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

Karen Read was charged with second-degree murder, manslaughter while operating under the influence of alcohol, and leaving the scene of personal injury resulting in death. Her trial in Norfolk County Superior Court lasted thirty-seven days, after which the jury deliberated for approximately twenty-eight hours. The jury sent three notes to the trial judge indicating they were deadlocked. On July 1, 2024, after receiving the third note, the trial judge declared a mistrial. A retrial was scheduled for April 1, 2025.Read moved to dismiss Counts One and Three, arguing that the Double Jeopardy Clause barred retrial. The trial judge denied the motion, and the Massachusetts Supreme Judicial Court (SJC) affirmed the decision. Read then filed a habeas petition in federal court under 28 U.S.C. § 2241, seeking to prevent the state court from retrying her on those counts, claiming a retrial would violate her double jeopardy rights. The United States District Court for the District of Massachusetts denied her habeas petition.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the trial judge exercised sound discretion in declaring a mistrial due to the jury's deadlock, which constituted "manifest necessity." The court also found that there was no acquittal on Counts One and Three, as the jury did not publicly affirm a not guilty verdict. The court affirmed the district court's decision and denied Read's motion to stay the state court proceedings pending appeal. View "Read v. Norfolk County Superior Court" on Justia Law

Walter Aceituno, a Guatemalan citizen, became a lawful permanent resident of the United States in 1989. In 2014, he pled guilty to drug-trafficking charges after being arrested in a sting operation involving the purchase of cocaine. His attorneys informed him that he would be deported as a result of his guilty plea, but did not explicitly state that he would be permanently barred from reentering the United States. Aceituno was deported in 2015 and later illegally reentered the U.S. in 2019, leading to further legal issues.The United States District Court for the District of Rhode Island granted Aceituno's petition for a writ of error coram nobis, allowing him to withdraw his 2014 guilty plea. The district court found that Aceituno's attorneys provided ineffective assistance by failing to inform him of the permanent reentry bar, and that Aceituno acted reasonably in not seeking earlier relief due to his ongoing efforts to reunite with his family through various legal means.The United States Court of Appeals for the First Circuit reviewed the case and reversed the district court's decision. The appellate court held that Aceituno's attorneys met the requirements set forth in Padilla v. Kentucky by informing him of the risk of deportation. The court found that the district court erred in concluding that the attorneys were required to inform Aceituno of the permanent reentry bar. Additionally, the appellate court determined that Aceituno's delay in seeking relief was unreasonable and that the equities did not justify the issuance of the writ. The court emphasized the importance of finality in legal proceedings and the lack of compelling circumstances to warrant coram nobis relief. The writ was quashed, and the petition was dismissed. View "Aceituno v. United States" on Justia Law

The case involves a challenge by twenty-two states, the District of Columbia, and the Governor of Kentucky against various federal agencies and officials, including the President, regarding the implementation of an Office of Management and Budget (OMB) Directive and related Executive Orders. The OMB Directive, issued on January 27, 2025, required federal agencies to pause the disbursement of federal funds to review their alignment with the President's priorities. The plaintiffs argued that this directive and the subsequent funding freezes were unconstitutional and violated the Administrative Procedure Act (APA).The United States District Court for the District of Rhode Island issued a preliminary injunction on March 6, 2025, against the federal agencies, preventing them from implementing the OMB Directive and related Executive Orders. The court found that the rescission of the OMB Directive did not moot the case, as the funding freezes continued. The court determined that the plaintiffs were likely to succeed on the merits of their APA claims, as the agency actions were arbitrary, capricious, and contrary to law. The court also found that the plaintiffs demonstrated irreparable harm and that the balance of equities and public interest favored granting the injunction.The United States Court of Appeals for the First Circuit reviewed the case. The court denied the defendants' motion for a stay pending appeal, concluding that the defendants failed to make a strong showing of likelihood of success on the merits. The court found that the plaintiffs' challenge was not a broad programmatic attack but targeted discrete final agency actions. The court also determined that the defendants did not demonstrate irreparable harm absent a stay and that the balance of equities and public interest did not favor a stay. View "New York v. Trump" on Justia Law

