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

Residents and the municipality of Morovis, Puerto Rico, brought suit against the Puerto Rico Aqueduct and Sewer Authority (PRASA) and its officials, alleging that for years, Morovis has suffered from a severe water crisis, with many residents lacking water service on most days. The plaintiffs, all PRASA subscribers, claimed that despite repeated notifications and proposed solutions—including a report from the U.S. Army Corps of Engineers—PRASA failed to address the crisis. They alleged that sometimes the outages could be resolved by simply turning on pumps or generators, and that PRASA officials were aware of the situation but did little to provide alternative water sources or adjust billing. The plaintiffs also recounted incidents suggesting deliberate inaction or sabotage by PRASA employees.The United States District Court for the District of Puerto Rico dismissed the case in its entirety at the pleading stage, concluding that the plaintiffs failed to state a claim for a substantive due process violation under the Fourteenth Amendment. The court found that the alleged conduct did not rise to the level of “shocking the conscience,” and also held that the plaintiffs’ contracts with PRASA could not form the basis of a substantive due process claim. The court did not decide whether Puerto Rico law created a protected property interest in water service.On appeal, the United States Court of Appeals for the First Circuit held that the district court erred in dismissing the substantive due process claim. The First Circuit ruled that the plaintiffs plausibly alleged government conduct that could shock the conscience, particularly under a deliberate indifference standard, given the prolonged and severe deprivation of water. The court vacated the district court’s dismissal and remanded for further proceedings, leaving unresolved whether a protected property interest exists and whether qualified immunity applies. View "Maldonado-Gonzalez v. Puerto Rico Aqueduct & Sewer Authority" on Justia Law

In April 2006, an oil tanker owned or operated by Ernst Jacob GmbH & Co. KG and insured by Shipowners Insurance & Guaranty Company, Ltd. ran aground off the coast of Puerto Rico. Although no oil was spilled, the response efforts to free the vessel and prevent a potential spill caused significant damage to coral reefs. The United States, acting through NOAA and in coordination with Puerto Rico’s Department of Natural and Environmental Resources, undertook restoration and assessment of the damaged natural resources. After unsuccessful attempts to secure payment from the responsible parties and their insurers, NOAA sought compensation from the Oil Spill Liability Trust Fund, which paid out restoration and assessment costs. Subsequently, the United States filed suit against the vessel’s owner and insurer to recover both compensated and uncompensated damages for injury to natural resources under the Oil Pollution Act of 1990 (OPA).The United States District Court for the District of Puerto Rico bifurcated the case into liability and damages phases. Without allowing discovery, the District Court granted partial summary judgment to the United States on liability, finding that the Coast Guard’s Federal On-Scene Coordinator (FOSC) had determined the grounding posed a “substantial threat of a discharge of oil,” and that this determination was not arbitrary or capricious. The court applied a deferential standard of review to the FOSC’s decision and did not address whether the damaged natural resources were “managed or controlled” by the United States, as required by OPA.On appeal, the United States Court of Appeals for the First Circuit held that it had jurisdiction under 28 U.S.C. § 1292(a)(3) due to the presence of admiralty claims. The court vacated and reversed the District Court’s grant of summary judgment, holding that liability under OPA requires proof by a preponderance of the evidence, not merely deference to the FOSC’s determination, and remanded for further proceedings, including resolution of whether the United States “manages or controls” the natural resources at issue. View "US v. Ernst Jacob GmbH & Co. KG" on Justia Law

