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

Michael Francis appealed the district court's denial of his motion to suppress evidence seized from his car, which included a firearm holster, a kilogram of cocaine, two cell phones, $10,000 in cash, and a black bandana. Francis had pled guilty to possession with intent to distribute cocaine but reserved his right to appeal the suppression ruling. The district court held that the search warrant was supported by probable cause and rejected Francis's claims that the supporting affidavit omitted critical information.The United States District Court for the District of New Hampshire held an evidentiary hearing and found that the affidavit by FBI Special Agent Ryan Burke did not recklessly or in bad faith omit information about the credibility of a cooperating witness. The court also determined that even if the omitted information had been included, it would not have negated probable cause. Francis's motion to suppress was denied, and he subsequently appealed.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the affidavit established probable cause on its face, as it contained detailed and corroborated information from the cooperating witness. The court also found no clear error in the district court's credibility determinations regarding Agent Burke's testimony. The omissions in the affidavit were not deemed reckless or intentional, and their inclusion would not have undermined the probable cause finding. Therefore, the appellate court upheld the denial of the motion to suppress. View "United States v. Francis" on Justia Law

Three FBI agents arrived at Alan Parrot's house to execute a search warrant. Initially, the interaction was calm, but it escalated when Parrot tried to close a sliding glass door after becoming upset. Special Agent Angell attempted to prevent the door from closing, leading to a scuffle during which Parrot kicked her in the stomach. Parrot was aware that Angell was a federal officer but claimed he did not know about the search warrant. He was subsequently arrested and charged with forcibly assaulting a federal officer under 18 U.S.C. § 111.The United States District Court for the District of Maine heard the case. The jury found Parrot guilty of violating 18 U.S.C. § 111. Parrot appealed, arguing that the jury should have been instructed that his ignorance of the search warrant could affect his criminal intent and that the self-defense instruction given was improper.The United States Court of Appeals for the First Circuit reviewed the case. The court held that 18 U.S.C. § 111 is a general intent statute, requiring only an intent to assault, not an intent to assault a federal officer performing official duties. The court found that Parrot's proposed jury instruction, which would have required the government to prove he knew about the search warrant, was not substantively correct. Additionally, the court determined that the self-defense instruction given was not plain error, as Parrot did not raise the issue of excessive force in the lower court. Consequently, the First Circuit affirmed Parrot's conviction. View "United States v. Parrot" on Justia Law

David Núñez Pérez was convicted in Puerto Rico in 2006 for carjacking and manslaughter. He sought habeas relief, arguing that his prosecution and convictions violated the Double Jeopardy Clause of the Fifth Amendment, based on the Supreme Court's 2016 decision in Puerto Rico v. Sánchez Valle, which held that Puerto Rico and the United States are not separate sovereigns for double jeopardy purposes.Núñez's petition was reviewed by the United States District Court for the District of Puerto Rico. The respondents argued that the petition was untimely under the Antiterrorism and Effective Death Penalty Act (AEDPA), which imposes a one-year statute of limitations for state prisoners' federal habeas petitions. They contended that the limitations period began when Núñez's convictions became final in 2007, making his 2019 petition more than a decade late. The District Court, however, concluded that the limitations period began with the Sánchez Valle decision in 2016 and that Núñez was entitled to equitable tolling, making his petition timely.The United States Court of Appeals for the First Circuit reviewed the case. The respondents argued on appeal that the petition was untimely even under the limitations period set by Sánchez Valle. However, the Court of Appeals found that the respondents had waived this argument by not raising it in their answer to Núñez's petition. The Court noted that the respondents had only argued that the petition was untimely under the limitations period starting from the finality of Núñez's convictions in 2007, and had not asserted that the petition was untimely under the limitations period starting from the Sánchez Valle decision.The Court of Appeals affirmed the District Court's judgment granting Núñez's habeas petition, concluding that the respondents had waived their argument regarding the petition's untimeliness under the Sánchez Valle limitations period. View "Nunez Perez v. Escobar Pabon" on Justia Law

