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

In this bankruptcy case, the First Circuit vacated the decision of the Bankruptcy Appellate Panel (BAP) and remanded with instructions that the case be returned to the bankruptcy court, holding that the bankruptcy court misapplied the standard for fraudulent intent and that the BAP exceeded the bounds of appellate review by engaging in fact-finding when it reversed the bankruptcy court.After Edward Stewart filed relief Chapter 7 bankruptcy Joseph and Sheila DeWitt filed a proof of claim, indicating that they held an unsecured claim for $558,335. The DeWitts then commenced an adversary proceeding seeking to exempt their unsecured claim from discharge. The bankruptcy court concluded that the DeWitts' unsecured claim was dischargeable. The BAP reversed. The First Circuit vacated the BAP's reversal of the bankruptcy court's judgment, holding (1) the BAP erred when it reweighed the evidence and conducted its own fact-finding; and (2) the bankruptcy court erred when determining what is required to prove "intent to deceive." View "Dewitt v. Stewart" on Justia Law

The First Circuit affirmed Defendant's federal drug-trafficking conviction and his twenty-year mandatory minimum recidivist sentence, holding that Defendant's claims on appeal lacked merit.A federal grand jury sitting in the District of New Hampshire indicted Defendant on a charge of conspiracy to distribute and to possess with intent to distribute controlled substances. After a jury trial, Defendant was convicted of the conspiracy charge. The district court imposed a twenty-year mandatory minimum recidivist term of immurement. The First Circuit affirmed, holding (1) Defendant was not entitled to a new trial because one of the seated jurors was not a New Hampshire resident; and (2) Defendant's claims of sentencing error were unavailing. View "United States v. Gonzalez" on Justia Law

The First Circuit affirmed the judgment of the district court denying Plaintiff's claims of sex discrimination and retaliation on summary judgment and declining Plaintiff's request to alter or amend that ruling under Fed. R. Civ. P. 59(e), holding that there was no reversible error in the proceedings below.This complaint stemmed from Plaintiff's unsuccessful pursuit of tenure within Harvard University's Anthropology Department. Plaintiff alleged that Harvard denied her tenure on the basis of sex discrimination and retaliation for engaging in protected conduct in violation of several state and federal antidiscrimination laws. The district court dismissed Plaintiff's claims on summary judgment and then denied Plaintiff's Rule 59(e) motion to alter or amend the summary judgment. The First Circuit affirmed, holding (1) the district court did not err in finding that Plaintiff did not meet her burden of showing Harvard's stated reason for denying tenure was merely pretext for discrimination; (2) because Plaintiff could not establish a causal link between her protected activity and the adverse employment decision, her retaliation claims failed; and (3) the district court did not err in denying Plaintiff's Rule 59(e) motion. View "Theidon v. Harvard University" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendants of mail fraud and violations of section one of the Sherman Act, holding that Defendants were not entitled to reversal of their convictions or a reduction in the restitution amounts Defendant were ordered to pay.Defendants were school bus operators who contracted with the Caguas, Puerto Rico municipal school system. In 2013, Defendants banded together with four other school bus operators in a bid-rigging and market-allocation conspiracy, thereby protecting themselves from the price-reducing effects of fair competition. After they were convicted they appealed, claiming, among other things, an absence of intestate nexus and insufficiency of the evidence. The First Circuit affirmed, holding (1) the bid rigging in this case was well within the reach of the Sherman Act; (2) there was no variance from or constructive amendment to the indictment; (3) the district court acted within its discretion in excluding evidence at trial about whether Defendants' conduct really cost Caguas money; (4) the district court did not err in setting the restitution amounts; and (5) Defendants were not entitled to relief on their remaining allegations of error. View "United States v. Vega-Martinez" on Justia Law

The First Circuit affirmed the judgment of the Title III court granting summary judgment against Bondholders, who owned bonds issued in 2008 by the Employees Retirement System of the Government of the Commonwealth of Puerto Rico (the System), and in favor of the Financial Oversight and Management Board for Puerto Rico (the Board), holding that the Bondholders did not have security interest in certain of the System's assets.In 2016, the System filed Title III petitions for bankruptcy protections offered under the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA), 48 U.S.C. 2101-2241, and PROMESA's Title III, 2161-2177. The System subsequently filed two lawsuits against the Bondholders seeking declaratory relief on the validity, priority, extent and enforceability of the Bondholders' asserted security interest in the System's postpetition assets, including employer contributions to the System received postpetition. The Title III court granted summary judgment against the Bondholders. The First Circuit affirmed, holding (1) 11 U.S.C. 552(a) prevents the Bondholders' security interest from attaching to postpetition employers' contributions; (2) the Bondholders did not have special revenue bonds under 11 U.S.C. 902(2)(A) or (D); and (3) Congress intended section 552 to apply retroactively. View "Employees Retirement System v. Andalusian Global Designated, Employees Retirement System" on Justia Law

