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

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The First Circuit affirmed the judgment of the district court denying Defendant's motion to suppress approximately twenty pounds of methamphetamine that a postal inspector delivered in two United States Postal Service Priority Mail Express packages, as well as the fruits of the packages' search, holding that the warrant authorizing one package's search was valid and that the warrantless search of the other package was constitutional. The district court assumed arguendo that Defendant held a reasonable expectation of privacy in the searched packages then concluded that neither search was unconstitutional. The First Circuit affirmed, holding (1) the warrant authorizing the search of one package was not facially invalid despite the government's attachment of the incorrect attachment because the error was a mere technical error and the package was described with sufficient particularity and there was no reasonable probability of another package being searched; and (2) the warrantless search of the second package was justified by both the private search doctrine and the consent of the package's addressee. View "United States v. Moss" on Justia Law

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The First Circuit affirmed the dismissal of Appellants' suit for declaratory and injunctive relief in federal court against the FBI seeking an order directing the FBI to upload a DNA profile to the national DNA database and to report the results, holding that the FBI's determination that the profile was ineligible for upload was not arbitrary or capricious. Appellant were convicted of murder and spent twenty years incarcerated. Appellants were granted a new trial after new testing of trial evidence cast doubt on the verdicts. Thereafter, DNA testing was conducted on a swab taken from the inside of a condom recovered in the vicinity of the victim during the initial investigation. The testing revealed an unknown male DNA profile. The FBI refused to upload the profile into the National DNA Index System, determining that it was ineligible for upload. Appellants then filed this suit seeking to compel the FBI to upload the profile. The district court dismissed the suit, concluding that the FBI's eligibility determination was unreviewable. The First Circuit affirmed, holding that, assuming that the FBI's eligibility determination was reviewable, the determination was not arbitrary and capricious. View "Cowels v. Federal Bureau of Investigation" on Justia Law

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The First Circuit affirmed the order of the district court granting summary judgment in favor of Defendant on Plaintiff's Age Discrimination in Employment Act (ADEA) claim regarding the termination of Plaintiff's employment, holding that the totality of the circumstances showed a lack of foundation for Plaintiff's pretextual argument. In granting Defendant's motion for summary judgment, the district court determined that the evidence did not support Plaintiff's argument that Defendant's articulated reason for terminating Plaintiff's employment was pretextual, let alone a pretext for age discrimination. The First Circuit affirmed, holding the district court did not misapply the summary judgment standard or err in holding that no reasonable fact-finder could determine that Defendant's reasons for terminating Plaintiff were pretextual. View "Rodriguez-Cardi v. MMM Holdings, Inc." on Justia Law

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In this action brought by parents of a severely disabled student against the school district alleging federal and statement claims the First Circuit vacated the district court's entry of judgment for the school district on Plaintiffs' federal claims on the basis that they were subject to the exhaustion requirement set forth in the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400-1491o, holding that no further administrative pursuit was required for the claims. Plaintiffs' federal claims claims included a Rehabilitation Act claim and a substantive due process claim under 42 U.S.C. 1983. The district court granted the school district's motion for judgment on the pleadings as to Plaintiffs' federal claims and remanded the state law claims to state court, concluding that the federal claims were subject to the IDEA's exhaustion requirement. The First Circuit vacated that decision, holding (1) the gravamen of Plaintiffs' Rehabilitation Act claim did not involve the denial of a free appropriate public education, and therefore, that claim was not subject to the exhaustion requirement of the IDEA; and (2) Plaintiffs' section 1983 claim was either exhausted or continued engagement with the IDEA's administrative scheme would have been futile. View "Doucette v. Georgetown Public Schools" on Justia Law

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In this insurance dispute, the First Circuit remanded the case for additional factfinding, holding that where the record was conflicted as to whether there was complete diversity of citizenship when the action was commenced, remand was required. Appellants were two affiliated insureds who owned and operated a commercial bakery in Pittsfield, Massachusetts. Appellee, their insurer, had in effect a commercial business insurance policy covering the bakery. When a pipe erupted in the bakery, causing covered losses, the parties were unable to settle the ensuing insurance claims. Appellants commenced a civil action against Appellee in the United States District Court for the District of Massachusetts, invoking federal diversity jurisdiction and alleging that complete diversity existed between the parties. The magistrate judge ultimately granted Appellee's motion for summary judgment. The First Circuit noted a jurisdictional hurdle and remanded the case, holding that remand was required for the district court to determine whether there was complete diversity between the parties at the time the action was commenced. View "Bearbones, Inc. v. Peerless Indemnity Insurance Co." on Justia Law

