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

In the spring of 2020, three veterans residing at the Soldiers’ Home in Chelsea, Massachusetts, died after contracting COVID-19. The personal representatives of the veterans’ estates filed suit against several Massachusetts state officials responsible for the facility, alleging violations of the veterans’ substantive due process rights under the Fourteenth Amendment. The complaint asserted that the officials failed to protect residents from COVID-19 by not implementing adequate safety protocols and maintaining inhumane living conditions, including lack of sanitation, improper restraint of residents, and exposure to illegal drugs.The United States District Court for the District of Massachusetts reviewed the complaint after the defendants moved to dismiss, arguing that the plaintiffs failed to state a claim for a substantive due process violation and that the officials were entitled to qualified immunity. The District Court granted the motion to dismiss. It held that the plaintiffs had not sufficiently alleged individual involvement by any defendant in the purported misconduct regarding COVID-19, and failed to provide details showing how the named veterans were specifically harmed by the living conditions. The court also found no clearly established legal authority placing the officials on notice that their conduct would violate the veterans’ rights, thus concluding qualified immunity applied.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s judgment. The First Circuit held that the complaint did not plausibly allege that the defendants directly caused the harm suffered by the veterans, nor did it sufficiently invoke exceptions to that requirement. The Court also found that the plaintiffs had not demonstrated a violation of clearly established law and thus, the defendants were entitled to qualified immunity. Consequently, the dismissal of the complaint was affirmed. View "Terenzio v. Urena" on Justia Law

A man was indicted for unlawful possession of a firearm and ammunition by a felon after Boston police discovered a loaded pistol under the front passenger seat of a car in which he was seated. The discovery occurred shortly after a drive-by shooting in the area, though later evidence showed the car was not involved in the shooting. Video evidence and police testimony established that the man exclusively occupied the front passenger seat from the time the car arrived at a market until the stop, wore a latex glove on his right hand, and repeatedly bent toward the floor mat area where the pistol was found. No fingerprints were found on the firearm, magazine, or ammunition.The United States District Court for the District of Massachusetts denied the defendant’s motions for judgment of acquittal and for a new trial. The motions argued the evidence was insufficient to prove possession and that the government’s references to the nearby shooting were prejudicial. The court found that, viewed in the light most favorable to the government, the circumstantial evidence—including the glove, the exclusive control over the seat, and his actions toward the floor—was sufficient for a reasonable jury to find constructive possession beyond a reasonable doubt.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the evidence supported the jury’s verdict of constructive possession under 18 U.S.C. § 922(g)(1). The appellate court affirmed that the district court correctly denied both the judgment of acquittal and the new trial motion, finding no miscarriage of justice or erroneous result. The court also affirmed the revocation of the defendant’s supervised release, as the evidence met the preponderance standard. The convictions and the revocation of supervised release were affirmed. View "United States v. Abercrombie" on Justia Law

Congress enacted a law in 2025 that withholds Medicaid funding for one year from certain abortion providers that meet four criteria, which in effect covers most Planned Parenthood affiliates and two other organizations. The statute also withholds funding from subsidiaries, successors, clinics, and “affiliates” of such entities, even if those affiliates do not themselves meet all four criteria. Some Planned Parenthood entities qualified for defunding under the law (“Qualifying Members”), while others did not (“Non-Qualifying Members”), but the latter still risked losing funding due to the ambiguous “affiliate” provision. Concerned about the impact on their ability to provide healthcare, Planned Parenthood Federation of America, a Qualifying Member, and a Non-Qualifying Member sued to enjoin enforcement, alleging the law was an unconstitutional bill of attainder, imposed unconstitutional conditions on their right of association, and violated equal protection.The United States District Court for the District of Massachusetts granted a temporary restraining order and then preliminary injunctions, finding that the plaintiffs were likely to succeed on all three claims. The court reasoned that the law punished Planned Parenthood in violation of the Bill of Attainder Clause, impermissibly conditioned Medicaid funding on disassociation from other affiliates in violation of the First Amendment, and failed equal protection review because it targeted Planned Parenthood for its associations. The government appealed these orders.The United States Court of Appeals for the First Circuit vacated the district court’s orders. The court held that the statute did not inflict punishment as understood in bill of attainder case law, but instead established new conditions prospectively on Medicaid funding. The court also held that the “affiliate” provision is best read to cover only entities under common corporate control, avoiding constitutional problems, and thus does not burden associational rights. Finally, the court found that the law is subject only to rational basis review and is rationally related to Congress’s objectives. The preliminary injunctions were vacated and the case remanded. View "Planned Parenthood Federation of America, Inc. v. Kennedy" on Justia Law

