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

The First Circuit affirmed Defendant’s convictions of drug offenses and failure to appear for arraignment, holding that, contrary to Defendant’s argument on appeal, Defendant’s counsel did not suffer from a conflict of interest arising from violation of attorney-client privilege and a local rule of professional conduct.The Court held that, under the rules set forth in Cuyler v. Sullivan, 446 U.S. 335, 348 (1980), and United States v. Soldevila-Lopez, 17 F.3d 480, 486 (1st Cir. 1994), Defendant failed to show an actual conflict of interest that adversely affected his lawyer’s performance. Further, “any tension in the lawyer’s mind between client loyalty and professional self-preservation” would have been addressed by a stipulation joined by Defendant, and the following colloquy demonstrated that Defendant understood his rights and the consequences of proceeding as he chose to do. View "United States v. Tirado" on Justia Law

The First Circuit vacated the judgment of the district court dismissing APB Realty, Inc.’s complaint against Georgia-Pacific alleging breach of contract stemming from the failure of a proposed deal concerning the purchase of rail freight cars. The district court dismssed the complaint for failure to state a claim upon which relief could be granted, finding that no contract had been formed between the parties. The First Circuit disagreed, holding that the complaint alleged facts from which the Court could plausibly infer the making and breaking of a contract. The Court remanded the cause for further proceedings. View "APB Realty, Inc. v. Georgia-Pacific LLC" on Justia Law

The First Circuit vacated in part the district court’s grant of summary judgment in favor of Defendants in this lawsuit alleging violations of the Emergency Medical Treatment and Active Labor Act (EMTALA) and claiming medical malpractice.Plaintiffs sued Hospital Pavia Hato Rey, APS Healthcare of Puerto Rico (APS), and two doctors. In granting summary judgment, the district court held that the action could not in “equity and good conscience” proceed without two necessary parties but that the parties could not be feasibly joined under Fed. R. Civ. P. 19. The judge found that complete diversity of citizenship of each plaintiff from each defendant was not met on the federal-EMTALA claim, and because no diversity jurisdiction existed, the court declined to exercise supplemental jurisdiction over the local-law claims. The First Circuit vacated the summary judgment for Hospital Pavia on the EMTALA claim and dismissed the local law claims, holding (1) the trial judge Fed. R. Civ. P. 19 analysis could not be sustained; and (2) this Court’s vacating part of the judge’s summary judgment ruling on the federal EMTALA claim undercut the analysis behind his supplemental jurisdiction decision. View "Delgado-Caraballo v. Hospital Pavia Hato Rey, Inc." on Justia Law

The First Circuit vacated in part the district court’s grant of summary judgment in favor of Defendants in this lawsuit alleging violations of the Emergency Medical Treatment and Active Labor Act (EMTALA) and claiming medical malpractice.Plaintiffs sued Hospital Pavia Hato Rey, APS Healthcare of Puerto Rico (APS), and two doctors. In granting summary judgment, the district court held that the action could not in “equity and good conscience” proceed without two necessary parties but that the parties could not be feasibly joined under Fed. R. Civ. P. 19. The judge found that complete diversity of citizenship of each plaintiff from each defendant was not met on the federal-EMTALA claim, and because no diversity jurisdiction existed, the court declined to exercise supplemental jurisdiction over the local-law claims. The First Circuit vacated the summary judgment for Hospital Pavia on the EMTALA claim and dismissed the local law claims, holding (1) the trial judge Fed. R. Civ. P. 19 analysis could not be sustained; and (2) this Court’s vacating part of the judge’s summary judgment ruling on the federal EMTALA claim undercut the analysis behind his supplemental jurisdiction decision. View "Delgado-Caraballo v. Hospital Pavia Hato Rey, Inc." on Justia Law

