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

Damian Cortez was involved in a criminal case where he was charged with conspiracy to distribute and possess with intent to distribute controlled substances, and possession with intent to distribute fentanyl. The government alleged that Cortez was part of a Massachusetts gang known as "NOB" and was involved in various criminal activities, including drug trafficking. Cortez conditionally pled guilty to the charges after his motions to suppress evidence obtained from two search warrants were denied by the district court.The United States District Court for the District of Massachusetts denied Cortez's motions to suppress evidence seized from an apartment in Attleboro, Massachusetts, and from two cell phones. Cortez argued that the affidavit supporting the search warrant for the apartment did not establish probable cause that he was involved in a RICO conspiracy or that he resided in the apartment. He also requested a Franks hearing, claiming that the affidavit contained false statements and omissions. The district court found that the affidavit provided sufficient probable cause and denied the request for a Franks hearing.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The court held that the affidavit established probable cause to believe that Cortez was involved in a RICO conspiracy and that he resided in the Attleboro apartment. The court noted that the affidavit included evidence from GPS data, photographic evidence, and direct observations linking Cortez to the apartment. The court also found that Cortez did not make a substantial preliminary showing that the affidavit contained false statements or omissions necessary to warrant a Franks hearing. Therefore, the court upheld the denial of the motion to suppress and the request for a Franks hearing. View "United States v. Cortez" on Justia Law

In 2009, Guillermo González-Santillan fled Puerto Rico to avoid his sentencing hearing for conspiracy to commit money laundering, after pleading guilty as part of a plea agreement. He remained a fugitive for thirteen years until he was apprehended in the Dominican Republic and returned to the United States. Upon his return, the government sought a two-point obstruction-of-justice sentencing enhancement due to his abscondment.The United States District Court for the District of Puerto Rico initially accepted González-Santillan's guilty plea and scheduled a sentencing hearing. However, after he failed to appear, the court revoked his bail and issued an arrest warrant. Following his capture, the court ordered an updated presentence report, which included the government's recommended obstruction-of-justice enhancement. González-Santillan objected, arguing that the plea agreement barred the enhancement and that the government failed to prove willfulness in his failure to appear.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the district court did not err in applying the obstruction-of-justice enhancement. The appellate court found that González-Santillan's thirteen-year abscondment clearly demonstrated willfulness, as evidenced by his failure to attend a scheduled probation meeting, his sentencing hearing, and his subsequent flight to another country. The court also concluded that the government did not breach the plea agreement by seeking the enhancement, as González-Santillan's abscondment constituted a material breach of the agreement, thereby releasing the government from its original obligations.The First Circuit affirmed González-Santillan's seventy-month sentence, upholding the district court's application of the obstruction-of-justice enhancement. View "United States v. Gonzalez-Santillan" on Justia Law

The case revolves around Robert Nightingale, who owed money to National Grid. The company hired two debt collectors who called Nightingale more than twice over several seven-day periods throughout 2017 and 2018. Nightingale sued National Grid and the debt collectors under the Massachusetts Consumer Protection Act, alleging that the calls invaded his privacy and caused him emotional distress. He also sought to certify a class of Massachusetts residents who had experienced similar invasions of privacy due to excessive calls from the defendants.The case was moved to federal district court, which declined to certify the class, stating that it did not meet the predominance requirement of Federal Rule of Civil Procedure 23(b)(3). The district court also granted summary judgment to the defendants, finding that Nightingale had not demonstrated a cognizable injury under the Massachusetts Consumer Protection Act.The United States Court of Appeals for the First Circuit disagreed with the district court's rulings. The appellate court held that Nightingale had alleged cognizable injuries, vacated the district court's grant of summary judgment, and also vacated the denial of class certification. The case was remanded for further proceedings consistent with the appellate court's opinion. The court found that Nightingale's receipt of unwanted calls constituted a cognizable invasion of privacy, and that his emotional distress was a cognizable injury under the Massachusetts Consumer Protection Act. The court also found that the district court had applied an incorrect legal rule in its class certification analysis. View "Nightingale v. National Grid USA Service Company Inc." on Justia Law

