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

In this complaint by a former employee alleging violations of the American Disabilities Act (ADA) there was no error in the district court’s jury instructions.Plaintiff filed a complaint against his former employer alleging that his termination violated the ADA. Plaintiff was fired from his job in the Town of Brookline’s Department of Public Works for unjustified absences from work and failing to provide adequate documentation for his use of sick leave. In his complaint, Plaintiff alleged that he had been suffering from sleep apnea and that the Town violated the ADA by discriminating against him on the basis of his sleep apnea disability, denying him a reasonable accommodation, and failing to engage in an interactive dialogue as required under the ADA. The First Circuit affirmed, holding that, contrary to Plaintiff’s contentions, the district court did not err in its instructions to the jury. View "McDonald v. Town of Brookline, Massachusetts" on Justia Law

Plaintiff, a pedestrian who was injured in a car accident, sued the vehicle’s driver and the driver’s insurance company, alleging negligence. The jury returned a verdict in favor of Defendants, finding that Plaintiff failed to prove that the driver was negligent in his driving and that his negligence proximately caused damage to Plaintiff. The district court denied Plaintiff’s motion for a new trial. The First Circuit affirmed, holding (1) the verdict was not against the weight of the evidence; (2) Plaintiff’s challenges to certain statements by defense counsel were without merit; and (3) the district court’s refusal to give a particular jury instruction was not reversible error. View "Mejias-Aguayo v. Doreste-Rodriguez" on Justia Law

Disappointed by the limited fruits of its multimillion-dollar investment with Abbott Laboratories (Abbott), John Hancock Life Insurance Company (Hancock) sued, seeking to recover damages under its contract with Abbott or, alternatively, to rescind the contract. At issue in this appeal was a contract provision that the parties viewed disparately either as a liquidated damages provision - and thus enforceable - or a penalty - and thus unenforceable. The district court concluded that the provision at issue was unenforceable. The First Circuit reversed this holding and affirmed the district court’s judgment in other respects, holding (1) Abbott failed to carry its burden of proving that the key provision was a penalty rather than a valid and enforceable liquidated damages provision; and (2) the district court did not err in striking Hancock’s prayer for rescission where Hancock recovered damages under the contract for Abbott’s breach of the contract. View "John Hancock Life Insurance Co. v. Abbott Laboratories" on Justia Law

The First Circuit affirmed the dismissal of plaintiffs' claims challenging the development of an offshore wind farm near Block Island, Rhode Island. The court held that Rhode Island's three-year personal injury statute of limitations applied to plaintiffs' claims, and plaintiffs' claims were barred by the applicable statute of limitations because they accrued after the three-year period. View "Riggs v. Curran" on Justia Law

The First Circuit held that, regardless of whether or to what extent USSG 2L1.1(b)(7)(D) incorporates a causation requirement, the district court did not err in applying the enhancement in this case. Defendant was convicted and sentenced for crimes related to his involvement in a scheme to smuggle migrants from the Dominican Republic into the United States by a small fishing boat. The district court did not err, let alone clearly err, in finding a causal connection between defendant's actions and the death of one of the migrants. The district court also did not err when it found it reasonable that defendant's actions could create the sort of dangerous circumstances likely to result in death. View "United States v. Ortiz-Carrasco" on Justia Law

Petitioner was convicted of, among other federal crimes, violating 18 U.S.C. 922(g), which prohibits certain persons from possessing or transporting firearms if that defendant has at least three prior convictions for an offense that falls within the Armed Career Criminal Act’s (ACCA) definition of a “violent felony.” The sentencing judge applied ACCA’s mandatory minimum fifteen-year sentence to Petitioner’s section 922(g) conviction. Petitioner filed this federal habeas petition, challenging his overall prison sentence of thirty years. Specifically, Petitioner argued that he did not have three prior convictions for an offense that qualifies as a “violent felony” within the meaning of ACCA. The district court granted Petitioner’s habeas petition. The First Circuit affirmed, holding that Petitioner’s two prior Maine convictions for aggravated assault did not qualify as violent felonies under ACCA insofar as aggravated assault in Maine may be committed with a mens rea of mere recklessness as opposed to purpose or knowledge. View "United States v. Bennett" on Justia Law

