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

A law firm and one of its clients challenged Maine’s Interest on Lawyers’ Trust Accounts (IOLTA) program, which requires attorneys to deposit certain client funds into pooled, interest-bearing accounts. The interest generated is collected by a nonprofit, the Maine Justice Foundation, and distributed to organizations supporting access to justice in Maine. The plaintiffs argued that being compelled to participate in the program forced them to subsidize advocacy with which they disagreed, violating their First and Fourteenth Amendment rights.The United States District Court for the District of Maine dismissed the claims against the Chief Justice of the Maine Supreme Judicial Court and the State Court Administrator on the merits, concluding that the plaintiffs failed to state a claim. Specifically, the District Court found that, under Maine’s rules, only client funds that could not generate net interest for the client (due to the amount or duration) are required to be deposited in IOLTA accounts, and the plaintiffs did not plausibly allege otherwise. The claim against the Maine Justice Foundation was dismissed for lack of jurisdiction, as the Foundation neither promulgates nor enforces the challenged rule.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s rulings. The appellate court held that the plaintiffs failed to plausibly allege they were compelled to deposit funds that would have generated net interest for the client, as required to make out a compelled-speech claim under controlling precedent. The court also found that any appeal of the dismissal against the Maine Justice Foundation was moot, since the complaint was fatally deficient regardless of the defendant. Thus, the First Circuit affirmed the judgment of the District Court. View "Wescott v. Stanfill" on Justia Law

The case concerns a defendant who, after previously being convicted of possessing child pornography and serving a prison sentence followed by supervised release, was found during his supervision with additional devices containing child sexual abuse material (CSAM). The defendant, Kevin Lee Ross, was subject to conditions including restrictions on his internet use, device monitoring, and random searches. During his term of supervised release, a tip from his brother led probation officers to search his residence and vehicle, where they discovered a cell phone, laptop, and external hard drive, all containing a large quantity of CSAM. Ross denied knowledge of the devices and their contents.A grand jury in the United States District Court for the District of Maine indicted Ross for possessing child pornography across three devices. At trial, Ross stipulated that certain exhibits contained child pornography as legally defined. Despite this, the government introduced and published nine representative exhibits to the jury and had a special agent describe their contents. Ross objected, arguing that, due to the stipulation, displaying the images and providing descriptions was unfairly prejudicial under Federal Rule of Evidence 403. The district court overruled his objections, relying on precedent that allows the government to present its evidence even where a defendant is willing to stipulate to certain elements. The jury convicted Ross.On appeal to the United States Court of Appeals for the First Circuit, Ross argued that the district court abused its discretion by allowing the publication and description of the CSAM exhibits in light of the stipulation. The First Circuit held that the district court did not abuse its discretion, finding that the evidence remained probative to issues of possession and knowledge, especially since Ross denied knowing the contents of the devices. The court affirmed Ross’s conviction. View "US v. Ross" on Justia Law

Two former police officers sued their employer, the Puerto Rico Police Department, alleging illegal retaliation after one reported age discrimination to the Equal Employment Opportunity Commission and the other testified in support. The plaintiffs claimed that, as a result, they suffered adverse employment actions such as dangerous shift changes, loss of duties, and fabricated complaints. The challenged conduct primarily occurred after Puerto Rico filed for financial reorganization under PROMESA, a federal statute enacted in response to the Commonwealth’s fiscal crisis.The United States District Court for the District of Puerto Rico presided over the case while Puerto Rico’s reorganization plan was pending in the Title III court. After the reorganization plan’s "Effective Date" passed, and while the plaintiffs’ suit was ongoing, the Department asserted that the claims had been discharged under the plan because the plaintiffs had not timely filed proofs of claim. The District Court agreed, permanently stayed the case, and enjoined the plaintiffs from pursuing their claims, finding that the claims must have arisen at least in part before the plan’s Effective Date since the suit was filed prior to that date. The District Court did not address the plaintiffs' judicial estoppel argument or their contention that post-petition claims were not dischargeable.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s judgment, but on different grounds. The appellate court held that the plaintiffs’ retaliation claims qualified as administrative expense claims under PROMESA (via incorporation of the Bankruptcy Code), and because the plaintiffs did not timely file such claims before the administrative claims bar date, they were discharged by the plan. The court also rejected the plaintiffs' judicial estoppel argument, finding no inconsistency in the Department’s litigation positions. The First Circuit’s judgment affirmed the permanent stay and injunction. View "Villalobos-Santana v. PR Police Department" on Justia Law