The case involves Wilfredo Isaac-Delgado, who was serving a term of supervised release after completing a prison term for federal offenses related to a bank robbery. During his supervised release, Isaac tested positive for multiple controlled substances, failed to abide by the regulations of his residential reentry center, and was charged with violating Puerto Rico's domestic violence statute for harassing a former romantic partner. Isaac's probation officer detailed these actions, each of which violated the conditions of Isaac's supervised release, in two motions to the district court. Those motions requested that the court revoke Isaac's supervised release. Isaac informed the court that he would not be contesting the violations described by his probation officer. Instead, he identified mitigating circumstances that, in his view, justified a sentence within the applicable Sentencing Guidelines range.The district court, relying on the uncontested representations about Isaac's conduct from the probation officer, imposed a sentence more than three times longer than the high end of the Guidelines range. Isaac challenged that sentence as procedurally unreasonable. The United States Court of Appeals for the First Circuit found no procedural flaw and affirmed the sentence imposed by the district court. The court held that Isaac's admission to the violations detailed in the probation officer's motions provided a sufficiently reliable basis for the factual finding regarding his prescribed medication. The court also held that the district court satisfied its obligations under 18 U.S.C. § 3553(a) by considering and rejecting Isaac's argument that his mental health and substance abuse treatment was working. View "United States v. Delgado" on Justia Law

The case revolves around Frequency Therapeutics, a biotech startup that was developing a treatment for severe sensorineural hearing loss called "FX-322". Initial trials were positive, but subsequent testing yielded disappointing results, causing a sharp drop in Frequency's stock price. Three stockholders filed a class action lawsuit alleging violations of sections 10(b) and 20(a) of the Securities and Exchange Act of 1934, and Securities and Exchange Commission Rule 10b-5. They claimed that Frequency's CEO, David Lucchino, and its Chief Development Officer, Carl LeBel, knew of problems with the study before the results were announced, yet gave investors assurances to the contrary.The United States District Court for the District of Massachusetts dismissed the complaint, finding that the plaintiffs failed to allege sufficient facts to support a finding of scienter under the Private Securities Litigation Reform Act. The plaintiffs appealed to the United States Court of Appeals for the First Circuit.The Court of Appeals affirmed the dismissal. The court found that the plaintiffs failed to demonstrate that the defendants had made the false statements with the degree of scienter required to state a Securities and Exchange Act claim. The court noted that the complaint did not provide specific facts about when the defendants learned of the adverse events, which was a glaring omission. The court also found that the increase in stock sales by the CEO was not sufficient to establish an inference of scienter on its own. The court concluded that the plaintiffs' allegations, taken collectively, did not give rise to a strong inference of scienter. View "Quinones v. Frequency Therapeutics, Inc." on Justia Law

This case involves a child with significant developmental disabilities, B.D., who attended Georgetown Public Schools. B.D.'s parents, Rachel and Michael Doucette, sued the school district and various personnel, alleging that the school's failure to properly implement B.D.'s individualized education program (IEP) and health and safety plan led to a series of five severe seizures that B.D. experienced at school in 2012. The Doucettes claimed that the school district violated B.D.'s constitutional rights under 42 U.S.C. § 1983 and Massachusetts tort law.The district court granted the school district's motion for summary judgment, finding that a reasonable jury could not conclude that the school district engaged in the conscience-shocking conduct necessary to sustain the constitutional claim, nor that the school district was liable under the state-law claims.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court found that the school district's conduct, while flawed, did not rise to the level of "conscience-shocking" behavior necessary to establish a violation of B.D.'s substantive due process rights. The court also found that the Doucettes failed to establish that the school district's conduct was the but-for cause of B.D.'s seizures, a necessary element of their state-law claims. View "Doucette v. Jacobs" on Justia Law

The case involves a family from Guatemala who entered the United States without valid entry documents and were served with Notices to Appear, charging them with removability under the Immigration and Nationality Act. The father, Roni Cruz Galicia, filed an application for asylum, withholding of removal, and protection under the Convention Against Torture, with his wife and child as derivative beneficiaries. Cruz claimed that they were members of a particular social group ("PSG") defined as "climate refugees," having fled Guatemala due to severe environmental conditions and the government's inadequate response.The Immigration Judge (IJ) found Cruz's testimony credible but rejected his asylum claim. The IJ determined that Cruz did not experience sufficient harm in Guatemala to constitute past persecution, the asserted PSG of "climate refugees" was not legally cognizable, and Cruz's fear of poor conditions in his home country did not constitute a well-founded fear of future persecution. Cruz appealed the IJ's asylum ruling to the Board of Immigration Appeals (BIA), which summarily affirmed the IJ's decision.In the United States Court of Appeals for the First Circuit, Cruz argued that his asserted PSG of "climate refugees" was legally cognizable and that he had experienced past persecution and had a well-founded fear of future persecution due to his membership in the PSG. The court found no error in the determination that Cruz failed to show that his asserted PSG is legally cognizable. The court also rejected Cruz's argument that the BIA erred by affirming the denial of his asylum claim summarily and without a written opinion. The court denied the petition. View "Cruz Galicia v. Garland" on Justia Law

