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

In this case convicting Defendant of multiple offenses stemming from his criminal scheme of purportedly sending clients cyanide so they could commit suicide the First Circuit reversed Defendant's conviction as to count 14 (witness tampering) and affirmed his remaining convictions, holding that the district court abused its discretion by admitting evidence having great prejudicial effect but little probative value, and the error was not harmless as to count 14.Defendant pleaded guilty to nine fraud-related counts and went to trial on the remaining counts. The jury found Defendant guilty on five of the six tried counts. The First Circuit reversed in part, holding (1) the evidence was sufficient to convict Defendant on counts 1 and 14 (the mailing injurious articles and witness tampering counts); (2) with respect to counts 1 and 14 and certain fraud-related counts (counts 5, 7, 12), the district court abused its discretion in admitting highly charged evidence having significant prejudicial effect but scant probative value, but this error was harmless as to most of the tried counts; (3) as to count 14, the error in admitting the evidence at issue was not harmless, requiring a new trial on that count; and (4) the district court did not err or abuse its discretion in sentencing Defendant. View "United States v. Kilmartin" on Justia Law

The First Circuit reversed the judgment of the district court dismissing for want of jurisdiction under the Tax Injunction Act (TIA) this lawsuit asking that the district court enjoin the collection of certain Rhode Island tolls as violative of the Commerce Clause of the United States Constitution, holding that the TIA's prohibition stating that district courts shall not enjoin levy or collection of "any tax under State law" where a remedy may be had in state courts is inapplicable to the Rhode Island tolls.A Rhode Island statute authorized the Rhode Island Department of Transportation to collect from tractor-trailers certain tolls in order to pay for replacement, reconstruction, maintenance, and operation of Rhode Island bridges. Plaintiff trucking entities brought this lawsuit. The district court dismissed the lawsuit, concluding that it lacked jurisdiction under the TIA. The First Circuit reversed, holding the the tolls in this case were not a "tax" under the statute. View "American Trucking Ass'n v. Alviti" on Justia Law

The First Circuit affirmed the decision of the district court granting the Attorney General's motion to dismiss Plaintiffs' complaint alleging that the "Au Pair Program" at issue in this case impliedly preempts Massachusetts from requiring host families to comply with its wage and hour laws and ordering Plaintiff's case dismissed, holding that the district court did not err or abuse its discretion.The United States Department of State (DOS) administers the Au Pair Program, through which foreign nationals may obtain a special visa then provide in-home childcare services to host families in the United States while the foreign nationals pursue post-secondary school studies. Plaintiffs, a DOS-approved private placement agency based on Massachusetts, and two individuals, brought this lawsuit seeking declaratory and injunctive relief and alleging that state law measures are preempted insofar as they protect au pair participants by imposing obligations on their host families as their employer that may be enforced against the host families. The district court found that there was no preemption. The First Circuit affirmed, holding that Plaintiffs did not meet their burden to establish field or conflict preemption. View "Capron v. Massachusetts Attorney General" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Defendant and dismissing Plaintiff's claims that Defendant terminated his employment to deprive him of a significant equity incentive, holding that no reasonable factfinder could conclude that when Defendant fired Plaintiff it deprived Plaintiff of compensation that he had already earned by virtue of his past services.In his complaint, Plaintiff alleged that Defendant breached the implied covenant of good faith and fair dealing. The district court granted summary judgment for Defendant, concluding that Plaintiff had not presented sufficient evidence to show that, at the time of his discharge, Plaintiff was deprived of compensation that he had fairly earned and legitimately expected by virtue of his past work. The First Circuit affirmed, holding that the district court did not err in entering summary judgment in favor of Defendant. View "Suzuki v. Abiomed, Inc." on Justia Law

The First Circuit reversed in part the magistrate judge's grant of summary judgment for Defendants and dismissing Plaintiff's civil rights action, holding that the magistrate judge erred by granted summary judgment on the claims that police officers unlawfully searched Defendant's property and falsely arrested Defendant and that a jury could find that one police officer and the chief of police violated Defendant's Fourth Amendment rights.Defendant was arrested for theft after police officers obtained a warrant to search Defendant's home for certain property. Defendant later brought this action alleging that there was no probable cause for his arrest. A magistrate judge dismissed all of Defendant's claims on summary judgment. The First Circuit reversed in part, holding (1) the magistrate judge erred by granting summary judgment on the claims under the federal and state civil rights acts that the officers unlawfully searched Defendant's property; (2) the magistrate judge erred in granting summary judgment on Defendant's federal and state civil rights claims for false arrest; and (3) Defendant alleged sufficient facts that a jury might reasonably find the chief of police and one police officer liable on the Fourth Amendment claims, and the Court declined to affirm the judgment on qualified immunity grounds. View "Jordan v. Town of Waldoboro" on Justia Law

