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

The First Circuit affirmed the sentenced imposed after Defendant pleaded guilty to both producing and possessing child pornography, holding that Defendant’s claims of error failed.After Defendant pleaded guilty, the district court sentenced him to 264 months’ imprisonment, to be followed by ten years of supervised release. Defendant appealed, seeking resentencing. The First Circuit affirmed, holding (1) the imposition of the supervised release condition restricting Defendant’s possession and use of internet-capable electronics was not clearly or obvious error; (2) Defendant’s sentence was substantively reasonable; and (3) the contention made in Defendant’s sealed brief was without merit. View "United States v. Aquino-Florenciani" on Justia Law

The First Circuit affirmed the district court’s judgment in favor of the Town of Camden, Maine on Plaintiff’s complaint claiming that Camden deprived him of his procedural due process rights when Camden laid him off because it violated the recall provision in his collective bargaining agreement (CBA).Plaintiff, a police dispatcher with Camden for thirty-one years, was laid off after Camden moved its police department’s dispatch operations to the Knox County Sheriff’s Department in the Town of Rockland. Plaintiff sued Camden pursuant to 42 .U.S.C. 1983. The jury returned a verdict in favor of Camden, determining (1) the CBA conditioned an employee’s recall right on the written submission, after layoff, of the employee’s mailing address and telephone number; and (2) Plaintiff had not contacted the town manager with his contact details after his layoff. The First Circuit affirmed, holding that the jury’s determination undid Plaintiff’s case because, without a right to recall, there was no deprivation of a protected property interest and no violation of Plaintiff’s due process rights. View "Clukey v. Town of Camden, Maine" on Justia Law

The First Circuit affirmed Defendant’s conviction for importation of controlled substances, possession with intent to distribute, and conspiracy, holding that by entering an unconditional guilty plea, Defendant forfeited his claim that the district erred in denying his motion to suppress.Defendant pleaded guilty unconditionally after the start of trial. On appeal, Defendant argued that the district court erred in denying his motion to suppress certain incriminating statements. The First Circuit held that by pleading guilty at trial, Defendant waived his right to challenge the denial of a motion to suppress filed on the eve of trial. View "United States v. Tineo-Gonzalez" on Justia Law

The First Circuit reversed the district court’s grant of Uber Technologies, Inc.’s motion to compel arbitration in this putative class action brought by users of Uber’s ride-sharing service in the Boston area, concluding that Uber’s mandatory arbitration clause found in an online contract was unenforceable.In their complaint, Plaintiffs alleged that Uber violated a Massachusetts consumer-protection statute by knowingly imposing fictitious or inflated fees. Uber moved to compel arbitration based on its terms and conditions (the agreement), which contained an arbitration clause and was available to Uber App users during the registration process. The district court granted the motion and dismissed the case. The First Circuit reversed, holding (1) Plaintiffs were not reasonably notified of the terms of the agreement and consequently did not provide their unambiguous assent to those terms; and (2) therefore, Uber failed to carry its burden on its motion to compel arbitration. View "Cullinane v. Uber Technologies, Inc." on Justia Law

The First Circuit affirmed the decision of the district court denying Petitioner’s request for discovery from Respondents in relation to opposition proceedings before the European Patent Office (EPO) under 28 U.S.C. 1782(a) for lack of relevance to the foreign proceeding.In the opposition proceedings, Petitioner, a patent agent, challenged the validity of several of Respondents’ European patents involving CRISPR-Cas9 technology used in the programmable genome editing of mammalian cells. Petitioner filed an application for discovery under section 1782 seeking documents and testimony from Respondents. The district court denied Petitioner’s petition, ruling that Petitioner had not demonstrated that the discovery sought was “relevant” to the opposition proceedings and failed to show that the EPO would be receptive to the district court’s assistance in providing the requested discovery. The First Circuit affirmed, holding that the district court did not misapply the law in denying the requested discovery under section 1782. View "In re Application of George W. Schlich" on Justia Law

