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

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The case concerns the appeal of Gilbert Perez, who sought to have his federal drug conviction overturned on the basis that the United States District Court for the District of Maine had incorrectly denied his motion to suppress the outcomes of a warrantless search of his backpack. Perez argued that the search was not justified under the search-incident-to-arrest exception to the warrant requirement of the Fourth Amendment to the U.S. Constitution. The District Court, relying on a previous case (United States v. Eatherton), had upheld the search. Perez contended that subsequent Supreme Court decisions had undermined the validity of Eatherton.On the night of his arrest, Perez had been seen acting suspiciously in a McDonald’s parking lot in Lawrence, Massachusetts. When he left the lot, carrying a backpack, he was monitored by state troopers. He was seen exiting a taxi, and large quantities of cash were found in the vehicle, arousing suspicion that he had been involved in a drug transaction. When Perez returned to the McDonald’s lot, he was approached by Trooper Jason Conant, who identified himself as a state trooper. Perez ran but was caught, and the backpack was removed from him and searched. The search revealed it contained fentanyl and cocaine. Perez was subsequently indicted on a federal drug-related charge.In his appeal, Perez maintained that the backpack's search was a violation of the Fourth Amendment. The United States Court of Appeals for the First Circuit disagreed, affirming the judgement of conviction. It concluded that neither of the Supreme Court cases cited by Perez had invalidated the Eatherton ruling. The panel also rejected the notion that Perez's backpack could be considered separate from his person at the time of arrest. As such, it fell within the search-incident-to-arrest exception to the Fourth Amendment's warrant requirement. View "US v. Perez" on Justia Law

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After a gang stole livestock from his Guatemalan farm and threatened his life, Juan Jose Espinoza-Ochoa fled to the United States and sought asylum based on his status as a landowning farmer. The Immigration Judge (IJ) and the Board of Immigration Appeals (BIA) denied Espinoza-Ochoa's application on the grounds that he had not established that the persecution was motivated by a protected ground and that his defined social group was "impermissibly circular." The United States Court of Appeals for the First Circuit disagreed with these findings, stating that a social group's reference to harm does not resolve its legal validity on its own and requires further substantive analysis. The Court found that the BIA had committed legal errors both in its particular social group analysis and in failing to consider whether being a landowning farmer was a central reason for Espinoza-Ochoa's persecution. Therefore, the Court granted Espinoza-Ochoa's petition, vacated the BIA's decision, and remanded the case for further proceedings. View "Espinoza-Ochoa v. Garland" on Justia Law

Posted in: Immigration Law
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In this case, Defendant-Appellee Martin Andersson purchased an insurance policy for his vessel from Plaintiff-Appellant Great Lakes Insurance SE. The vessel ran aground off the coast of the Dominican Republic, and Great Lakes brought a declaratory judgment action to determine coverage under the policy. Andersson filed counterclaims for breach of contract and equitable estoppel. Great Lakes' motion for summary judgment was denied, and Andersson was granted partial summary judgment on his breach of contract claim. Great Lakes appealed, claiming the district court erred in refusing to apply the policy's definition of seaworthiness.The United States Court of Appeals for the First Circuit held that under the absolute implied warranty of seaworthiness, the insured vessel must be seaworthy at the policy's inception, and if not, the policy is void. The court affirmed the district court's ruling, stating that Great Lakes' argument that the absolute implied warranty required the vessel to carry up-to-date charts for all geographic areas covered by the policy in order to be considered seaworthy was unsupported by admiralty case law and was unreasonable.Additionally, the court held that Great Lakes' argument that the express terms of the policy required updated paper charts for every location that could be navigated under the entirety of the policy coverage area was unsupported by the express language of the policy itself. The court found no precedent supporting the claim that updated paper charts for every location covered by the policy were required to be onboard the vessel at the inception of the policy. As a result, the Court of Appeals affirmed the district court's decision in favor of Andersson. View "Great Lakes Insurance SE v. Andersson" on Justia Law

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In this case, Virginia Cora Ward, as the administratrix of the estate of Edmund Edward Ward, brought a case against AlphaCore Pharma, LLC (ACP) and Bruce Auerbach. The decedent, Edmund Ward, was a participant in a clinical trial for a drug known as ACP-501, which was developed by ACP and administered by the National Institutes of Health (NIH). The trial took place in Maryland, where Ward traveled from his home in Massachusetts to receive treatment. Ward later withdrew from the trial due to deteriorating kidney function.In 2016, Ward filed a complaint against ACP, Auerbach, and several others, alleging fraudulent inducement to participate in the clinical trial. ACP and Auerbach moved to dismiss the case for lack of personal jurisdiction, arguing that they lacked sufficient contacts with Massachusetts. The United States District Court for the District of Massachusetts agreed with them and dismissed the case. Ward appealed to the United States Court of Appeals for the First Circuit.The First Circuit affirmed the district court's decision. The court held that neither ACP nor Auerbach had sufficient related and purposeful contacts in and with Massachusetts to establish personal jurisdiction. The court rejected Ward's claims that ACP and Auerbach had contacts with Massachusetts through their interactions with Ward's Massachusetts-based doctor, their alleged shipment of the drug to Massachusetts, their involvement in drafting the clinical trial protocol, and their alleged reimbursement of Ward's travel expenses. The court found that these claims were either unsupported by evidence or were not sufficient to establish personal jurisdiction. As a result, the court affirmed the district court's dismissal of the case against ACP and Auerbach for lack of personal jurisdiction. View "Ward v. Schaefer" on Justia Law

