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

Brian Watson was convicted in 2017 by a jury for the felony sale of a controlled drug (fentanyl) resulting in death. The prosecution's evidence included testimony from Dr. Daniel Isenschmid, a forensic toxicologist, who discussed toxicology tests conducted by his colleagues, revealing fentanyl and its metabolites in the victim's blood. Watson appealed, arguing that the trial court erred by allowing Dr. Isenschmid to testify about tests he did not perform. The New Hampshire Supreme Court affirmed the conviction, finding that Dr. Isenschmid's involvement in the case was sufficient to satisfy the Confrontation Clause.Watson then filed a habeas corpus petition under 28 U.S.C. § 2254 in the United States District Court for the District of New Hampshire, claiming that his Confrontation Clause rights were violated by Dr. Isenschmid's testimony. The warden moved for summary judgment, which the district court granted, concluding that the state court's decision was neither contrary to nor an unreasonable application of Supreme Court precedent.The United States Court of Appeals for the First Circuit reviewed the case and upheld the district court's decision. The court found that Watson did not provide clear and convincing evidence to show that the state court's factual findings were incorrect. The court also determined that the state court's decision was not contrary to or an unreasonable application of clearly established federal law. The First Circuit noted that Dr. Isenschmid had personally reviewed all relevant documentation, data, and test results, and had issued and signed the toxicology report, making his testimony permissible under the Confrontation Clause. The court affirmed the district court's grant of summary judgment in favor of the warden. View "Watson v. Edmark" on Justia Law

In 2020, a federal grand jury indicted David DeQuattro, an architect, and Cedric Cromwell, Chairman of the Mashpee Wampanoag Tribal Council and President of the Mashpee Wampanoag Gaming Authority. They were charged with various federal offenses, including bribery and extortion, related to Cromwell allegedly soliciting and DeQuattro allegedly providing checks and other items of value to protect a contract between DeQuattro's firm and the Gaming Authority for building a casino on tribal land.The United States District Court for the District of Massachusetts held a jury trial where DeQuattro was convicted of one count of federal-program bribery, and Cromwell was convicted of two counts of federal-program bribery and multiple counts of Hobbs Act extortion. However, the District Court later entered a judgment of acquittal on the Hobbs Act-related counts, determining that the Hobbs Act did not clearly abrogate tribal immunity. Both defendants appealed their § 666 convictions, and the government cross-appealed the judgment of acquittal on the Hobbs Act counts.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed both the § 666 convictions and the judgment of acquittal. The court found that the evidence did not suffice to show that the RGB contract was "business" of the Tribe, as required under § 666, because the Gaming Authority, which entered the contract, was a separate legal entity from the Tribe and received almost all its funding from a third party. The court also reversed the District Court's judgment of acquittal on the Hobbs Act convictions, holding that tribal officials do not enjoy immunity from federal criminal prosecution and that the evidence was sufficient to show Cromwell's intent to engage in a quid pro quo arrangement. The case was remanded for further proceedings consistent with this opinion. View "United States v. Dequattro" on Justia Law

Michael Hermalyn, a former employee of DraftKings, left his position to join a rival company, Fanatics, based in California. DraftKings, headquartered in Massachusetts, claimed that Hermalyn's new role violated a noncompete agreement he had signed, which included a Massachusetts choice-of-law provision and a one-year noncompete clause. DraftKings sued Hermalyn in the U.S. District Court for the District of Massachusetts for breach of the noncompete agreement.The district court sided with DraftKings, applying Massachusetts law to determine the enforceability of the noncompete agreement. The court found the noncompete enforceable and issued a preliminary injunction preventing Hermalyn from competing against DraftKings in the United States for one year. Hermalyn appealed, arguing that California law, which generally bans noncompetes, should apply instead of Massachusetts law. Alternatively, he argued that if Massachusetts law applied, the injunction should exclude California.The United States Court of Appeals for the First Circuit reviewed the case. The court examined whether the district judge abused her discretion in granting the preliminary injunction and whether she made any legal errors in applying Massachusetts law. The appellate court found that Massachusetts law was correctly applied, noting that Massachusetts generally respects choice-of-law provisions unless they violate a fundamental policy of another state with a materially greater interest. The court concluded that Hermalyn failed to demonstrate that California's interest in banning noncompetes was materially greater than Massachusetts's interest in enforcing them.The First Circuit also upheld the scope of the preliminary injunction, rejecting Hermalyn's argument to exclude California. The court reasoned that excluding California would undermine the effectiveness of the injunction, as Hermalyn's role involved interacting with clients in states where online sports betting is legal. Consequently, the appellate court affirmed the district court's decision and awarded costs to DraftKings. View "DraftKings Inc. v. Hermalyn" on Justia Law