A former U.S. Navy Reserve officer, after serving in Afghanistan, maintained contact with an Afghan businessman who had provided interpreters to U.S. forces. In 2018, the businessman asked the officer to write letters of recommendation for Afghan nationals seeking Special Immigrant Visas (SIVs) to the United States, offering payment in return. The officer agreed, negotiating a price and ultimately producing multiple letters that attested to his personal knowledge of the applicants’ character and service, despite not actually knowing or remembering them. The letters were used in SIV applications, and the officer received payment, which he attempted to disguise as consulting fees through a false invoice.A grand jury in the United States District Court for the District of New Hampshire indicted the officer on four counts: conspiracy to commit bribery and false writing, bribery, false writing, and conspiracy to commit concealment money laundering. At trial, the officer moved for acquittal on the basis of insufficient evidence of falsity in the letters, but the district court denied the motion. The jury convicted him on all counts, and the district court later denied a renewed motion for acquittal, finding sufficient evidence for the jury to conclude the letters contained false statements and that the government was not required to prove falsity for all charges. The court sentenced the officer to thirty months’ imprisonment.On appeal, the United States Court of Appeals for the First Circuit reviewed the sufficiency of the evidence de novo and affirmed the convictions. The court held that there was sufficient evidence for a rational jury to find the letters contained false statements about the applicants’ character and the officer’s personal knowledge. The court also rejected challenges to the bribery and money laundering convictions, finding no clear or obvious error and no impermissible merger of offenses. The convictions and sentence were affirmed in full. View "United States v. Pittmann" on Justia Law

A man experiencing a mental health crisis was fatally shot by police officers in his Newton, Massachusetts apartment building after a report of an attempted armed robbery at a nearby candy store. When officers arrived, the man, holding a kitchen knife, fled into his apartment building. Officers pursued him to the third floor, where he threatened self-harm and engaged in erratic behavior. Police attempted to negotiate with him for about twenty minutes, eventually convincing him to drop the knife and a fire extinguisher. As officers prepared to incapacitate him with a beanbag shotgun, the weapon malfunctioned. Some officers reported that the man then picked up the knife and moved toward them, prompting two officers to fire their sidearms, resulting in his death.The decedent’s parents, acting as representatives of his estate, filed suit in the United States District Court for the District of Massachusetts against the City of Newton and several police officers. They alleged excessive force under 42 U.S.C. § 1983, violations of the Americans with Disabilities Act (ADA) and the Rehabilitation Act, and various state law claims. The district court dismissed all claims, finding the officers were entitled to qualified immunity and that the plaintiffs had not sufficiently pleaded municipal liability or viable claims under the ADA or state law.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s dismissal de novo. The First Circuit affirmed the dismissal of all claims except the § 1983 excessive force claim against the officers related to the fatal shooting. The court held that, at the pleading stage, there were disputed material facts regarding whether the decedent was armed and posed an immediate threat when lethal force was used. The judgment was vacated as to this claim and remanded for further proceedings; all other dismissals were affirmed. View "Conlon v. Scaltreto" on Justia Law

During the 2023–2024 academic year, students at a private university in Massachusetts engaged in a series of pro-Palestinian protests following violence in the Middle East. The protests included rallies, walkouts, chalk messages, and an encampment near the campus Hillel center. Some Jewish and Israeli students reported feeling unsafe or unwelcome, and a few specific incidents were alleged, such as being blocked from campus areas or subjected to hostile remarks. The university responded by revising protest policies, suspending student groups, and eventually clearing the encampment, but did not discipline all protestors or end the demonstrations immediately.The United States District Court for the District of Massachusetts dismissed the plaintiffs’ suit, which alleged violations of Title VI of the Civil Rights Act, the Ku Klux Klan Act, and state law, for failure to state a claim. The court found that the plaintiffs had not plausibly alleged actionable harassment or that the university was deliberately indifferent to any such harassment. The court also declined to exercise supplemental jurisdiction over the state-law claims.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The First Circuit held that most of the protestors’ conduct constituted protected speech under the First Amendment and did not amount to actionable harassment under Title VI. The court further found that the university was not deliberately indifferent, as it took a series of escalating actions in response to the protests. The court also concluded that the plaintiffs failed to state a claim under the Ku Klux Klan Act because they did not plausibly allege a conspiracy with the purpose of depriving Jewish or Israeli students of their rights. The dismissal of the state-law claims was affirmed, and the court found no abuse of discretion in denying further leave to amend the complaint. View "StandWithUs Center for Legal Justice v. MIT" on Justia Law

