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

Anlert Perez-Segura pled guilty to conspiring to import cocaine into the United States. In exchange for a specific term of imprisonment, he waived his right to appeal any aspect of his conviction and sentence. He was caught captaining a boat carrying cocaine off Puerto Rico's western coast. A grand jury indicted him on four counts, and he agreed to plead guilty to one count in exchange for the government dropping the remaining counts and advocating for a 120-month sentence, the mandatory minimum. The plea agreement included a supplement acknowledging that the court could impose a sentence below the mandatory minimum if he qualified for the "safety valve" under 18 U.S.C. § 3553(f).The United States District Court for the District of Puerto Rico held a change-of-plea hearing and later a sentencing hearing. At the sentencing hearing, Perez-Segura's counsel indicated that he did not qualify for the safety valve because he was uncooperative. The court sentenced him to 120 months' imprisonment, and he appealed.The United States Court of Appeals for the First Circuit reviewed the case. Perez-Segura argued that the district court erred by not inquiring further into his eligibility for the safety valve and that his counsel was ineffective for not advocating for it. The appellate court found that his waiver of the right to appeal was enforceable and that he did not demonstrate a miscarriage of justice. The court also noted that his ineffective assistance claim was better suited for a collateral proceeding due to the lack of a developed record on why his counsel acted as she did and whether her actions were prejudicial.The First Circuit dismissed the appeal, allowing Perez-Segura to raise his ineffective assistance claim in a collateral proceeding. View "United States v. Perez-Segura" on Justia Law

Mario Rafael Castillo was charged with one count of aggravated sexual abuse of a child under twelve and one count of abusive sexual contact of a child under twelve. He pleaded guilty to the second count, which involved his younger granddaughter, while the government dismissed the first count. The plea agreement allowed Castillo to seek a 78-month sentence, and the government could argue for up to 180 months. Castillo was initially sentenced to 235 months by the district court, which applied a sentencing guidelines cross-reference that increased the advisory guideline range.The United States Court of Appeals for the First Circuit vacated the initial sentence due to a procedural error in applying the cross-reference. On remand, the district court acknowledged the lower guideline range but reimposed the 235-month sentence. Castillo appealed again, arguing that the prosecutor breached the plea agreement by not genuinely recommending the 180-month sentence and instead undermining it.The United States Court of Appeals for the First Circuit reviewed the case and agreed with Castillo. The court found that the prosecutor's statements, although technically recommending 180 months, effectively undermined the plea agreement by emphasizing the district court's authority to impose a harsher sentence and suggesting that Castillo was a danger to society. The court held that the prosecutor's actions constituted a breach of the plea agreement.The First Circuit vacated Castillo's sentence and remanded the case for resentencing before a different judge, emphasizing the importance of prosecutors upholding their end of plea agreements to maintain the integrity of the judicial process. View "United States v. Castillo" on Justia Law

The plaintiffs, Norene Rodríguez and Iris Rodríguez, sued Encompass Health Rehabilitation Hospital of San Juan, Inc. and Dr. José Báez Córdova for medical malpractice related to the treatment of their mother, Gloria Rodríguez González, who died after being treated for COVID-19. They alleged negligence in her care, particularly in failing to provide timely prophylactic medication for deep vein thrombosis, which they claimed led to her death.The United States District Court for the District of Puerto Rico granted summary judgment in favor of the defendants. The court concluded that the plaintiffs had not demonstrated any genuine issue of material fact and that the defendants were entitled to judgment as a matter of law. The court also found that Dr. Báez was immune from suit under Puerto Rico law, as he was acting within his duties as a faculty member of the University of Puerto Rico (UPR) at the time of the alleged malpractice. Consequently, Encompass could not be held vicariously liable for his actions. The plaintiffs' remaining claims were deemed waived for lack of development.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that Dr. Báez was immune from suit under Puerto Rico law, as he was acting in his capacity as a UPR faculty member supervising medical residents. The court also upheld the district court's application of the local anti-ferret rule, which disregarded certain facts not adequately supported by specific citations to the record. The plaintiffs' argument that Encompass was vicariously liable for the actions of other non-immune personnel was deemed waived, as it was not raised in the lower court. The appellate court found no abuse of discretion in the district court's denial of an evidentiary hearing. View "Rodriguez v. Encompass Health Rehabilitation Hospital of San Juan, Inc." on Justia Law