Two pilots, Luis F. Bonnet and Carlos R. Benítez Maldonado, were employed by Benítez Aviation, Inc. (BAI), which managed a Cessna aircraft. In April and May 2019, Bonnet and Benítez piloted several flights without the required certificates for commercial operations. The FAA suspended their Airline Transport Pilot (ATP) certificates for 270 days, alleging they operated the flights as air carriers or commercial operators without proper certification. The pilots received their regular salaries but no additional compensation for these flights.The FAA issued a Notice of Proposed Certificate Action, which the pilots appealed to the National Transportation Safety Board (NTSB). An administrative law judge (ALJ) upheld the FAA's suspension order, finding that the flights were conducted for compensation and hire, thus requiring compliance with Part 135 regulations. The NTSB affirmed the ALJ's decision, concluding that the flights were subject to air carrier or commercial operator requirements and that the pilots violated multiple FAA regulations. The NTSB also found that the ALJ did not exhibit bias and that the 270-day suspension was appropriate.The United States Court of Appeals for the First Circuit reviewed the case. The court held that substantial evidence supported the NTSB's findings that the flights were operated as common carriers for compensation, thus requiring Part 135 certification. The court also found that the pilots were responsible for ensuring compliance with FAA regulations, regardless of BAI's role in booking the flights. The court upheld the NTSB's decision, including the 270-day suspension of the pilots' certificates, finding it justified based on the pilots' regulatory violations and the potential risk to passenger safety. The petition for review was denied. View "Bonnet v. Whitaker" on Justia Law

Joyce Toth purchased a Food Sensitivity Test from Target's website and followed the instructions to create an account on Everlywell's website, where she clicked a checkbox indicating that she had read and accepted the terms and conditions. These terms included an arbitration agreement. Toth later received test results that she found confusing and inaccurate, leading her to file a putative class action against Everlywell, alleging deceptive marketing and misuse of personal medical information.The United States District Court for the District of Massachusetts granted Everlywell's motion to compel arbitration, holding that Toth had formed a valid "clickwrap" contract by clicking the checkbox. The court found that Everlywell provided reasonable notice of the terms and secured Toth's assent. It also rejected Toth's arguments that the contract lacked consideration, that Everlywell did not provide reasonable notice, and that the contract was illusory or unconscionable.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court held that Toth had received reasonable notice of the terms and had meaningfully assented to them by clicking the checkbox. The court also found that the arbitration agreement was valid and enforceable, noting that the User Agreement incorporated the AAA rules, which delegate issues of arbitrability to the arbitrator. Toth's arguments regarding the unilateral-modification clauses and the alleged unconscionability of the arbitration agreement were deemed insufficient to invalidate the delegation provision. Thus, the court concluded that the arbitration agreement was enforceable, and Toth's claims must be resolved through arbitration. View "Toth v. Everly Well, Inc." on Justia Law

José Santana De la Rosa and José Algarín Pabón filed a lawsuit against Edwin Santana De la Rosa, alleging abuse of process under Puerto Rico law. They claimed that Edwin, who had sued them in Puerto Rico over financial dealings, had changed his domicile to New York after Hurricane Maria in 2017, thus establishing diversity jurisdiction for their federal case. Edwin moved to dismiss the case for lack of subject matter jurisdiction, asserting he was still domiciled in Puerto Rico. The district court ordered jurisdictional discovery, which revealed Edwin's significant ties to both Puerto Rico and New York.The U.S. District Court for the District of Puerto Rico found that although Edwin spent considerable time in New York after the hurricane, José and Algarín failed to prove that Edwin intended to remain there indefinitely. The court noted Edwin's continued ties to Puerto Rico, including his Puerto Rico address on tax returns, a Puerto Rico driver's license, and voter registration. Consequently, the district court granted Edwin's motion to dismiss for lack of subject matter jurisdiction.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the district court did not clearly err in its determination that Edwin did not intend to change his domicile to New York. The court emphasized that Edwin's continued ties to Puerto Rico, such as his tax filings, driver's license, and voter registration, supported the district court's conclusion. The appellate court also declined José and Algarín's request for an evidentiary hearing, noting that they had not timely requested it during the lower court proceedings. View "Santana de la Rosa v. Santana de la Rosa" on Justia Law

Ken Johansen filed a lawsuit against Liberty Mutual, alleging violations of the Telephone Consumer Protection Act (TCPA). Liberty Mutual had contracted with Digitas, Inc. for marketing services, which included ensuring compliance with legal requirements. Johansen's complaint stemmed from telemarketing calls he received, which were traced back to Spanish Quotes, a subcontractor of Digitas. Liberty Mutual sought indemnification from Digitas under their Master Services Agreement (MSA), which included a warranty and indemnification clause.The United States District Court for the District of Massachusetts reviewed the case and found that Digitas had breached its contractual duty to indemnify Liberty Mutual. The court partially granted Liberty Mutual's motion for summary judgment, determining that Digitas had violated its warranty by allowing telemarketing practices that led to Johansen's complaint. The court also found that Liberty Mutual had met the preconditions for triggering Digitas's indemnity obligation. However, the court did not determine the damages and closed the case, leading Digitas to appeal.The United States Court of Appeals for the First Circuit reviewed the appeal. The court affirmed the district court's decision, agreeing that Digitas breached its warranty and that Liberty Mutual satisfied the preconditions for indemnification. The appellate court concluded that the MSA did not require a finding of actual liability for the indemnity obligation to be triggered. The court also found that Liberty Mutual had provided Digitas with the opportunity to control the defense, which Digitas did not properly assume. The case was remanded for further proceedings to address any remaining issues, including the determination of damages. View "Liberty Mutual Insurance v. Digitas, Inc." on Justia Law