Puerto Rico Telephone Company (PRTC) sought to confirm an arbitration award against WorldNet Telecommunications in federal court under section 9 of the Federal Arbitration Act (FAA). PRTC relied on then-existing First Circuit precedent, which allowed federal courts to exercise subject-matter jurisdiction over such applications if the underlying dispute involved a federal question. After the district court dismissed PRTC’s action for lack of Article III standing, PRTC appealed.The United States District Court for the District of Puerto Rico dismissed the case, finding that PRTC had not shown the necessary injury-in-fact to establish standing under Article III of the Constitution. PRTC then appealed to the United States Court of Appeals for the First Circuit. While the appeal was pending, the United States Supreme Court decided Badgerow v. Walters, which held that federal courts lack subject-matter jurisdiction over applications to confirm or vacate arbitration awards under sections 9 and 10 of the FAA, except in circumstances not present in this case. PRTC requested that the First Circuit vacate the district court’s judgment and direct dismissal without prejudice for lack of subject-matter jurisdiction, so that PRTC could pursue relief in the Commonwealth courts. WorldNet argued that the First Circuit should instead affirm the district court’s dismissal on standing grounds.The United States Court of Appeals for the First Circuit held that, in light of Badgerow v. Walters, federal courts do not have subject-matter jurisdiction over PRTC’s application to confirm the arbitration award under section 9 of the FAA. The First Circuit vacated the district court’s judgment and remanded with instructions to dismiss the case without prejudice for lack of subject-matter jurisdiction. The court did not address the standing issue. View "Puerto Rico Telephone Co. v. Worldnet Telecommunications, LLC" on Justia Law

In late 2020 and early 2021, Massachusetts law enforcement investigated a suspected drug trafficking organization operating in the South Shore area. The investigation focused on two apartments believed to be used for storing and distributing drugs, and a blue Jeep Grand Cherokee linked to the organization. On January 11, 2021, officers executed state search warrants at both apartments, recovering large quantities of narcotics, cash, firearms, and drug-trafficking equipment. Earlier that day, officers conducted a warrantless stop of the Jeep, driven by Aderito Patrick Amado, and found additional drugs and cash. Amado was charged with conspiracy to possess with intent to distribute fentanyl, fentanyl analogue, and cocaine; three counts of possession with intent to distribute those substances; two counts of being a felon in possession of firearms; and one count of possessing firearms in furtherance of drug trafficking.The United States District Court for the District of Massachusetts denied Amado’s motion to suppress evidence from the Jeep, finding that officers had reasonable suspicion for the stop. After a nine-day trial, a jury convicted Amado on all counts except one firearm-in-furtherance charge. The district court sentenced him to a total of 384 months’ imprisonment, within the advisory Guidelines range, and ten years of supervised release. Amado appealed, challenging the denial of his suppression motion, the application of an obstruction-of-justice enhancement, his designation as a career offender, and the substantive reasonableness of his sentence compared to a co-defendant’s shorter term.The United States Court of Appeals for the First Circuit affirmed the district court’s rulings. The court held that reasonable suspicion supported the stop of the Jeep, the obstruction-of-justice enhancement was warranted due to Amado’s perjury at trial, and the career-offender designation was proper and did not affect the advisory range. The court also found no substantive sentencing error, noting material differences between Amado and his co-defendant. The convictions and sentence were affirmed. View "United States v. Amado" on Justia Law

