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

After a jury trial, Defendant was found guilty of five counts of wire fraud, five counts of engaging in unlawful monetary transactions, two counts of filing false tax returns, and one count of bank fraud. Defendant appealed. In this opinion, the first Circuit addressed only Defendant’s argument that the district court’s inquiry into Defendant’s claims of juror misconduct was inadequate. The First Circuit remanded with instructions that the district court conduct an investigation into the juror misconduct allegations, holding that, under the circumstances of this case, the district court was required to conduct some further inquiry once it was apprised of the potential juror misconduct. View "United States v. Zimny" on Justia Law

Defendant pled guilty to two counts of carjacking. After a jury trial, Defendant was convicted of one count of using, carrying, and brandishing a firearm during a crime of violence and four counts of illegal possession of firearms. Defendant was sentenced to 180 months’ imprisonment. The First Circuit affirmed, holding (1) there was sufficient evidence for the jury to find that Defendant brandished a real gun during a crime of violence; (2) the district court did not err in admitting testimony from the government’s firearms expert related to the illegal possession counts; and (3) Defendant’s sentence was reasonable. View "United States v. Martinez-Armestica" on Justia Law

Defendants - Rivera-Ruperto, Salinas-Acevedo, and Santiago-Cardero - were found guilty of various federal drug and firearms-related crimes. Each was sentenced to multiple years of imprisonment. For Rivera-Ruperto, this was the second of two trials. The First Circuit separately addressed Rivera-Ruperto’s challenges from the first trial in a decision also released today. Here the First Circuit addressed all three defendants’ appeals as to the second trial. The First Circuit affirmed, holding (1) each of Rivera-Ruperto’s challenges failed in this second appeal; (2) the district court did not err in preventing Salinas-Acevedo from presenting an entrapment defense at trial; and (3) as to Santiago-Cordero, the judge did not err in refusing to give an entrapment jury instruction and in denying his post-verdict motion for acquittal. View "United States v. Rivera-Ruperto" on Justia Law

After two trials, Appellant was found guilty of various federal drug and firearms-related crimes for his participation in six “Operation Guard Shack” drug deals orchestrated by the FBI. Each trial was presided over by a different district judge. Thus, there were two cases on appeal. In this present appeal from the first trial, Appellant argued that the district court committed several reversible errors. The First Circuit affirmed, holding that the district court (1) did not err when it denied Appellant’s claim for ineffective assistance of counsel during the plea-bargaining stage; (2) did not commit obvious error in failing to instruct the jury that it was required to find drug quantity beyond a reasonable doubt; (3) did not clearly err in denying Appellant’s sentencing manipulation claim; and (4) did not sentence Appellant to a grossly disproportionate sentence in violation of the Eighth Amendment. View "United States v. Rivera-Ruperto" on Justia Law

The Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA), enacted in 2016 to address Puerto Rico’s financial crisis, provides for a temporary stay of debt-related litigation against the Puerto Rico government. The statute, however, allows creditors to move for relief from the stay and directs courts to grant such relief “after notice and a hearing…for cause shown.” Movant Peaje Investments LLC and various appellants in Altair Global Credit Opportunities Fund (A), LLC v. Garcia-Padilla (the Altair Movants) filed lift-stay motions. The First Circuit (1) affirmed the district court’s denial of the Peaje Movant’s motion, holding that Peaje failed to set forth a legally sufficient claim of “cause” to lift the PROMESA stay; and (2) the Altair Movants presented sufficient allegations to entitle them to a hearing. View "Peaje Investments LLC v. Garcia-Padilla" on Justia Law

At issue in this case was New Hampshire Senate Bill 319 (the Act), which was signed into law in 2014. The Act permits a reproductive health care facility to demarcate a zone under certain conditions and forbids members of the public to knowingly enter or remain on the portion of the public way or sidewalk within that zone. After the U.S. Supreme Court decided in McCullen v. Coakley that a buffer zone statute in Massachusetts was unconstitutional, Plaintiffs commenced this action in federal district court seeking to enjoin enforcement of the Act and to have the Act declared facially unconstitutional under McMullen. The statute, however, has never been activated or enforced. The district court dismissed the action. The First Circuit affirmed the district court's dismissal for want of jurisdiction, holding that Plaintiffs have shown neither standing or ripeness. View "Reddy v. Foster" on Justia Law