Two brothers operated an energy-conservation contracting business and, beginning in 2013, engaged in a bribery scheme involving the Mass Save program, a state-mandated initiative to promote energy efficiency. One brother owned CAP Electric, Inc., and recruited the other to establish Air Tight Solutions, LLC as a Mass Save contractor with the assistance of a CLEAResult employee, who was responsible for selecting and overseeing contractors. The brothers paid this employee, and later another, regular bribes in cash and gifts to secure contracts, favorable treatment, and advance warning of audits. Air Tight performed little or no work directly, subcontracted projects, and disguised employees and payments to conceal the scheme. Over several years, their companies received multi-million dollar payments from the program.The United States District Court for the District of Massachusetts accepted their guilty pleas to conspiracy, honest-services wire fraud, making false statements, and (for one brother) aiding and assisting false tax returns. The district judge sentenced both to 27 months in prison (above-guidelines for one), and ordered forfeiture of $13.2 million and $3.6 million respectively. The brothers challenged the sentences and forfeitures on several grounds, including alleged errors in calculating tax loss, application of sentencing enhancements, and the process and proportionality of the forfeiture orders.The United States Court of Appeals for the First Circuit reviewed the case. It held that the district court did not err in calculating tax loss or applying sentencing enhancements for sophisticated means, obstruction of justice, and aggravating role. The appellate court also held that the district court correctly found a sufficient connection between the criminal conduct and the forfeited proceeds, and that any procedural errors in the forfeiture process were harmless. Finally, the court determined that the forfeiture orders were not unconstitutionally excessive. The First Circuit affirmed the sentences and forfeiture orders. View "United States v. Ponzo" on Justia Law

Two individuals challenged the Puerto Rican electoral commission and its acting president, arguing that restrictions on early and absentee voting during the 2020 general election unlawfully burdened the right to vote for citizens over sixty, especially considering the COVID-19 pandemic. In August 2020, they brought suit under 42 U.S.C. § 1983, seeking relief on constitutional grounds. The district court promptly issued a preliminary injunction, then a permanent injunction, allowing voters over sixty to vote early by mail. After judgment, the plaintiffs were awarded nearly $65,000 in attorneys’ fees under 42 U.S.C. § 1988.While the fee motion was pending, Puerto Rico’s government was in the process of debt restructuring under Title III of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA). The restructuring plan, confirmed in January 2022, discharged claims against Puerto Rico arising before the plan’s effective date unless creditors filed proof of claim by a set deadline. Defendants argued in the U.S. District Court for the District of Puerto Rico that the attorneys’ fees award was subject to the plan’s discharge and enjoined from collection, because the plaintiffs had not filed a timely administrative expense claim. The district court rejected this, finding the fee award unrelated to the bankruptcy case.On appeal, the United States Court of Appeals for the First Circuit concluded that the claim for attorneys’ fees, though arising from post-petition litigation, related to events before the plan’s effective date. The court held that because the plaintiffs had actual knowledge of the restructuring proceedings but did not file a timely proof of claim, their fee claim was discharged under the confirmed plan and enjoined from collection. The First Circuit reversed the district court’s order, holding that the discharge injunction applied to the attorneys’ fee award. View "Ocasio v. Comision Estatal de Elecciones" on Justia Law

