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

The defendant pleaded guilty to one count of coercion and enticement of a minor. The plea agreement included a joint recommendation for a 120-month sentence, which is the statutory minimum, despite the calculated Guidelines sentencing range being significantly higher. The government did not provide an explanation for this recommendation at the sentencing hearing. The district court sentenced the defendant to 292 months in prison, imposed a condition of supervised release prohibiting unsupervised contact with any minor, including his children, and ordered a special assessment and restitution.The defendant appealed, arguing that the government breached the plea agreement by not adequately supporting the recommended sentence and that the sentence and conditions imposed were unreasonable. The United States Court of Appeals for the First Circuit reviewed the case. The court agreed that the government breached the plea agreement by failing to provide a minimal explanation for the recommended sentence, which was necessary given the significant downward variance from the Guidelines range. However, the court concluded that this breach did not constitute plain error and affirmed the length of the sentence as reasonable.The court also upheld the restriction on the defendant's unsupervised contact with his children, finding it reasonably related to the nature of the offense and necessary to protect the community and minors. However, the court vacated the special assessment and restitution orders, remanding these issues to the district court for further consideration. The special assessment was vacated because the district court did not make a finding regarding the defendant's indigency, and the restitution order was vacated because the district court did not find that the victim's mother was a victim within the statutory definition. View "United States v. Acevedo-Osorio" on Justia Law

In February 2013, a correctional officer named Osvaldo Albarati was murdered while driving home from the federal prison where he worked. Oscar Martínez-Hernández, an inmate at the prison, was convicted and sentenced to life imprisonment for orchestrating the murder. The prosecution argued that Martínez-Hernández, along with another inmate, planned the killing in retaliation for Albarati's efforts to confiscate contraband, including cellphones, from inmates. The defense contended that the evidence was insufficient and that the government had manipulated evidence and allowed false testimony.The United States District Court for the District of Puerto Rico oversaw the trial, which lasted twelve days and included testimony from twenty government witnesses. The defense presented two witnesses. The jury found Martínez-Hernández guilty on all counts, including aiding and abetting the murder of a federal officer, conspiracy to commit murder, murder for hire, and related firearms charges. The defense's motion for a new trial, based on the late disclosure of a prison logbook and other alleged errors, was denied by the district court.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the evidence presented at trial was sufficient to support the jury's verdict. The court also concluded that the late disclosure of the prison logbook did not warrant a new trial, as the logbook's contents did not significantly undermine the overwhelming evidence of Martínez-Hernández's guilt. The court rejected the defense's claims of prosecutorial misconduct and improper admission of hearsay statements, finding no abuse of discretion by the district court. The court affirmed Martínez-Hernández's conviction and the denial of his motion for a new trial. View "United States v. Martinez-Hernandez" on Justia Law

Joseph Segrain, an inmate at Rhode Island's Adult Correctional Institutions, filed a civil lawsuit against the Rhode Island Department of Corrections and several correctional officers, alleging violations of his Eighth Amendment rights and various state laws. Segrain claimed that on June 28, 2018, officers used excessive force by executing a leg-sweep maneuver, spraying him with pepper spray, and delaying his decontamination. The district court granted summary judgment in favor of the officers on all claims, leading Segrain to appeal.The United States District Court for the District of Rhode Island initially reviewed the case. The court found that no reasonable jury could conclude that the officers' conduct constituted an Eighth Amendment violation. It granted summary judgment on the basis that the force used was minimal and necessary to maintain order. The court also dismissed the state law claims, concluding that the officers' actions did not meet the legal standards for battery, intentional infliction of emotional distress, or excessive force under Rhode Island law.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed the district court's judgment regarding the 42 U.S.C. § 1983 claim that Officer Walter Duffy's use of pepper spray violated Segrain's Eighth Amendment rights. It found that a reasonable jury could conclude that Duffy's use of pepper spray was excessive and not in good faith. The court vacated the district court's judgment on the Rhode Island Constitution Article I, Section 8 claim regarding Duffy's use of pepper spray and remanded for further proceedings. However, the court affirmed the district court's judgment on all other claims, including the leg-sweep maneuver and the delayed decontamination, granting qualified immunity to the officers on those issues. View "Segrain v. Duffy" on Justia Law

