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

The First Circuit affirmed the grant of summary judgment to Ocwen Loan Servicing, LLC in Josephine Donahue's suit against Ocwen and the Government National Mortgage Association (GNMA), holding that summary judgment was properly granted on the only claim at issue here.Donahue executed a mortgage for her home that was assigned to Ocwen. Donahue later defaulted on the mortgage. Ocwen held a foreclosure auction and was the highest bidder. Donahue subsequently field suit against GNMA and Ocwen, alleging three counts. The district court granted summary judgment to Ocwen on all claims but did not address Donahue's still-pending claims against GNMA. Donahue appealed, seeking review of only the grant of summary judgment to Ocwen on Count III of her complaint. Donahue subsequently dismissed her claims against GNMA. The First Circuit affirmed, holding (1) the prudent course is to assume appellate jurisdiction, despite the parties' disagreement as to whether this Court has appellate jurisdiction, given how clear the merits are; and (2) there was no disputed fact precluding summary judgment on the only claim at issue here. View "Donahue v. Federal National Mortgage Ass'n" on Justia Law

The First Circuit held that Students for Fair Admissions, Inc. (SFFA) had associational standing to bring its claims against the President and Fellows of Harvard College and the Board of Overseers (collectively, Harvard) and that Harvard's race-conscious undergraduate admissions program does not violate Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d et seq.In its suit, SFFA alleged that Harvard's race-conscious admissions processed violated Title VI by discriminating against Asian American applicants in favor of white applicants. SFFA sought a declaratory judgment, injunctive relief, attorneys' fees and costs. The district court denied Harvard's motion to dismiss for lack of standing and then found that Harvard had met its burden of showing its admissions process did not violate Title VI. The First Circuit affirmed, holding (1) SFFA had associational standing to bring its claims; and (2) under governing Supreme Court law, Harvard's admissions program does not violate Title VI. View "Students for Fair Admissions v. President & Fellows of Harvard College" on Justia Law

The First Circuit affirmed Defendant's conviction for conspiracy to possess with intent to distribute heroin, entered pursuant to a guilty plea, holding that the district court did not err in accepting Defendant's plea.On appeal, Defendant argued that the district court failed to determine that there was a factual basis for his guilty plea, as required by Fed. R. Crim. P. 11(b)(3). The First Circuit disagreed, holding that Defendant's admission to participating in a conspiracy that involved at least one other person provided a reasoned basis to believe that he was guilty of conspiracy and that Defendant could not show that the district court's acceptance of his plea prejudiced him. View "United States v. Delarosa Arias" on Justia Law

The First Circuit denied Petitioner's petition for review of the final decision of the Federal Motor Carrier Safety Administration (the FMSCA) determining that Sorreda Transport, LLC's business safety rating was unsatisfactory, holding that the the FMSCA's findings and conclusions were supported by substantial evidence in the record and its decision denying Sorreda's petition for review was not arbitrary or capricious.After the FMSCA, an agency within the United States Department of Transportation that regulates the trucking industry, used a notice informing Sorreda of its proposed unsatisfactory rating, Sorreda appealed. The FMSCA issued a final order denying Sorreda's petition for administrative review. Sorreda then filed a timely petition for review in the First Circuit. The First Circuit denied the petition, holding that the FMSCA's findings were supported by substantial evidence and that its determination that Sorreda's business safety rating was unsatisfactory was neither arbitrary nor capricious under the applicable regulations. View "Sorreda Transport, LLC v. United States Department of Transportation" on Justia Law

In this case, the First Circuit held that a viable substantive due process state-created danger claim was presented against two Maine State Police officers and that the district court erred in granting the officers' summary judgment motion on qualified immunity grounds.This 42 U.S.C. 1983 action arose out of the attacks, murder, and rapes committed in 2015 by Anthony Lord against Brittany Irish and those close to her (Plaintiffs) after actions and inactions by the defendant officers. Plaintiffs sought relief based on the state-created substantive due process danger doctrine, under which officers may be held liable for failing to protect plaintiffs from danger created or enhanced by their affirmative acts. The district court granted summary judgment to the officers on the grounds of qualified immunity. The First Circuit (1) affirmed the district court's ruling that a jury could find that the officers violated Plaintiffs' substantive due process rights; and (2) reversed the grant of Defendants' summary judgment motion on qualified immunity grounds, holding that a reasonable jury could conclude that the facts of this case could give rise to a constitutional violation under the state-created danger doctrine. View "Irish v. Fowler" on Justia Law