The case concerns significant changes made by the U.S. Department of Housing and Urban Development (HUD) to the Continuum of Care (CoC) program, which provides federal funding for homeless assistance projects. In November 2025, HUD issued a new Notice of Funding Opportunity (NOFO) that rescinded a previously issued two-year NOFO and introduced new requirements, including a drastic reduction in renewal funding for core permanent housing projects and new eligibility conditions. These changes threatened to eliminate funding for many projects, risking increased homelessness in the affected communities. Two groups of plaintiffs, including states, cities, and advocacy organizations, challenged HUD’s actions, alleging violations of the Administrative Procedure Act (APA) and constitutional provisions.The United States District Court for the District of Rhode Island issued preliminary injunctions prohibiting HUD from rescinding the prior NOFO and from implementing the challenged conditions in the new NOFOs. The court found that HUD’s actions likely violated the APA, were arbitrary and capricious, and would cause irreparable harm by creating funding gaps and service disruptions for vulnerable populations. After Congress passed new appropriations legislation in early 2026—setting a structure for grant renewals to avoid funding gaps—HUD moved to dissolve the injunctions, arguing that the legislative changes eliminated any ongoing harm and affected the merits of the legal claims. The district court denied the motion, concluding that the risk of harm persisted and that the plaintiffs remained likely to succeed on their claims.On appeal, the United States Court of Appeals for the First Circuit reviewed only the district court’s denial of HUD’s motion to dissolve the preliminary injunctions. The court held that HUD failed to make a strong showing that the intervening appropriations law eliminated the plaintiffs’ risk of harm or undermined the basis for the injunctions. The First Circuit therefore denied HUD’s request for a stay pending appeal. View "National Alliance to End Homelessness v. Department of Housing and Urban Development" on Justia Law

Federal agents began investigating after tracing firearms used in crimes in Massachusetts to purchases made by a South Carolina resident, Brunson. During interviews in 2021, Brunson told agents he had purchased twenty-four firearms for someone known as “Boston,” later identifying Roache as that individual. Brunson described a process in which Roache would select, pay for, and then receive firearms from him. Additional investigation revealed more firearms linked to Brunson’s purchases had been recovered in Massachusetts, and records showed similar transactions between Brunson and Roache continued into early 2023. In total, agents traced at least forty-six firearms purchased by Brunson, with evidence directly connecting Roache to six purchases in 2023.Roache and Brunson were indicted and pled guilty in the United States District Court for the District of Massachusetts to conspiring to traffic firearms. The Presentence Investigation Report (PSR) recommended a six-level sentencing enhancement based on the number of firearms Brunson stated he had purchased for Roache, as well as those confirmed in 2023. Roache objected, arguing that Brunson’s statements about the earlier purchases were uncorroborated and unreliable. The district court overruled Roache’s objection, finding that Brunson’s statements were sufficiently reliable, given corroborative evidence and the consistency of the described transactions with later confirmed acts. Roache was sentenced to fifty-seven months’ imprisonment, with three years of supervised release.The United States Court of Appeals for the First Circuit reviewed the district court’s application of the six-level enhancement for procedural error. The appellate court held that the district court did not abuse its discretion in crediting Brunson’s statements about the number of firearms trafficked, as those statements were supported by adequate indicia of reliability, and affirmed the sentence. View "United States v. Roache" on Justia Law

Kendell Seafood Imports, Inc. and Mark Foods, LLC are both fish importers. Kendell alleged that Mark Foods tortiously interfered with its agreement with Chilean Sea Bass, Inc. (CSB), a fish distributor. According to Kendell, it had arranged with CSB to purchase the distributor’s entire catch for several years, including 2021, and that CSB agreed to roll over an outstanding 2020 balance into the 2021 price. Kendell further claimed that Mark Foods was aware of this agreement and attempted to solicit business from CSB during the same period, thereby interfering with Kendell’s relationship and causing it harm.After Kendell initially sued Mark Foods for tortious interference in the United States District Court for the District of Rhode Island, Mark Foods moved to dismiss the complaint. In response, Kendell filed an amended complaint with similar facts but with additional details about the agreement with CSB. The district court treated the amended complaint as operative and, after considering substantive arguments from both parties, granted Mark Foods’ motion to dismiss with prejudice. The district court found that Kendell’s allegations did not plausibly support three essential elements of tortious interference: the defendant’s knowledge of the contract, intentional interference, and resulting damages.The United States Court of Appeals for the First Circuit reviewed the case on appeal. It held that the district court properly applied the pending motion to dismiss to the amended complaint, as the amendments did not affect the relevant arguments. Applying Rhode Island law, the First Circuit concluded that Kendell had not sufficiently pleaded that Mark Foods knew about the specific agreement with CSB. Because this element was not plausibly alleged, the court affirmed the district court’s order dismissing the case with prejudice. View "Kendell Seafood Imports, Inc. v. Mark Foods, LLC" on Justia Law

