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

The First Circuit vacated the judgment of the district court in part ruling in favor of Putnam Investments, LLC and other fiduciaries of Putnam’s defined-contribution 401(k) retirement plan on Plaintiffs’ lawsuit claiming that Defendants breached fiduciary duties to the plan's participants, clarifying several principles for the district court that should guide its subsequent rulings on remand.Plaintiffs, two former Putnam employees who participated in the Plan, brought this lawsuit on behalf of a now-certified class of other participants in the Plan and on behalf of the Plan itself pursuant to the civil enforcement provision of ERISA, see 29 U.S.C. 1132(a)(2), arguing that Defendants offered a range of mutual investments, including Putnam’s mutual funds, without regard to whether such funds were prudent investment options and that Defendants treated Plan participants worse than other investors in Putnam mutual funds. The district court ruled in favor of Defendants. The First Circuit (1) affirmed the district court’s dismissal of Plaintiffs’ prohibited transaction claim under 1106(a)(1)(C), breach of loyalty claim, and disgorgement claim; (2) vacated the court’s dismissal of Plaintiffs’ prohibited transaction claim under 1106(b)(3) and the finding that Plaintiffs failed as a matter of law to show loss; and (3) remanded for further proceedings. View "Brotherston v. Putnam Investments, LLC" on Justia Law

At issue was whether it is appropriate to use the categorical approach in determining what is a “crime of violence” under 18 U.S.C. 924(c)(3)(b).The First Circuit affirmed the district court’s denial of Appellant’s motion, before he entered a conditional plea of guilty to using, carrying, or brandishing a firearm in relation to a “crime of violence” in violation of 18 U.S.C. 924(c)(1), to dismiss a portion of the charge on the ground that the residual clause at 18 U.S.C. 924(c)(3)(B) is unconstitutionally vague under Johnson v. United States, 135 S. Ct. 2551 (2015), and Sessions v. Dimaya, 138 S. Ct. 1204 (2018). The First Circuit held that section 924(c)(3)(B) is not void for vagueness because the statute reasonably allows for a case-specific approach rather than a categorical approach and because Appellant’s conspiracy to commit a Hobbs Act robbery qualified as a “crime of violence.” View "United States v. Douglas" on Justia Law

The First Circuit affirmed the sentence imposed upon Defendant, a convicted fraudster, particularly the restitution order entered pursuant to the Mandatory Victims Restitution Act (MVRA), 18 U.S.C. 3663A, in the amount of $581,880, holding that the district court satisfied the requirements of the MVRA.Defendant pleaded guilty to seven counts of mail fraud and two counts of visa fraud. The government sought a total of $581,880 in restitution on behalf of 368 victims. The district court adopted the government’s calculations and ordered restitution accordingly. The First Circuit affirmed, holding (1) both the district court and the First Circuit had jurisdiction over the matter; and (2) there was no abuse of discretion in the order of restitution. View "United States v. Naphaeng" on Justia Law

The First Circuit affirmed Defendant’s sentence of 276 months in prison for conspiracy to commit kidnapping, holding that the sentence was neither procedurally flawed nor substantively unreasonable.After Defendant pleaded guilty to conspiracy to commit kidnapping, the district court imposed a below-guidelines sentence. On appeal, Defendant challenged the sentence’s procedural and substantive reasonableness. The First Circuit affirmed the sentence, holding (1) the ransom-demand enhancement under section 2A4.1(b)(1) of the guidelines was not plain error; (2) Defendant’s arguments regarding the judge not expressly ruling on his objections to the presentence report’s inclusion of a two-level obstruction-of-justice enhancement and rejection of a two-level minor-role reduction did not amount to procedural unreasonableness; and (3) Defendant’s sentence was substantively reasonable. View "United States v. Romero" on Justia Law

The First Circuit affirmed the district court’s judgment in favor of Stephen Elliott on his suit against American Capital Energy, Inc. (ACE) and its two principals (collectively, Appellants) claiming breach of contract and violations of the Massachusetts Wage Act, holding that Ellicott’s compensation constituted “wages” under the Wage Act and that the statute of limitations for his Wage Act claim was properly tolled.Elliott filed suit against Appellants seeking compensation for unpaid sales commissions. The jury found all three Appellants liable under the Wage Act and ACE liable for breach of contract. The First Circuit affirmed, holding (1) the jury could reasonably conclude that Ellicott’s sales commissions constituted wages under the Wage Act; (2) tolling the statute of limitations so as to allow Ellicott’s Wage Act claims against one of the principals was justified; and (3) the district court did not abuse its discretion in granting Ellicott’s motions in limine excluding evidence about whether Elliott had agreed to split his sales commissions. View "Ellicott v. American Capital Energy, Inc." on Justia Law

