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

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

The First Circuit affirmed in part and vacated in part the judgment of the district court entered judgment for the pleadings on all of Plaintiff's claims, holding that Plaintiff's state certiorari claim did not fail to state a claim on the pleadings.Plaintiff, a former City of Haverhill police officer, brought this action against the city's chief of police and the city's mayor after Plaintiff was denied his request for an identification card to allow him to carry a concealed firearm across state lines under the Law Enforcement Officers Safety Act. Defendants removed the case to federal district court, which entered judgment on the pleadings for Defendants on all four of Plaintiff's claims. The First Circuit directed the dismissal of Plaintiff's state certiorari claim without prejudice for lack of jurisdiction and otherwise affirmed, holding (1) Massachusetts has, in its state certiorari procedure, provided a constitutionally adequate remedy precluding assertion of a federal procedural due process claim in this case; (2) Plaintiff failed to plead facts sufficient to support his federal substantive due process claim; (3) the district court properly dismissed Plaintiff's 42 U.S.C. 1983 due process claim; and (4) Plaintiff's negligence claim and purported equity claim plainly failed to assert a claim under state law. View "Lambert v. Fiorentini" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment to the Administrator of the United States General Services Administration (GSA) and dismissing the discrimination and retaliation claim brought by Plaintiff, a former employee of that agency, holding that summary judgment was properly granted on Plaintiff's claims.Specifically, the Court held (1) the district court did not err in granting summary judgment to the GSA on Plaintiff's sex discrimination claims under Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq.; (2) the district court did not err in granting summary judgment to the GSA on Plaintiff's age discrimination claims under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq.; and (3) Plaintiff's retaliation claims under Title VII and the ADEA also lacked merit. View "Paul v. Murphy" on Justia Law

The First Circuit affirmed Defendant's conviction for conspiracy to commit kidnapping in violation of 18 U.S.C. 1201(c), for which Defendant was sentenced to life imprisonment, holding that Defendant's challenges to his conviction were unavailing.Specifically, the Court held (1) the district court did not err in denying Defendant's motion to suppress the evidence that law enforcement authorities seized from Defendant's apartment; (2) Defendant's challenges to the validity of the search warrant were without merit; (3) the district court did not err in barring a certain witness from testifying due to the "irrelevant, cumulative, or confusing" nature of the testimony that he would provide; (4) the district court did not reversibly err in admitting into evidence a transcript of a recording of statements by one of Defendant's co-conspirators; (5) the district court's challenged statement in an instruction to the jury was not sufficiently prejudicial to constitute reversible error; and (6) the remainder of Defendant's challenged were either without merit or waived. View "United States v. Veloz" on Justia Law

The First Circuit affirmed Defendant's conviction of conspiracy to possess with intent to distribute and to distribute oxycodone, holding that the district court did not err in denying Defendant's motion to suppress.The motion to suppress centered around a series of five search warrants federal law enforcement officers executed as part of an investigation into an oxycodone-distribution conspiracy involving Defendant. The officers obtained location data for Defendant's cell phones and recovered a significant amount of cash stored in a hidden compartment in Defendant's vehicle. This information led to charges that Defendant was the New York-based oxycodone supplier for his co-conspirators' Massachusetts operation. Defendant filed, without success, a motion to suppress, arguing that the first warrant for cellular location data, which served as the foundation for the subsequent warrants, was not supported by probable cause. Defendant was subsequently convicted. The First Circuit affirmed, holding that the warrant for Defendant's vehicle was properly issued, and therefore, the evidence seized from the vehicle was properly admitted at trial. View "United States v. Bregu" on Justia Law

The First Circuit affirmed the decision of the district court denying Appellant's motion to vacate an arbitrator's award, holding that Appellant's attack on the merits of the arbitral award was unavailing.IBC Advanced Alloys Corp. purchased a Beralcast Corporation from Gerald Hoolahan and Gary Mattheson in exchange for cash and shares in the IBC. When Hoolahan decided to sell his shares in the company one year later, he was blocked. Hoolahan later discovered that Mattheson hadn't been similarly blocked when he placed his shares on the market. Hoolahan initiated an arbitration against IBC. During a subsequent hearing it was discovered that IBC had harbored ill-will against Hoolahan, causing it to block Hoolahan's attempt to sell. The arbitrator awarded Hoolahan damages in the amount he would have received if he had sold his shares at the same rate Mattheson received. After IBC unsuccessfully requested that the arbitrator modify the award IBC asked the district court to vacate the award. The district court denied relief. The First Circuit affirmed, holding that IBC did not make a showing that the arbitrator acted in manifest disregard of the law when deciding the award. View "Hoolahan v. IBC Advanced Alloys Corp." on Justia Law

In this breach of contract action the First Circuit affirmed as not clearly erroneous the district court's judgment in favor of Defendant after a bench trial finding no binding contract between the parties, holding that Plaintiff offered no persuasive argument that the district court committed clear error.The First Circuit in this case clarified the difference between facts sufficient to make a claim plausible for pleading purposes and facts sufficient to render a judgment against the claimant clearly erroneous. In a prior decision, the First Circuit reviewed a grant of a motion to dismiss for failure to state a claim and stated that the Court could "plausibly infer" that the parties had formed a contract. The Court emphasized that just because a complaint states a plausible claim for relief does not mean that the claimant has conclusively proven that claim. With the case before the First Circuit a second time, the Court held that by reading too much into its prior ruling, Plaintiff misapprended the manner in which the burden of proof rested once the district court tried the case to a decision and further provided no persuasive argument that the district court committed clear error on remand by determining that no contract existed between the parties. View "APB Realty, Inc. v. Georgia-Pacific LLC" on Justia Law