Two state forensic chemists in Massachusetts tampered with drug evidence and falsified test results, affecting tens of thousands of drug cases. The Massachusetts Supreme Judicial Court (SJC) vacated over 30,000 criminal cases due to this misconduct. The SJC ruled that under the Fourteenth Amendment, affected individuals were entitled to the repayment of most funds collected due to their vacated convictions but not the automatic return of forfeited property. Instead, individuals had to file motions for relief from judgment under Rule 60(b) of the Massachusetts Rules of Civil Procedure.The plaintiffs, whose criminal convictions were vacated, sought a federal court order for the automatic return of their forfeited property and related relief. The Commonwealth defendants moved to dismiss the complaint, arguing that the claims were barred by the Eleventh Amendment, which prohibits suits in federal court against a state by its own citizens. The United States District Court for the District of Massachusetts dismissed the complaint in part, ruling that it could not order the automatic return of forfeited property but allowed other claims to proceed under the Ex parte Young exception to the Eleventh Amendment.The United States Court of Appeals for the First Circuit reviewed the case and concluded that the Eleventh Amendment bars all the relief sought by the plaintiffs. The court held that the plaintiffs' claims focused on a past wrong, and the Ex parte Young exception applies only to prospective relief against ongoing violations of federal law. Additionally, the state officials sued lacked the authority to enforce or change the state court procedures. The court reversed the district court's partial denial of the motion to dismiss and remanded with instructions to dismiss the case in full. View "Cotto v. Campbell" on Justia Law

George Rodrique, II, a photographer for WCVB-TV, sued his employer, Hearst Stations, Inc. ("Hearst"), after it denied his request for a religious exemption from the company's COVID-19 vaccination requirement and subsequently terminated him for refusing to receive the vaccine. Rodrique claimed that Hearst's actions violated Title VII of the Civil Rights Act of 1964, which prohibits religious discrimination in employment.The United States District Court for the District of Massachusetts granted Hearst's motion for summary judgment, concluding that Rodrique's objections to the vaccine were not religious in nature. The court did not address whether accommodating Rodrique's request would have imposed an undue hardship on Hearst.Rodrique appealed to the United States Court of Appeals for the First Circuit, arguing that his objections were indeed religious and that granting the exemption would not have caused undue hardship. He contended that Hearst provided insufficient evidence that the COVID-19 vaccine reduces virus transmission.The First Circuit assumed, without deciding, that Rodrique's objections were religious. However, it affirmed the district court's summary judgment on different grounds, holding that Hearst reasonably relied on objective medical evidence, including public health guidance, to conclude that the vaccine reduces the likelihood of transmitting COVID-19. The court found that Hearst's reliance on such evidence was reasonable and that accommodating Rodrique's request would have imposed an undue hardship on the company. Thus, the First Circuit affirmed the district court's order granting summary judgment to Hearst. View "Rodrique v. Hearst Communications, Inc." on Justia Law

The case involves Maine healthcare workers who were terminated from their employment for refusing to comply with a COVID-19 vaccine mandate based on their religious beliefs. The mandate, initially promulgated by emergency rule on August 12, 2021, was no longer enforced as of July 12, 2023, and was repealed effective September 5, 2023. The plaintiffs filed suit in the United States District Court for the District of Maine, asserting that the mandate's lack of religious exemptions violated the First and Fourteenth Amendments. Their motion for a temporary restraining order and preliminary injunction was denied, and the denial was affirmed by the First Circuit. The Supreme Court also denied their application for emergency injunctive relief.The defendants moved to dismiss the complaint for failure to state a claim, which was granted. The First Circuit affirmed in part and reversed in part, reinstating the First Amendment Free Exercise and Fourteenth Amendment Equal Protection Clause claims for declaratory and injunctive relief against state health officials. Following the repeal of the mandate, the defendants moved to dismiss the remaining claims as moot, and the district court granted the motion, also denying the plaintiffs leave to amend the complaint.The United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the district court's determinations. The court held that the challenge was moot because the COVID-19 vaccine mandate had been repealed and was no longer in effect. The court also found that no exceptions to mootness, such as voluntary cessation or capable of repetition yet evading review, applied. The court further affirmed the denial of the plaintiffs' request to amend their complaint, concluding that justice did not require permitting further amendments to broaden the scope of their claims. View "Lowe v. Gagne-Holmes" on Justia Law

Humana, a health insurance company and Medicare Part C and Part D sponsor, filed a lawsuit against Biogen, a drug manufacturer, and Advanced Care Scripts, Inc. (ACS), a specialty pharmacy, in the District of Massachusetts. Humana alleged that Biogen and ACS engaged in fraudulent schemes involving three multiple sclerosis drugs, violating the civil RICO statute. Humana claimed that Biogen "seeded" the market with these drugs, funneled patients into Medicare, and indirectly funded patient copays through third-party patient-assistance programs (PAPs). Humana also alleged that ACS aided Biogen's scheme by steering patients and acting as an intermediary between Biogen and the PAPs, causing the submission of false certifications to Humana.The district court dismissed the case, ruling that Humana lacked standing to bring RICO claims because it was an indirect purchaser and failed to plead the RICO claims with particularity as required by Federal Rule of Civil Procedure 9(b). The court found that Humana did not specify the time, place, and content of the alleged fraudulent communications and failed to detail the false certifications' language, timing, and context. Humana's motion for leave to amend the complaint was also denied.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's dismissal, agreeing that Humana failed to meet the heightened pleading standard of Rule 9(b) for its RICO claim. The court held that Humana did not provide specific details about the fraudulent certifications or the use of mail or wire communications in furtherance of the scheme. The court also upheld the denial of leave to amend, citing undue delay and the inefficiency of seeking amendment after dismissal. View "Humana Inc. v. Biogen, Inc." on Justia Law

