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

A court-appointed receiver (the Receiver), acting on behalf of a class of defrauded persons (the underlying plaintiffs), attempted to collect judgments previously rendered against several corporations and their proprietors. When the Receiver was able to recoup only a portion of the amount, it filed a tax-refund claim. The IRS denied the tax-refund claim. Thereafter, the Receiver responded by bringing this suit pursuant to 28 U.S.C. 1346(a). At issue in this case was the statute’s requirement that a taxpayer who seeks to reduce her tax liability under certain circumstances have an “unrestricted right” to income when she first reported it. The district court fashioned a judicially-created exception to the statute’s “unrestricted right” requirement, proceeded to deny the government’s motion to dismiss, and granted a modicum of relief. The First Circuit reversed, holding that the district court erred in refusing to follow section 1341(a)’s unambiguous textual mandate by carving out a special exemption from the “unrestricted right” requirement for parties in either the Receiver’s or the underlying plaintiffs’ position. Remanded for entry of judgment dismissing the tax-refund suit. View "Robb Evans & Associates, LLC v. United States" on Justia Law

Brittany Irish and her mother Kimberly Irish brought this 42 U.S.C. 1983 action against ten Maine State Police officers after Brittany’s former boyfriend broke into her parents’ home, fatally shot her boyfriend, shot and seriously wounded Kimberly, abducted Brittany, and engaged in a shootout with the police during which another individual was fatally shot. The complaint alleged that the Irishes’ losses arose out of failures by Defendants to protect them “from dangers which Defendants themselves created.” The district court dismissed the Irishes’ complaint for failure to state a claim and also found that qualified immunity shielded the defendants from liability. The First Circuit vacated the district court’s ruling as to the individual police officers, holding that it could not be said that Plaintiffs failed to state a substantive due process claim or that Defendants were entitled to qualified immunity. Remanded with instructions for discovery. View "Irish v. State of Maine" on Justia Law

Defendant pleaded guilty to six counts of a ten-count indictment, including conspiracy to commit export violations, conspiracy to smuggle goods, and four counts of unlawfully exporting U.S. goods to Iran through the People’s Republic of China. The district court imposed a sentence of 108 months, the upper end of the Guidelines sentencing range. Defendant appealed, arguing that his 108-month incarcerative sentence was unreasonable. Defendant made three different arguments in support of his claim. The First Circuit affirmed, holding that, under the circumstances of this case, imposition of the 108-month sentence was not substantively unreasonable. View "United States v. Cheng" on Justia Law

On her last day of work with Mova Pharmaceutical Corporation, Nilda Rodriguez-Lopez (Rodriguez) began experiencing symptoms. Rodriguez was diagnosed with several physical and mental conditions and filed a claim for long-term disability (LTD) benefits under Mova’s employee welfare benefits plan (the Plan). Triple-S Vida, Inc. denied Rodriguez’s application for LTD benefits, finding she did not meet the Plan’s definition of disabled. After she exhausted her administrative remedies, Rodriguez filed suit. The district court granted Triple-S’s motion for summary judgment, concluding that Triple-S’s denial of LTD benefits was neither arbitrary nor capricious. Rodriguez appealed, claiming that the Plan did not reflect a clear grant of discretionary authority to Defendant, and therefore, Triple-S’s determination to deny her LTD benefits was subject to the de novo standard of review. The First Circuit vacated the judgment, holding that the Plan did not confer discretionary authority upon Triple-S, and therefore, de novo review applied. Remanded. View "Rodriguez-Lopez v. Triple-S Vida, Inc." on Justia Law

In a multiple-count indictment, Defendant was charged with conspiring with twenty-nine others to distribute drugs in several Boston area neighborhoods. In pretrial proceedings, Defendant filed a motion to suppress evidence obtained pursuant to wiretaps obtained by the government, claiming, in part, that the government, in bad faith, failed to meet the strict procedural requirements for obtaining wiretaps under 18 U.S.C. 2517-2522. The trial court denied the motion to suppress without a hearing. After a trial, the jury failed to reach a unanimous verdict, and the district court declared a mistrial. Thereafter, Defendant pled guilty solely to conspiracy to distribute marijuana, reserving his right to appeal the denial of his suppression motion. The First Circuit affirmed, holding (1) the district court did not err in finding that Defendant failed to present a credible case of bad faith omissions; (2) the district court properly determined that the facts set forth in the wiretap applications were sufficient to support its grant of wiretap intervention; (3) the lack of strict adherence to statutory sealing requirements did not mandate suppression; and (4) the trial court did not err in denying Defendant a hearing to explore his misrepresentation and bad faith concerns. View "United States v. Rodrigues" on Justia Law