The case involves a dispute between several states and the U.S. Department of Education regarding the termination of grants for Teacher Quality Partnership (TQP) and Supporting Effective Educator Development (SEED) programs. The Department sent letters to 104 out of 109 grant recipients, stating that their grants were terminated due to involvement in diversity, equity, and inclusion (DEI) initiatives or other reasons that allegedly conflicted with Department priorities.The U.S. District Court for the District of Massachusetts issued a temporary restraining order (TRO) requiring the Department to restore the status quo and continue funding the grants. The Department appealed the TRO and requested a stay pending the resolution of the appeal.The United States Court of Appeals for the First Circuit reviewed the Department's motion for a stay. The court found that the Department's termination letters lacked specific reasons for the terminations, making it difficult for the recipients and the court to understand the basis for the decision. The court also noted that the Department had not filed an administrative record, which is necessary for judicial review.The court determined that the Department's actions were likely arbitrary and capricious under the Administrative Procedure Act (APA) because the termination letters did not provide a clear explanation and failed to consider the reliance interests of the grant recipients. The court also found that the Department had not demonstrated irreparable harm that would result from the TRO, while the grant recipients would suffer significant harm if the funding was cut off.The First Circuit denied the Department's motion for a stay pending appeal, allowing the TRO to remain in effect. The court emphasized the importance of the Department providing a reasoned explanation for its actions and considering the impact on the grant recipients. View "State of California v. US Department of Education" on Justia Law

Kilvert, a Rhode Island company, acquired a commercial property and claimed that SBC Tower, a Delaware company, breached their lease agreement by failing to pay fifty percent of the payments received from subleases. Kilvert filed a Commercial Property Eviction Complaint in Rhode Island district court, seeking eviction and damages. SBC Tower removed the case to the United States District Court for the District of Rhode Island based on diversity jurisdiction. Kilvert moved to remand, arguing that Rhode Island law grants exclusive jurisdiction over landlord-tenant disputes to state district courts.The United States District Court for the District of Rhode Island agreed with Kilvert and granted the motion to remand, holding that Rhode Island law mandates that the state district court is the proper court for this action, making removal improper. SBC Tower appealed the decision.The United States Court of Appeals for the First Circuit reviewed the case de novo. The court determined that the Rhode Island statute in question, R.I. Gen. Laws § 8-8-3(a)(2), allocates jurisdiction among state courts and does not divest federal courts of jurisdiction in cases where diversity jurisdiction is present. The court held that the statute does not preclude removal to federal court and that the federal court has the authority to hear the case. Consequently, the First Circuit reversed the district court's judgment and remanded the case for further proceedings. View "289 Kilvert, LLC v. SBC Tower Holdings LLC" on Justia Law

In 2023, Jorge Luis Armenteros-Chervoni, an attorney in Puerto Rico, was convicted of five offenses in the United States District Court for the District of Puerto Rico. The convictions stemmed from a visit to a correctional institution in the Commonwealth. Three convictions were for making materially false statements, and two were for attempting to provide prohibited objects to an inmate.The District Court denied Armenteros's pretrial motion to dismiss the indictment on multiplicity grounds, stating that such a dismissal was premature. At trial, the government presented testimony from an inmate about prior smuggling operations and the demand for contraband in the prison. The jury found Armenteros guilty on all counts, and he was sentenced to nine months of imprisonment for each count, to be served concurrently, along with supervised release and special assessments.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed with Armenteros that two of the three false statement convictions and one of the two prohibited object convictions were multiplicitous. The court vacated these convictions and their corresponding sentences. However, the court affirmed the remaining two convictions, finding no merit in Armenteros's claims of trial error. The court held that the evidence presented at trial was relevant and not unfairly prejudicial, and that the District Court did not abuse its discretion in limiting defense counsel's closing argument. View "United States v. Armenteros-Chervoni" on Justia Law

Scott Cannon, individually and as the personal representative of the estate of Blaise Cannon, filed a wrongful death and punitive damages claim against Blue Cross and Blue Shield of Massachusetts (BCBS). Cannon alleged that BCBS's denial of coverage for a specific inhaler led to asthma-related complications that contributed to Blaise's death. Blaise was a beneficiary of his partner's BCBS health insurance policy, which was governed by the Employee Retirement Income Security Act of 1974 (ERISA).The United States District Court for the District of Massachusetts granted summary judgment to BCBS on the grounds of ERISA preemption. The court found that Cannon's wrongful death claim was preempted by ERISA because it related to an employee benefit plan and arose from the denial of benefits under that plan. The court also held that the claim conflicted with the remedial scheme established by ERISA, which provides specific civil enforcement mechanisms.The United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that Cannon's claim was statutorily preempted under ERISA because it had a connection with the ERISA-regulated health insurance plan. The court also found that the claim was preempted under ERISA's civil enforcement provisions, as it sought remedies for the denial of benefits under the plan. The court rejected Cannon's argument that the Supreme Court's decision in Rutledge v. Pharmaceutical Care Management Association altered the preemption analysis, reaffirming that ERISA preempts state laws that relate to employee benefit plans. The court concluded that Cannon's wrongful death claim was derivative of Blaise's potential claim for benefits, which would have been preempted by ERISA. View "Cannon v. Blue Cross and Blue Shield of Massachusetts, Inc." on Justia Law

