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

The First Circuit affirmed Defendant's sentence of 100 months of imprisonment imposed for his convictions of possession of a firearm by a prohibited person and illegal possession of a machine gun, holding that the sentence was neither procedurally nor substantively unreasonable.A probation officer recommended a sentence of forty-one to fifty-one months for Defendant's offenses under the U.S. Sentencing Guidelines. At sentencing, the Government requested a sentence of at least sixty-three months' imprisonment or, in the alternative, an upward variance. The district court adopted the Guidelines' calculation and then imposed an upward variance of forty-nine months' imprisonment for a total of 100 months' imprisonment. The First Circuit affirmed, holding that the sentence was procedurally sound and substantively reasonable. View "United States v. Garcia-Mojica" on Justia Law

The First Circuit reversed the order of the district court denying Defendant's request for a sentence reduction under Section 404 of the First Step Act of 2018, holding that the district court erred in finding that Defendant was ineligible for a reduction on the grounds that his offense was not a "covered offense" under the First Step Act.Specifically, the district court concluded that because the penalties for the quantity of controlled substances attributed to Defendant remained the same after passage of the Fair Sentencing Act of 2010, he was not convicted for "a violation of a Federal criminal statute, the statutory penalties for which were modified." The First Circuit reversed and remanded the case, holding that Congress intended to provide potential relief to persons like Defendant whose penalties were dictated by 21 U.S.C. 841(b)(1)(C), and therefore, Defendant was convicted for a "covered offense" under Section 404. View "United States v. Smith" on Justia Law

The First Circuit affirmed the judgment of the district court granting a preliminary junction to Defendant's former employer (Plaintiff), a healthcare company incorporated in Delaware, that enforced a nonsolicitation clause in the employment contract between the parties, holding that the district court did not err in applying Delaware law to assess whether Plaintiff had satisfied the "likelihood of success" requirement.The injunction sought by Plaintiff enforced a nonsolicitation clause in the parties' contract barring Defendant from engaging in certain work for his new employer, one of Plaintiff's competitors. The choice-of-law provision set forth in the employment contract explicitly stated that the agreement should be interpreted and enforced in accordance with Delaware law, without giving effect to its laws pertaining to conflict of las. The district court held that Massachusetts' choice-of-law rules permitted it to enforce the choice-of-law provision, thus premising its issuance of the preliminary injunction on its application of Delaware law. Defendant appealed, arguing that Massachusetts and not Delaware law applied to Plaintiff's breach of contract claims, and therefore, Plaintiff could not satisfy the likelihood-of-success requirement in seeking a preliminary injunction based on those claims. The First Circuit affirmed, holding that there was no merit in Defendant's challenge to the issuance of the preliminary injunction against him. View "NuVasive, Inc. v. Day" on Justia Law

The First Circuit dismissed this interlocutory appeal for lack of appellate jurisdiction and remanded the matter to the district court, holding that Appellant's challenge to the district court's denial of summary judgment was not a final, appealable order.Plaintiff, an inmate at Souza Baranowski Correctional Center (SBCC), brought this lawsuit alleging that Appellant, an SBCC prison official, and other SBCC officials failed to protect him from a substantial risk of serious harm in violation of his constitutional rights. Appellant and the remaining defendants filed for summary judgment on grounds of qualified immunity. The district court granted summary judgment to all SBCC officials except Appellant. Appellant filed a timely interlocutory appeal, alleging that the district court erred because the undisputed material facts showed Appellant was not deliberately indifferent to a substantial risk of harm to Plaintiff. The First Circuit dismissed the appeal, holding that Appellant's challenge rested on factual, rather than legal, grounds, and therefore, this Court lacked appellate jurisdiction. View "Norton v. Rodrigues" on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment in favor of the United States and the Director of the United States Citizenship and Immigration Services (collectively, the Government) on Plaintiff's claims that the inclusion of the phrase "so help me God" at the end of the both of allegiance administered at United States naturalization ceremonies is unlawful and unconstitutional, holding that the district court correctly denied Plaintiff's claims.In her complaint, Plaintiff argued that the inclusion of "so help me God" as a means of completing the naturalization oath violates the First and Fifth Amendments and the Religious Freedom Restoration Act, 42 U.S.C. 2000bb-2000bb-4 (RFRA). The district court granted summary judgment on all claims. The First Circuit affirmed, holding that the phrase "so help me God" in the oath does not violate the Establishment Clause, the Free Exercise Clause, the RFRA, Equal Protection, or the Due Process Clause. View "Perrier-Bilbo v. United States" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Plaintiff's 2018 complaint seeking vacated of a forfeiture order and return of his forfeited property, holding that Honeycutt v. United States, 137 S. Ct. 1626 (2017), did not apply in this case.Plaintiff was convicted of conspiracy under the Racketeer Influenced and Corrupt Organization (RICO) Act, engaging in monetary transactions with criminal deprived property and money laundering arising out of his control of a money-laundering ring. The district court ordered Plaintiff to forfeit the sum of $136,344,231. The district court did not challenge the district court's finding that all of the money at issue passed through a bank account he controlled. Plaintiff later filed a complaint arguing that the Supreme Court's decision in Honeycutt should be applied retroactively to invalidate the forfeiture judgment against him. The district court dismissed the complaint, concluding that Plaintiff failed to state a claim as to each asserted avenue of relief. The First Circuit affirmed, holding (1) Honeycutt did not apply as a matter of fact to Plaintiff's case given his control over the funds at issue; and (2) Honeycutt did not preclude liability in Plaintiff's case. View "Saccoccia v. United States" on Justia Law