Michael Francis appealed the district court's denial of his motion to suppress evidence seized from his car, which included a firearm holster, a kilogram of cocaine, two cell phones, $10,000 in cash, and a black bandana. Francis had pled guilty to possession with intent to distribute cocaine but reserved his right to appeal the suppression ruling. The district court held that the search warrant was supported by probable cause and rejected Francis's claims that the supporting affidavit omitted critical information.The United States District Court for the District of New Hampshire held an evidentiary hearing and found that the affidavit by FBI Special Agent Ryan Burke did not recklessly or in bad faith omit information about the credibility of a cooperating witness. The court also determined that even if the omitted information had been included, it would not have negated probable cause. Francis's motion to suppress was denied, and he subsequently appealed.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the affidavit established probable cause on its face, as it contained detailed and corroborated information from the cooperating witness. The court also found no clear error in the district court's credibility determinations regarding Agent Burke's testimony. The omissions in the affidavit were not deemed reckless or intentional, and their inclusion would not have undermined the probable cause finding. Therefore, the appellate court upheld the denial of the motion to suppress. View "United States v. Francis" on Justia Law

Three FBI agents arrived at Alan Parrot's house to execute a search warrant. Initially, the interaction was calm, but it escalated when Parrot tried to close a sliding glass door after becoming upset. Special Agent Angell attempted to prevent the door from closing, leading to a scuffle during which Parrot kicked her in the stomach. Parrot was aware that Angell was a federal officer but claimed he did not know about the search warrant. He was subsequently arrested and charged with forcibly assaulting a federal officer under 18 U.S.C. § 111.The United States District Court for the District of Maine heard the case. The jury found Parrot guilty of violating 18 U.S.C. § 111. Parrot appealed, arguing that the jury should have been instructed that his ignorance of the search warrant could affect his criminal intent and that the self-defense instruction given was improper.The United States Court of Appeals for the First Circuit reviewed the case. The court held that 18 U.S.C. § 111 is a general intent statute, requiring only an intent to assault, not an intent to assault a federal officer performing official duties. The court found that Parrot's proposed jury instruction, which would have required the government to prove he knew about the search warrant, was not substantively correct. Additionally, the court determined that the self-defense instruction given was not plain error, as Parrot did not raise the issue of excessive force in the lower court. Consequently, the First Circuit affirmed Parrot's conviction. View "United States v. Parrot" on Justia Law

David Núñez Pérez was convicted in Puerto Rico in 2006 for carjacking and manslaughter. He sought habeas relief, arguing that his prosecution and convictions violated the Double Jeopardy Clause of the Fifth Amendment, based on the Supreme Court's 2016 decision in Puerto Rico v. Sánchez Valle, which held that Puerto Rico and the United States are not separate sovereigns for double jeopardy purposes.Núñez's petition was reviewed by the United States District Court for the District of Puerto Rico. The respondents argued that the petition was untimely under the Antiterrorism and Effective Death Penalty Act (AEDPA), which imposes a one-year statute of limitations for state prisoners' federal habeas petitions. They contended that the limitations period began when Núñez's convictions became final in 2007, making his 2019 petition more than a decade late. The District Court, however, concluded that the limitations period began with the Sánchez Valle decision in 2016 and that Núñez was entitled to equitable tolling, making his petition timely.The United States Court of Appeals for the First Circuit reviewed the case. The respondents argued on appeal that the petition was untimely even under the limitations period set by Sánchez Valle. However, the Court of Appeals found that the respondents had waived this argument by not raising it in their answer to Núñez's petition. The Court noted that the respondents had only argued that the petition was untimely under the limitations period starting from the finality of Núñez's convictions in 2007, and had not asserted that the petition was untimely under the limitations period starting from the Sánchez Valle decision.The Court of Appeals affirmed the District Court's judgment granting Núñez's habeas petition, concluding that the respondents had waived their argument regarding the petition's untimeliness under the Sánchez Valle limitations period. View "Nunez Perez v. Escobar Pabon" on Justia Law

The case involves a dispute between several states and the U.S. Department of Education regarding the termination of grants for Teacher Quality Partnership (TQP) and Supporting Effective Educator Development (SEED) programs. The Department sent letters to 104 out of 109 grant recipients, stating that their grants were terminated due to involvement in diversity, equity, and inclusion (DEI) initiatives or other reasons that allegedly conflicted with Department priorities.The U.S. District Court for the District of Massachusetts issued a temporary restraining order (TRO) requiring the Department to restore the status quo and continue funding the grants. The Department appealed the TRO and requested a stay pending the resolution of the appeal.The United States Court of Appeals for the First Circuit reviewed the Department's motion for a stay. The court found that the Department's termination letters lacked specific reasons for the terminations, making it difficult for the recipients and the court to understand the basis for the decision. The court also noted that the Department had not filed an administrative record, which is necessary for judicial review.The court determined that the Department's actions were likely arbitrary and capricious under the Administrative Procedure Act (APA) because the termination letters did not provide a clear explanation and failed to consider the reliance interests of the grant recipients. The court also found that the Department had not demonstrated irreparable harm that would result from the TRO, while the grant recipients would suffer significant harm if the funding was cut off.The First Circuit denied the Department's motion for a stay pending appeal, allowing the TRO to remain in effect. The court emphasized the importance of the Department providing a reasoned explanation for its actions and considering the impact on the grant recipients. View "State of California v. US Department of Education" on Justia Law

