidated cases, the First Circuit affirmed the decision of the district court rejecting Plaintiffs' suits seeking to enjoin the enforcement of Section 12616 of the Agriculture Improvement Act of 2018, which bans the sponsorship and exhibition of cockfighting matches in Puerto Rico, holding that Section 12616 is a valid exercise of Congress's Commerce Clause power and does not violate Plaintiffs' individual rights.On their complaints, Plaintiffs argued that Section 12616 violated their First Amendment and Due Process rights and that Congress exceeded its powers under the Commerce and Territorial Clauses and further lodged both facial and as-applied pre-enforcement challenges to the statute. The district court granted the government's motion for summary judgment. The First Circuit affirmed, holding (1) Plaintiffs had standing to bring these lawsuits; (2) Section 12616 is a legitimate exercise of the Commerce Clause power; and (3) Section 12616 does not infringe on Plaintiffs' First Amendment freedoms of speech and association. View "Hernandez-Gotay v. United States" on Justia Law

In these consolidated appeals the First Circuit affirmed Defendant's sentence imposed following his conviction on the charge of being a felon in possession of a firearm and Defendant's sentence imposed following the revocation of a supervised release term imposed in connection with a prior, unrelated conviction, holding that Defendant's claims of error were unavailing.The district court imposed a sixty-six term of immurement for the felon-in-possession charge and a twenty-four-month sentence with respect to the supervised release violation. The First Circuit affirmed the sentences, holding (1) the sentence imposed on the felon-in-possession conviction survived Defendant's challenges; and (2) the district court acted within its discretion in imposing the sentence in connection with the revocation of Defendant's supervised release term. View "United States v. Santa-Soler" on Justia Law

The First Circuit affirmed Defendant's sentence imposed in connection with his plea of guilty to one count of possession of a firearm by a felon, holding that the sentence was reasonable.After Defendant pleaded guilty, the district court sentenced Defendant to seventy-two months of incarceration. On appeal, Defendant challenged his sentence, arguing that the district court miscalculated his base offense level under the United States Sentencing Guidelines. The First Circuit affirmed, holding (1) it was in the district court's discretion to impose a sentence outside of the Guidelines range, and any alleged error in calculating Defendant's base offense level was harmless; and (2) Defendant's sentence was substantively reasonable. View "United States v. Ouellette" on Justia Law

The First Circuit affirmed Defendant's conviction of one count of conspiracy to distribute and possess with intent to distribute drugs and one count of possessing a firearm as an alien unlawfully present in the United States, holding that Defendant failed to establish a reasonable probability that he would not have pled guilty had he been advised as required by Rehaif v. United States, 139 S. Ct. 2191 (2019).Defendant pled guilty without the benefit of a plea agreement and was sentenced to 144 months' imprisonment on the drug count and 120 months' imprisonment on the firearm count, to be served concurrently. One month after Defendant's sentencing, the United States Supreme Court issued its opinion in Rehaif. Before the First Circuit, Defendant asked that his conviction on the firearm count be vacated because he did not plead guilty to knowing the facts that made him a person prohibited from possessing a firearm, as Rehaif requires. The First Circuit affirmed, holding (1) Defendant failed to establish that his substantial rights were affected by the district court's failure to anticipate Rehaif; and (2) the district court did not err in imposing a livelihood enhancement that Defendant received at sentencing. View "United States v. Patrone" on Justia Law