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In November 2010, Mario Cruzado was brought in for questioning by Boston police regarding the death of Frederick Allen III, a gay, African-American man. During the interview, Cruzado used a racial slur when referring to a picture of Allen. In 2012, Cruzado was charged and convicted of first-degree murder for killing Allen and was sentenced to life imprisonment. Cruzado's conviction was based, in part, on the recorded police interview, which was admitted as evidence to show Cruzado's racial animus and thus his motive for the killing. Cruzado appealed his conviction and the denial of his motion for a new trial, arguing that the admission of the recorded police interview violated his right to due process.The Massachusetts Supreme Judicial Court (SJC) consolidated Cruzado's appeals and denied them, holding that the state trial court did not abuse its discretion in determining that the probative value of the evidence outweighed its prejudicial effect. The SJC also stated that Cruzado's argument that the admission of the racial slur violated his due process rights was unavailing, as the slur came from his own mouth. Cruzado then filed a federal petition for writ of habeas corpus, which was denied by the United States District Court for the District of Massachusetts.In an appeal to the United States Court of Appeals for the First Circuit, Cruzado argued that the admission of the recorded police interview violated his right to due process. The Court held that Cruzado's due process rights were not violated, as the racial slur held substantial probative value in demonstrating whether the crime may have been partially motivated by racial animus. The Court also noted that the potential prejudicial effect of the racial slur was mitigated by the trial judge conducting an individual voir dire of potential jurors to eliminate potential bias and that Cruzado did not request a limiting instruction to disregard or not infer anything from his use of the racial slur. Therefore, the United States Court of Appeals for the First Circuit affirmed the District Court's rejection of Cruzado's petition for habeas relief. View "Cruzado v. Alves" on Justia Law

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In this case, Gary E. Leach was convicted of cyberstalking and extortion and subsequently sentenced to a term of forty-two months in prison, followed by thirty-six months of supervised release. The supervised release included a condition prohibiting Leach from working or volunteering in any capacity that would put him in direct contact with children without prior approval from his probation officer. Leach appealed his sentence and the condition of his supervised release, raising several arguments.First, Leach argued that the district court erred in not providing him with sufficient notice of its intention to impose an upwardly variant sentence. However, the First Circuit Court of Appeals disagreed, noting that a sentencing court is not required to give the parties advance notice before imposing an upwardly variant sentence. The court also noted that the factors justifying the upward variance were plainly apparent from the record.Second, Leach argued that his sentence was procedurally flawed due to the lack of a sufficient explanation to justify the above-guidelines sentence. The First Circuit rejected this argument, explaining that the district court had identified relevant factors justifying an upward variance and explained why the guidelines did not adequately account for each factor, given the idiosyncrasies of the case at hand.Third, Leach argued that his sentence was substantively unreasonable. The First Circuit disagreed, finding that the sentence fell within the "wide universe of supportable sentencing outcomes."Finally, Leach challenged the condition of his supervised release that prohibited him from working or volunteering in any capacity that would put him in direct contact with children. The First Circuit rejected this argument, finding that the condition was reasonably related to protecting the public from future crimes by Leach. The court also noted that the condition was not overly restrictive, as it only required Leach to secure advance approval from a probation officer for such activity if it would put him in direct contact with children.Therefore, the First Circuit affirmed Leach's sentence and the conditions of his supervised release. View "US v. Leach" on Justia Law