In March 1997, James Garrey was involved in a fatal altercation at a bar in Franklin, Massachusetts, where he stabbed and killed Corey Skog following a dispute. Garrey, who is white, was later convicted of first-degree murder by a Massachusetts jury and sentenced to life imprisonment. During jury selection, the prosecution exercised a peremptory strike to remove a minority-race juror, Juror 6-7. Garrey objected, arguing the strike was improper and motivated by race, referencing Batson v. Kentucky and Powers v. Ohio. The trial judge allowed the strike after the prosecutor cited the juror’s occupation as a guidance counselor as the reason, not her race.Garrey appealed his conviction to the Massachusetts Supreme Judicial Court (SJC), asserting that the trial judge erred by accepting the prosecutor’s justification and by referencing the lack of minority participants in the trial. The SJC affirmed the conviction, finding the prosecutor’s explanation sufficient and not pretextual, and that the trial judge did not improperly rely on racial considerations. Garrey’s subsequent motions for a new trial in state court were denied.He then petitioned the United States District Court for the District of Massachusetts for habeas corpus relief under 28 U.S.C. § 2254, alleging Batson and Powers errors and unreasonable factual findings by the SJC. The District Court denied relief, concluding the SJC’s application of federal law and findings were not unreasonable.On appeal, the United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the District Court. The First Circuit held that the SJC did not unreasonably determine the facts or misapply clearly established federal law under Batson or Powers, and found the prosecutor’s rationale and the trial court’s process constitutionally sufficient. The judgment denying habeas relief was affirmed. View "Garrey v. Kelly" on Justia Law

A dispute arose between two siblings, Wayne Orkin and Lisa Albert, over the operation and ownership of a business called Boost Web SEO, Inc. Orkin managed the day-to-day business and generated all of its revenue, while Albert incorporated the company and was listed as its registered agent and officer. No written agreements clarified their roles, profit sharing, or compensation. In 2014, residual income from a payment processing arrangement was assigned to Boost Web, which both parties treated as company revenue for years. In 2021, after a breakdown in their relationship, Albert cut Orkin’s access to company funds and accused him of fraudulent activities in communications with a third-party vendor. Orkin then redirected company revenues to an account he controlled, prompting legal action.The litigation began in Massachusetts Superior Court, where Orkin (and his father) sued Albert and her son for various state-law claims, and Albert removed the case to the U.S. District Court for the District of Massachusetts. Boost Web intervened with a crossclaim against Orkin. After partial summary judgment, the remaining claims—Orkin’s defamation and related claims against Albert, and Boost Web’s conversion claim against Orkin—proceeded to a bench trial. The district court ruled for Albert on the defamation claim, finding her email was not defamatory or was protected as true, and for Boost Web on conversion, awarding it damages for funds Orkin took as personal expenses and for redirected residuals. The court also found Orkin in contempt for interfering with its orders and permanently enjoined him from pursuing related litigation in Florida.The United States Court of Appeals for the First Circuit reviewed the case. It held that the district court erred in dismissing Orkin’s defamation claim, finding that Albert’s email could be defamatory per se and remanded for further proceedings on truthfulness. It affirmed the conversion judgment regarding the redirected residuals but vacated the judgment concerning personal expenses, holding that Orkin was entitled to some compensation and remanded to determine the appropriate amount. The court vacated the contempt order and the permanent injunction, finding the previous orders did not unambiguously decide Boost Web’s ownership. The case was remanded for further proceedings consistent with these holdings. View "Orkin v. Albert" on Justia Law