A management company brought suit in federal court against a contractor and its surety, seeking to recover financial losses allegedly suffered by several subcontractors after the contractor and surety failed to pay for work performed on post-hurricane rebuilding projects in Puerto Rico and the Virgin Islands. The management company’s claims were based on assignments it had received from the subcontractors, who were not themselves parties to the suit. The complaint asserted that federal diversity jurisdiction existed because the management company was completely diverse from the defendants and the amount in controversy exceeded $75,000.The United States District Court for the District of Puerto Rico stayed the case, requiring the plaintiff to pursue certain remedies in local courts first. On appeal, the United States Court of Appeals for the First Circuit identified a potential jurisdictional defect: the complaint did not allege the citizenship of the subcontractors, whose assignments formed the basis of the claims. The appellate court remanded the case to the district court to determine whether the subcontractors were completely diverse from the defendants and whether the assignments were collusive attempts to manufacture federal jurisdiction.After remand, the district court found that the plaintiff had failed to provide sufficient evidence to establish the subcontractors’ citizenship or to show that the assignments were not collusive. The First Circuit held that the plaintiff, as the party invoking federal jurisdiction, bore the burden of establishing complete diversity and the validity of the assignments for jurisdictional purposes. Because the plaintiff failed to meet this burden, the First Circuit remanded with instructions to dismiss the complaint for lack of subject matter jurisdiction. Costs were awarded to the appellees. View "Gore and Assoc. Mgmt. Co., Inc. v. SLSCO Ltd." on Justia Law

Víctor Miguel Duluc-Méndez was convicted for his role in a 2013 carjacking in Puerto Rico that resulted in the death of the vehicle’s driver. Duluc and a juvenile accomplice forcibly took a car, detained the driver, withdrew money from his account, and later, the juvenile fatally shot the driver. Duluc was apprehended shortly after and admitted to the carjacking, though he denied knowledge of the juvenile’s intent to kill. He pleaded guilty to the carjacking charge, and the United States District Court for the District of Puerto Rico sentenced him to 240 months in prison.After serving about ten years, Duluc moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing his mother’s deteriorating health and his siblings’ inability to care for her, supported by letters from his family. He also emphasized his substantial post-conviction rehabilitation, including completion of over a thousand hours of programming, leadership roles, and strong recommendations from prison staff and fellow inmates. The government opposed the motion, arguing that Duluc had not shown he was the only available caregiver and that rehabilitation alone was insufficient for compassionate release. The district court denied the motion in a brief order, finding Duluc’s family circumstances unconvincing and citing his criminal record, without addressing his rehabilitation arguments.The United States Court of Appeals for the First Circuit reviewed the denial. The court held that the district court abused its discretion by failing to consider Duluc’s argument that his rehabilitation, combined with his family circumstances, could constitute “extraordinary and compelling reasons” for release. The appellate court vacated the district court’s order and remanded the case for further proceedings, instructing the lower court to consider Duluc’s rehabilitation in its analysis. View "United States v. Duluc-Mendez" on Justia Law

A husband and wife brought a lawsuit after the wife suffered a pelvic fracture during a forceps-assisted delivery performed by a doctor at a women’s health group. They alleged that the doctor failed to obtain the wife’s informed consent by not disclosing the risks associated with the procedure. The plaintiffs claimed that this omission violated Massachusetts law and sought damages for the resulting injury.The United States District Court for the District of Massachusetts handled the case initially. During pretrial proceedings, the defendants moved to strike the plaintiffs’ expert witnesses, arguing that the plaintiffs had not made their experts available for deposition as required by the Federal Rules of Civil Procedure. The plaintiffs did not respond to this motion, and the District Court granted it, excluding the expert testimony. The plaintiffs later failed to appear at a pretrial conference, citing email issues, and only addressed the missed conference, not the exclusion of their experts. The District Court declined to vacate its order striking the experts, finding the plaintiffs’ delay and lack of explanation unjustified. Subsequently, the District Court granted summary judgment to the defendants, concluding that expert testimony was necessary to support the informed consent claim under Massachusetts law.On appeal, the United States Court of Appeals for the First Circuit reviewed the District Court’s decisions. The appellate court held that the District Court did not abuse its discretion in refusing to reconsider the order striking the expert witnesses, given the plaintiffs’ prolonged inaction and failure to address the underlying issues. The First Circuit also held that, under Massachusetts law, expert testimony was required to establish that the risk of pelvic fracture from a forceps-assisted delivery was more than negligible, and thus, summary judgment for the defendants was appropriate. The judgment of the District Court was affirmed. View "Meka v. Haddad" on Justia Law