The First Circuit dismissed Petitioner's petition for review of a decision of the Bureau of Immigration Appeals (BIA) rejecting reopening and reconsideration of denial of relief from removal, holding that the limitations in 8 U.S.C. 1252(a)(2)(C)-(D) divest this Court of jurisdiction over the petition.Petitioner, a native and citizen of Sudan, was removed from the United States after his robbery conviction. Petitioner later filed a motion to reopen removal proceedings as to his requests for relief based on purported changed country conditions in Sudan. The motion was filed outside the ninety-day deadline for motions to reopen and the thirty-day deadline for motions to reconsider. The immigration judge denied the motion. The BIA dismissed Petitioner's appeal, concluding that 8 C.F.R. 1003.23(b)(1) prevented Petitioner from filing his motion to reopen and, alternatively, that the motion was denied in the exercise of the BIA's discretion. The First Circuit dismissed Petitioner's petition for review, holding that because no questions of law or constitutional claims were presented by Petitioner's challenge to the BIA's alternative discretionary holding, the jurisdictional bar set forth under 8 U.S.C. 1252(a)(2)(C)-(D) applied. View "Daoud v. Barr" on Justia Law

In this appeal of a bankruptcy court's decision on the merits of all the claims before it the First Circuit dismissed in part Appellant's appeal from the district court's decision affirming the bankruptcy court rulings and awards on the merits, holding that Appellant's appeal of the damages award was untimely and that the amount of attorneys' fees awarded by the bankruptcy court was appropriate.After the bankruptcy court issued its decision, Appellant waited 237 days - after the bankruptcy court decided a motion for attorneys' fees and costs incurred by the prevailing party - to file a notice of appeal. The district court affirmed the bankruptcy court rulings and awards on the merits. The First Circuit dismissed in part Appellant's appeal and affirmed in part the district court's decision, holding (1) Appellant's notice of appeal from the bankruptcy court's order of damages was untimely and therefore must be dismissed; and (2) the bankruptcy court's determination as to attorneys' fees was not an abuse of discretion. View "PC Puerto Rico, LLC v. Empresas Martinez Valentin Corp." on Justia Law

The First Circuit affirmed the judgment of the district court in favor of Sun Life Assurance Company of Canada finding that Sun Life properly permitted an offset of Appellant's benefits under tis employer-sponsored long-term disability insurance policy (the Plan) by the amount of Appellant's service-connection disability compensation (Veterans' Benefits), holding that the district court did not err.Specifically, the First Circuit held (1) Appellant's Veterans' Benefits fell squarely within the definition of "Compulsory Benefit Act or Law"; (2) that the district court did not err by concluding as a matter of law that Veterans' Benefits unambiguously qualify as a form of "Other Income Benefit" covered by the Plan's offset provision; and (3) the district court did not err by rejecting as a matter of law Appellant's assertion that Sun Life's offset determination was motivated, at least in part, by Appellant's military service in violation of the Uniformed Services Employment and Reemployment Rights Act. View "Martinez v. Sun Life Assurance Co. of Canada" on Justia Law

The First Circuit affirmed the district court decision denying Appellant's petition for habeas corpus relief, holding that the state court's evaluation of Appellant's constitutional claim was not contrary to, nor involved an unreasonable application of, federal law.Appellant was convicted in Rhode Island state court on felony assault and firearms charges. The Rhode Island Supreme Court affirmed. Appellant then applied for postconviction relief based on the ineffective assistance of counsel. The trial justice denied relief, and the Supreme Court affirmed. Appellant later filed a petition for a writ of habeas corpus in federal court, claiming ineffective assistance of counsel in violation of the Sixth Amendment. The district court concluded that Appellant's counsel's performance was constitutionally deficient but that the state Supreme Court's conclusion that Appellant had failed to satisfy the prejudice prong was not an unreasonable application of clearly established federal law. The First Circuit affirmed, holding (1) the Rhode Island Supreme Court's use of the incurable prejudice standard did not lead to a decision "contrary to" federal law; and (2) the Supreme Court's application of Strickland was not unreasonable. View "Chum v. Coyne-Fague" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment to Defendants on Plaintiff's Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621, and relinquishing supplemental jurisdiction over his claims under Puerto Rico law, holding that a reasonable jury could not find pretext discrimination and that the district court did not abuse its discretion in declining to exercise continued supplemental jurisdiction.In his complaint, Plaintiff alleged that he was fired on account of his age. The district court concluded that Plaintiff failed to put forth evidence that he was complying with the legitimate job performance expectations for his position and therefore failed to make a prima facie showing of discrimination. The First Circuit affirmed, holding (1) assuming that Plaintiff established a prima facie case, Plaintiff failed to show that his poor performance reviews were pretextual; and (2) while retention was an option, the district court did not exceed the boundary of its discretion in declining to exercise continued supplemental jurisdiction. View "Santana-Vargas v. Banco Santander Puerto Rico" on Justia Law