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

Defendant pled guilty to failing to register as a sex offender in violation of the Sex Offender Registration and Notification Act (SORNA). The district court sentenced Defendant to time served on the SORNA violation followed by five years of supervised release. The court also imposed several conditions of release. Defendant appealed, arguing that the special conditions were not reasonably related to his conviction, his history, or the goals of sentencing. Defendant further claimed that the conditions were overbroad and imposed a greater deprivation of liberty than was reasonably necessary. The Supreme Court held that the conditions were reasonable but remanded for further clarification consistent with this opinion. View "United States v. DaSilva" on Justia Law

Plaintiffs, a group of construction-industry employers’ associations and employers, sought relief from a broad category of enforcement actions that may be brought under the Massachusetts Earned Sick Time Law (ESTL). Plaintiffs did so before any action to enforce the ESTL had been filed against any employer who was a party to a collective bargaining agreement (CBA). Plaintiffs argued that the ESTL was preempted by section 301 of the Labor-Management Relations Act with respect to those employers in the state who are parties to CBAs. Plaintiffs sought a judgment, inter alia, prohibiting the Massachusetts Attorney General from granting private rights of action to employees who are members of collective bargaining units. The district court dismissed the suit for failure to state a claim insofar as it constituted a facial, preemption-based challenge to the ESTL, and for lack of jurisdiction insofar as it represented an as-applied preemption-based challenge that was not ripe for adjudication. The First Circuit dismissed the suit for want of jurisdiction, holding that Plaintiffs’ request for pre-enforcement relief was not ripe for adjudication. View "Labor Relations Division of Construction Industries of Massachusetts, Inc. v. Healey" on Justia Law

Plaintiff, an African-American, filed an employment discrimination case against Amtrak, his employer, alleging that his opportunities for overtime were reduced because of his race and that he was subjected to a hostile work environment. The district court granted summary judgment in favor of Amtrak. The First Circuit affirmed, holding (1) Plaintiff failed to meet his initial burden of establishing a prima facie case of disparate treatment discrimination; and (2) even if Plaintiff’s complaints rose to the level of a hostile work environment, Plaintiff failed to demonstrate that he was subjected to any complained-of actions because of his race. View "Garmon v. National Railroad Passenger Corp." on Justia Law

After Appellants went bankrupt, Appellees foreclosed on their home. Appellants each received an IRS Form 1099-A in the mail at the end of the tax year stating that the foreclosure might have tax consequences. The mortgage debt, however, was discharged during Appellants’ Chapter 7 bankruptcy proceedings. Appellants sued Appellees, claiming that the Forms were a coercive attempt to collect on the mortgage debt, which Appellees had no right to collect. The bankruptcy court found the Forms gave Appellants “no objective basis” to believe Appellees were trying to collect the discharged mortgage debt. The district court affirmed. The First Circuit affirmed, holding that the evidence in the record showed that the Forms were not objectively coercive. View "Bates v. CitiMortgage, Inc." on Justia Law

Plaintiff filed a complaint against his employer, the United States Postal Service (USPS), and his supervisor, Michael King, (together, Defendants), alleging that Defendants terminated him from the Brookline, Massachusetts Post Office in retaliation for taking Family Medical Leave Act (FMLA) leave. Appellant alleged FMLA interference and FMLA retaliation in violation of 29 U.S.C. 2615, among other claims. The district court granted summary judgment on all claims with the exception of the FMLA retaliation claim. After a bench trial, the district court entered judgment for Defendants, concluding that Defendants could not have acted with retaliatory animus because King, as the USPS decisionmaker, lacked the requisite knowledge that Plaintiff’s leave was protected under the FMLA. The First Circuit affirmed, holding that the district court properly found that King lacked the requisite knowledge necessary to hold to hold him liable for retaliation in violation of the FMLA. View "Chase v. United States Postal Service" on Justia Law

