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

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

Jeffrey Neece sued the City of Chicopee, alleging that the mayor's decision not to renew his employment contract was retaliation for his testimony in a gender-discrimination case against the city. Neece claimed that his testimony undermined the city's defense, while the mayor argued that Neece was unproductive and unresponsive to his colleagues. The jury rejected Neece's retaliation claims. Neece appealed, arguing that he was entitled to a new trial because the district court limited the evidence he could present about a key event: a closed-door meeting between the city's attorneys and the city council about the merits of the gender-discrimination case and the impact of Neece's testimony.The United States Court of Appeals for the First Circuit upheld the district court's decision, concluding that the district court did not abuse its discretion in limiting evidence about the meeting. The court found that the mayor, who did not attend the meeting, was the decision-maker in not renewing Neece's contract. Neece was unable to show that the mayor ever learned about the details of the meeting, making the meeting irrelevant to the mayor's state of mind or alleged retaliatory motive. The court also found that the city did not waive its attorney-client privilege regarding the mayor's private conversations with the city attorney about the settlement of the gender-discrimination case. Therefore, the court affirmed the jury's verdict in favor of the city. View "Neece v. City of Chicopee" on Justia Law

Ronald Tilley, the appellant, was convicted for robbing a credit union in Bangor, Maine, in 2019. His pre-sentence investigation report (PSI Report) revealed two prior convictions involving potential sexual misconduct, leading to a suggestion for special conditions of supervised release requiring Tilley to participate in sex-offender treatment. The first conviction in 2005 involved an incident where Tilley's then-wife accused him of choking and sexually assaulting her. The second conviction in 2008 was for violating a protective order and involved sexually explicit text messages allegedly exchanged between Tilley and his underage niece. Tilley objected to the sex-offender treatment conditions, leading to a compromise requiring him to undergo a Sexual Offense Assessment and Treatment Evaluation (SOATE).The SOATE, conducted by a licensed clinical social worker, placed Tilley in the "well below average risk" category for sexual recidivism due to the time elapsed since his last sexual misconduct. However, the assessment recommended caution due to a deceptive response in a sexual history polygraph. The SOATE also diagnosed Tilley with antisocial personality disorder and opioid use disorder, and recommended that he have no unsupervised contact with minors and participate in weekly group therapy for sexually problematic behavior.Based on the SOATE report, the government petitioned to add several special conditions to Tilley's supervised release terms, including participation in sex-offender treatment and restrictions on associating with minors. Tilley objected to these conditions, arguing that they were not supported by his previous convictions and that the relevance of these convictions was significantly mitigated by the time elapsed without any sexual misconduct incidents.The United States District Court for the District of Maine granted the government's petition, finding that the proposed modifications promoted the goals of supervised release. The court also found the conditions restricting Tilley's association with minors to be proportionate and reasonably related to the goals of supervised release and his history and characteristics.Tilley appealed, arguing that the district court relied on "clearly erroneous facts" in imposing the modified conditions. The United States Court of Appeals for the First Circuit reviewed the case for abuse of discretion and found no clear error. The court upheld the district court's decision, concluding that the modified conditions were reasonable and supported by the record. View "US v. Tilley" on Justia Law

A defamation lawsuit was filed by Dana Cheng, a New York resident and political commentator, against Dan Neumann and Beacon, a Maine news outlet, for characterizing Cheng as "far-right" and a "conspiracy theorist" in an article. Neumann and Beacon sought dismissal of the case under both federal law and a New York anti-SLAPP law, which applies to meritless defamation lawsuits. The district court conducted a choice-of-law analysis, decided that New York law applied, and granted the motion to dismiss under New York's anti-SLAPP statute.The district court's decision was appealed to the United States Court of Appeals for the First Circuit. The appellate court agreed with the district court's ruling but for a different reason: it decided that Cheng's lawsuit had to be dismissed under binding First Amendment principles protecting free speech by the press. Back at the district court, Neumann requested attorneys' fees under the fee-shifting provision of New York's anti-SLAPP law. The district court denied Neumann's request after determining that Maine, not New York, law applied to the specific issue of attorneys' fees.Neumann appealed again, arguing that the district court erred in its choice-of-law analysis. The appellate court, noting the lack of clear controlling precedent on the issue, certified to the Supreme Judicial Court of Maine the question of which state's law applies to the attorneys' fees issue. View "Cheng v. Neumann" on Justia Law

In 2019, Jason Candelario and three co-defendants conspired to rob a Maine resident of drugs and money. During the robbery, one of the co-defendants shot the victim, who survived. Two years later, a federal grand jury indicted the four defendants. In 2022, Candelario pleaded guilty to charges including conspiracy to commit a Hobbs Act robbery, interference with commerce by violence, and illegal possession of a firearm. His co-defendants also pleaded guilty to various charges.The district court calculated a guideline sentencing range of 140 to 175 months for Candelario. Despite Candelario's request for a 120-month sentence citing mitigating factors such as a difficult childhood and genuine remorse, the court imposed a 175-month sentence. The court found this sentence appropriate due to the seriousness of the crime, Candelario's criminal history, the risk of recidivism, and the need for deterrence.Candelario appealed his sentence to the United States Court of Appeals for the First Circuit, arguing that it was substantively unreasonable and created an unwarranted disparity with the sentences imposed on his co-defendants. The appellate court affirmed the district court's decision, finding that Candelario's sentence was both reasonable and proportionate. The court noted that the co-defendants had lower guideline sentencing ranges, played different roles in the robbery, and cooperated with the government, which justified their lower sentences. The court also found that the district court had provided a plausible sentencing rationale and a defensible result. View "United States v. Candelario" on Justia Law

The case involves Irvin Abreu, who pleaded guilty to one count of sexual exploitation of a child. The district court sentenced him to 315 months in prison, applying an enhanced mandatory minimum sentence of 300 months due to his prior state-law conviction for enticement of a child under the age of sixteen. Abreu appealed, arguing that his prior state-law conviction should not trigger the twenty-five-year minimum for his federal crime.Previously, the district court had determined during pre-trial proceedings that Abreu's prior conviction did trigger the twenty-five-year mandatory minimum under § 2251(e). Abreu subsequently changed his plea to guilty, and at sentencing, the district court considered a U.S. Sentencing Guidelines range of 300 to 327 months due to the mandatory minimum sentence.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court agreed with the district court's ruling that the enhancement does apply, concluding that the Massachusetts child-enticement statute is divisible and that Abreu's prior offense is related to the generic crimes listed in § 2251(e). The court also rejected Abreu's argument that § 2251(e) is unconstitutionally vague under the Fifth Amendment's Due Process Clause. View "US v. Abreu" on Justia Law