A patron at Encore Boston Harbor Casino challenged the casino's practice of redeeming slot-machine tickets. When patrons finish using a slot machine, they receive a TITO ticket, which can be redeemed for cash. The casino offers two redemption options: cashier cages, which provide full cash value, and self-serve kiosks (TRUs), which dispense only bills and issue a TRU ticket for any remaining cents. The TRU ticket can be redeemed at the cashier cage or used in another slot machine. The plaintiff argued that this practice was unfair and deceptive, violating Massachusetts regulations and consumer protection laws.The case was initially filed in Massachusetts state court and then removed to federal court. The district court dismissed the plaintiff's unjust enrichment claim, ruling that an adequate legal remedy was available under Chapter 93A. The court later granted summary judgment in favor of the defendants on the remaining claims, including breach of contract, promissory estoppel, conversion, and unfair and deceptive business practices. The court found that the casino's practice did not violate its internal controls or Massachusetts regulations and that the plaintiff failed to show the practice was unfair or deceptive.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's dismissal of the unjust enrichment claim, agreeing that Chapter 93A provided an adequate legal remedy. The court also upheld the summary judgment on the remaining claims, concluding that the casino's practice of issuing TRU tickets for cents did not violate regulations or constitute unfair or deceptive practices. The court found no evidence that the practice was immoral, unethical, oppressive, or unscrupulous, and ruled that the plaintiff's common law claims also failed. View "Schuster v. Wynn Resorts Holdings, LLC" on Justia Law

In this case, the petitioner, a state prisoner, challenged the dismissal of his federal habeas petition, which alleged violations of his constitutional rights under the Fifth, Sixth, and Fourteenth Amendments. The petitioner, along with two accomplices, planned and executed a robbery that resulted in the murder of a pizza delivery driver. The petitioner was convicted of first-degree murder, armed robbery, and breaking and entering, and was sentenced to life in prison without parole.The Massachusetts Supreme Judicial Court (SJC) affirmed the petitioner's conviction, rejecting his claims of insufficient evidence, improper admission of redacted statements from a co-defendant, and errors in jury instructions. The SJC found that the evidence was sufficient to support the petitioner's conviction under theories of felony-murder and extreme atrocity or cruelty. It also held that the redacted statements did not violate the petitioner's Confrontation Clause rights and that the trial court's jury instructions were appropriate.The United States Court of Appeals for the First Circuit reviewed the district court's denial of the habeas petition de novo. The court applied the standards set forth in the Antiterrorism and Effective Death Penalty Act (AEDPA), which requires deference to state court decisions unless they are contrary to or involve an unreasonable application of clearly established federal law, or are based on an unreasonable determination of the facts.The First Circuit affirmed the district court's decision, holding that the SJC's rulings were not unreasonable. The court found that the evidence was sufficient to support the petitioner's conviction, the redacted statements did not violate the Confrontation Clause, and the jury instructions were proper. The court also concluded that any errors in the trial court's rulings were harmless and did not prejudice the petitioner. View "St. Jean v. Marchilli" on Justia Law

Alain Glody Cirhuza Badose, a national of the Democratic Republic of the Congo, entered the United States in 2014 on a student visa. He applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT), claiming danger due to his political opinion. In 2019, an Immigration Judge (IJ) denied his claims based on an adverse credibility determination and insufficient nexus between the harm described and a protected ground. While his appeal was pending, Badose married a U.S. citizen and sought to remand his case to the IJ for adjustment of status based on the marriage. The government did not oppose the motion.The Board of Immigration Appeals (BIA) denied the remand request and affirmed the IJ's removal order, citing Badose's lack of candor and history of lying to immigration officials. The BIA suggested that Badose's marriage was a sham, given its timing after the IJ's denial. Badose argued that the BIA arbitrarily departed from its consistent practice of granting unopposed remand requests and engaged in impermissible factfinding regarding his marriage.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the BIA had indeed arbitrarily departed from its established practice of granting unopposed remand requests and engaged in impermissible factfinding by suggesting Badose's marriage was a sham. The court held that the BIA's actions were an abuse of discretion and vacated the BIA's decision. The court granted Badose's petition for review and remanded the case to the BIA with instructions to remand to the IJ for consideration of Badose's adjustment of status application. View "Badose v. Garland" on Justia Law

Holsum de Puerto Rico, Inc. ("Holsum") contracted with Peerless Food Equipment ("Peerless") to manufacture a machine for sandwiching cookies and with Compass Industrial Group, LLC ("Compass") for a tray-loader machine. The machines malfunctioned, leading Holsum to sue both companies for breach of contract and negligence. The jury found in favor of Holsum against Compass but ruled in favor of Peerless. Peerless then sought attorney fees from Holsum, citing a fee-shifting provision in their contract and a Puerto Rico court rule.The United States District Court for the District of Puerto Rico denied Peerless's motion for attorney fees. The court found that the fee-shifting provision was not clearly incorporated into the contract through a hyperlink and that Holsum did not act obstinately or frivolously in bringing its claims against Peerless. Peerless appealed this decision.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court agreed that the contract did not clearly communicate the incorporation of the fee-shifting provision via the hyperlink. Additionally, the court found no abuse of discretion in the district court's determination that Holsum's claims were not frivolous and that Holsum did not act obstinately in refusing to settle before trial. The appellate court emphasized that exercising the right to a jury trial in good faith does not constitute obstinacy. View "Holsum de Puerto Rico, Inc. v. ITW Food Equipment Group LLC" on Justia Law