Kilvert, a Rhode Island company, acquired a commercial property and claimed that SBC Tower, a Delaware company, breached their lease agreement by failing to pay fifty percent of the payments received from subleases. Kilvert filed a Commercial Property Eviction Complaint in Rhode Island district court, seeking eviction and damages. SBC Tower removed the case to the United States District Court for the District of Rhode Island based on diversity jurisdiction. Kilvert moved to remand, arguing that Rhode Island law grants exclusive jurisdiction over landlord-tenant disputes to state district courts.The United States District Court for the District of Rhode Island agreed with Kilvert and granted the motion to remand, holding that Rhode Island law mandates that the state district court is the proper court for this action, making removal improper. SBC Tower appealed the decision.The United States Court of Appeals for the First Circuit reviewed the case de novo. The court determined that the Rhode Island statute in question, R.I. Gen. Laws § 8-8-3(a)(2), allocates jurisdiction among state courts and does not divest federal courts of jurisdiction in cases where diversity jurisdiction is present. The court held that the statute does not preclude removal to federal court and that the federal court has the authority to hear the case. Consequently, the First Circuit reversed the district court's judgment and remanded the case for further proceedings. View "289 Kilvert, LLC v. SBC Tower Holdings LLC" on Justia Law

In 2023, Jorge Luis Armenteros-Chervoni, an attorney in Puerto Rico, was convicted of five offenses in the United States District Court for the District of Puerto Rico. The convictions stemmed from a visit to a correctional institution in the Commonwealth. Three convictions were for making materially false statements, and two were for attempting to provide prohibited objects to an inmate.The District Court denied Armenteros's pretrial motion to dismiss the indictment on multiplicity grounds, stating that such a dismissal was premature. At trial, the government presented testimony from an inmate about prior smuggling operations and the demand for contraband in the prison. The jury found Armenteros guilty on all counts, and he was sentenced to nine months of imprisonment for each count, to be served concurrently, along with supervised release and special assessments.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed with Armenteros that two of the three false statement convictions and one of the two prohibited object convictions were multiplicitous. The court vacated these convictions and their corresponding sentences. However, the court affirmed the remaining two convictions, finding no merit in Armenteros's claims of trial error. The court held that the evidence presented at trial was relevant and not unfairly prejudicial, and that the District Court did not abuse its discretion in limiting defense counsel's closing argument. View "United States v. Armenteros-Chervoni" on Justia Law

Scott Cannon, individually and as the personal representative of the estate of Blaise Cannon, filed a wrongful death and punitive damages claim against Blue Cross and Blue Shield of Massachusetts (BCBS). Cannon alleged that BCBS's denial of coverage for a specific inhaler led to asthma-related complications that contributed to Blaise's death. Blaise was a beneficiary of his partner's BCBS health insurance policy, which was governed by the Employee Retirement Income Security Act of 1974 (ERISA).The United States District Court for the District of Massachusetts granted summary judgment to BCBS on the grounds of ERISA preemption. The court found that Cannon's wrongful death claim was preempted by ERISA because it related to an employee benefit plan and arose from the denial of benefits under that plan. The court also held that the claim conflicted with the remedial scheme established by ERISA, which provides specific civil enforcement mechanisms.The United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that Cannon's claim was statutorily preempted under ERISA because it had a connection with the ERISA-regulated health insurance plan. The court also found that the claim was preempted under ERISA's civil enforcement provisions, as it sought remedies for the denial of benefits under the plan. The court rejected Cannon's argument that the Supreme Court's decision in Rutledge v. Pharmaceutical Care Management Association altered the preemption analysis, reaffirming that ERISA preempts state laws that relate to employee benefit plans. The court concluded that Cannon's wrongful death claim was derivative of Blaise's potential claim for benefits, which would have been preempted by ERISA. View "Cannon v. Blue Cross and Blue Shield of Massachusetts, Inc." on Justia Law