Plaintiff was injured while receiving treatment at a federally funded healthcare facility. Plaintiff later filed an administrative claim with the Department of Health and Human Services (HHS) using a Standard Form 95 (SF 95). Plaintiff, however, failed to fill out the box for a sum certain. HHS denied Plaintiff’s claim. Thereafter, Plaintiff sued the United States seeking damages under the Federal Tort Claims Act (FTCA). The United States moved to dismiss the case for lack of subject matter jurisdiction on the basis of Plaintiff’s failure to provide a timely sum-certain demand. The magistrate judge treated the motion as one for summary judgment and recommended that judgment enter for the United States, concluding that Plaintiff did not timely satisfy the FTCA’s requirements. The district judge adopted the magistrate judge’s recommendation on de novo review. The First Circuit affirmed, arguing that, where Plaintiff’s SF 95 did not include a sum certain, none of Plaintiff’s arguments for reversal had merit. View "Holloway v. United States" on Justia Law

In 1993, Vendura was hired by TRW Inc. and became a participant in the TRW Salaried Pension Plan. In 2002, Northrop Grumman Corp. acquired TRW and renamed the company (herein referred to as NGSMC). After NGSMC attempted to terminate Vendura’s employment Vendura challenged the attempt, and Vendura and NGSMSC signed a settlement agreement providing that Vendura would remain an employee of NGSMSC under certain conditions. In 2013, Vendura filed a claim for pension benefits to the Administrative Committee for the NGSMSC Plan, arguing that he was entitled to twenty years of benefit service under the settlement agreement. The Administrative Committee informed Vendura that he was eligible for a pension reflecting only twelve years of service. Vendura filed an eight-count complaint against Defendants, claiming, inter alia, a violation of ERISA. The district court granted summary judgment for Defendants. At issue on appeal concerned the number of “years of benefit service” that should be credited to Vendura in calculating his pension benefits under his pension plan. The First Circuit granted summary judgment to Defendants, holding that the Administrative Committee properly calculated Vendura’s pension benefits. View "Vendura v. Boxer" on Justia Law

This case concerned a dispute relating to contracts for the construction of a municipal transportation terminal on land owned by a municipality (Municipality). Municipality awarded the construction project to OSSAM Construction Inc. (OSSAM). After disputes arose regarding payments for the work performed in connection with the construction contracts, Municipality notified OSSAM that the contract between the parties was being terminated. Municipality then took control of the construction site. OSSAM and related individuals (Plaintiffs) filed suit against Municipality and its officials, claiming, inter alia, that Defendants violated 42 U.S.C. 1983 when they acted under color of law to interfere with Plaintiffs' constitutional rights during the construction site takeover and that these actions consisted a breach of contract. The district court (1) dismissed Plaintiffs’ section 1983 claim, concluding that it lacked subject matter jurisdiction because the parties had failed to comply with the mediation/arbitration clause in their contract; and (2) declined to exercise supplemental jurisdiction over related state law claims. The First Circuit affirmed, albeit on different grounds, holding (1) the section 1983 claim should be dismissed for failure to state a claim; and (2) accordingly, there is no supplemental jurisdiction over the state law claims. View "Masso-Torrellas v. Municipality of Toa Alta" on Justia Law

Defendant pled guilty to being a felon in possession of a firearm. Prior to the sentencing hearing, the government submitted a motion requesting that the district court apply the sentencing enhancement for trafficking in firearms under section 2K2.1(b)(5) of the United States Sentencing Guidelines. The district court found that the sentencing enhancement applied and sentenced Defendant to a term of imprisonment of seventy-one months. Defendant appealed the trafficking enhancement. The First Circuit affirmed, holding that the district court did not plainly err in finding that the trafficking enhancement applied. View "United States v. Taylor" on Justia Law