The case involves James Harper, who challenged an IRS "John Doe" summons issued to Coinbase, a cryptocurrency exchange, seeking records of numerous customers, including Harper. Harper argued that the IRS's actions violated his Fourth and Fifth Amendment rights and did not meet statutory requirements under the Administrative Procedure Act (APA). The IRS had issued the summons to investigate potential tax noncompliance among Coinbase users.The United States District Court for the District of New Hampshire dismissed Harper's complaint. The court found that Harper lacked a reasonable expectation of privacy in his Coinbase account information and that the records were Coinbase's property, not Harper's. The court also concluded that the IRS summons was reasonable and that Harper had received constitutionally adequate process. Additionally, the court dismissed Harper's statutory challenge, ruling it was an improper collateral attack on prior district court proceedings that had enforced the summons and found it met statutory standards.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 Harper lacked a protectable interest under the Fourth or Fifth Amendment. It held that Harper had no reasonable expectation of privacy in the information he voluntarily provided to Coinbase and that the records were Coinbase's property. The court also found that Harper's due process claim failed because he had no protected liberty interest in the confidentiality of his financial information. Finally, the court ruled that the IRS summons was not "final agency action" under the APA, thus not subject to judicial review.The First Circuit affirmed the district court's dismissal of Harper's complaint, concluding that Harper's constitutional and statutory claims were without merit. View "Harper v. Werfel" on Justia Law

The defendant pleaded guilty to one count of coercion and enticement of a minor. The plea agreement included a joint recommendation for a 120-month sentence, which is the statutory minimum, despite the calculated Guidelines sentencing range being significantly higher. The government did not provide an explanation for this recommendation at the sentencing hearing. The district court sentenced the defendant to 292 months in prison, imposed a condition of supervised release prohibiting unsupervised contact with any minor, including his children, and ordered a special assessment and restitution.The defendant appealed, arguing that the government breached the plea agreement by not adequately supporting the recommended sentence and that the sentence and conditions imposed were unreasonable. The United States Court of Appeals for the First Circuit reviewed the case. The court agreed that the government breached the plea agreement by failing to provide a minimal explanation for the recommended sentence, which was necessary given the significant downward variance from the Guidelines range. However, the court concluded that this breach did not constitute plain error and affirmed the length of the sentence as reasonable.The court also upheld the restriction on the defendant's unsupervised contact with his children, finding it reasonably related to the nature of the offense and necessary to protect the community and minors. However, the court vacated the special assessment and restitution orders, remanding these issues to the district court for further consideration. The special assessment was vacated because the district court did not make a finding regarding the defendant's indigency, and the restitution order was vacated because the district court did not find that the victim's mother was a victim within the statutory definition. View "United States v. Acevedo-Osorio" on Justia Law

In February 2013, a correctional officer named Osvaldo Albarati was murdered while driving home from the federal prison where he worked. Oscar Martínez-Hernández, an inmate at the prison, was convicted and sentenced to life imprisonment for orchestrating the murder. The prosecution argued that Martínez-Hernández, along with another inmate, planned the killing in retaliation for Albarati's efforts to confiscate contraband, including cellphones, from inmates. The defense contended that the evidence was insufficient and that the government had manipulated evidence and allowed false testimony.The United States District Court for the District of Puerto Rico oversaw the trial, which lasted twelve days and included testimony from twenty government witnesses. The defense presented two witnesses. The jury found Martínez-Hernández guilty on all counts, including aiding and abetting the murder of a federal officer, conspiracy to commit murder, murder for hire, and related firearms charges. The defense's motion for a new trial, based on the late disclosure of a prison logbook and other alleged errors, was denied by the district court.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the evidence presented at trial was sufficient to support the jury's verdict. The court also concluded that the late disclosure of the prison logbook did not warrant a new trial, as the logbook's contents did not significantly undermine the overwhelming evidence of Martínez-Hernández's guilt. The court rejected the defense's claims of prosecutorial misconduct and improper admission of hearsay statements, finding no abuse of discretion by the district court. The court affirmed Martínez-Hernández's conviction and the denial of his motion for a new trial. View "United States v. Martinez-Hernandez" on Justia Law