In this diversity case, the First Circuit affirmed the district court's entry of summary judgment against Clarendon National Insurance Company's claim that Philadelphia Indemnity Insurance Company breached its contract with Lundgren management Group, Inc. when Philadelphia declined to tender a defense to Lundgren, holding that the district court did not err in granting summary judgment against Clarendon.Clarendon provided indemnity insurance to Lundgren, a building management corporation, from 2004 to 2005. Philadelphia insured Lundgren from 2007 to 2008. In 2009, Denise Doherty, a resident in a Lundgren-managed building, filed the underlying complaint against Lundgren after mold was discovered in her residence. Lundgren tendered the defense of the underlying complaint to Philadelphia. Philadelphia denied coverage, and Clarendon financed the defense of Lundgren. After the case settled, Philadelphia denied Clarendon's claim for contribution. Clarendon received an assignment from Lundgren of the claim arising in the Doherty matter and then filed the instant suit. The district court entered summary judgment dismissing Clarendon's complaint. The First Circuit affirmed, holding that the district court (1) did not err by granting summary judgment on the duty to defend issue; and (2) properly entered summary judgment dismissing the claims alleging violations of Mass. Gen. Laws ch. 93A and 176D. View "Clarendon National Insurance Co. v. Philadelphia Indemnity Insurance Co." on Justia Law

The First Circuit affirmed the judgment of the district court giving Defendant a consecutive 144-month sentence for two robbery convictions rather than making the sentence concurrent with another sentence he was already serving, holding that the district court did not abuse its discretion in imposing a consecutive sentence.Defendant pled guilty to two counts of aiding and abetting in interfering with commerce by robbery and being a felon in possession of a firearm. Te district court sentenced Defendant to 144 months each on the counts, to be served concurrently with each other but consecutively to the sentence Defendant was already serving for a firearm offense. On appeal, Defendant argued, among other things, that the district court erred in imposing a consecutive, rather than a concurrent, sentence to his sentence for the firearm offense. The First Circuit affirmed, holding (1) the district court did not abuse its discretion in imposing a consecutive sentence; and (2) Defendant's sentence was substantively reasonable. View "United States v. Fuentes-Moreno" on Justia Law

The First Circuit affirmed Defendant's sentence imposed in connection with his plea of guilty of possession with intent to distribute a controlled substance, holding that the sentence was both procedurally and substantively reasonable.Defendant was sentenced to 108 months' imprisonment for possession of a firearm in furtherance of a drug trafficking crime and an additional six months' imprisonment for possession with intent to distribute a controlled substance. Defendant appealed his sentence for the controlled substance offense, arguing (1) the sentence was procedurally unreasonable because the district court overruled his objection to a statement included in the Amended Pre-Sentence Investigation Report (PSR); and (2) the sentence was substantively unreasonable because the court allegedly did not consider information showing a lower sentenced would have sufficed. The Supreme Court affirmed, holding (1) Defendant's argument supporting his assertion that his sentence was procedurally unreasonable lacked merit; and (2) it was not substantively unreasonable for the district court to impose the sentence for the controlled substance offense. View "United States v. Arce-Calderon" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Appellants' complaint challenging the constitutionality of the winner-take-all method for selecting presidential electors that the Commonwealth of Massachusetts adopted, holding that Appellants failed to state a claim upon which relief could be granted.Pursuant to its constitutional authority, Massachusetts enacted a statutory scheme that provides for the appointment of electors for president and Vice President on a winner-take-all (WTA) basis. Appellants sued the Commonwealth challenging the constitutionality of the WTA system as applied in Massachusetts, arguing that the WTA method violates their right to an equally weighted vote under the Equal Protection Clause as well as their associational rights under the First and Fourteenth Amendments. The district court dismissed the complaint for lack of standing and failure to state a claim. The First Circuit affirmed, holding (1) Appellants did have standing to bring their claims; but (2) Appellants failed to state a claim for relief under either of their constitutional theories. View "Lyman v. Baker" on Justia Law