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

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The First Circuit reversed in part and affirmed in part the decision of the district court dismissing with prejudice Plaintiff's claims of alleging that he was denied the fruits of a profitable exclusive-seller agreement for the sale of a Ferrari when Defendant caused the breach of that agreement by threatening economic harm to the other party to the contract, holding that Plaintiff plausibly pleaded his claim of tortious interference with an existing contract. Plaintiff brought suit against Defendant alleging claims of tortious interference with an advantageous business relationship, tortious interference with an existing contract, and violations of Massachusetts's Consumer Protection Law, Mass. Gen. Laws ch. 93A, 11. The district court dismissed the suit, concluding that Plaintiff had failed plausibly to allege any impermissible motive or means of interference with Plaintiff's business relationships or existing contracts. The First Circuit reversed in part, holding (1) Plaintiff plausibly pleaded that Defendant harmed Plaintiff by tortiously interfering with the contract; and (2) the district court correctly dismissed Plaintiff's remaining claims. View "Hamann v. Carpenter" on Justia Law

Posted in: Consumer Law, Contracts
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The First Circuit affirmed the judgment of the district court concluding that the denial of Plaintiff's disability benefits claim violated the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., holding that Aetna Life Insurance Company's decision to deny Plaintiff's benefits claim was arbitrary and capricious. Plaintiff employed for benefits under his employer's long-term disability benefits plan, which Aetna administered and funded, after Plaintiff was diagnosed with malignant melanoma. Aetna denied the application under the plan's exclusion for disabilities caused by pre-existing conditions. Plaintiff subsequently brought this action. The district court entered judgment for Plaintiff and awarded him back benefits, interest, fees, and costs. The First Circuit affirmed, holding that an unconflicted fiduciary would likely have found coverage. The Court remanded the case for any further proceedings that may be necessary. View "Lavery v. Restoration Hardware Long Term Disability Benefits Plan" on Justia Law

Posted in: ERISA
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The First Circuit affirmed Appellants' convictions for drug trafficking under the Maritime Drug Law Enforcement Act (MDLEA), 46 U.S.C. 70501-70508, holding that the protective principle of international law permitted the United States to arrest and prosecute Appellants even if, as they argued, their vessel possessed Costa Rican nationality. Appellants were on a small speed boat in the western Caribbean Sea when they were interdicted by the U.S. Coast Guard and subsequently arrested. Appellants moved to dismiss their indictment under the MDLEA, which allows U.S. law enforcement to arrest foreign nationals for drug crimes committed in international waters, arguing that the statute exceeds Congress's authority under Article I of the Constitution and violates the Due Process Clause. The district court denied the motion to dismiss, and Appellants pleaded guilty. On appeal, Appellants again challenged the constitutionality of the MDLEA, arguing that their vessel was not properly deemed stateless. The First Circuit affirmed, holding (1) the protective principle of international law, as applied by the First Circuit, permits prosecution under the MDLEA even of foreigners on foreign vessels; and (2) there was no abuse of discretion in the sentence imposed. View "United States v. Davila-Reyes" on Justia Law

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The First Circuit vacated the decision of the Board of Immigration Appeals (BIA) denying Petitioner's motion to reopen as untimely, holding that the grounds that the BIA gave for rejecting Petitioner's arguments were not sustainable and thus could not support the BIA's decision to reject Petitioner's motion as untimely. Petitioner, a Guatemalan national who entered the United States without inspection, faced the prospect of removal on the basis of a 2010 BIA decision denying her asylum, withholding of removal, and relief under the Convention Against Torture. Years later, Petitioner filed a motion to reopen and sought to excuse the untimeliness of the motion on the basis of changed country conditions in Guatemala. The BIA denied the motion as untimely. The First Circuit vacated the BIA's decision and remanded, holding that sufficient evidence did not support the BIA's grounds for rejecting Petitioner's changed country arguments, and therefore, the BIA erred in rejecting Petitioner's motion as untimely. View "Perez-Tino v. Barr" on Justia Law

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In this federal whistleblower case, the First Circuit granted Petitioner's petition for review of the determination of the Merit Systems Protection Board (MSPB) dismissing Petitioner's Individual Right of Action appeal under the Whistleblower Protection Act (WPA), 5 U.S.C. 1214(a)(3), holding for the first time in this circuit that the WPA only requires that a complainant include sufficient factual basis to enable an agency to investigate. Petitioner alleged that his supervisors retaliated against him because he delivered a document to a colleague that the colleague later used to support his own whistleblower case against the agency. Before the MSPB, Petitioner argued (1) he suffered reprisal for "lawfully assisting" the coworker in the coworker's exercise of his rights under the WPA, and (2) even if he did not engage in a protected activity, he was perceived by the agency and his supervisors to have done so and, as a result, suffered reprisal. The MSPB concluded that Petitioner's actions had been too minimal to constitute actual assistance under the WPA and that Petitioner had failed to exhaust his perceived assistance claim. The First Circuit remanded the case for further proceedings, holding that Petitioner satisfied the WPA's exhaustion requirement as to his perceived assistance claim. View "Mount v. U.S. Department of Homeland Security" on Justia Law

