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

The district court did not err in granting the government’s motion for J.C.D. to be tried as an adult for an armed carjacking J.C.D. allegedly committed when he was seventeen years old.J.C.D. was charged with one count of carjacking. The government filed a motion to transfer J.C.D. to adult status. After balancing the statutory factors, the magistrate judge recommended that the government’s motion to transfer the case be denied. The district court granted the government’s motion to transfer, contrary to the magistrate judge’s recommendation, concluding that the statutory factors, when balanced, warranted transfer of J.C.D. to adult status in the interest of justice. The First Circuit affirmed, holding that J.C.D.’s challenges raised on appeal failed. View "United States v. J.C.D." on Justia Law

The Penobscot Nation filed suit against the state of Maine and certain state officials (collectively, the State Defendants) claiming rights to a sixty-mile stretch of the Penobscot River, known commonly as the Main Stem. The district court made two rulings on cross-motions for summary judgment, concluding (1) the Penobscot Indiana Reservation includes the islands of the Main Stem but not the waters of the Main Stem, and (2) Penobscot Nation was allowed to take fish for individual sustenance in the entirety of the Main Stem section of the river. The First Circuit affirmed the first ruling and vacated the second ruling on sustenance fishing and ordered dismissal, holding (1) the plain language of the definition of “Penobscot Indian Reservation” in the Maine Implementing Act and the Maine Indiana Claims Settlement Act includes the specified islands in the Main Stem but not the Main Stem itself; and (2) Plaintiffs’ second claim was not ripe, and, under the circumstances, the Nation lacked standing to pursue the claim. View "United States v. Mills" on Justia Law

In this excessive force case, the First Circuit sustained the district court’s post-verdict denial of qualified immunity to Defendant, a police officer on crowd-control duty who grabbed Plaintiff from behind by the collar and dragged him backward and downward to the pavement after seeing Plaintiff taunting K-9 dogs. A jury found that Defendant violated Plaintiff’s right to be free from excessive force under the Fourth Amendment. The district court then denied Defendant’s post-verdict motion for judgment as a matter of law, thus rejecting Defendant’s argument that he was entitled to qualified immunity. The First Circuit affirmed, holding that Defendant’s actions not only violated Plaintiff’s Fourth Amendment right but also fell outside the margin of error that qualified immunity provides. View "Ciolino v. Gikas" on Justia Law

The First Circuit affirmed the sentence imposed on Defendant after Defendant pleaded guilty to criminal charges based on her conduct during the court of a large-scale fraudulent financial scheme, which she led for five years. The district court sentenced Defendant to 135 months’ imprisonment for one count of conspiracy to commit wire fraud and bank fraud and to twenty-four months’ imprisonment for one count of aggravated identity theft and ordered that Defendant serve these terms consecutively, for a total term of 159 months’ imprisonment. On appeal, the First Circuit held that Defendant failed to carry her heavy burden that her within-the-range sentence was unreasonable. View "United States v. Castrillon-Sanchez" on Justia Law

A final determination of liability but not damages in arbitration can satisfy the final requirement of Article V(1)(e) of the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards when the parties have agreed to submit the issue of liability to the arbitrator for a distinct determination prior to a separate proceeding to assess damages.At issue in this appeal was the district court’s judicial recognition of an English arbitrator’s determination of joint contract liability against the seller and the renovator of a building. The parties agreed to bifurcate litigation of the liability and damages issues. Accordingly, the district court treated the liability judgment, which was decided before the damages issues, as final and thus entitled to judicial recognition. Specifically, the district court held the contractor for the renovation work bound as a party to the agreement providing for arbitration of disputes. The renovator and contractor appealed, claiming that the arbitrator’s judgment of liability in the bifurcated arbitration proceeding lacked the finality required for judicial confirmation of a foreign arbitral award under 9 U.S.C. 207. The First Circuit affirmed, holding that the arbitrator’s liability judgment was final in this instance and that the contractor could indeed be subjected to arbitration. View "University of Notre Dame (USA) in England v. TJAC Waterloo, LLC" on Justia Law

The First Circuit affirmed Defendant’s conviction for possessing a firearm entered after a second jury trial but vacated his sentence, holding that the district court erred in determining that Defendant was subject to a 180-month mandatory minimum sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e). The court held (1) the trial judge did not improperly comment on the credibility of two witnesses at trial; and (2) the district court erred in finding that Defendant had at least three previous convictions by any court for a violent felony under the ACCA, and therefore, the district court improperly ruled that the ACCA’s 180-month mandatory minimum sentence applied. View "United States v. Starks" on Justia Law

Plaintiff filed suit against the Secretary of Defense alleging discrimination on the basis of sex in violation of Title VII, 42 U.S.C. 2000e-2000e-17 based on his unsuccessful application for two teaching positions at an elementary school run by the Department of Defense. The district court granted summary judgment for Defendant. The First Circuit affirmed, holding that Plaintiff failed to offer any evidence establishing a genuine issue of material fact regarding whether Defendant’s proffered reason for not hiring Plaintiff was pretextual, and therefore, Plaintiff could not succeed in his challenge to the district court’s ruling dismissing his claim on summary judgment. View "Cruz v. Mattis" on Justia Law

The First Circuit affirmed the judgments convicting and sentencing Tony Bedini and Iskender Kapllani (together, Defendants) for conspiracy to distribute cocaine. On appeal, Defendants argued, inter alia, that they suffered unfair prejudice from being charged with participating in a single drug conspiracy but then jointly tried based on evidence that allegedly showed their participation in two separate drug conspiracies. The First Circuit held (1) the record supported a jury finding that Defendants participated in a single drug conspiracy; (2) the district court did not err in rejecting the jury instruction that Defendants had requested regarding whether the jury had to find a single conspiracy; and (3) Defendants’ remaining challenges to their convictions and sentences were without merit. View "United States v. Bedini" on Justia Law

This appeals arose from a dispute over whether application of the Massachusetts Earned Sick Time Law (MESTL), 2014 Mass. Legit. Serv. ch. 505 (West), to interstate rail carriers that employ workers in Massachusetts is preempted by the Railroad Unemployment Insurance Act (RUIA), 45 U.S.C. 351-369. The First Circuit affirmed in part and vacated in part the judgment of the district court, holding that the RUIA, preempts some parts of the MESTL as applied to employees of interstate rail carriers. However, this case must be remanded to determine whether other parts of the MESTL that are not within the preemptive reach of the RUIA and are not otherwise preempted by other federal law might still be applied to interstate rail carriers. View "CSX Transportation, Inc. v. Healey" on Justia Law

The First Circuit denied Petitioner’s petition for review of the Board of Immigration Appeals’ (BIA) decision affirming the Immigration Judge’s (IJ) denial of her application for withholding of removal. Petitioner, a native and citizen of Guatemala, was charged with removability. Petitioner conceded removability but then applied for withholding of removal and for protection under the Convention Against Torture (CAT). The IJ denied relief, and the BIA affirmed, concluding that Petitioner did not establish that she would likely be harmed by criminal gangs in Guatemala based upon an enumerated ground. Petitioner contested only the BIA’s ruling affirming the denial of her request for withholding of removal. The First Circuit held that there was substantial evidence to support the BIA’s findings. View "Marroquin-Rivera v. Sessions" on Justia Law