The district court erred in awarding attorney’s fees to Defendants in this case alleging various claims under Puerto Rico and federal law, including claims under the Copyright Act, 17 U.S.C. 505. Plaintiff sued Sony Corporation of America and other related defendants in connection with a songwriting contest that Sony had co-sponsored. The district court dismissed the claims with prejudice on the grounds that they were subject to mandatory arbitration under an agreement that Plaintiff had signed upon entering the contest and that his claims were subject to dismissal under Fed. R. Civ. P. 12(b)(6). The First Circuit affirmed. Thereafter, Defendants moved for attorney’s fees under section 505 of the Copyright Act, which provides for attorney’s fees to the prevailing party. The district court granted the motion and awarded attorney’s fees. The First Circuit reversed, holding that Defendants did not qualify as prevailing parties under section 505. View "Cortes-Ramos v. Sony Corp. of America" on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment to Defendants - the Town of Abington, Massachusetts and leaders of the Abington Police Department (Department) - on Plaintiff’s federal and state law claims in which he alleged that Defendants retaliated against him while he was an officer in the Department.The Court held that the district court did not err in granting summary judgment as to (1) Plaintiff’s claims that he brought under 42 U.S.C. 1983 for retaliation against him for exercising his First Amendment rights; (2) Plaintiff’s other section 1983 claim that Defendants impermissibly retaliated against him for his protected union activity; and (3) Plaintiff’s pendent Massachusetts law claims. Finally, the district court did not abuse its discretion in granting the Massachusetts Office of Attorney General’s motion to quash a deposition subpoena. View "Delaney v. Town of Abington" on Justia Law

The First Circuit remanded Appellant’s case for resentencing, holding that the district court erred by ordering a twelve-month term of home detention as part of Appellant’s sentence.Appellant was convicted, pursuant to a plea agreement, and sentenced on drug and firearms charges. On appeal, Appellant argued, among other things, that the district court improperly ordered a twelve-month term of home detention on the drug count, to be served after his mandatory minimum five-year term of imprisonment on the firearms count. The First Circuit agreed, holding (1) the appellate waiver provision in Appellant’s plea agreement may not be construed to bar his challenge to his term of home confinement where the term was twice as long as the high end of the applicable imprisonment range and the parties had recommended a sentence at the low end of the range; and (2) the twelve-month term of home confinement was an unjustified variance from the applicable guidelines range of zero-to-six months’ imprisonment. View "United States v. Lopez-Pastrana" on Justia Law

The First Circuit affirmed the sentence imposed following the revocation of Defendant’s supervised release term, holding that Defendant’s claims of sentencing error were unavailing.Defendant admitted to violating his supervised release conditions. The district court imposed a term of two years’ incarceration, to be followed by an additional thirty-four months of supervised release. The First Circuit affirmed the sentence, holding (1) the notification requirement of Fed. R. Crim. P. 32(h) did not obligate the district court to provide him advance notice of its intention to impose a sentence above the peak of the guideline range; (2) the district court did not err either in its treatment of the relevant sentencing factors or in its choice to give heavy weight to the gravity of the violations committed by Defendant; and (3) Defendant’s sentence was substantively reasonable. View "United States v. Daoust" on Justia Law

The First Circuit affirmed the sentence imposed following the revocation of Defendant’s supervised release term, holding that Defendant’s claims of sentencing error were unavailing.Defendant admitted to violating his supervised release conditions. The district court imposed a term of two years’ incarceration, to be followed by an additional thirty-four months of supervised release. The First Circuit affirmed the sentence, holding (1) the notification requirement of Fed. R. Crim. P. 32(h) did not obligate the district court to provide him advance notice of its intention to impose a sentence above the peak of the guideline range; (2) the district court did not err either in its treatment of the relevant sentencing factors or in its choice to give heavy weight to the gravity of the violations committed by Defendant; and (3) Defendant’s sentence was substantively reasonable. View "United States v. Daoust" on Justia Law

The First Circuit affirmed Defendant’s convictions of arson, wire fraud, and the use of fire in furtherance of a federal felony, holding that any alleged errors during trial were, whether individually or collectively, harmless.On appeal, Defendant argued that the prosecution violated his Confrontation Clause rights when an investigator testified that the cause of the fire was incendiary, rather than electrical, because the investigator relied on conclusions drawn by Defendant’s insurer’s electrical expert without calling that expert to the stand. Defendant also argued that this was a violation of Fed. R. Evid. 703. The First Circuit held (1) any such violation, if one occurred at all, of Defendant’s Confrontation Clause rights was harmless beyond a reasonable doubt; and (2) any error under Fed. R. Evid. 703 was harmless. View "United States v. Saad" on Justia Law