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

Eric Moore, an employee of Industrial Demolition LLC, injured his hip while working at the Brayton Point Power Station demolition site in December 2019. Despite his injury, Moore was able to continue working with reasonable accommodations. He returned to work with a doctor's note outlining his limitations and requested accommodations from Industrial Demolition. Although initially allowed to work with restrictions, Moore's supervisor became hostile towards him, leading to Moore's termination after an argument over his job-related limitations and requests for accommodation.A federal jury in the District Court for the District of Massachusetts found that Industrial Demolition failed to accommodate Moore's injury and retaliated against him for requesting or using a reasonable accommodation. The jury awarded Moore $10,035 in damages. Both Moore and Industrial Demolition were dissatisfied with the result and sought to reverse or amend the judgment or to grant a new trial.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's verdict, finding that the jury's determination that Moore was retaliated against for requesting or using a reasonable accommodation was supported by sufficient evidence. The court also upheld the district court's decision to allow the jury to consider the NLRB settlement payment in calculating damages, rejecting Moore's argument that the settlement should be excluded as collateral source income. Additionally, the court affirmed the district court's denial of Moore's motion for a new trial on the issue of punitive damages, concluding that the evidence did not support a finding of outrageous or egregious conduct by Industrial Demolition warranting punitive damages. View "Moore v. Industrial Demolition LLC" on Justia Law

The plaintiffs, representing nine closed-end mutual funds, sued Ocean Capital LLC and several individuals and firms for allegedly committing securities violations. The plaintiffs claimed that the defendants misled their shareholders by failing to make complete and accurate disclosures, violating Sections 13(d), 14(a), and 20(a) of the Securities and Exchange Act of 1934 and other applicable SEC rules. The district court granted the defendants' motions for judgment on the pleadings and to dismiss, leading the plaintiffs to appeal.The United States District Court for the District of Puerto Rico initially reviewed the case. U.S. Magistrate Judge Giselle Lépez-Soler recommended dismissing the plaintiffs' complaint on grounds of failure to state a claim and mootness. The district court adopted this recommendation, dismissing the plaintiffs' claims but retaining jurisdiction over the defendants' counterclaims. The plaintiffs then moved for a stay of the proceedings on the counterclaims, which was denied. The district court granted the defendants' requested relief on their counterclaims, ordering the plaintiffs to seat the defendants' nominees for the board of directors of three funds. The plaintiffs timely appealed these decisions.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's dismissal of the plaintiffs' Sections 13(d), 14(a), and 20(a) claims. The court found that the plaintiffs failed to state a Section 13(d) claim for the non-PRRTFF IV funds and did not demonstrate irreparable harm for PRRTFF IV. The court also concluded that the plaintiffs' Section 14(a) claims were insufficient, as the statements in question were not materially misleading. Consequently, the court upheld the district court's judgment on the defendants' counterclaims, ordering the plaintiffs to seat the defendants' nominees. View "Tax-Free Fixed Income Fund for Puerto Rico Residents, Inc. v. Ocean Capital LLC" on Justia Law

Dahua Technology USA, Inc. ("Dahua") and Feng "Frank" Zhang, a former Dahua executive, are involved in a contract dispute. Zhang claims Dahua breached its obligation to pay him severance of $680,000 per month for sixteen months, while Dahua asserts the severance was intended to be a total of $680,000 paid in sixteen monthly installments. Dahua sued under diversity jurisdiction, seeking reformation of the contract and alleging breach of the implied covenant of good faith and fair dealing. Zhang counterclaimed for breach of contract.The United States District Court for the District of Massachusetts initially granted summary judgment in Dahua's favor, finding a mistake in the severance provision. However, the United States Court of Appeals for the First Circuit vacated this judgment, leading to an eleven-day bench trial. The district court concluded that the severance provision contained a mistake but could not be reformed under Massachusetts law, and thus must be enforced as written. Consequently, the district court entered judgment for Zhang in the amount of $10,200,000, plus prejudgment interest.On appeal, the United States Court of Appeals for the First Circuit reviewed the case. The court found the severance provision ambiguous and vacated the judgment, remanding the case for resolution consistent with extrinsic evidence of the parties' intent. The court affirmed the district court's ruling that Dahua's implied covenant of good faith and fair dealing claim fails. View "Dahua Technology USA, Inc. v. Zhang" on Justia Law

