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

Three Guatemalan citizens—an adult couple and their minor child—entered the United States in September 2021 and were subsequently served with Notices to Appear, charging them with removability under the Immigration and Nationality Act. The adults filed applications for asylum, withholding of removal, and relief under the Convention Against Torture (CAT), naming their daughter as a derivative beneficiary, while the daughter filed her own applications for the same relief. Their claims centered on threats and an attack they experienced in Guatemala related to their ownership of a hardware store, as well as concerns about general criminality and safety for their family.After a merits hearing, the Immigration Judge (IJ) found the petitioners credible but concluded that they had not met their burdens for any form of relief. The IJ determined that the evidence showed only isolated incidents rather than a pattern of persecution, and that the threats were linked solely to their business. The IJ held that their proposed particular social groups—“Guatemalan small business owners” and the “Lopez-Ramos-Hernandez nuclear family”—were not cognizable, and that there was no nexus between the harm suffered and a protected ground. The IJ also found that the petitioners had not shown a reasonable fear of future persecution, nor that they could not safely relocate within Guatemala. Consequently, the IJ denied their claims for asylum, withholding of removal, and CAT protection.The petitioners appealed to the Board of Immigration Appeals (BIA), which affirmed the IJ’s decision without opinion, making the IJ’s decision the final agency determination. Upon review, the United States Court of Appeals for the First Circuit held that substantial evidence supported the agency’s factual findings and that no error of law occurred. The court denied the petition for review, upholding the denial of asylum, withholding of removal, and CAT protection. View "Ramos-Hernandez v. Bondi" on Justia Law

A political news producer in Puerto Rico contacted a senior government official, warning that the son of the Treasury Secretary possessed damaging chat messages about the administration and might release them unless political attacks on his father ceased. The producer and the official met twice; the producer described a binder of messages and relayed demands for $300,000, renewal of two government contracts, and payments to media personalities in exchange for withholding the chats and favorable coverage. After the chats were leaked, resulting in political turmoil and resignations, the official became a confidential FBI source, recorded a second meeting, and collaborated with agents. The producer later deleted relevant messaging records from the official's phone during an FBI interview.The United States District Court for the District of Puerto Rico held a jury trial. The jury convicted the producer on three counts: attempted extortion under the Hobbs Act (18 U.S.C. § 1951), transmitting a threatening communication with intent to extort (18 U.S.C. § 875(d)), and destruction of records in a federal investigation (18 U.S.C. § 1519). The defendant moved for acquittal and a new trial, arguing insufficient evidence, prosecutorial misconduct, and errors in jury instructions. The district court denied these motions and sentenced him to fifty-one months in prison.On appeal, the United States Court of Appeals for the First Circuit reviewed sufficiency of the evidence and the alleged procedural errors. It held that the evidence was sufficient for all counts, including proof of wrongful threats and intent to extort, and that the government did not commit prosecutorial misconduct or Brady violations. The court found no reversible error in the jury instructions or limitations on cross-examination and affirmed the convictions in full. View "United States v. Diaz-Colon" on Justia Law

Two Massachusetts State Police officers, Lieutenant Daniel Griffin and Sergeant William Robertson, were implicated in a years-long scheme involving fraudulent overtime billing between 2015 and 2017. Both routinely claimed pay for hours they did not work, either by arriving late, leaving early, or “double-dipping” by billing overtime for tasks performed during regular hours. They also encouraged subordinates to engage in the same practices. The overtime funds in question were supplied through federal grants meant to support highway safety initiatives. In addition to the overtime fraud, Griffin separately engaged in wire fraud relating to private school financial aid and tax fraud connected to a private security business.The United States District Court for the District of Massachusetts presided over a jury trial, which resulted in convictions for both defendants on all counts related to wire fraud, theft of federal funds, and conspiracy. Griffin pled guilty to additional charges of wire fraud and tax falsification before trial. Sentences were imposed: Griffin received 60 months’ imprisonment, three years’ supervised release, substantial restitution, and forfeiture; Robertson received 36 months’ imprisonment, three years’ supervised release, joint and several liability for restitution, and forfeiture.Upon appeal to the United States Court of Appeals for the First Circuit, the court reviewed a broad array of challenges. The First Circuit largely affirmed the convictions, sentences, and restitution orders. It found no reversible error in the district court’s handling of the constitutional challenge, sufficiency of the evidence, guidelines calculations, sentencing disparities, and restitution. However, the Circuit Court vacated and remanded the forfeiture order against Griffin, holding that the government failed to prove by a preponderance of the evidence that the full amount of financial aid received was “traceable to” fraud, as required by statute. All other aspects of the district court’s judgment were affirmed. View "United States v. Robertson" on Justia Law

