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

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

The First Circuit affirmed the judgment of the district court finding that Plaintiffs, patients whose healthcare providers used eClinicalWorks, LLC (ECW) software to record and store their medical records, lacked standing to bring this case, holding that, without further injury, Plaintiffs lacked standing to bring this case.Plaintiffs were the estates of two deceased patients whose medical records were kept and stored by healthcare providers using ECW. Plaintiffs alleged that ECW's system was riddled with bugs that showed healthcare providers false and incomplete data about patients' medical problems and treatments and that ECW hid the glitches from government regulators. Plaintiffs brought several state common-law claims and sought to represent a class of millions of other similarly-situated patients. The district court dismissed the case under Fed. R. Civ. P. 12(b)(1). The First Circuit affirmed, holding that the arguments as presented sought redress based on a moot risk of misdiagnosis or mistreatment that no statute or common-law claim makes suable. Therefore, Plaintiffs lacked standing to bring this case. View "Amrhein v. eClinical Works, LLC" on Justia Law

The First Circuit affirmed Defendant's convictions for one count of conspiracy and one count of structuring the export of monetary transactions, holding that there was no error in the proceedings below.Defendant's convictions arose from his role in assisting the leader of conspiracy in smuggling cash through the Logan International Airport in Boston and onto a plane headed to Portuguese islands in the Atlantic Ocean. The First Circuit affirmed the convictions, holding (1) the district court did not err in denying Defendant's motion to suppress certain evidence against him; (2) the district court did not err by admitting into evidence certain statements that the leader made to undercover agents and to admit records of Defendant's phone contacts with the leader; (3) there was no merit to Defendant's argument that the district court erred by refusing to issue certain jury instructions that Defendant argued he requested; and (4) Defendant's remaining allegations of error were without merit. View "United States v. Melo" on Justia Law

The First Circuit affirmed the judgment of the district court granting Defendants' motion to dismiss Plaintiffs' complaint alleging that Defendants knew that Mount Ida College was on the brink of insolvency but concealed this information, holding that Plaintiffs' claims were properly dismissed.Mount Ida, a higher education institution in Massachusetts, permanently closed after providing its students six weeks' notice that it was closing. Plaintiffs, current and prospective students, brought a putative class action against Mount Ida, its board of trustees, and five Mount Ida administrators (collectively, Defendants), alleging seven Massachusetts state law claims. The district court dismissed the complaint. The First Circuit affirmed, holding (1) Plaintiffs' breach of fiduciary duty claim failed; (2) the district court did not err in dismissing Plaintiffs' violation of privacy claim; (3) no claims were stated for fraud, negligent misrepresentation, or fraud in the inducement; (4) Plaintiffs' allegations did not plausibly allege a breach of implied contract; and (5) the district court properly dismissed Plaintiffs' Mass. Gen. Laws ch. 93A claim. View "Squeri v. Mount Ida College" on Justia Law

The First Circuit affirmed Defendant's convictions of three counts of securities fraud for insider trading, holding that Defendant was not entitled to relief on any of his claims.Specifically, the First Circuit held (1) the district court did not err in admitting into evidence a redacted recording and transcript of Defendant's Securities and Exchange Commission deposition; (2) the district court did not abuse its discretion in placing limits on Defendant's ability to cross-examine a witness; (3) Defendant waived his challenge to the district court's decision prohibiting Defendant from entering into evidence a certain email exchange; and (4) any prejudice resulting from the admission of the testimony of Defendant's ex-wife did not affect the outcome of the trial. View "United States v. Altvater" on Justia Law

The First Circuit affirmed the judgment of the district court confirming a Financial Industry Regulatory Authority (FINRA) arbitral award denying certain claims against Concorde Investment Services, LLC, holding that the arbitrator's conclusion was reasonable in light of the claims made and the evidence presented.Appellant's claims against Concorde were for negligence, breach of fiduciary duty, violations of FINRA sustainability rules and regulations against deceptive securities practices, and failure to properly supervise. Appellant's claims against Concorde were denied. Appellant filed a motion to vacate in part and confirm in part the award, and Concorde filed a motion to confirm the award. The district court denied the motion to vacate and granted the motion to confirm. The First Circuit affirmed, holding that the arbitrators did not engage in a manifest disregard of the law and that none of the statutory bases for vacating the awards set forth in the Federal Arbitration Act were met. View "Ebbe v. Concorde Investment Services, LLC" on Justia Law

The First Circuit affirmed the judgment of the district court ruling in favor of the Rhode Island municipalities on their suit seeking to invalidate the conditions that the United States Department of Justice (DOJ) imposed on the cities in connection with the allocation of federal law enforcement grants, holding that the DOJ lacked authority to imposed the challenged conditions.When state and local governments refused to assist wholeheartedly in federal enforcement of immigration-related laws, the DOJ purposed to condition unrelated federal law enforcement grants on the provision of the governments' assistance with the enforcement of the immigration-related laws. Two Rhode Island cities - Providence and Central Falls - brought this suit seeking to enjoin the DOJ from imposing the challenged conditions on their grants. The district court granted summary judgment for the Cities, concluding that the DLJ exceeded its statutory authority in imposing the challenge conditions on the grants. The First Circuit affirmed, holding that the DOJ was not vested with the authority to impose the challenged conditions on the Cities' grants. View "City of Providence v. United States Department of Justice" on Justia Law

The First Circuit vacated the district court's decision granting summary judgment to the City of Somerville, Massachusetts and dismissing Plaintiff's claim that the City unlawfully forced him to retire as a police officer when it discovered that he had basically no vision in one eye, holding that Plaintiff raised a triable issue of fact precluding summary judgment.Plaintiff brought this lawsuit alleging violations of the Americans with Disabilities Act, the Rehabilitation Act, and Massachusetts discrimination law. In granting summary judgment to the City, the district court ruled in part that no reasonable jury could find that Plaintiff could perform high-speed pursuit driving, which the court concluded was an essential function of his job. The First Circuit vacated the summary judgment, holding that Plaintiff raised a triable issue of fact as to whether his monocular vision rendered him unqualified to perform the essential job functions of an incumbent officer in the City's police department. View "Melo v. City of Somerville" on Justia Law