The First Circuit affirmed the district court’s decision upholding the determination of the Massachusetts Bureau of Special Education Appeals (BSEA) ruling against all of Plaintiff’s claims seeking placement for her minor child in a school outside of the Boston Public Schools (BPS) system, holding that there was no basis in which to reverse the district court’s decision.Plaintiff, on behalf of her minor child, initiated this proceeding pursuant to the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. A hearing officer denied relief. The district court affirmed the BSEA’s decision. On appeal, Plaintiff raised a number of claimed errors during the hearing. The First Circuit affirmed, holding (1) the district court applied the proper standard in evaluating the minor child’s education progress; and (2) Plaintiff’s challenges to the conduct of the hearing itself did not warrant reversal of the district court’s decision. View "Johnson v. Boston Public Schools" on Justia Law

The First Circuit denied Petitioner’s application seeking permission to file a successive motion under 28 U.S.C. 2255 to vacate her conviction and sentence for possessing a destructive device during and in relation to and in furtherance of a crime of violence, holding that Petitioner’s application did not meet the requirements for certification of a successive section 2255 motion.Petitioner sought to file this successive motion in 2016 following the Supreme Court’s decision in Johnson v. United States, 135 S. Ct. 2551 (2015). Petitioner then supplemented her motion after Sessions v. Dimaya, 138 S. Ct. 1204 (2018), was decided. Petitioner hoped to argue in the district court that the rule announced in Johnson and reiterated in Dimaya rendered the definition of “crime of violence” under which she was convicted unconstitutionally void for vagueness. The First Circuit denied the application, holding that Johnson’s rule, reaffirmed in Dimaya, did not extend to Petitioner’s conviction under 924(c)’s residual clause. View "Brown v. United States" on Justia Law

In this case arising from the fatal shooting of an armed civilian by a state trooper, the First Circuit affirmed the district court’s grant of summary judgment to Defendant, holding that Defendant was entitled to qualified immunity.Qualified immunity protects public officials, including police officers such as Defendant, from civil liability while acting under color of state law, with the exception of officials who act incompetently or in disregard of clearly established legal principles. The district court concluded that, under the facts of this case, Defendant was entitled to qualified immunity. The First Circuit affirmed, holding that, under the totality of the circumstances, the district court’s entry of summary judgment in Defendant’s favor on the basis of qualified immunity was correct. View "Conlogue v. Hamilton" on Justia Law

At issue in this bankruptcy case was whether a defaulting subcontractor who has no contractual right to compensation is nonetheless entitled to an equitable recovery if the general contractor has benefited at the subcontractor’s expense.Insite, a bankrupt subcontractor, filed an adversary proceeding against Walsh, a general contractor, in bankruptcy court claiming that Walsh improperly withheld payments belonging to its bankruptcy estate. The bankruptcy court found the doctrine announced in Pearlman v. Reliance Insurance Co., 371 U.S. 132, 141-42 (1962), prevented Insite from gaining a property interest in the funds withheld by Walsh. The district court affirmed. The First Circuit vacated the judgment below and remanded, holding (1) the Pearlman doctrine did not address the primary issue in this case; and (2) while Insite was not due funds under its contract with Walsh, the bankruptcy and district courts must consider whether Walsh was benefited by Insite’s post-default performance in such a way that Insite had an equitable claim under Puerto Rico law. View "Insite Corp. Inc. v. Walsh Construction Co. Puerto Rico" on Justia Law

The First Circuit affirmed the district court’s dismissal of Appellant’s habeas petition, holding that the state court ruling challenged in this case was neither contrary to nor an unreasonable application of clearly established federal law.Appellant was convicted in state court of murder in the second degree and sentenced to life imprisonment. Thereafter, Appellant filed a motion asking the court to conduct a jury inquiry on the basis that a book found in the jury deliberation room entitled “Guilty: Liberal 'Victims' and Their Assault on America (Guilty)” was “extraneous material” that could have improperly influenced the jurors’ deliberations. The trial justice denied the motion after a non-evidentiary hearing. The state appellate court affirmed Appellant’s conviction and the denial of his jury inquiry motion. Appellant later filed a petition for habeas relief in the federal district court and filed a motion for an evidentiary hearing. The district court denied both the petition and the motion. The First Circuit affirmed, holding that the state appellate court’s decision that the book did not qualify as “extraneous” material was not objectively unreasonable. View "Bebo v. Medeiros" on Justia Law