A thirteen-year-old student in Brewer, Maine, developed a relationship with a twenty-year-old man, who was a coach associated with her school. Over two years, the man sexually assaulted the student multiple times. During that period, rumors circulated at the local high school about their inappropriate relationship. The student reported these rumors to the principal, denied any truth to them, and the principal took limited follow-up action. Other school staff and a police officer had some interactions with the student and the perpetrator, but no one reported or investigated the abuse at the time. The student, now an adult, later sued various school officials, the school department, a police officer, and others, alleging they failed to protect her from abuse despite being aware of warning signs, and sought relief under federal and Maine law.At the United States District Court for the District of Maine, most claims were dismissed at the pleading stage for failing to state a claim. The remaining claims, including those brought under Title IX and 42 U.S.C. § 1983, were resolved in favor of defendants at summary judgment. The court also dismissed the claims against the unidentified police officer for lack of personal jurisdiction, denied the plaintiff’s request for more time to serve that officer, and later denied leave to amend the complaint to add the officer once identified.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court’s decisions in all respects. The First Circuit held that the plaintiff’s allegations did not plausibly establish municipal liability under § 1983, nor did they show actual knowledge by school officials sufficient to support a Title IX claim. The appellate court also found no abuse of discretion in the district court’s procedural rulings regarding service of process and amendment of the complaint. View "Hewes v. Gardiner" on Justia Law

In the spring of 2020, three veterans residing at the Soldiers’ Home in Chelsea, Massachusetts, died after contracting COVID-19. The personal representatives of the veterans’ estates filed suit against several Massachusetts state officials responsible for the facility, alleging violations of the veterans’ substantive due process rights under the Fourteenth Amendment. The complaint asserted that the officials failed to protect residents from COVID-19 by not implementing adequate safety protocols and maintaining inhumane living conditions, including lack of sanitation, improper restraint of residents, and exposure to illegal drugs.The United States District Court for the District of Massachusetts reviewed the complaint after the defendants moved to dismiss, arguing that the plaintiffs failed to state a claim for a substantive due process violation and that the officials were entitled to qualified immunity. The District Court granted the motion to dismiss. It held that the plaintiffs had not sufficiently alleged individual involvement by any defendant in the purported misconduct regarding COVID-19, and failed to provide details showing how the named veterans were specifically harmed by the living conditions. The court also found no clearly established legal authority placing the officials on notice that their conduct would violate the veterans’ rights, thus concluding qualified immunity applied.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s judgment. The First Circuit held that the complaint did not plausibly allege that the defendants directly caused the harm suffered by the veterans, nor did it sufficiently invoke exceptions to that requirement. The Court also found that the plaintiffs had not demonstrated a violation of clearly established law and thus, the defendants were entitled to qualified immunity. Consequently, the dismissal of the complaint was affirmed. View "Terenzio v. Urena" on Justia Law