An employee of the Falmouth Public Schools in Maine, enrolled in a health insurance plan administered by Anthem Health Plans of Maine, Inc., challenged the plan’s exclusion of coverage for weight-loss medications. After being diagnosed with obesity and prescribed FDA-approved weight-loss drugs, the employee’s requests for coverage were repeatedly denied. Her medical providers appealed to Anthem, supporting the necessity of the medication, but Anthem maintained its denial, citing the plan’s explicit exclusion of weight-loss medications regardless of obesity diagnosis.The employee, on behalf of herself and a proposed class, sued Anthem’s parent company, Elevance Health, Inc., in the United States District Court for the District of Maine. She alleged that the exclusion constituted disability discrimination under Section 1557 of the Patient Protection and Affordable Care Act, which incorporates the nondiscrimination requirements of Section 504 of the Rehabilitation Act. Elevance moved to dismiss, arguing the complaint failed to plausibly allege disability discrimination. The district court granted the motion, reasoning that the exclusion applied to all enrollees, regardless of disability status, and did not target disabled individuals for discriminatory treatment. The court found the allegations of discrimination to be conclusory and insufficient to support claims of intentional, proxy, or disparate impact discrimination.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The appellate court held that the plaintiff failed to plausibly allege that the exclusion of weight-loss medication coverage constituted discrimination under Section 1557. The court concluded that the exclusion was facially neutral, did not serve as a proxy for disability discrimination, and did not result in a lack of meaningful access to plan benefits for disabled individuals. Accordingly, the dismissal of the complaint was affirmed. View "Holland v. Elevance Health, Inc." on Justia Law

A mother of four regularly sought care at a federally funded health center in Rhode Island from 2006 onward. Over a period of several years, she repeatedly reported persistent, weeks-long headaches with changing characteristics to her primary-care providers, also disclosing experiences of domestic abuse. Despite these reports, she was diagnosed with migraines and prescribed medication, but was never referred to a neurologist or for neuroimaging. In 2019, her symptoms worsened, and she lost consciousness, leading to hospitalization and the discovery of a slow-growing brain tumor, which had caused a buildup of cerebral fluid. Surgery to remove the tumor resulted in cerebellar strokes and permanent neurological damage, severely limiting her mobility and ability to care for her family.After the Department of Health and Human Services denied her administrative claim, she and her family filed suit under the Federal Tort Claims Act (FTCA) in the United States District Court for the District of Rhode Island. The district court found negligence by the primary-care providers, awarded her damages for medical expenses, pain and suffering, and homemaker loss, and awarded her children damages for loss of consortium. The government appealed, arguing that the children’s consortium claims were not properly presented administratively, that the homemaker damages were excessive, and that the findings on standard of care, causation, and medical expenses were erroneous.The United States Court of Appeals for the First Circuit held that the children’s loss-of-consortium claims were barred for failure to exhaust administrative remedies and reversed those damages. The court vacated the homemaker damages award as excessive and unsupported by the evidence, remanding for further proceedings. The court affirmed the district court’s findings on negligence and causation and upheld the pain and suffering awards, but reduced the medical expense award by the cost of an unrelated spinal MRI. The judgment was thus affirmed in part, reversed in part, modified in part, and remanded. View "Urizar-Mota v. US" on Justia Law