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

The First Circuit affirmed the judgment of the district court entering summary judgment against Plaintiff and dismissing her complaint asserting claims under the Americans with Disabilities Act (ADA) and Age Discrimination in Employment Act (ADEA) for discrimination and retaliation, holding that the district court did not err in granting summary judgment as to the ADA and ADEA claims and in dismissing the claims under analogous Puerto Rico laws.Plaintiff, a teacher at the Robinson School in Puerto Rico, sued the school and two school administrators alleging that the school had discriminated and retaliated against her because of her age and perceived disability. The district court granted summary judgment for Defendants as to the ADA and ADEA claims and dismissed without prejudice the discrimination and retaliation claims under the analogous Puerto Rico laws against the school upon declining to exercise supplemental jurisdiction. The First Circuit affirmed, holding that the district court did not err. View "Lopez-Lopez v. Robinson School" on Justia Law

The First Circuit affirmed Defendant's conviction of possessing with intent to distribute controlled substances in a protected area and conspiring to distribute controlled substances in a protected area, holding that the district court did not plainly err with respect to any of Defendant's challenges.Specifically, the First Circuit held (1) the district court did not commit plain error in admitting evidence of the conspiracy's activities occurring after he withdrew from the conspiracy or, alternatively, in not instructing the jury to ignore such evidence; (2) the district court did not plainly err in admitting evidence of a drug trafficking organization's violent acts; and (3) the delay between Defendant's indictment and arrest did not violate his Sixth Amendment right to a speedy trial. View "United States v. Perez-Couvertier" on Justia Law

The First Circuit reversed the judgment of the district court dismissing, for failure to state a claim, Plaintiff's complaint alleging that, by labeling Wesson brand vegetable oil (Wesson Oil) "100% Natural," Conagra Brands, Inc. violated Mass. Gen. Laws ch. 93A, holding that Plaintiff's complaint clearly alleged a Chapter 93A injury for pleading purposes.After learning that Wesson Oil contained genetically modified organisms (GMOs), Plaintiff sued Conagra, the manufacturer and distributor, alleging that, by labeling the oil "100% Natural," Conagra violated Massachusetts's prohibition against unfair or deceptive trade practices. The federal district court dismissed the complaint for failure to state a claim, concluding that Wesson Oil's label was neither unfair nor deceptive because it conformed to the Food and Drug Administration's labeling policy. The First Circuit reversed, holding that Plaintiff's claim may proceed because Plaintiff plausibly alleged that a reasonable consumer might think that the phrase "100% Natural" means that a product contains no GMOs, and then base her purchasing decision on that belief. View "Lee v. Conagra Brands, Inc." on Justia Law

The First Circuit issued this narrow opinion in response to the Commonwealth of Massachusetts's appeal from the district court's denial of its "Motion Regarding Substantial Compliance and To Terminate Monitoring and Court Supervision" and reversed, holding that the district court's analysis was flawed.The underlying suit was long-running class-action litigation concerning the Commonwealth of Massachusetts's compliance with federal statutory requirements for provision of services to a plaintiff class of Medicaid-eligible children with serious emotional disturbances. The district court found the Commonwealth liable for violating Medicaid provisions as to "reasonable promptness" and "early and periodic screening, diagnosis, and treatment" services. The court then issued remedial orders and a court monitor was appointed. Later the Commonwealth filed the motion at issue. Plaintiffs agreed that the court could terminate monitoring and reporting over the portions of the judgment the Commonwealth was in substantial compliance with. The district court denied the motion in its entirety. The First Circuit reversed, holding that the district court's analysis was flawed from the outset. View "Rosie D. v. Baker" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's petition for a writ of habeas corpus, holding that, under the highly deferential standard prescribed by the Antiterrorism and Effective Death Penalty Act for federal habeas review of state criminal convictions, Appellant's claims to habeas relief failed.Appellant was convicted in a Massachusetts superior court of murder in the first degree and related crimes. The Supreme Judicial Court (SJC) affirmed the convictions. Appellant subsequently petitioned the District Court for the District of Massachusetts for a writ of habeas corpus. The district court denied the petition but granted a certificate of appealability. The First Circuit affirmed, holding (1) sufficient evidence supported Appellant's conviction for first-degree murder as a joint venturer, and the SJC's sufficiency determination was not unreasonable; and (2) the SJC reasonably determined that the trial court's admission into evidence of certain items did not constitute error. View "Gomes v. Silva" on Justia Law