A man was indicted for unlawful possession of a firearm and ammunition by a felon after Boston police discovered a loaded pistol under the front passenger seat of a car in which he was seated. The discovery occurred shortly after a drive-by shooting in the area, though later evidence showed the car was not involved in the shooting. Video evidence and police testimony established that the man exclusively occupied the front passenger seat from the time the car arrived at a market until the stop, wore a latex glove on his right hand, and repeatedly bent toward the floor mat area where the pistol was found. No fingerprints were found on the firearm, magazine, or ammunition.The United States District Court for the District of Massachusetts denied the defendant’s motions for judgment of acquittal and for a new trial. The motions argued the evidence was insufficient to prove possession and that the government’s references to the nearby shooting were prejudicial. The court found that, viewed in the light most favorable to the government, the circumstantial evidence—including the glove, the exclusive control over the seat, and his actions toward the floor—was sufficient for a reasonable jury to find constructive possession beyond a reasonable doubt.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the evidence supported the jury’s verdict of constructive possession under 18 U.S.C. § 922(g)(1). The appellate court affirmed that the district court correctly denied both the judgment of acquittal and the new trial motion, finding no miscarriage of justice or erroneous result. The court also affirmed the revocation of the defendant’s supervised release, as the evidence met the preponderance standard. The convictions and the revocation of supervised release were affirmed. View "United States v. Abercrombie" on Justia Law

Congress enacted a law in 2025 that withholds Medicaid funding for one year from certain abortion providers that meet four criteria, which in effect covers most Planned Parenthood affiliates and two other organizations. The statute also withholds funding from subsidiaries, successors, clinics, and “affiliates” of such entities, even if those affiliates do not themselves meet all four criteria. Some Planned Parenthood entities qualified for defunding under the law (“Qualifying Members”), while others did not (“Non-Qualifying Members”), but the latter still risked losing funding due to the ambiguous “affiliate” provision. Concerned about the impact on their ability to provide healthcare, Planned Parenthood Federation of America, a Qualifying Member, and a Non-Qualifying Member sued to enjoin enforcement, alleging the law was an unconstitutional bill of attainder, imposed unconstitutional conditions on their right of association, and violated equal protection.The United States District Court for the District of Massachusetts granted a temporary restraining order and then preliminary injunctions, finding that the plaintiffs were likely to succeed on all three claims. The court reasoned that the law punished Planned Parenthood in violation of the Bill of Attainder Clause, impermissibly conditioned Medicaid funding on disassociation from other affiliates in violation of the First Amendment, and failed equal protection review because it targeted Planned Parenthood for its associations. The government appealed these orders.The United States Court of Appeals for the First Circuit vacated the district court’s orders. The court held that the statute did not inflict punishment as understood in bill of attainder case law, but instead established new conditions prospectively on Medicaid funding. The court also held that the “affiliate” provision is best read to cover only entities under common corporate control, avoiding constitutional problems, and thus does not burden associational rights. Finally, the court found that the law is subject only to rational basis review and is rationally related to Congress’s objectives. The preliminary injunctions were vacated and the case remanded. View "Planned Parenthood Federation of America, Inc. v. Kennedy" on Justia Law

In March 1997, James Garrey was involved in a fatal altercation at a bar in Franklin, Massachusetts, where he stabbed and killed Corey Skog following a dispute. Garrey, who is white, was later convicted of first-degree murder by a Massachusetts jury and sentenced to life imprisonment. During jury selection, the prosecution exercised a peremptory strike to remove a minority-race juror, Juror 6-7. Garrey objected, arguing the strike was improper and motivated by race, referencing Batson v. Kentucky and Powers v. Ohio. The trial judge allowed the strike after the prosecutor cited the juror’s occupation as a guidance counselor as the reason, not her race.Garrey appealed his conviction to the Massachusetts Supreme Judicial Court (SJC), asserting that the trial judge erred by accepting the prosecutor’s justification and by referencing the lack of minority participants in the trial. The SJC affirmed the conviction, finding the prosecutor’s explanation sufficient and not pretextual, and that the trial judge did not improperly rely on racial considerations. Garrey’s subsequent motions for a new trial in state court were denied.He then petitioned the United States District Court for the District of Massachusetts for habeas corpus relief under 28 U.S.C. § 2254, alleging Batson and Powers errors and unreasonable factual findings by the SJC. The District Court denied relief, concluding the SJC’s application of federal law and findings were not unreasonable.On appeal, the United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the District Court. The First Circuit held that the SJC did not unreasonably determine the facts or misapply clearly established federal law under Batson or Powers, and found the prosecutor’s rationale and the trial court’s process constitutionally sufficient. The judgment denying habeas relief was affirmed. View "Garrey v. Kelly" on Justia Law

