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

In these cases against four defendants - Manuel De Jesus Rosario-Perez (Rosario), Jorge Gomez-Gonzalez (Gomez), Bryant Setiawan-Ramos (Setiawan), and Santiago Hernandez-Rosa (Hernandez) - the First Circuit affirmed the various drug and weapons charges as to Rosario, Gomez, and Hernandez but vacated Setiawan's convictions and remanded his case for a new trial, holding that Setiawan's convictions must be set aside on a cumulative error theory.Each defendant was indicted for conspiracy to distribute drugs within 1,000 feet of a school and possession with intent to distribute heroin, cocaine, and marijuana. The indictment also charged everyone but Rosario with carrying and using firearms in relation to drug trafficking. Each defendant was convicted of one or more counts. The First Circuit affirmed, holding (1) most of Defendants' claims were without merit; but (2) the district court's decision to admit evidence that Setiawan killed "Teton," a drug seller, while excluding evidence that a witness named "Cascote" killed Teton was improper, and the cumulative effect of the decision warranted a new trial. View "United States v. Rosario-Perez" on Justia Law

In this class action lawsuit stemming from the 2011 nuclear disaster at the Fukushima Daiichi Nuclear Power Plant (FNPP) in Japan, the First Circuit affirmed the judgment of the United States District Court for the District of Massachusetts dismissing Plaintiffs' suit under the doctrine of forum non conveniens, holding that the district court did not abuse its discretion in finding that an adequate alternative forum was available in Japan.Plaintiffs were individuals and business entities who suffered property damage and/or economic harm as a result of the FNPP disaster. Plaintiffs filed suit against General Electric Company (GE) alleging that GE negligently designed the FNPP's nuclear reactors and safety mechanisms, both of which were implicated in the explosions. Plaintiffs alleged that venue was proper in the District of Massachusetts because GE maintained its corporate headquarters and principal place of business in Boston, Massachusetts. The district court dismissed the suit under the doctrine of forum non conveniens, determining that an adequate alternative forum was available to Plaintiffs in Japan and that dismissal was in the private and public interest. The First Circuit affirmed, holding that Japan satisfied the forum availability requirement despite the jurisdictional idiosyncrasies presented in this case. View "Imamura v. General Electric Co." on Justia Law

The First Circuit reversed the district court's order sanctioning Attorney for failing to appear at a status conference, holding that where Attorney was fined without first being given a chance to show cause or explain her failure to appear, the court's order was an abuse of discretion.After Attorney failed to appear at a status conference the district court opened the conference by imposing a monetary sanction on Attorney for her failure to appear. Attorney filed two motions for reconsideration asking the court to excuse her non-appearance due to "mistake" in scheduling. The district court denied the motions for reconsideration. The First Circuit reversed, holding that the sanctions were an abuse of discretion because (1) the district judge in this case does not uniformly sanction all counsel who fail to appear; (2) it cannot be determined which non-appearing attorneys are sanctions and which ones are not; and (3) the district court fined Attorney without first giving her a chance to show cause or explain her failure to appear. View "In re Pimentel-Soto" on Justia Law

The First Circuit held that the requirements for establishing membership in a particular social group in support of a request for asylum or withholding of removal do not categorically preclude applicants from successfully relying on any group defined in material part as women "unable to leave" a domestic relationship.Petitioner, a native and citizen of the Dominican Republic, sought asylum, withholding of removal, and protection under the Convention Against Torture. Petitioner alleged that her former domestic partner and the father of her son abused her in the past, will abuse her in the future, and will remain unfettered by Dominican law enforcement authorities. The immigration judge ruled against Petitioner in part on claimed inadequacy of the tendered social groups. The Board of Immigration Appeals (BIA) affirmed. The First Circuit remanded the case for further proceedings, holding that the BIA's holding that Petitioner's claim necessarily failed because the groups to which she claimed to belong were necessarily deficient was arbitrary and unexamined. View "De Pena-Paniagua v. Barr" on Justia Law

The First Circuit affirmed the district court's denial of HIMA San Pablo Caguas's motion for judgment as a matter of law as well as its remitted verdict after a jury found HIMA responsible for ten percent of Plaintiff's damages, holding that the jury had a legally sufficient evidentiary basis to find HIMA responsible for ten percent of Plaintiff's damages and that the district court did not abuse its discretion in remitting the verdict.Plaintiff's father died from complications relating to the removal of his dialysis catheter at a HIMA facility. Plaintiff sued HIMA and other defendants, alleging negligence. The jury found the co-defendants jointly liable for medical malpractice and awarded Plaintiff $1,000,000 in compensatory damages, finding HIMA responsible for ten percent of Plaintiff's damages. HIMA moved for judgment as a matter of law and, in the alternative, for remittitur of the jury's damages award. The district court denied the motion for judgment as a matter of law but granted remittitur, reducing the damages award to $400,000. The First Circuit affirmed, holding that the district court did not err in denying HIMA's motion for judgment of a matter of law and did not abue its discretion in applying the federal standard in its remittitur analysis and remitting the verdict. View "Suero-Algarin v. HIMA San Pablo Caguas" on Justia Law