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The First Circuit vacated Defendant's conviction of conspiracy to provide material support to ISIS but affirmed his remaining convictions, holding that the court erred in instructing the jury on the conspiracy to provide material support to ISIS count and that the error was not harmless. Defendant was conviction of conspiracy to provide material support to ISIS (Count One), conspiracy to obstruct justice (Count Two), obstruction of justice (Count Three), conspiracy to commit acts of terrorism transcending national boundaries (Count Four), and obstruction of justice (Count Five). The First Circuit vacated the conviction on Count One and affirmed the remaining convictions, holding (1) the instruction as to count one with respect to the definition of "coordination" constituted legal error, and the error was not harmless; and (2) Defendant was not entitled to reversal on his remaining convictions. View "United States v. Wright" on Justia Law

Posted in: Criminal Law
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The First Circuit denied Petitioner's petition for judicial review of the decision of the Board of Immigration Appeals (BIA) affirming the immigration judge's (IJ) denial of Petitioner's application for refugee status, holding that substantial evidence supported the findings of the immigration court. Petitioner, a native of El Salvador, entered the United States unlawfully. Petitioner sought asylum, withholding of removal, and relief under the Convention Against Torture, asserting that he was abused and threatened as a child by family and purported gang members in El Salvador. The IJ denied Petitioner's application for refugee status and ordered his removal to El Salvador. The BIA dismissed Petitioner's appeal and affirmed the IJ. The First Circuit affirmed, holding that substantial evidence supported the immigration court's findings. View "Miranda-Bojorquez v. Barr" on Justia Law

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The First Circuit affirmed the judgment of the district court denying Defendant's motion to suppress approximately twenty pounds of methamphetamine that a postal inspector delivered in two United States Postal Service Priority Mail Express packages, as well as the fruits of the packages' search, holding that the warrant authorizing one package's search was valid and that the warrantless search of the other package was constitutional. The district court assumed arguendo that Defendant held a reasonable expectation of privacy in the searched packages then concluded that neither search was unconstitutional. The First Circuit affirmed, holding (1) the warrant authorizing the search of one package was not facially invalid despite the government's attachment of the incorrect attachment because the error was a mere technical error and the package was described with sufficient particularity and there was no reasonable probability of another package being searched; and (2) the warrantless search of the second package was justified by both the private search doctrine and the consent of the package's addressee. View "United States v. Moss" on Justia Law

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The First Circuit affirmed the dismissal of Appellants' suit for declaratory and injunctive relief in federal court against the FBI seeking an order directing the FBI to upload a DNA profile to the national DNA database and to report the results, holding that the FBI's determination that the profile was ineligible for upload was not arbitrary or capricious. Appellant were convicted of murder and spent twenty years incarcerated. Appellants were granted a new trial after new testing of trial evidence cast doubt on the verdicts. Thereafter, DNA testing was conducted on a swab taken from the inside of a condom recovered in the vicinity of the victim during the initial investigation. The testing revealed an unknown male DNA profile. The FBI refused to upload the profile into the National DNA Index System, determining that it was ineligible for upload. Appellants then filed this suit seeking to compel the FBI to upload the profile. The district court dismissed the suit, concluding that the FBI's eligibility determination was unreviewable. The First Circuit affirmed, holding that, assuming that the FBI's eligibility determination was reviewable, the determination was not arbitrary and capricious. View "Cowels v. Federal Bureau of Investigation" on Justia Law

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The First Circuit affirmed the order of the district court granting summary judgment in favor of Defendant on Plaintiff's Age Discrimination in Employment Act (ADEA) claim regarding the termination of Plaintiff's employment, holding that the totality of the circumstances showed a lack of foundation for Plaintiff's pretextual argument. In granting Defendant's motion for summary judgment, the district court determined that the evidence did not support Plaintiff's argument that Defendant's articulated reason for terminating Plaintiff's employment was pretextual, let alone a pretext for age discrimination. The First Circuit affirmed, holding the district court did not misapply the summary judgment standard or err in holding that no reasonable fact-finder could determine that Defendant's reasons for terminating Plaintiff were pretextual. View "Rodriguez-Cardi v. MMM Holdings, Inc." on Justia Law