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The First Circuit vacated the district court's dismissal of Appellant's sexual harassment claims based on a hostile work environment, holding that the district court erred in concluding that alleged incidents of harassment that occurred earlier than 2014 were time-barred and that the error contributed to other flaws in the court's analysis. Appellant brought this action claiming sexual harassment and retaliation under both Title VII of the Civil Rights Act and Puerto Rico Commonwealth law. Defendant asserted that he was sexually harassed for more than a decade and thus subjected to a hostile work environment and that managers at his workplace retaliated against him for complaining about this treatment. The district court granted summary judgment for Defendant on all claims. The First Circuit remanded the case, holding (1) the district court did not err in dismissing the retaliation claims; but (2) a jury could reasonably find that incidents that allegedly occurred in 2014 were instances within the limitations period of a claimed pattern of sexually charged interactions, and the court's statute-of-limitations error necessarily impacted its assessment of the hostile work environment claim. View "Nieves-Borges v. El Conquistador Partnership, L.P." on Justia Law

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The First Circuit affirmed the judgment of the district court dismissing Plaintiff's complaint against three Maine prison officials and denying Plaintiff's motion for leave to amend, holding that the district court did not abuse its discretion in rejecting as futile Plaintiff's motion for leave to file her amended complaint. Plaintiff's complaint alleged federal constitutional violations, a civil rights conspiracy, and supplementary state law claims. The district court dismissed the complaint, concluding that the complaint did not state any plausible claims against the defendants. Plaintiff then moved for reconsideration and for leave to amend. The district court denied both motions and entered a final judgment in favor of Defendants, concluding that allowing the motion to amend would be futile because the proposed amended complaint failed to state any plausible claims for relief. The First Circuit affirmed, holding that the facts alleged in Plaintiff's proposed amended complaint were insufficient to make out plausible claims of either supervisory liability or civil rights conspiracy against Defendants. View "Parker v. Landry" on Justia Law

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The First Circuit reversed the judgment of the district court finding that Local 402 never requested to appeal its deactivation to the International Executive Board (IEB) and that it failed to prove that it was deactivated in retaliation for having exercised its free-speech rights, holding that Local 402 did request an appeal to the IEB. Local 402, which was an affiliate of Council 93, which was created by the American Federation of State, County and Municipal Employees (AFSCME) represented Massachusetts Department of Developmental Services (DDS) employees in Waltham, Massachusetts. In 2017, Local 402 was deactivated. Local 402 later filed suit against Council 93 and AFSCME alleging three claims. The district court granted summary judgment for Local 402 for one count but ruled in favor of Council 93 as to the remaining counts. Local 402 filed a notice of appeal, but the district court held that Local 402 did not preserve its appeal rights. The First Circuit reversed, holding that Local 402 exercised its right to appeal to the IEB. View "Conille v. AFSCME, Council 93" on Justia Law

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In this lawsuit alleging that Verizon Wireless violated the Telephone Consumer Protection Act (TCPA), 47 U.S.C. 227, the First Circuit affirmed the district court's denial of Verizon's motion to compel arbitration but reversed the court's grant of summary judgment in Verizon's favor, holding that the district court erred in concluding that Plaintiff's TCPA claims failed as a matter of law because her telephone number was not assigned to a cellular telephone service. In her complaint, Plaintiff claimed that Verizon's unauthorized, automated calls to her cellular telephone violated the TCPA. The district court concluded that Plaintiff's telephone number was not assigned to a cellular telephone service within the meaning of the relevant provision of the TCPA and granted summary judgment to Verizon. The First Circuit reversed, holding (1) the district court correctly denied Verizon's motion to compel arbitration; but (2) in concluding that Plaintiff's number was not assigned to a cellular telephone service the district court failed to consider the hybrid nature of Plaintiff's telephone service with Republic Wireless and erred in treating other facts as dispositive. View "Breda v. Cellco Partnership" on Justia Law

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The First Circuit denied Petitioner for review of a Board of Immigration Appeals (BIA) order affirming the immigration judge's (IJ) denial of his applications for asylum, withholding of removal, and protection under the Convention Against Torture (CAT), holding that the BIA did not err in concluding that Petitioner was ineligible for asylum, and Petitioner's remaining claims were likewise unavailing. The IJ concluded that Petitioner was ineligible for asylum because he lacked membership in a cognizable "particular social group." The BIA reached the same conclusion. The First Circuit affirmed, holding (1) the BIA did not err in concluding that Petitioner was ineligible for asylum because he lacked membership in a cognizable "particular social group"; (2) resolution of Petitioner's asylum claim also disposed of Petitioner's withholding of removal claim; and (3) substantial evidence in the record supported the BIA's finding that Petitioner was not entitled to protection under the CAT. View "Ramirez-Perez v. Barr" on Justia Law