A dispute arose between two siblings, Wayne Orkin and Lisa Albert, over the operation and ownership of a business called Boost Web SEO, Inc. Orkin managed the day-to-day business and generated all of its revenue, while Albert incorporated the company and was listed as its registered agent and officer. No written agreements clarified their roles, profit sharing, or compensation. In 2014, residual income from a payment processing arrangement was assigned to Boost Web, which both parties treated as company revenue for years. In 2021, after a breakdown in their relationship, Albert cut Orkin’s access to company funds and accused him of fraudulent activities in communications with a third-party vendor. Orkin then redirected company revenues to an account he controlled, prompting legal action.The litigation began in Massachusetts Superior Court, where Orkin (and his father) sued Albert and her son for various state-law claims, and Albert removed the case to the U.S. District Court for the District of Massachusetts. Boost Web intervened with a crossclaim against Orkin. After partial summary judgment, the remaining claims—Orkin’s defamation and related claims against Albert, and Boost Web’s conversion claim against Orkin—proceeded to a bench trial. The district court ruled for Albert on the defamation claim, finding her email was not defamatory or was protected as true, and for Boost Web on conversion, awarding it damages for funds Orkin took as personal expenses and for redirected residuals. The court also found Orkin in contempt for interfering with its orders and permanently enjoined him from pursuing related litigation in Florida.The United States Court of Appeals for the First Circuit reviewed the case. It held that the district court erred in dismissing Orkin’s defamation claim, finding that Albert’s email could be defamatory per se and remanded for further proceedings on truthfulness. It affirmed the conversion judgment regarding the redirected residuals but vacated the judgment concerning personal expenses, holding that Orkin was entitled to some compensation and remanded to determine the appropriate amount. The court vacated the contempt order and the permanent injunction, finding the previous orders did not unambiguously decide Boost Web’s ownership. The case was remanded for further proceedings consistent with these holdings. View "Orkin v. Albert" on Justia Law

The case concerns an engineer who worked for a microchip design company. While employed, he downloaded proprietary design files, including a file for a microchip known as the HMC1022A, and retained them after leaving his employer. Shortly after his departure, he started a competing business that marketed and sold microchips bearing strong similarities to his former employer’s products, using some of the appropriated design files in the manufacturing process. He concealed the origins of these files by renaming them and sought to keep his new business secret from his former employer.A federal grand jury indicted him on a range of charges, including possession of stolen trade secrets, wire fraud, export violations, visa fraud, and unlawful procurement of citizenship. The United States District Court for the District of Massachusetts presided over the jury trial. The defendant was convicted on only one count: unlawful possession of a trade secret, specifically the design layout and GDS file for the HMC1022A microchip. He was acquitted of all other charges, and the court dismissed related charges against his business partner and spouse. Post-trial, the defendant moved to dismiss the indictment, arguing selective enforcement and prosecution on the basis of his Chinese ethnicity, but the district court denied these motions.Upon review, the United States Court of Appeals for the First Circuit affirmed the conviction. The court held that there was sufficient evidence for a reasonable jury to find that the file in question was both a trade secret and that the defendant knew it to be so. The court also affirmed the district court’s rejection of the selective prosecution and enforcement claims, determining that the defendant had not shown similarly situated individuals of a different race were treated differently, nor that the investigation or prosecution was motivated by discriminatory purpose. The conviction and sentence were therefore upheld. View "United States v. Yu" on Justia Law