Carlos Cruz-Rivera filed a motion in 2020 to reduce his sentence under 18 U.S.C. § 3582(c)(1)(A), as amended by the First Step Act. Cruz was originally charged with multiple counts, including carjacking and weapons-related offenses, and received a nearly 73-year sentence, largely due to mandatory minimums under 18 U.S.C. § 924(c). The First Step Act amended § 924(c) to prevent "stacking" of sentences for first-time offenders, but this change was not retroactive. Cruz argued that the disparity between his original sentence and what it would be under the amended law constituted "extraordinary and compelling reasons" for a sentence reduction.The United States District Court for the District of Puerto Rico initially denied Cruz's motion, adopting the government's reasoning. Cruz appealed, and the United States Court of Appeals for the First Circuit vacated and remanded the case for reconsideration in light of its decision in United States v. Ruvalcaba, which clarified that district courts could consider nonretroactive sentencing amendments as part of the "extraordinary and compelling reasons" analysis. On remand, the District Court again denied the motion without specifying the grounds for its decision.The United States Court of Appeals for the First Circuit reviewed the case and found that the District Court's brief text order did not clarify whether it had properly considered the factors outlined in Ruvalcaba. The appellate court noted that the government's arguments might have led the District Court to apply an unduly narrow interpretation of what constitutes "extraordinary and compelling reasons." Consequently, the First Circuit vacated the District Court's decision and remanded the case for further consideration, ensuring that the correct legal standards are applied. The appellate court also denied Cruz's request to assign the case to a different judge on remand. View "United States v. Cruz-Rivera" on Justia Law

In June 2022, Karen Read was indicted for murder in Massachusetts. She pled not guilty, and the trial in Norfolk County Superior Court ended in a mistrial due to a non-unanimous jury verdict. The case attracted significant public attention and demonstrators gathered near the courthouse. The demonstrators' behavior, including loud protests and displaying materials directed at trial participants, raised concerns about the fairness of the trial.The state court issued an order creating a 200-foot buffer zone around the courthouse to prevent demonstrations during the trial. This order was challenged in state court but upheld by the Massachusetts Supreme Judicial Court. Before the retrial, the Commonwealth sought a broader order, which the state court granted, expanding the buffer zone to include additional areas around the courthouse. This new order was based on evidence of disruptions during the first trial, including noise from demonstrators that could be heard by jurors.A group of demonstrators filed for a preliminary injunction in the District of Massachusetts to challenge the expanded buffer zone. The district court denied the motion, finding that the order was likely narrowly tailored to serve a significant governmental interest. The plaintiffs then appealed to the United States Court of Appeals for the First Circuit.The First Circuit noted that the plaintiffs clarified they did not challenge the order as applied to courthouse property or seek to engage in noisy protests. They only sought to demonstrate quietly on public property without interfering with trial participants. The court vacated the district court's denial of the preliminary injunction and remanded the case for further proceedings to determine if the order's lack of a mens rea requirement rendered it insufficiently tailored. The court suggested that the state court could amend the order to include a mens rea requirement to address the First Amendment concerns. View "Grant v. Trial Court of the Commonwealth of Massachusetts" on Justia Law

Broc Waltermeyer, an incarcerated federal inmate, alleged that he received inadequate medical treatment for his chronic knee pain while at the Federal Correctional Institute in Berlin, New Hampshire. He claimed that despite receiving various non-surgical treatments, including cortisone injections, pain medication, special shoes, knee braces, access to a low bunk, and a cane, he continued to experience pain. Waltermeyer argued that he should have been provided with knee replacement surgery, which was recommended to be deferred by an outside specialist until he was older.The United States District Court for the District of New Hampshire dismissed Waltermeyer's complaint, holding that his claims failed because he had an alternative administrative remedy. The district court also denied his motion for a preliminary injunction, as he had been transferred to a different facility, making the defendants no longer responsible for his care. Waltermeyer then amended his complaint to seek only money damages, leading to the current appeal.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's dismissal. The court held that Waltermeyer's claims were meaningfully different from those in Carlson v. Green, where the Supreme Court recognized a Bivens-type Eighth Amendment claim against federal prison officials for deliberate indifference to serious medical needs. The court found that Waltermeyer received substantial treatment, albeit not the treatment he preferred, and that the medical procedures administered were in accordance with doctors' recommendations. The court concluded that the differences in the nature of the medical care provided and the absence of gross inadequacy or deliberate indifference made Waltermeyer's case distinct from Carlson, thus precluding the extension of a Bivens remedy. View "Waltermeyer v. Hazlewood" on Justia Law

In 2015, two Ecuadorian citizens, Mayancela and Santander, along with Mayancela's minor children, entered the United States without admission or parole. The Department of Homeland Security (DHS) charged them with removability under section 212(a)(6)(A)(i) of the Immigration and Nationality Act (INA). They did not contest their removability but applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). An immigration judge (IJ) in the Boston Immigration Court denied their applications, and the Board of Immigration Appeals (BIA) affirmed the denials.The IJ found that while both petitioners testified credibly, they did not meet the burden of proof for their claims. The IJ concluded that Mayancela did not establish that her persecution was on account of her membership in the particular social groups "Ecuadorian women" and "Ecuadorian females," attributing the harm to her cousin's violent behavior and substance abuse. The IJ also found that Santander's asylum application was untimely and that the government had shown a fundamental change in Ecuador's conditions, rebutting any presumption of a well-founded fear of future persecution. The BIA affirmed the IJ's decision, agreeing that the evidence did not establish the requisite nexus for Mayancela's claims and that the government had sufficiently demonstrated changed conditions in Ecuador for Santander.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the agency failed to conduct the required mixed-motivation nexus analysis for Mayancela's asylum claim and vacated the agency's decision regarding her asylum and withholding of removal claims, remanding for further proceedings. The court affirmed the agency's decision denying Santander's asylum and withholding of removal claims, as well as the denial of CAT protection for both petitioners, finding that the record did not compel a contrary conclusion. View "Mayancela Guaman v. Bondi" on Justia Law