The First Circuit vacated the district court's order denying in part Defendants' motions to dismiss this suit brought Plaintiffs, a putative class of shippers who use the services of ocean freight carriers to import goods into Puerto Rico through the Port of San Juan, holding that Plaintiffs lacked standing to sue for a declaration that the collection of a fee from the carriers was unlawful.Plaintiffs' claims stemmed from a cargo scanning program implemented by the Puerto Rico Ports Authority (PRPA). Pursuant to that program, PRPA contracted with Rapiscan Systems, Inc. to provide the technology and services needed to scan all containerized inbound cargo. Rapsican assigned its rights and obligations to S2 Services Puerto Rico LLC (S2). PRPA charged ocean freight carriers a fee for their use of the of the scanning facilities at the maritime port. Plaintiffs sued PRPA, Rapiscan, and S2 (collectively, Defendants) alleging that, in response to the fee, the carriers were forced to be collection agents that collected fees from the shipper entities. The district court granted in part and denied in part Defendants' motions to dismiss. The First Circuit remanded this case for dismissal on jurisdictional grounds, holding that Plaintiffs failed to set forth allegations that were sufficient to establish their standing. View "Dantzler, Inc. v. S2 Services Puerto Rico, LLC" on Justia Law

The First Circuit denied Petitioner's petition seeking review of the Board of Immigration Appeals' (BIA) denial of her untimely motion to reopen her family's removal proceedings, holding that the BIA's denial of Petitioner's motion to reopen was not an abuse of discretion.Petitioner, a native and citizen of Indonesia, applied for asylum, withholding of removal, and protection under the Convention Against Torture for her herself, her husband, and her two daughters. An immigration judge denied the application, and the BIA affirmed. Six years later, Petitioner filed a motion to reopen the removal proceedings. The BIA denied the motion as untimely. The First Circuit affirmed, holding that the BIA's decision not to reopen the proceedings was neither arbitrary nor capricious. View "Sutarsim v. Barr" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Plaintiff's complaint alleging that Defendants, his former employer along with its administrators, conspired to deprive him of his First, Fourth, Fifth, and Fourteenth Amendment rights, holding that the district court correctly dismissed the claims but erred in dismissing the Puerto Rico law claims with prejudice.In his complaint, Plaintiff alleged that several adverse employment actions taken against him by his employer were done in retaliation for his whistleblowing activities. The First Circuit (1) summarily affirmed the district court's dismissal of four of Plaintiff's claims, holding that Plaintiff failed to "seriously develop" argument in their favor on appeal; (2) affirmed the district court's dismissal of the remaining claims; and (3) vacated the district court's dismissal of the Puerto Rico claims with prejudice, holding that those claims should have been dismissed without prejudice. View "Borras-Borrero v. Corporacion del Fondo del Seguro del Estado" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's motion to dismiss the indictment and affirmed the sentence imposed, holding that the district court correctly denied the motion to dismiss and that the sentence was reasonable.Appellant was charged with conspiring to manufacture, distribute, and import cocaine into the United States. Appellant moved to dismiss the indictment, arguing that the government could not prove the element of the offense that Appellant knew or intended that the cocaine would be sent to the United States. The district court denied the motion to dismiss. Appellant entered into a conditional plea agreement and then appealed. The First Circuit (1) affirmed the district court's denial of Appellant's motion to dismiss, holding that Appellant's challenge to the validity of the indictment failed; and (2) affirmed Defendant's below-guideline sentence, holding that the sentence was reasonable. View "United States v. Alexander" on Justia Law

The First Circuit affirmed the imposition of a role-in-the-offense enhancement in connection with Defendant's conviction for racketeering conspiracy under the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1962(d), holding that there was no error in Defendant's sentence.Defendant pleaded guilty to conspiracy to conduct enterprise affairs through a pattern of racketeering activity. A PSI report applied a three-level role-in-the-offense enhancement under USSG 3B1.1(b). The probationer arrived at the enhancement by analyzing Defendant's role in each of the predicate racketeering acts separately and concluded that the enhancement applied only to a murder plot. The government argued that the role enhancement should apply across the board based on Defendant's managerial role in the overall conspiracy. The district court effectively adopted the government's interpretation of the relevant guideline and sentenced Defendant to the statutory maximum sentence. The First Circuit affirmed, holding (1) the role-in-the-offense enhancement is dependent upon the defendant's role in the criminal enterprise as a whole instead of his role in the discrete acts of racketeering activity that underpin the RICO conviction; and (2) the district court's factual finding that Defendant played a managerial or supervisory role in the RICO conspiracy was not plainly erroneous. View "United States v. Lopez" on Justia Law