The case concerns an engineer who worked for a microchip design company. While employed, he downloaded proprietary design files, including a file for a microchip known as the HMC1022A, and retained them after leaving his employer. Shortly after his departure, he started a competing business that marketed and sold microchips bearing strong similarities to his former employer’s products, using some of the appropriated design files in the manufacturing process. He concealed the origins of these files by renaming them and sought to keep his new business secret from his former employer.A federal grand jury indicted him on a range of charges, including possession of stolen trade secrets, wire fraud, export violations, visa fraud, and unlawful procurement of citizenship. The United States District Court for the District of Massachusetts presided over the jury trial. The defendant was convicted on only one count: unlawful possession of a trade secret, specifically the design layout and GDS file for the HMC1022A microchip. He was acquitted of all other charges, and the court dismissed related charges against his business partner and spouse. Post-trial, the defendant moved to dismiss the indictment, arguing selective enforcement and prosecution on the basis of his Chinese ethnicity, but the district court denied these motions.Upon review, the United States Court of Appeals for the First Circuit affirmed the conviction. The court held that there was sufficient evidence for a reasonable jury to find that the file in question was both a trade secret and that the defendant knew it to be so. The court also affirmed the district court’s rejection of the selective prosecution and enforcement claims, determining that the defendant had not shown similarly situated individuals of a different race were treated differently, nor that the investigation or prosecution was motivated by discriminatory purpose. The conviction and sentence were therefore upheld. View "United States v. Yu" on Justia Law

A woman from Peru entered the United States in 2013 without valid documents and was later placed in removal proceedings. She conceded removability but sought asylum, withholding of removal, and protection under the Convention Against Torture, primarily based on years of physical and sexual abuse she experienced from her former partner, Mauro. She described a lengthy relationship characterized by escalating violence, failed police protection, and threats involving their child. De La Cruz claimed she was persecuted due to her membership in several proposed social groups, mostly linked to her status as a Peruvian woman in various familial or social configurations, and she submitted evidence about gender-based violence in Peru.The Immigration Judge found De La Cruz credible and her asylum application timely but denied all forms of relief. The judge concluded that the abuse she suffered was not on account of a statutorily protected ground, but rather arose from personal disputes within the relationship. As such, the judge found no sufficient nexus between the harm and the protected grounds necessary for asylum or withholding of removal, and determined her fear of future torture was speculative and unsupported for CAT relief. The Board of Immigration Appeals affirmed, agreeing that the Immigration Judge applied the correct legal standards and did not clearly err in the factual findings.The United States Court of Appeals for the First Circuit reviewed the case, applying substantial evidence review to factual findings and de novo review to legal conclusions. The court held that substantial evidence supported the agency’s determination that there was no nexus between the harm suffered and a protected ground, and agreed that the fear of future torture was too speculative to warrant CAT protection. Accordingly, the petition for review was denied. View "De La Cruz-Quispe v. Bondi" on Justia Law