The First Circuit reversed the judgment of the district court denying Defendant's motion for reconsideration of the denial of his motion to suppress certain evidence, holding that the district court erred in determining that Defendant's sister had either actual or apparent authority to consent to the search.Defendant filed a motion to suppress fentanyl obtained from within closed black garbage bags that were found in his sister's storage unit during a warrantless search. The district court denied the motion to suppress and denied Defendant's subsequent motion for reconsideration. Specifically, the district court concluded that Defendant's sister, who had apparent authority to consent to the search, gave it even if she did not have actual authority to give consent. The First Circuit reversed, holding that the government failed to meet its burden to show that Defendant's sister had either actual or apparent authority to consent to the search of the evidence at issue. View "United States v. Moran" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Defendants and dismissing Plaintiff's civil rights suit alleging excessive force claims under 42 U.S.C. 1983 and Massachusetts state law, holding that the district court did not err in entering summary judgment against Plaintiff on his excessive force claims.Plaintiff was apprehended by Bellingham police officers in the woods after he was found lying in a shallow ravine with his pants unbuckled. The officers arrested Plaintiff and took him to the Bellingham police station, where Plaintiff became irrational and violent. Plaintiff pleaded guilty to several state criminal charges stemming from these incidents. Thereafter, Plaintiff filed this suit against the police officers that apprehended him in the woods and those who attempted to subdue him at the police station. The district court granted summary judgment for Defendants. The First Circuit affirmed, holding (1) Heck v. Humphrey, 512 U.S. 477 (1994), barred Plaintiff's excessive force claims arising from the events in the woods; and (2) the excessive force claims arising from the incidents at the police station failed as a matter of law because Defendants did not use excessive force against Plaintiff at the police station. View "O'Brien v. Town of Bellingham" on Justia Law

The First Circuit affirmed Defendant's convictions for insider-trading securities fraud and related conspiracy offenses, holding that there was sufficient evidence to sustain the convictions and that the district court did not err in instructing the jury or in denying Defendant's motion for a new trial.Defendant was convicted of eleven counts of inside-trading securities fraud and related conspiracy offenses. The First Circuit affirmed the convictions, holding (1) the jury's verdicts rested on sufficient evidence showing that Defendant owed a corporate inside a duty of trust and confidence, and the evidence similarly sufficed to prove Defendant's willful breach of his duty to the corporate insider; (2) the district court's decisions to give or refuse to give certain jury instructions were without error; and (3) the district court did not manifestly abuse its discretion in denying Defendant's motion for a new trial. View "United States v. Kanodia" on Justia Law

In this case concerning the potential liability of two private equity funds for pension fund withdrawal owed by a company owned by the two funds when the company went bankrupt, the First Circuit reversed the judgment of the district court holding the two funds jointly and severally responsible for the company's withdrawal liability, holding that summary judgment should be granted to the two funds.At issue was whether two private equity funds, Sun Capital Partners III, LP (Sun Fund III) and Sun Capital Partners IV, LP (Sun Fund IV), were liable for $4.5 million in pension fund withdrawal liability owed by a brass manufacturing company that was owned by the Sun Funds when the manufacturing company went bankrupt. Under the Multiemployer Pension Plan Amendments Act, the issue of liability depended on whether the two funds had created an implied partnership-in-fact that constituted a control group. That question, in turn, depended on the application of the partnership test in Luna v. Commissioner, 42 T.C. 1067 (1964). The district court that there was an implied partnership-in-fact constituting a control group. The First Circuit reversed, holding that the Luna test was not met in this case and that there was no firm indication of congressional intent to impose liability on the private investors. View "Sun Capital Partners III, LP v. New England Teamsters & Trucking Industry Pension Fund" on Justia Law

The First Circuit affirmed the judgment of the district court entering summary judgment in favor of Brown University on Jane Doe's claims alleging several contract and tort claims arising from the university's sanctions against her for her second violation of the university's Code of Academic Conduct, holding that the district court did not err.Specifically, the Court held (1) the district court did not err in entering summary judgment with respect to Doe's claims alleging breach of contract, breach of the implied covenant of good faith and fair dealing, promissory estoppel, negligence, and negligent misrepresentation; and (2) the district court did not err in denying Doe's request for additional discovery under Fed. R. Civ. P. 56(d) on the grounds that Doe failed to show how the information to be obtained would have defeated summary judgment. View "Doe v. Brown University" on Justia Law