Petitioners, a married couple from Guatemala, have resided in Massachusetts for over twenty years and have four U.S. citizen children. In 2015, the U.S. Department of Homeland Security issued Notices to Appear, charging them with removability. They applied for cancellation of removal under 8 U.S.C. § 1229b, citing their son L.C.'s medical and educational needs. The Immigration Judge (IJ) denied their application, finding they did not meet the "exceptional and extremely unusual hardship" requirement due to insufficient corroborating evidence about L.C.'s situation in Guatemala. The Board of Immigration Appeals (BIA) affirmed the IJ's decision and later denied their first motion to reopen based on the impact of the COVID-19 pandemic.Petitioners filed a second motion to reopen, claiming ineffective assistance of counsel by their previous attorney, who failed to submit crucial evidence about L.C.'s educational needs. They provided new evidence, including country conditions in Guatemala and additional information about their children's medical and educational challenges. The BIA denied this motion, stating that Petitioners had not shown that their counsel's performance was so deficient that they suffered prejudice and that they had not established a prima facie case for cancellation of removal.The United States Court of Appeals for the First Circuit reviewed the BIA's decision. The court found that the BIA provided insufficient explanation for its ruling, making it impossible to review the legal bases for its conclusions. The court noted that the BIA did not adequately address whether the failure to submit corroborating evidence about L.C.'s educational needs constituted ineffective assistance of counsel or whether Petitioners had established a prima facie case for relief. Consequently, the court granted the petition for review, vacated the BIA's decision, and remanded the case for further proceedings. View "Chanchavac Garcia v. Bondi" on Justia Law

The case involves Leika Joanna García-Gesualdo, who filed an employment discrimination lawsuit against Honeywell Aerospace of Puerto Rico, Inc., and Honeywell International, Inc. García-Gesualdo alleged that Honeywell discriminated against her in violation of Title VII of the Civil Rights Act of 1964 and the Americans with Disabilities Act (ADA). The EEOC investigated her claims but decided not to proceed further, issuing a right-to-sue letter on March 29, 2022. García-Gesualdo filed her lawsuit on July 7, 2022, 100 days after the EEOC's decision.The United States District Court for the District of Puerto Rico dismissed García-Gesualdo's claims as time-barred, agreeing with Honeywell that the complaint was filed more than ninety days after the EEOC issued the right-to-sue letter. The court noted that García-Gesualdo's attorney received emails from the EEOC on March 29 and April 6, indicating that a new document was available on the EEOC's portal. The district court concluded that the ninety-day period began on either March 29 or April 6, making the July 7 filing untimely.The United States Court of Appeals for the First Circuit reviewed the case and reversed the district court's dismissal. The appellate court held that neither the March 29 email nor the April 6 email provided sufficient notice of García-Gesualdo's right to sue. The court emphasized that the emails did not unambiguously indicate that the EEOC had terminated its processes or that the ninety-day period to file a lawsuit had begun. Therefore, the appellate court concluded that the facts establishing untimeliness were not clear on the face of the pleadings, and the case was remanded for further proceedings. View "Garcia-Gesualdo v. Honeywell Aerospace of Puerto Rico, Inc." on Justia Law

A couple from Guatemala, Gustavo Evelio Mendez Nolasco and Blanca America Niz Mendez, entered the United States without inspection in 1981 and 2001, respectively. They married in 2004 and have four children, three of whom are U.S. citizens and one a Legal Permanent Resident. They own a landscaping business and a home in Massachusetts. They applied for cancellation of removal, arguing that their children would face exceptional and extremely unusual hardship if they were deported to Guatemala.An Immigration Judge (IJ) denied their applications, finding that they did not demonstrate good moral character due to undisclosed criminal histories and that their children would not face the requisite level of hardship. The IJ considered factors such as the children's limited Spanish skills, the family's financial assets, and the conditions in Guatemala but concluded that the hardships were not substantially beyond what is typically expected upon removal.The Board of Immigration Appeals (BIA) affirmed the IJ's decision, agreeing with the IJ's assessment of the hardship factors and finding no need to address the good moral character determination. The BIA highlighted the children's limited Spanish skills, the couple's assets, and the potential for their oldest child to remain in the U.S. and petition for their legal status adjustment.The United States Court of Appeals for the First Circuit reviewed the case and found no legal error in the agency's application of the hardship standard. The court noted that the BIA properly considered the relevant factors and evaluated them in the aggregate. The court denied the petition for review, concluding that the agency's decision was consistent with its precedent and that the couple did not meet the exceptional and extremely unusual hardship standard. View "Mendez Nolasco v. Bondi" on Justia Law