The First Circuit affirmed the district court's grant of summary judgment against Appellant and dismissing his race discrimination and retaliation claims against the Maine Department of Corrections (MDOC), holding that Appellant lacked the proof needed to reach trial.Appellant left his job with MDOC as a state corrections officer to apply for a position in the federal prison system. Appellant met the minimum qualification and interviewed for each open spot but was turned down each time. Appellant subsequently reapplied for his former job, but MDOC refused to rehire him. Appellant sued MDOC in federal court for race discrimination and retaliation. The district court judge granted summary judgment for MDOC. The First Circuit affirmed, holding that a reasonable jury could not find that MDOC's rejection of Appellant's application for reinstatement was a product of unlawful discrimination or made in retaliation for his complaint to the Maine Human Rights Commission. View "Brandt v. Fitzpatrick" on Justia Law

The First Circuit held that the New Hampshire Judicial Retirement Plan (Plan) does not allow a former judge who resigned with sufficient years of creditable service, but before reaching the minimum retirement age, to receive a Service Retirement Allowance (SRA) upon later reaching the retirement age.Plaintiff was fifty-four years old when she resigned from her position as a superior court justice for the state of New Hampshire. Plaintiff served in that position for sixteen-and-a-half years. At the age of sixty-one, Plaintiff applied for an SRA. The Board of Trustees of the Board of Trustees (Board) of the Plan denied her application. Plaintiff filed suit against the Plan seeking a declaratory judgment that she was eligible for an SRA. The district court granted summary judgment in favor of the Plan as to Plaintiff's claim for violation of N.H. Rev. Stat. 100-C, 5, concluding that the plain language of the statute requires a judge to be in active service when she elects to retire and claim a service retirement allowance. The First Circuit affirmed, holding that, under the circumstances of this case, Plaintiff was not eligible to receive an SRA on her application. View "Coffey v. New Hampshire Judicial Retirement Plan" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment in favor of Employer in this disability discrimination case brought by Plaintiff, a former employee, holding that the district court did not err in entering summary judgment against Plaintiff on her claims.Plaintiff was a military veteran who suffers from post-traumatic stress disorder (PTSD). After she was discharged from her employment, Plaintiff sued Employer for disability discrimination under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213, and the Maine Human Rights Act, Me. Stat. tit. 5 4551-4634, alleging that she was wrongfully discharged based on her PTSD. Plaintiff also claimed that Employer unlawfully failed to accommodate her disability. The district court granted summary judgment for Employer. The First Circuit affirmed, holding that the district court properly granted summary judgment for Employer on Plaintiff's discriminatory discharge claim and failure to accommodate claim. View "Trahan v. Wayfair Maine LLC" on Justia Law

The First Circuit affirmed in part and vacated in part the judgment of the district court dismissing Plaintiff's case against various defendants, holding that the district court did not err in dismissing Plaintiff's federal law claims or state law negligent training/supervision claim but erred in dismissing Plaintiff's state law negligence claim.Kelsey Zell, a high school junior, was hit by a fellow student and sustained a concussion. Zell faced a one-day suspension for her role in the altercation. Zell and her parents (together, Plaintiffs) unsuccessfully challenged the suspension decision. Plaintiffs later filed a complaint against the school district's superintendent, the dean of students, and other school officials, alleging several claims. The district court dismissed the claims and denied Plaintiffs' motion to amend their complaint. The court then denied Defendants' motion for sanctions. The First Circuit affirmed in part and vacated in part, holding that the district court (1) did not err in dismissing Zell's federal law claims or state law negligent training/supervision claim and Zell's motion to amend as it relates to these issues; (2) did not err in denying the denial of Defendant's motion for sanctions against Zell's counsel; but (3) erred in dismissing Plaintiff's state law negligence claim. View "Zell v. Ricci" on Justia Law

The First Circuit affirmed Defendant's upwardly variant sentence for one count of possession with intent to distribute cocaine and one count of using a firearm during and in relation to a drug-trafficking crime, holding that the sentence was neither procedurally nor substantively unreasonable.Pursuant to a plea agreement, Defendant pled guilty to drug-related crimes. After a sentencing hearing, the district court sentenced Defendant to an upwardly variant sentence of 180 months of imprisonment, thus declining to impose the government's requested sentence. On appeal, Defendant challenged both the procedural and substantive reasonableness of his sentence. The First Circuit affirmed, holding that the 180-month sentence was neither procedurally nor substantively unreasonable. View "United States v. Diaz-Rivera" on Justia Law