The case revolves around Agustin Vinas, who was convicted under 18 U.S.C. § 1958 for attempting to hire a hitman to murder a contractor and his business partner. Vinas, a subcontractor, claimed that the contractor owed him $8,500 for construction work and had threatened to harm him and his family when he tried to collect the debt. Vinas was arrested after a series of meetings with an undercover law enforcement officer posing as a hitman. He pleaded guilty to using facilities of interstate commerce in the commission of murder-for-hire, and the government agreed to dismiss the second count related to interstate travel in the commission of murder-for-hire.The District Court for the District of Rhode Island sentenced Vinas to time served, which amounted to nearly two years in pretrial detention. The government had recommended a sentence of ten years' imprisonment, arguing that a substantial sentence was necessary for specific and general deterrence. However, the defense argued for a sentence of time served, citing Vinas's attempts to peacefully collect the debt, the threats he received from the contractor, his mental health issues, and his efforts towards rehabilitation while in pretrial custody.The government appealed the sentence to the United States Court of Appeals for the First Circuit, arguing that the sentence was substantively unreasonable given the seriousness of the crime. The government also contended that the District Court had categorically refused to consider general deterrence and had created a disparity with defendants in other cases who were given longer sentences for the same statutory violation. The Court of Appeals affirmed the District Court's decision, finding that the sentence was within the expansive universe of reasonable sentences and that the District Court had adequately considered the sentencing factors set forth in 18 U.S.C. § 3553(a). The Court of Appeals also found that the government had not preserved its arguments regarding general deterrence and sentencing disparity, and that these arguments did not meet the plain error standard. View "United States v. Vinas" on Justia Law

A former teacher at Hanover High School in Massachusetts, Kari MacRae, was terminated from her position due to controversial memes she posted on her personal TikTok account. The memes, which were posted before she was hired, touched on sensitive topics such as gender identity, racism, and immigration. After her posts became public knowledge, the school district decided to terminate her employment, citing concerns about potential disruption to the learning environment.In the lower courts, MacRae filed a lawsuit against the school district, the school's principal, and the superintendent, alleging that they had unconstitutionally retaliated against her for exercising her First Amendment rights. The district court granted the defendants' motion for summary judgment, concluding that the school district's interest in preventing disruption outweighed MacRae's First Amendment rights.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court applied the Garcetti framework, which balances the interests of a public employee in commenting on matters of public concern against the interest of the state in promoting the efficiency of public services. The court found that while MacRae's posts did touch on matters of public concern, the school district's interest in preventing disruption to the learning environment was reasonable and outweighed MacRae's First Amendment interest. The court also noted that the timing of the posts, the media attention they received, and the controversy they stirred in the community all supported the school district's prediction of disruption. View "MacRae v. Mattos" on Justia Law

The case involves William Rios, a part-time security guard for Centerra Group LLC, who was fired after being found asleep at his post. Rios, who has diabetes, sued Centerra alleging violations of the Americans with Disabilities Act (ADA). He claimed that he had an episode of hypoglycemic shock which caused him to fall asleep on the job, and thus, Centerra should have accommodated his disability. However, Rios did not present any evidence that Centerra knew about his hypoglycemic episode when it fired him.The district court granted summary judgment to Centerra on all claims. Rios appealed, challenging the district court's decisions on his ADA discrimination claim, ADA claim for failure to provide a reasonable accommodation, ADA claim for hostile work environment, ADA claim for retaliation, and the denial of his Federal Rule of Civil Procedure 56(d) motion seeking additional discovery to respond to the motion for summary judgment.The United States Court of Appeals for the First Circuit affirmed the district court's decisions. The court found that Rios failed to present evidence from which a reasonable jury could find that Centerra held a discriminatory animus toward him based on his disability. The court also found that Rios failed to provide any evidence of discriminatory animus that would allow a reasonable jury to infer that Centerra's reasons for firing Rios were pretextual. The court further held that the district court did not abuse its discretion in denying Rios's Rule 56(d) motion given his failure to show good cause or due diligence in pursuing discovery for information regarding similarly situated employees. View "Sheridan v. Centerra Group, LLC" on Justia Law