The appellants, Meredith O'Neil, Jessica Svedine, Deanna Corby, and Roberto Silva, sued various officials from the Canton Police Department and the Town of Canton, Massachusetts, seeking declaratory and injunctive relief to prevent the enforcement of Massachusetts witness intimidation statutes, Mass. Gen. Laws ch. 268 §§ 13A and 13B. They claimed that these statutes violated their First Amendment rights, fearing prosecution for their actions during a November 5, 2023 protest and alleging that their speech would be chilled for a planned protest on November 12, 2023. The appellants moved for emergency relief to enjoin the enforcement of these statutes.The United States District Court for the District of Massachusetts denied the emergency motion on November 10, 2023. The court assumed the plaintiffs had standing but found they did not demonstrate a reasonable likelihood of success on the merits of their claims. The court held that the statutes served compelling interests in protecting the administration of justice and were narrowly tailored. The court also found that the plaintiffs had not shown they faced a risk of irreparable harm, noting that the plaintiffs had other public forums to express their views. The balance of harms and public interest considerations also weighed against granting the injunction.The United States Court of Appeals for the First Circuit reviewed the case and dismissed the appeal as moot. The court noted that the state court had dismissed the charges against the appellants for lack of probable cause, and no ongoing conduct remained for the court to enjoin. The court also found that the appellants' general allegations of future protests did not show a credible threat of prosecution, failing to establish standing for their pre-enforcement challenges. The case was remanded to the district court for further proceedings as appropriate. View "O'Neil v. Canton Police Department" on Justia Law

Joan Stormo and her siblings hired attorney Peter Clark for a real estate transaction, but Clark's actions caused the deal to fall through. Stormo sued Clark for malpractice and won. Clark's insurer, State National Insurance Company, denied coverage based on a prior-knowledge exclusion and Clark's delay in reporting the lawsuit. Stormo, as Clark's assignee, then sued State National for breach of contract and unfair claim-settlement practices.The U.S. District Court for the District of Massachusetts found that factual questions necessitated a trial on the breach-of-contract claim but granted summary judgment to State National on the unfair claim-settlement practices claim. The jury found for Stormo on the breach-of-contract claim, awarding over $1 million in damages. However, the district court granted State National's motion for judgment as a matter of law, ruling that Clark's late notice of the claim voided coverage under the policy.The United States Court of Appeals for the First Circuit affirmed the district court's judgment. The court held that under Massachusetts law, a claims-made policy like Clark's does not require the insurer to show prejudice from late notice to deny coverage. Since Clark failed to provide timely notice, State National had no duty to indemnify or defend him. Consequently, Stormo's claims for breach of contract and unfair claim-settlement practices failed. View "Stormo v. State National Insurance Co." on Justia Law

A school bus owned by First Student, Inc., and insured by National Union Fire Insurance Company of Pittsburgh, PA, collided with two underinsured vehicles in Rhode Island, injuring Tiffany Briere and her minor daughter. Briere submitted a claim for underinsured motorist benefits to National Union, which was denied on the grounds that First Student had rejected such coverage. Briere then sued National Union, arguing that Rhode Island law required the policy to offer underinsured motorist coverage.The United States District Court for the District of Rhode Island granted summary judgment to National Union and First Student. The court found that the Rhode Island statute requiring underinsured motorist coverage did not apply because the insurance policy was not "delivered or issued for delivery" in Rhode Island. The policy had been issued by a New York-based broker and delivered to FirstGroup's headquarters in Ohio. Consequently, the court ruled that the policy was exempt from the statutory requirement.The United States Court of Appeals for the First Circuit reviewed the case and vacated the district court's summary judgment. The appellate court held that National Union had waived its defense based on the delivery requirement because it had not mentioned this ground in its initial denial letter to Briere. The court emphasized that insurers must notify their insureds of all grounds for denying coverage in their denial letters. Since National Union failed to do so, it could not later rely on the delivery requirement defense. The case was remanded for further proceedings to address other potential defenses and issues not considered by the district court. View "Briere v. National Union Fire Insurance Co. of Pittsburgh, PA" on Justia Law