The First Circuit affirmed Defendant's sentence for two counts of production of child pornography and two counts of transportation of a minor with the intent to engage in criminal activity, holding that the sentence was substantively reasonable.Defendant pleaded guilty, and his plea agreement tentatively calculated a prison term of 210 to 262 months. The district court made its own calculations, resulting in a proposed sentence of between 324 and 405 months. The court then granted Defendant a downward variance and sentenced him to a prison term of 300 months. On appeal, Defendant argued that the district court abused its discretion by impermissibly balancing the sentencing pros and cons. The First Circuit affirmed, holding that, taking into account the totality of the circumstances, the district court did not abuse its discretion. View "United States v. Jurado-Nazario" on Justia Law

The First Circuit affirmed the order of the federal district court allowing Rhode Island's motion to return to state court its state court complaint against several oil and gas companies for damage caused by fossil fuels, holding that the allegations in Rhode Island's complaint did not give rise to federal-officer jurisdiction.In 2018, faced with rising sea levels and other property damage from extreme weather events caused by climate change, Rhode Island sued, in state court, several oil and gas companies for damage caused by fossil fuels while those companies misled the public about their products' true risks. The oil companies removed the case to federal district court. Rhode Island moved for the case to be remanded to state court. The district court granted the motion and ordered the case remanded to state court. The First Circuit affirmed, holding that the district court did not err in finding that there was no subject matter jurisdiction under the federal-officer removal statute. View "State of Rhode Island v. Shell Oil Products Co., LLC" on Justia Law

The First Circuit affirmed the judgment of the district court granting judgment to the Commissioner of the Maine Department of Education in this federal constitutional challenge to the requirement of Maine's tuition assistance program that a private school must be "a nonsectarian school in accordance with the First Amendment" to qualify as "approved" to receive tuition assistance payments, holding that the program's condition violated neither the Free Exercise Clause nor the Establishment Clause.To ensure that Maine's school administrative units (SAUs) make the benefits of a free public education available Maine provides by statute that SAUs that do not operate a public secondary school of their own may either contract with a secondary school for school privileges or pay the tuition at the public school or an approved private school at which the student from their SAU is accepted. Plaintiffs brought this suit against the Commissioner, arguing that the program's requirement that a private school be a nonsectarian school to receive tuition assistance payments infringed various of their federal constitutional rights. The district court granted judgment to the Commissioner. Having twice before rejected similar federal constitutional challenges to the "nonsectarian" requirement and even accounting for fresh United States Supreme Court precedent the First Circuit affirmed, holding that Plaintiffs' constitutional challenges failed. View "Carson v. Makin" on Justia Law

The First Circuit affirmed the district court's dismissal of this complaint alleging that Puerto Rico's series of laws that affect the relationship between public employees in the Commonwealth and their employers impermissibly interfere with their collective bargaining rights, holding that the complaint failed to state a claim upon which relief may be granted.To address Puerto Rico's fiscal criss, the Puerto Rico Legislative Assembly passed the four laws challenged in this case affecting the rights and benefits of public sector workers. Two Puerto Rico unions brought this action alleging that these measures violated the Contract Clause of the United States Constitution and the Collective Bargaining Clause of the Puerto Rico Constitution. The district court dismissed the complaint. The First Circuit affirmed, holding that the district court properly dismissed the complaint for failure to state a claim. View "Hermandad de Empleados v. Financial Oversight & Management Board" on Justia Law

The First Circuit affirmed Defendant's sentence of forty-two months' imprisonment for illegal possession of a machine gun, holding that the sentence was both procedurally and substantively reasonable.On appeal, Defendant argued that the district court erroneously applied a four-level enhancement to his total offense level for possession of a firearm in connection with another felony of drug possession pursuant to U.S.S.G. 2K2.1(b)(6). Specifically, Defendant argued that possession of a firearm in connection with mere drug possession for personal use was insufficient to apply the enhancement. The First Circuit affirmed, holding (1) Defendant was clearly in possession of the firearm in furtherance of drug trafficking under this Court's case law, and therefore, the evidence was sufficient to justify an enhanced sentence for that reason; and (2) Defendant's sentence was substantively reasonable. View "United States v. Reyes-Torres" on Justia Law