Posted in: Criminal Law
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In this case, the United States Court of Appeals for the First Circuit had to decide whether rainwater that accumulated on a parapet roof one or more stories above the ground is considered "surface waters" under Massachusetts law for the purposes of the insurance policies in question. This determination was crucial for deciding whether the insureds, Medical Properties Trust, Inc. (MPT) and Steward Health Care System LLC (Steward), were subject to coverage limitations on "Flood" damage in the policies issued by Zurich American Insurance Company (Zurich) and American Guarantee and Liability Insurance Company (AGLIC).The interpretation of "surface waters" posed a novel issue of Massachusetts law that had not been previously addressed by the Massachusetts Supreme Judicial Court (SJC). The court decided to certify the issue to the SJC as the existing case law did not provide a clear answer and the resolution may require policy judgments on applying Massachusetts law to this key insurance coverage issue.The case arose from a situation where Norwood Hospital Facility, a building owned by MPT and leased to Steward, suffered significant damage after severe thunderstorms. Rainwater accumulated on the hospital's roof and a second-floor courtyard, eventually seeping into the hospital's upper floors. Both Zurich and AGLIC, in their initial evaluations, determined that water damage in the hospital's basement was caused by "Flood," and would be subject to the policies' respective coverage limits. However, the insurers later characterized all the water damage, including that from the roof, as "surface water" and subject to the "Flood" coverage limits.The court concluded that whether rainwater pooled on a parapet roof constitutes "surface waters" in the policies' "Flood" definition is determinative of this interlocutory appeal. Therefore, the court certified the issue to the SJC for its consideration. View "Zurich American Insurance Co. v. Medical Properties Trust, Inc." on Justia Law

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Shaun Walker appealed his 36-month sentence for participating in a failed Hobbs Act conspiracy to rob a home business. Walker raised four objections to his sentence, including challenges to enhancements for economic loss and possession of dangerous weapons and denials of reductions for incomplete conspiracy and mitigating role. The United States Court of Appeals for the First Circuit found no error in the enhancements for economic loss and dangerous weapon possession, as well as the denial of incomplete conspiracy reduction. However, the Court vacated and remanded for resentencing on the issue of the mitigating role reduction. The Court was unable to affirm the district court's denial of the reduction due to a lack of explanation, and was unable to conclude that any error in the district court's application of the reduction was harmless. Therefore, the case was remanded for the district court to reevaluate Walker's role in the conspiracy. View "US v. Walker" on Justia Law

Posted in: Criminal Law
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This case involves the Boston Parent Coalition for Academic Excellence Corp., which challenged the temporary admissions plan for three selective public schools in Boston. The admissions plan was based on students' grade point averages (GPAs), zip codes, and family income, rather than on standardized test scores. The Coalition claimed that the plan had a disparate impact on White and Asian students and violated the Equal Protection Clause of the Fourteenth Amendment and Massachusetts law.The United States Court of Appeals for the First Circuit found that the Coalition's claim lacked merit. It held that the Coalition failed to show any relevant disparate impact on White and Asian students, who were over-represented among successful applicants compared to their percentages of the city's school-age population. The court also found that the Coalition failed to demonstrate that the plan was motivated by invidious discriminatory intent. It pointed out that the Plan's selection criteria, which included residence, family income, and GPA, could hardly be deemed unreasonable.The court noted that any distinction between adopting a criterion (like family income) notwithstanding its tendency to increase diversity, and adopting the criterion because it likely increases diversity, would, in practice, be largely in the eye of the labeler. It emphasized that the entire point of the Equal Protection Clause is that treating someone differently because of their skin color is not like treating them differently because they are from a city or from a suburb.The court also rejected the Coalition's appeal of the district court's denial of its motion under Federal Rule of Civil Procedure 60(b), which sought relief from the judgment based on newly discovered evidence that some members of the School Committee harbored racial animus. The court found that the district court did not abuse its discretion in denying the motion, as the Coalition had failed to show that the newly discovered evidence was of such a nature that it would probably change the result were a new trial to be granted.The court therefore affirmed the judgment of the district court. View "Boston Parent Coalition for Acad. Excellence Corp. v. The School Committee of the City of Boston" on Justia Law

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The case involves the defendant-appellant, Augusto Valdez, who appealed from his guilty plea and conviction for which he received 120 months' imprisonment, followed by a five-year term of supervised release. Valdez raised two issues: firstly, he asserted that the district court should have granted his motion to withdraw his guilty plea because he conspired only with a confidential source and not a co-conspirator, and that the court did not ensure that he knew he couldn't conspire illegally with a government agent. Secondly, he sought to vacate his sentence because the district court should have, on its own initiative, verified his eligibility for the safety valve under U.S.S.G. § 5C1.2.The United States Court of Appeals for the First Circuit affirmed the decision of the district court. The court found that Valdez knowingly and voluntarily entered his guilty plea and was not misled about the nature of the conspiracy charge, thereby rejecting his argument that his plea was not knowing, voluntary, and intelligent. His argument that he could not be convicted for conspiring only with a government agent was rejected because the facts revealed two true conspirators: Valdez and a Texas source. The court also found that Valdez waived his right to argue for the application of the safety valve because he failed to object to the PSR and requested the mandatory minimum sentence, which was inconsistent with his later argument for the application of the safety valve. View "United States v. Valdez" on Justia Law