The underlying dispute in this case concerned a mortgage purported granted by Andrew and Maureen DeMore to the predecessor in interest to HSBC Bank, USA, N.A. on a parcel of property owned by the DeMores. This appeal came by way of bankruptcy court after each of the DeMores filed separate voluntary petitions for bankruptcy under Chapter 7 of the Bankruptcy Code. Donald Lassman, as trustee for the DeMores’ bankruptcy cases, filed adversary actions against HSBC to avoid the mortgage, arguing that the mortgage on the DeMores’ property was voidable under Massachusetts state law because the certificate of acknowledgment was “materially defective.” Specifically, Lassman asserted that the certificate failed to make clear that the DeMores executed the mortgage as their free act and deed. The Bankruptcy Court granted summary judgment to Lassman. The district court reversed. The First Circuit affirmed, holding that the certificate of acknowledgment was not materially defective because it made clear that the DeMores had executed the mortgage as their free act and deed. View "HSBC Bank USA, N.A. v. Lassman" on Justia Law

Defendant was convicted of possessing a firearm after being convicted of a felony and possessing a machine gun. Defendant was sentenced to a term of imprisonment of sixty-five months. In Defendant’s prior appeal, the First Circuit vacated his sentence and remanded for resentencing. After Defendant’s sentencing hearing on remand, the district court imposed a variant sentence of sixty months' imprisonment. The First Circuit affirmed, holding that Defendant identified no basis for vacating the sentence, that the district court’s reasoning was sufficient to justify the variance, and that the variance was not imposed in error. View "United States v. Santa-Otero" on Justia Law

Here the United States Citizenship and Immigration Services approved an I-130 “immediate relative” visa petition based on an the marriage of Petitioner, a Chinese national, to a United States citizen. In a parallel removal proceeding, the immigration court inquired into the bona fides of the anchoring marriage. The immigration judge (IJ) found that the marriage was a sham, rendering Petitioner’s ineligible to adjust her status. The IJ then ordered Petitioner’s removal to China. The Board of Immigration Appeals (BIA) affirmed. The First Circuit denied Petitioner’s petition for judicial review, holding (1) the IJ had jurisdiction to examine the bona fides of Petitioner’s marriage; and (2) the record did not compel a conclusion contrary to the “sham marriage” conclusion reached by the IJ and the BIA. View "Chan v. Lynch" on Justia Law

Plaintiff brought this class action against his former landlord (Landlord) alleging that Landlord violated several provisions of the Massachusetts Security Deposit Law by impermissibly deducting certain charges from his security deposit and failing to return the deposit within thirty days after he moved out of his leased apartment. Plaintiff sought recovery under the Security Deposit Law’s penalty provision, Mass. Gen. Laws ch. 186, 15B(7), which includes the availability of treble damages. The district court concluded that Plaintiff was entitled to recover his security deposit but was not entitled to recovery under section 15B(7), and denied Plaintiff’s class certification motion on mootness grounds. The First Circuit certified a question regarding the relevant provisions of the Massachusetts Security Deposit Law to the Massachusetts Supreme Judicial Court and refrained from deciding the merits of Plaintiff’s other claims until that question was resolved. View "Phillips v. Equity Residential Management, LLC" on Justia Law

Defendant pleaded guilty to production of child pornography. Defendant’s plea agreement contained a knowing and voluntary waiver of any right to appeal his sentence. Defendant appealed, challenging certain special conditions of supervised release imposed in connection with his guilty plea. The First Circuit (1) affirmed the majority of Defendant’s sentence, holding that, with respect to all but one of the challenged conditions, Defendant fell short of establishing that the enforcement of the appellate waiver would result in a miscarriage of justice; but (2) vacated the portion of the condition that authorized penile plethysmograph (PPG) testing, holding that enforcement of Defendant’s appellate waiver with respect to the PPG testing requirement would result in a miscarriage of justice. View "United States v. Berrios-Cruz" on Justia Law