The First Circuit affirmed the decision of the district court denying Petitioner’s request for discovery from Respondents in relation to opposition proceedings before the European Patent Office (EPO) under 28 U.S.C. 1782(a) for lack of relevance to the foreign proceeding.In the opposition proceedings, Petitioner, a patent agent, challenged the validity of several of Respondents’ European patents involving CRISPR-Cas9 technology used in the programmable genome editing of mammalian cells. Petitioner filed an application for discovery under section 1782 seeking documents and testimony from Respondents. The district court denied Petitioner’s petition, ruling that Petitioner had not demonstrated that the discovery sought was “relevant” to the opposition proceedings and failed to show that the EPO would be receptive to the district court’s assistance in providing the requested discovery. The First Circuit affirmed, holding that the district court did not misapply the law in denying the requested discovery under section 1782. View "In re Application of George W. Schlich" on Justia Law

In this appeal brought by a criminal defendant challenging the length of his terms of imprisonment and supervised release and several of the supervised release conditions, the First Circuit dismissed the appeal with the one exception of Defendant’s objection to one of his supervised release conditions, which the Court vacated and directed the district court to reconsider on remand.Pursuant to a plea deal, Defendant pleaded guilty to possession of child pornography. The district court sentenced Defendant to a term of 108 months’ imprisonment and sentenced him to a 144-month term of supervised release with multiple conditions. On appeal, Defendant argued that his appeal waiver was not made knowingly and voluntarily or, in the alternative, that enforcing the waiver would result in a miscarriage of justice. After dismissing most of Defendant’s claims on appeal, the First Circuit vacated the condition that, by its terms, prevented Defendant from having any contact with his minor children without approval of a probation officer, holding that because no justification was given for imposing the condition and the condition implicated Defendant’s fundamental constitutional interest in his relationship with his children, the condition must be vacated. View "United States v. Cabrera-Rivera" on Justia Law

Plaintiff was not entitled to relief on her constitutional challenges to Maine’s Wrongful Birth Statute.After she gave birth to a healthy child, Plaintiff brought this lawsuit against Merck & Co., Inc., claiming that a contraceptive implant manufactured by Merck and/or its applicator were defective. Plaintiff also sued the federal government under the Federal Tort Claims Act, alleging that a doctor at a federally-funded community health center unsuccessfully implanted the Merck product. Defendants moved to dismiss the complaint in reliance on Maine’s Wrongful Birth Statute. The district court dismissed Plaintiff’s case, rejecting her constitutional challenges to the Wrongful Birth Statute. The First Circuit affirmed, holding that Plaintiff’s challenges to the constitutionality of the Wrongful Birth Statute under the Maine and United States Constitutions failed. View "Doherty v. Merck & Co., Inc." on Justia Law

The district court did not err in imposing a 218-month sentence on Defendant for conspiracy to distribute and possession with intent to distribute 100 grams or more of a mixture or substance containing heroin, holding that the sentence was not procedurally unreasonable.On appeal, Defendant challenged the drug quantity that the district court attributed to him. The First Circuit affirmed, holding that, contrary to Defendant’s argument on appeal, certain witness statements concerning Defendant’s heroin distribution, as out-of-court statements, were not inherently less reliable for sentencing purposes. Rather, the district court’s reliance on the witness statements and its adoption of a narrowly tailored drug quantity determination supported by that evidence were reasonable. View "United States v. Lee" on Justia Law

The First Circuit affirmed the entry of a jury verdict awarding over $1.3 in compensatory damages and $1.3 million in punitive damages to Plaintiff, a black female former employee of the Massachusetts Bay Transportation Authority (MBTA), who claimed that her supervisors at the MBTA conspired to terminate her employment because of her race.The Court held (1) the evidence was sufficient to support the compensatory damages award for wrongful termination and to justify the punitive damages amount; (2) the trial judge committed clear error in imposing a sanction for removing the entry of default, but the MBTA failed to show that it was prejudiced by the default sanction order; (3) MBTA failed to show that it was prejudiced when the trial judge allowed a hostile work environment theory not explicitly pled in the complaint to go to the jury; and (4) MBTA waived its claim that it should be able to take advantage of Buntin v. City of Boston, 857 F.3d 69 (1st Cir. 2017), decided while this case was on appeal. View "Dimanche v. Massachusetts Bay Transportation Authority" on Justia Law