Defendant pleaded guilty to the unlawful possession of a machine gun. While he was on supervised release Defendant pleaded guilty to being a felon in possession of a firearm. Defendant was sentenced to a forty-eight-month term of imprisonment to be followed by three more years of supervised release. Thereafter, Appellant conceded a violation of his original supervised release based on the conduct underlying his felon-in-possession charge. The district court evoked the original period of supervision and sentenced Defendant to a twenty-four-month term of immurement, to run consecutively to his forty-eight-month sentence on the felon-in-possession charge. The First Circuit summarily affirmed Defendant’s sentence, holding that his sentence was neither procedurally nor substantively unreasonable. View "United States v. Marquez-Garcia" on Justia Law

Plaintiffs were prevented from building a new home by the Cohasset Conservation Commission. Plaintiffs brought this action against Defendant, a Florida landscape design firm that was hired by the attorney representing the neighborhood association formed to oppose the construction of Plaintiffs’ proposed home. Defendant assisted in the association’s opposition by producing and presenting renderings of Plaintiffs’ proposed home to the Commission. The federal district court ruled in Defendant’s favor on all counts, granting Defendant’s special motion to dismiss under the Massachusetts anti-SLAPP statute and also granting, in the alternative, Defendant’s motion to dismiss under Fed. R. Civ. P. 12(b)(6). The First Circuit certified a question to the Massachusetts Supreme Judicial Court regarding whether Defendant could avail itself of the special motion provision under Mass. Gen. Laws ch. 231, 59H. The court then held that, if the anti-SLAPP statute applies to Defendant, then Plaintiffs’ negligence, gross negligence, and Mass. Gen. Laws ch. 93A claims must also be dismissed under the special motion, leaving only Plaintiffs’ defamation claim for further consideration by the district court under the special motion. View "Steinmetz v. Coyle & Caron, Inc." on Justia Law

Plaintiff pleaded guilty to two firearms-related misdemeanors. When Plaintiff subsequently attempted to renew his Class A License to Carry, the Chief of Police of the Town of Northborough, Massachusetts denied Defendant’s applications, finding that Defendant’s prior convictions barred him from obtaining a Class A License under Massachusetts law. Plaintiff brought this action arguing that the denial of his application for a Class A License violated his constitutional right to possess a firearm for self-defense within the home and seeking declaratory and injunctive relief under 42 U.S.C. 1983. The district court granted summary judgment in favor of the Commonwealth. The First Circuit affirmed, holding (1) the denial of a Class A License does not implicate Plaintiff’s Second Amendment right to possess a firearm in his home for self-defense because a Firearm Identification (FID) Card, in conjunction with a permit to purchase, allows one to acquire a firearm and to possess it in one’s home; (2) because Plaintiff failed to show a constitutional violation his section 1983 claim failed as well; and (3) Plaintiff lacked standing to challenge the constitutionality of the Massachusetts statutory scheme governing the issuance of FID Cards. View "Morin v. Leahy" on Justia Law

This case concerned defects in the execution of two life insurance annuity polices that the decedent purchased through National Western Life Insurance Co. Plaintiffs, the decedent’s wife and children, sued National Western seeking a declaration that the policies were void and a return of the premiums paid by the decedent. National Western filed a motion to dismiss because Plaintiffs failed to join a necessary party - the decedent’s brother, who was named under both policies as the sole beneficiary - even though National Western had already paid him. The district court denied the motion, ruling that the beneficiary at issue was not “required to be joined if feasible” under Fed. R. Civ. P. 19(a). The court then granted summary judgment for Plaintiffs. The First Circuit vacated the judgment of the district court, holding that the sole beneficiary of the annuities was required to be joined if feasible under rule 19(a). The court remanded the case to the district court to determine whether it was equitable for the case to proceed without him. View "Maldonado-Vinas v. National Western Life Insurance Co." on Justia Law