The plaintiff was an employee of the Puerto Rico Aqueduct and Sewer Authority and a former member of the relevant labor union. In 2016, he attempted to resign from the union and objected to the continued deduction of union dues from his wages, arguing that compelled dues for non-bargaining activities violated his First Amendment rights. The employer and union, acting under Puerto Rican law and the terms of a collective bargaining agreement, denied his requests, continued to deduct dues, and the plaintiff filed suit seeking declaratory, injunctive, and monetary relief.The United States District Court for the District of Puerto Rico presided over the initial proceedings. After the Supreme Court’s decision in Janus v. American Federation of State, County, and Municipal Employees overruled Abood v. Detroit Board of Education and invalidated mandatory union payments by nonmembers in the public sector, the employer and union ceased deducting dues from the plaintiff. The union then sought to deposit the amount withheld after his resignation, plus interest and nominal damages, with the court. The District Court ultimately granted the union’s request to deposit funds and dismissed the plaintiff’s claims as moot, reasoning that he had received all requested relief. The plaintiff’s subsequent motion to alter or amend the judgment was denied, with the court stating he was entitled to the deposited funds.The United States Court of Appeals for the First Circuit reviewed the appeal. The First Circuit found that the plaintiff was entitled to the funds deposited by the union, rejecting the argument that there was no judgment awarding him monetary relief. However, the court determined that the issue of whether the plaintiff could seek prevailing party attorneys’ fees—potentially affecting mootness—had not been fully addressed below. The First Circuit remanded the case to the District Court for further proceedings on that issue, while retaining jurisdiction over the appeal. View "Cruz v. UIA" on Justia Law

A Haitian national, Jonalson Dor, was admitted to the United States as a lawful permanent resident in 2007. In August 2018, he pled guilty in Massachusetts state court to possession of marijuana with intent to distribute under Massachusetts law. At that time, both state and federal law included "hemp" in the definition of "marijuana." In December 2018, Congress amended the federal Controlled Substances Act (CSA) to exclude "hemp" from its definition of "marijuana." The Department of Homeland Security initiated removal proceedings against Dor in 2019, originally based on earlier marijuana convictions. Those convictions were later vacated, and in 2023, DHS amended its charges, basing Dor’s removability on his 2018 conviction.An Immigration Judge in Boston denied Dor’s motion to terminate the proceedings, holding that the relevant version of the CSA was the one in effect at the time of the criminal conviction, not at the time of removal. The judge found Dor removable under the INA’s controlled substance provision. Dor appealed to the Board of Immigration Appeals (BIA), which affirmed the IJ’s decision on March 18, 2025, agreeing that the time of conviction was the controlling point for determining if a state conviction matches the federal controlled substance definition.Reviewing the case de novo, the United States Court of Appeals for the First Circuit considered whether the definition of a “controlled substance” under the INA should reference the CSA as it existed at the time of conviction or at the time of removal proceedings. The court joined other circuits in holding that the relevant CSA definition is the one in effect at the time of conviction. Because Dor’s 2018 conviction categorically matched the federal definition then in force, the court denied his petition for review and upheld the removal order. View "Dor v. Bondi" on Justia Law

This case involves allegations of Medicare fraud under the False Claims Act (FCA) against MD Labs, an independent clinical laboratory. Between 2017 and 2019, OMNI Healthcare, a medical practice, sent MD Labs nearly 600 requests for PCR urinary tract infection (UTI) tests, which are more costly than traditional bacterial urine culture (BUC) tests. OMNI, acting on the instruction of its owner, directed staff to order only PCR tests, even when providers had requested BUC tests, with the admitted intention of building a Medicare fraud case against MD Labs. There is no evidence MD Labs knew of OMNI's intentions; MD Labs simply received and processed test orders submitted by physicians.The United States District Court for the District of Massachusetts reviewed the case after discovery and cross-motions for summary judgment. OMNI alleged that MD Labs “knowingly” submitted false claims to Medicare by seeking reimbursement for medically unnecessary PCR tests. MD Labs argued it was entitled to rely on the ordering physician’s determination of medical necessity and that it lacked the required scienter for FCA liability. The district court granted summary judgment to MD Labs, finding that OMNI had not produced sufficient evidence that MD Labs “knowingly” submitted false claims.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s decision. The court held, as a matter of first impression in the circuit, that a laboratory generally may rely on a doctor’s order as evidence that a test is medically necessary for FCA purposes, absent evidence of fraud or other improper conduct by the lab. OMNI failed to present evidence that MD Labs had actual knowledge, was deliberately indifferent, or recklessly disregarded the medical necessity of the tests ordered. Accordingly, summary judgment was affirmed for MD Labs on all federal and state claims. View "United States, ex rel. