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

In May 2021, a police officer in Goffstown, New Hampshire, observed a vehicle driving without headlights. When the officer attempted to stop the vehicle, the driver, later identified as Brian Elliott, fled, leading to a high-speed chase. Elliott eventually stopped and fled on foot, during which he allegedly pointed a firearm at the officer and threatened to shoot. Elliott was later apprehended, and a search revealed firearms, ammunition, and fentanyl in his possession.A federal grand jury in the District of New Hampshire indicted Elliott on four counts, including drug and firearm charges. Elliott pled guilty to three counts in exchange for the dismissal of one count and a sentencing recommendation within the guideline range. The district court accepted the plea agreement and, after a hearing, applied a six-level enhancement for assaulting a police officer during the offense. The court found the officer's testimony credible and calculated a guideline range of 108 to 135 months, ultimately sentencing Elliott to 120 months.The United States Court of Appeals for the First Circuit reviewed Elliott's appeal, which challenged the procedural and substantive reasonableness of his sentence. Elliott argued that the district court erred in applying the enhancement and that his sentence was substantively unreasonable. The First Circuit found no clear error in the district court's credibility determination regarding the officer's testimony and upheld the application of the enhancement. The court also held that the 120-month sentence was substantively reasonable, given the seriousness of the offense and Elliott's criminal history. Consequently, the First Circuit affirmed the district court's judgment. View "US v. Elliott" on Justia Law

Eucineia Soares da Silva Pazine, a Brazilian national, sought asylum in the United States, claiming she faced persecution from her husband, Lucas Luiz Pazine, and his associates. She testified that her husband was abusive, both physically and emotionally, and that after she left him and returned to Brazil with their children, she continued to receive threats from his cousin Dulce and his lawyers. These threats included surveillance and attempts to coerce her into giving up custody of her children and her property.An Immigration Judge (IJ) found her testimony credible but denied her asylum claim, stating that the abuse she suffered in the United States did not qualify as persecution under asylum law, which requires harm to occur in the applicant's home country. The IJ also concluded that the threats from Dulce and the lawyers were motivated by a personal dispute over custody and property, not by her membership in a particular social group (PSG) such as "Brazilian Women." Consequently, the IJ denied her applications for asylum, withholding of removal, and protection under the Convention Against Torture (CAT).The Board of Immigration Appeals (BIA) upheld the IJ's decision, agreeing that there was no nexus between the harm she feared and a protected ground under asylum law. The BIA found no clear error in the IJ's determination that the threats were related to a personal dispute rather than her membership in a PSG. The BIA also declined to address her new "pattern or practice" theory of persecution, as it was not raised before the IJ.The United States Court of Appeals for the First Circuit reviewed the case and denied the petition for review. The court found that substantial evidence supported the agency's no-nexus finding, concluding that the threats from Dulce and the lawyers were primarily motivated by personal disputes over custody and property, not by her gender or membership in a PSG. The court also noted that the BIA correctly applied the "one central reason" standard in its analysis. View "Pazine v. Garland" on Justia Law

Carlos Gonzalez's residence was searched by the government for evidence of an illegal pill-making operation. Gonzalez moved to suppress the evidence found during the search, arguing that the search warrant was based on stale information and lacked probable cause. The district court agreed, finding that the facts supporting the search warrant were too old and that the affidavit was so bare bones that no reasonable officer could have relied on it. The court noted that the mastermind of the operation had moved out months earlier, there was little suspicious activity afterward, and the equipment was portable.The United States District Court for the District of Massachusetts granted Gonzalez's motion to suppress the evidence. The court concluded that the information in the affidavit was too stale to support probable cause and that the connection between the residence and any recent criminal activity was extremely thin. The court also determined that the good-faith exception did not apply because the affidavit was too conclusory and lacked sufficient detail to justify reliance on the warrant.The United States Court of Appeals for the First Circuit reviewed the case. The court decided to bypass the probable-cause determination and focused on whether a reasonable officer could have relied on the warrant in good faith. The court found that a reasonable officer could have believed that the pill-making operation was still ongoing at the residence, given the long-standing nature of the operation, the continued ownership of the house by the mastermind, and the involvement of Gonzalez and his girlfriend. The court vacated the district court's ruling on the motion to suppress and remanded the case for further proceedings. View "US v. Gonzalez" on Justia Law

Jonathan Mullane, a law student intern at the United States Department of Justice (DOJ) in 2018, was terminated from his position due to ex parte communications with a law clerk regarding a pro se case he had filed. Subsequently, the United States Securities and Exchange Commission (SEC) rescinded an internship offer to him. Mullane requested documents related to his termination from both the DOJ and SEC under the Freedom of Information Act (FOIA) and the Privacy Act. He claimed that the agencies did not conduct adequate searches and improperly withheld documents. The agencies moved for summary judgment, and the district court granted their motions in full.The United States District Court for the District of Massachusetts granted summary judgment in favor of the DOJ and SEC, dismissing Mullane's claims. Mullane appealed the district court's decision regarding the DOJ, arguing that the DOJ's search for documents was inadequate and that the district court erred in holding that the Privacy Act imposes a jurisdictional exhaustion requirement. Mullane also challenged the district court's denial of his requests for pre-dismissal discovery.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the DOJ conducted an adequate search for documents under FOIA, as the search was reasonably calculated to discover the requested documents. The court also found that Mullane had waived any argument against the district court's conclusion that the Privacy Act's exhaustion requirements are jurisdictional. Consequently, the First Circuit affirmed the district court's grant of summary judgment in favor of the DOJ, dismissing Mullane's FOIA and Privacy Act claims. View "Mullane v. Department of Justice" on Justia Law

The case involves Juan Rodriguez and Junito Melendez, who were convicted of conspiracy to distribute and possess with intent to distribute more than 500 grams of cocaine. Melendez was identified as the front man of the operation, interacting with customers and suppliers, while Rodriguez managed backend operations from his residence. The operation involved acquiring cocaine from suppliers, cooking some into crack cocaine, and selling it. The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) began investigating the defendants in 2018, leading to the seizure of Melendez's iPhone and subsequent wiretaps that provided evidence of their drug activities.In the United States District Court for the District of Massachusetts, a jury found both defendants guilty of the conspiracy charges. Melendez was also found guilty of distributing 500 grams or more of cocaine and had a prior conviction for a serious drug felony. He pleaded guilty to conspiracy to commit Hobbs Act robbery. The district court sentenced Rodriguez to 52 months and Melendez to 156 months in prison. Melendez's sentence included enhancements for drug quantity and his role as an organizer or leader in the conspiracy.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's decisions, finding no error in the denial of motions to suppress evidence from Melendez's iPhone and wiretaps, the admission of certain evidentiary testimony, and the jury instructions. The court also upheld the sentencing enhancements for Melendez, concluding that the evidence supported the drug quantity attributed to him and his role as an organizer in the conspiracy. The court found that any potential errors were harmless and did not affect the overall outcome of the case. View "United States v. Rodriguez" on Justia Law

The case involves Esmeraldo Burgos-Balbuena, a Dominican Republic citizen, who was arrested after a high-speed boat chase off the coast of Puerto Rico. Burgos was charged with unlawfully reentering the United States after a previous removal. He accepted responsibility and agreed to plead guilty, with both parties recommending an 18-month prison sentence. However, the court sentenced him to 37 months, citing his repeated unlawful entries and dangerous evasion of arrest.The United States District Court for the District of Puerto Rico reviewed the case. Burgos's plea agreement included a joint recommendation for an 18-month sentence, but the presentence investigation report (PSR) calculated a sentencing range of 30 to 37 months due to a higher total offense level and a criminal history category of III. The district court accepted the PSR's calculations and sentenced Burgos to 37 months, emphasizing his criminal history and the dangerous nature of his recent offense.The United States Court of Appeals for the First Circuit reviewed the case. Burgos argued that the government failed to comply with the plea agreement and challenged his sentence on procedural and substantive grounds. The court found that the government adhered to the plea agreement by recommending the 18-month sentence and did not implicitly repudiate it. The court also found no procedural error in the district court's sentencing, noting that the court considered all relevant factors and provided a thorough explanation for the sentence. The court further held that the 37-month sentence was substantively reasonable given Burgos's criminal history and the dangerous nature of his conduct.The First Circuit affirmed the district court's decision, upholding Burgos's 37-month sentence. View "United States v. Burgos-Balbuena" on Justia Law

In 2023, Shaiquan Moran-Stenson pled guilty to unlawfully possessing ammunition as a felon, violating 18 U.S.C. § 922(g)(1). The U.S. District Court for the District of Maine enhanced his base offense level under the United States Sentencing Guidelines § 2K2.1(a)(4)(A), citing a prior Maine drug trafficking conviction. Moran-Stenson objected, arguing that his Maine conviction did not qualify as a predicate offense for the enhancement.The U.S. District Court for the District of Maine overruled Moran-Stenson's objection, applying the modified categorical approach to determine that his Maine drug trafficking conviction was a predicate offense. The court found that the Maine statute was divisible and that the specific drug involved, cocaine base, was a federally controlled substance. Consequently, the court sentenced Moran-Stenson to seventy-seven months in prison, followed by three years of supervised release.On appeal, the United States Court of Appeals for the First Circuit reviewed whether the district court correctly applied the modified categorical approach. The appellate court affirmed the district court's decision, holding that the Maine statute's "scheduled drugs" component was divisible. The court concluded that the specific drug trafficked, cocaine base, was an element of the offense, allowing the use of the modified categorical approach. The court found that Moran-Stenson's prior conviction for trafficking cocaine base qualified as a predicate controlled substance offense under § 2K2.1(a)(4)(A), justifying the sentencing enhancement. View "United States v. Moran-Stenson" on Justia Law

Amy Rae, a school nurse employed by Woburn Public Schools (WPS), alleged that she faced retaliatory harassment due to her advocacy for students with disabilities and complaints about her own mistreatment. Rae claimed that the harassment, primarily by Kennedy Middle School Principal Carl Nelson, began in 2011 and continued for over a decade. She filed a lawsuit in November 2022, asserting claims under Section 504 of the Rehabilitation Act, Title II of the Americans with Disabilities Act (ADA), Massachusetts's antidiscrimination statute (Chapter 151B), and for intentional infliction of emotional distress.The United States District Court for the District of Massachusetts dismissed Rae's complaint on May 5, 2023, ruling that she failed to state any claims for which relief could be granted. The court found that Rae could not rely on the continuing violations doctrine to save her untimely discrimination claims and dismissed her timely state and federal discrimination claims on other grounds.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court's dismissal de novo. The appellate court agreed that Rae could not invoke the continuing violations doctrine to rescue her time-barred claims, as her allegations included discrete acts of retaliation that accrued separately. The court also affirmed the district court's dismissal of Rae's timely ADA, Section 504, and Chapter 151B claims, concluding that Rae did not plausibly allege severe or pervasive harassment necessary to sustain a retaliatory harassment claim. The court noted that Rae's allegations of two incidents within the actionable period were insufficient to meet the standard for severe or pervasive harassment. Thus, the appellate court affirmed the district court's decision to dismiss Rae's complaint. View "Rae v. Woburn Public Schools" on Justia Law

Xiomara Santiago was hired as the Deputy Director for the Head Start Program in Utuado, Puerto Rico. Following a mayoral election, the new mayor, Jorge Pérez, terminated her employment. Santiago claimed her dismissal violated her Fourteenth Amendment due process rights and was politically motivated, violating her First Amendment rights. She sought a preliminary injunction to be reinstated.The United States District Court for the District of Puerto Rico held hearings and ultimately denied Santiago's request for a preliminary injunction. The court concluded that Santiago had not shown a likelihood of success on the merits of either her due process or political discrimination claims. The magistrate judge's Report & Recommendation, which the district judge adopted, found that Santiago's initial hire was contrary to Puerto Rico law, meaning she did not have a property interest in her employment. Additionally, the court found insufficient evidence to support her claim of political discrimination.The United States Court of Appeals for the First Circuit reviewed the district court's decision. The appellate court affirmed the lower court's ruling, agreeing that Santiago had not demonstrated a likelihood of success on the merits of her claims. The court noted that Santiago's argument regarding the incorrect application of Puerto Rico law was waived because it was raised for the first time on appeal. Furthermore, the court found no clear error in the district court's assessment that Santiago's political affiliation was not a substantial factor in her termination. The court concluded that the district court did not abuse its discretion in denying the preliminary injunction. View "Santiago v. Municipality of Utuado" on Justia Law

Sara Caruso, a flight attendant for Delta Air Lines, failed a breathalyzer test on August 4, 2018, after a layover in Dallas, Texas. Caruso claimed she was drugged and sexually assaulted by Delta First Officer James Lucas the night before. The Dallas Police Department found insufficient evidence to support her claim, and Delta also took no action against Lucas after its investigation. Caruso completed an alcohol rehabilitation program and sought accommodations from Delta for PTSD related to the alleged assault. Although Delta and Caruso initially agreed on accommodations, Caruso resigned after a month back at work.Caruso sued Delta in Massachusetts state court, alleging violations of Massachusetts General Laws chapter 151B, Title VII of the Civil Rights Act of 1964, and the Americans with Disabilities Act (ADA). The case was removed to the U.S. District Court for the District of Massachusetts, which granted summary judgment for Delta on all counts. The court found no causal connection between Delta's actions and the alleged harassment and determined that Delta responded reasonably to the allegations. Additionally, Caruso's disability discrimination claims failed because she did not engage in an interactive process in good faith with Delta to develop reasonable accommodations.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The court held that Caruso failed to show a causal connection between Delta's actions and the alleged harassment, and that Delta's investigation and response were reasonable. The court also found that Caruso did not cooperate in the interactive process for her disability accommodations, and her retaliation claims were either waived or undeveloped. Thus, the summary judgment for Delta was affirmed on all counts. View "Caruso v. Delta Air Lines, Inc." on Justia Law