A petitioner, Kathya Roxana Duarte De Martinez, sought review of a Board of Immigration Appeals (BIA) order affirming the denial of her application for cancellation of removal. Duarte argued that her removal would cause "exceptional and extremely unusual hardship" to her minor son, A.M., who has an intellectual disability. She claimed that A.M. would be deprived of educational services in El Salvador due to his inability to learn Spanish, which would severely impact his development and social functioning.An Immigration Judge (IJ) initially heard the case, finding Duarte and her husband credible but ultimately concluding that the hardship to A.M. and his brother did not meet the high statutory standard. The IJ noted that A.M. could attend a special education program in El Salvador, which was affordable for the family. Duarte appealed to the BIA, which affirmed the IJ's decision, stating that the availability of special education services in El Salvador, even if inferior, did not constitute exceptional and extremely unusual hardship. The BIA also noted that language barriers are common hardships and found no clear error in the IJ's findings.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the BIA failed to consider A.M.'s specific circumstances, including his severe language impairment and the impact of his disabilities on his ability to learn Spanish. The court held that the agency did not undertake the required individualized inquiry into whether A.M. would be deprived of all schooling or an opportunity to obtain any education. The court granted the petition, vacated the BIA's decision, and remanded the case for further proceedings consistent with its opinion. View "Duarte De Martinez v. Bondi" on Justia Law

Pedro Martínez-Mercado, a former postmaster of the Sabana Grande Post Office in Puerto Rico, moved to New Jersey with a postal remittance bag containing over $11,000 in cash and money orders. He was convicted by a jury in the District of Puerto Rico for misappropriating postal funds and stealing or converting government property, in violation of 18 U.S.C. §§ 1711 and 641. The district court sentenced him to six months in prison.Martínez appealed, arguing that the district court should have allowed him to present evidence showing his intent to return the funds, that the court gave an erroneous supplemental jury instruction, that the prosecutor made improper remarks during rebuttal, and that the evidence was insufficient to support his convictions.The United States Court of Appeals for the First Circuit reviewed the case. The court found that Martínez waived his argument regarding the exclusion of evidence about his intent to repay by failing to object to the district court's in limine ruling and by not raising the issue under the plain error standard on appeal. The court also determined that Martínez waived his challenge to the supplemental jury instruction by explicitly agreeing to the revised instruction during trial.Regarding the prosecutor's remarks, the court acknowledged that the comment suggesting Martínez's defense was a common tactic used by defendants with no defense was improper. However, it concluded that the isolated remark did not affect the trial's fairness, given the strong evidence against Martínez and the district court's instructions to the jury.Finally, the court found that the evidence was sufficient to support Martínez's convictions. The evidence showed that Martínez knowingly and intentionally converted postal funds for his own use and deprived the United States of those funds, at least temporarily. The court affirmed the judgment of the district court. View "United States v. Martinez-Mercado" on Justia Law

In this case, a seaman, Magnus Aadland, filed a lawsuit in 2017 against Boat Santa Rita II, Inc. (BSR II) and related parties, alleging that he fell ill while working offshore in 2014 and was owed maintenance and cure, which were not provided. Aadland sought compensatory damages for unpaid maintenance and cure, emotional distress, punitive damages, and attorney's fees.The United States District Court for the District of Massachusetts initially ruled in favor of BSR II, finding that Aadland had reached maximum medical recovery (MMR) by the time of the trial in September 2020 and that BSR II had satisfied its duty of cure. The court also denied Aadland's claims for emotional distress, punitive damages, and attorney's fees.On appeal, the United States Court of Appeals for the First Circuit vacated the District Court's judgment, finding that the District Court had erred in its application of the law, particularly regarding the duty of cure and the applicability of the Fifth Circuit's decision in Gauthier v. Crosby Marine Service, Inc. The First Circuit remanded the case for further proceedings.On remand, the District Court ruled that Aadland had not reached MMR as of September 2020 and that BSR II owed cure in the amount of $605,338.07, which was the amount paid by Aadland's private insurer, Tufts. The court credited BSR II's $400,000 payment to Tufts and $238,374 in advances to Aadland against this amount, resulting in a credit for BSR II. The court again denied Aadland's claims for emotional distress, punitive damages, and attorney's fees.On further appeal, the First Circuit affirmed the District Court's judgment regarding emotional distress damages but vacated the judgment regarding punitive damages and attorney's fees, finding that BSR II's breach of its duty of cure was willful. The case was remanded for the District Court to determine whether punitive damages and attorney's fees should be awarded. The First Circuit also affirmed the District Court's finding that Aadland had not reached MMR as of September 2020 and the setoff amount for BSR II's payment to Tufts. View "Aadland v. Boat Santa Rita II, Inc." on Justia Law