Israa Hassan, a United States citizen, filed an I-130 petition seeking permanent resident status for her noncitizen husband, Kamal Ali. U.S. Citizenship and Immigration Services (USCIS) denied the petition based on its determination that Ali’s prior marriage had been fraudulent. Ali and Hassan (together, Plaintiffs) filed a lawsuit alleging that USCIS had violated their Fifth Amendment procedural due process rights by denying the I-130 petition without sua sponte offering a pre-decision evidentiary hearing. The magistrate judge issued an order granting the government’s motion for summary judgment, concluding that, even assuming that Plaintiffs had a liberty interest in Ali having permanent resident status through the petition, due process did not require an evidentiary hearing. The First Circuit affirmed, holding that, even assuming that Plaintiffs were entitled to some form of constitutionally protected liberty interest in this matter, the district court properly held that Plaintiffs did not show how their preferred procedure would have made any difference to the outcome. View "Ali v. United States" on Justia Law

After a jury trial, Defendant was convicted of illegal insider trading. The conviction arose from Defendant’s act of receiving material, nonpublic information about a local bank from a fellow member of the Oakley Country Club and then using that information to make a substantial trading profit. Defendant appealed, arguing, in part, that the district court wrongly instructed the jury on the mens rea element of his offense. Defendant did not object to these instructions at trial. The First Circuit affirmed, holding (1) the government presented sufficient evidence to support the jury’s verdict; and (2) the trial court erred in its instructions to the jury regarding the mens rea element of Defendant’s offense, but Defendant failed to establish that the error was plain error. View "United States v. Bray" on Justia Law

After a bench trial, Defendant was convicted of both conspiracy to commit healthcare fraud and healthcare fraud. The convictions arose from Defendant’s role in an extensive scheme to defraud Medicare by billing the program for services provided to patients falsely presented as eligible to receive them. Defendant was sentenced to thirty-six months of imprisonment to be followed by three years of supervised release. Defendant appealed, arguing that there was insufficient evidence to prove beyond a reasonable doubt that she acted with the required culpable state of mind. The First Circuit affirmed, holding that the evidence was sufficient to permit a reasonable fact-finder to conclude, beyond a reasonable doubt, that Defendant conspired to commit, and committed, healthcare fraud. View "United States v. Troisi" on Justia Law

After a jury trial, Defendant was convicted of conspiracy to distribute and possess with intent to distribute controlled substances. Defendant was sentenced to 210 months imprisonment. Defendant appealed, challenging both his conviction and sentence. The First Circuit affirmed, holding (1) the government provided sufficient evidence that the conspiracy in question had the required “jurisdictional nexus” to the United States; (2) venue in the District of New Hampshire was proper, and the manufactured venue doctrine is hereby rejected; (3) there was no error in the district court’s failure to instruct the jury on jurisdictional nexus and manufactured venue; and (4) Defendant’s sentence was substantively reasonable. View "United States v. Celaya Valenzuela" on Justia Law

Defendant was convicted on two counts of making false statements to federal authorities regarding his possible participation in the Boston Marathon bombing. Defendant appealed, challenging, in part, the district court’s admission into evidence of a signed confession in which Defendant admitted to making the false statements at issue during informal interviews with federal agents. The First Circuit affirmed the convictions, holding that the district court did not err in (1) admitting the confession at trial; (2) excluding testimony from Defendant’s proposed expert on false confessions without first conducting a hearing under Daubert v. Merrell Dow Pharmaceuticals, Inc.; and (3) in denying Defendant’s motion for acquittal. View "United States v. Phillipos" on Justia Law