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

The First Circuit answered two questions of first impression regarding the Federal Arbitration Act (FAA) by holding (1) in a case where a federal district court is confronted with a motion to compel arbitration under the FAA and the parties have delegated questions of arbitrability to the arbitrator, the applicability of the FAA is a threshold question for the court to determine before compelling arbitration under the FAA; and (2) a provision of the FAA that exempts contracts of employment of transportation workers from the FAA’s coverage applies to a transportation-worker agreement that purports to establish an independent-contractor relationship. Accordingly, the First Circuit affirmed the district court’s order denying the motion to compel arbitration and dismissed this appeal for lack of appellate jurisdiction. View "Oliveira v. New Prime, Inc." on Justia Law

The First Circuit reversed the grant of summary judgment to Defendant in this action for breach of contract. Plaintiff filed suit against Defendant alleging that in causing a $200,000 loan to be taken out against a life insurance policy, Defendant had violated the non-contravention agreement inducing the lender to enter into the loan agreement. The district court concluded that Defendant breached the non-contravention agreement but that he was immune from liability under a non-recourse provision in the loan agreement. In reversing, the First Circuit held that the terms of the non-contravention agreement applied to the facts of this case without nullification by the loan agreement’s non-recourse clause. View "Dukes Bridge LLC v. Beinhocker" on Justia Law

Appellant entered guilty pleas to possessing marijuana with the intent to distribute and possessing firearms in furtherance of a drug-trafficking crime. The district court sentenced Appellant to a total incarcerative sentence of 162 months. Appellant appealed, challenging his sentence as both procedurally and substantively unreasonable. The First Circuit affirmed the sentence, holding (1) Appellant’s appeal was not within the scope of the waiver of appeal to which Appellant agreed; (2) the sentence was not procedurally unreasonable; and (3) the sentence was not substantively unreasonable. View "United States v. Sanchez-Colberg" on Justia Law

Appellant entered a straight guilty plea to possession of firearms by a convicted felon and possession of machine guns for possessing two seized firearms. The sentencing court considered the second firearm as an aggravating factor in imposing an upwardly variant sentence of seventy-two months. Appellant challenged his sentence on appeal. The First Circuit affirmed, holding (1) the district court did not err in taking the second gun into account as part of the factors to be considered at sentencing; (2) the sentencing court adequately explained its reasons for imposing the upward variance; and (3) Defendant’s seventy-two-month sentence did not fall outside the expansive universe of substantively reasonable sentences. View "United States v. Matos-De-Jesus" on Justia Law

When the five defendants in this case failed to pass the required exams to obtain their medical licenses, they gained certification by obtaining falsified scores. All five defendants were indicted for conspiracy to commit honest-services mail fraud, money or property mail fraud, and aggravated identity theft. The First Circuit affirmed Defendants’ convictions for honest-services mail fraud conspiracy but reversed the convictions for money or property mail fraud and aggravated identity theft, holding that there was sufficient evidence to support the convictions for conspiracy to commit honest-services mail fraud but insufficient evidence to support both Defendants’ convictions for money or property mail fraud and the identity theft convictions. View "United States v. Berroa" on Justia Law

The Court of Appeals for the First Circuit held that aliens who are subject to reinstated orders of removal may not apply for asylum, even though they may be entitled to withholding of removal. In reaching this conclusion, the First Circuit ruled that certain provisions of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 did not entitle Petitioner, a citizen of Guatemala who was subject to a reinstated order of removal, to seek asylum. The First Circuit affirmed the decisions of the immigration judge (IJ) and Board of Immigration Appeals (BIA) that determined that Petitioner could not apply for asylum even where the IJ determined that he was entitled to withholding of removal based on the persecution he would face in Guatemala. View "Garcia-Garcia v. Sessions" on Justia Law

Plaintiff appealed the district court’s grant of summary judgment in favor of her former employer, AstraZeneca Pharmaceutical LP, on Plaintiff’s claims that AstraZeneca violated the Americans with Disabilities Act (ADA) and several provisions of Puerto Rico law. Plaintiff attempted to persuade the First Circuit that there existed several material factual disputes in this case. The First Circuit affirmed the summary judgment, holding (1) AstraZeneca was entitled to summary judgment on both Plaintiff’s ADA disability discrimination claim and her ADA retaliation claim; and (2) Plaintiff failed to shoulder her burden to proceed to trial on her claims sounding in Puerto Rico law. View "Delgado-Echevarria v. AstraZeneca Pharmaceutical LP" on Justia Law

The First Circuit affirmed the district court’s grant of summary judgment to the City of Portland on Plaintiff’s claim that the City unconstitutionally denied him the opportunity to apply for a permit for his taxi to pick up passengers at the Portland International Jetport on the basis of his race and national origin. The district court ruled that Plaintiff did not have standing to bring his constitutional challenge because Plaintiff had not established a likelihood that he was “ready and able” to apply for the permit. The First Circuit affirmed, holding that there was no genuine issue of material fact regarding the likelihood that Plaintiff would seek the permit. View "McDonough v. City of Portland" on Justia Law

Appellant appealed the district court’s imposition of a two-year sentence imposed following the revocation of a term of supervised release. Specifically, Appellant argued that the district court erred in (1) stating that it had granted Appellant “two previous opportunities” to “get his act together,” and (2) imposing a substantively unreasonable sentence. The First Circuit affirmed, holding (1) there was no error in the court’s characterization of the outcome of a hearing as an “opportunity” afforded to Appellant; and (2) Appellant’s two-year sentence, though severe, did not fall outside the boundaries of the range of reasonable sentences. View "United States v. Soto-Soto" on Justia Law

Appellant entered a straight plea to illegal possession of a machine gun. The district judge sentenced Appellant to forty-eight months’ imprisonment followed by thirty-six months’ supervised release. On appeal, Appellant challenged the reasonableness of his sentence. The First Circuit affirmed, holding (1) the district court did not err in not applying, sua sponte, an additional one-level reduction to Appellant’s total offense level for acceptance of responsibility; (2) the district court’s decision to impose a forty-eight-month sentence was not in error; and (3) Appellant’s ineffective assistance of counsel claim could not be addressed on direct appeal. View "United States v. Fuentes-Echevarria" on Justia Law