Jesse Sutherland was employed as an oil service technician at Peterson's Oil Service, Inc. ("Peterson's"). Two months into his job, he injured his right knee, leading to a torn meniscus and damaged patella. Sutherland requested reduced work hours due to his injury and eventually took a 12-week leave for knee surgery. Upon attempting to return to work, he was informed of his termination, effective the date he was supposed to return, citing a lack of work during the COVID-19 pandemic. Sutherland sued Peterson's for disability discrimination and related claims.The United States District Court for the District of Massachusetts granted summary judgment in favor of Peterson's, leading Sutherland to appeal. The district court concluded that Sutherland did not provide sufficient evidence to establish a prima facie case of disability discrimination, particularly questioning whether his knee injury qualified as a disability under the ADA.The United States Court of Appeals for the First Circuit reviewed the case and found that the district court erred in its analysis. The appellate court concluded that Sutherland provided sufficient evidence to show that his knee injury was a disability under the ADA, as it substantially limited his major life activities. The court also found that Sutherland's requests for reduced work hours were reasonable and that Peterson's failed to engage in the interactive process required by law. The appellate court vacated the district court's summary judgment on Sutherland's disability-related claims and remanded the case for further proceedings. However, the court affirmed the district court's decision regarding Sutherland's wrongful termination claim based on alleged violation of Massachusetts public policy, as Sutherland did not provide sufficient evidence of a well-defined public policy supporting his views on biofuel. View "Sutherland v. Peterson's Oil Service, Inc." on Justia Law

Regina M. Thornton was employed by Ipsen Biopharmaceuticals, Inc. as Associate Director - Patient Safety. In September 2021, Ipsen required employees to receive COVID-19 vaccinations. Thornton requested a religious exemption, which Ipsen denied. After she did not comply with the vaccination requirement, Ipsen terminated her employment. Thornton sued Ipsen in the Superior Court of Massachusetts, alleging violations of Title VII, Massachusetts law (Chapter 151B), the Fourteenth Amendment, and the Massachusetts Declaration of Rights (MDR). Ipsen removed the case to the United States District Court for the District of Massachusetts and moved to dismiss all counts. The Magistrate Judge granted Ipsen's motion, dismissing Thornton's complaint. Thornton appealed.The United States District Court for the District of Massachusetts dismissed Thornton's complaint, finding that she failed to state a plausible claim of religious discrimination under Title VII or Chapter 151B. The court concluded that Thornton did not adequately state her religious beliefs or how they related to vaccines. The court also found that Thornton's federal constitutional claims failed because Ipsen was not a state actor, and her MDR claims failed because the MDR does not provide a private right of action.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed the Magistrate Judge's dismissal of Thornton's religious discrimination claims under Title VII and Chapter 151B, finding that she had plausibly alleged that her religious beliefs conflicted with the vaccination requirement. However, the court affirmed the dismissal of her federal constitutional claims, as the Fourteenth Amendment does not apply to private actors like Ipsen. The court also affirmed the dismissal of her MDR claims, noting that Thornton had waived any argument that her claim should be reimagined under the Massachusetts Civil Rights Act. View "Thornton v. Ipsen Biopharmaceuticals, Inc." on Justia Law

On June 1, 2021, two masked men, later identified as Hall and Medina, abducted a U.S. postal worker at gunpoint to interrogate him about a package with missing contents, which was found to contain illicit drugs. During an undercover operation, law enforcement arrested Hall, Garay, and Medina while they attempted to collect other drug-laden packages. Officers seized five telephones from the defendants and obtained search warrants for the phones' contents and historical cell site location information (CSLI) for two defendants. A federal grand jury indicted the defendants on charges including kidnapping, conspiracy, and drug possession.The U.S. District Court for the District of Rhode Island found the warrants lacked probable cause due to missing referenced exhibits in the applications and suppressed the evidence. The court also rejected the government's argument that the good faith exception from United States v. Leon should apply, leading to the current appeal.The United States Court of Appeals for the First Circuit reviewed the case and concluded that the officer executing the warrants acted in good faith. The court noted that the officer, Inspector Atwood, had no reason to believe the affidavits were not attached and relied reasonably on the USAO to file the applications correctly. The court distinguished this case from United States v. Sheehan, emphasizing that the incorporation language was explicit and the error was not systemic but isolated. Consequently, the First Circuit vacated the suppression order and remanded the case for further proceedings. View "United States v. Medina" on Justia Law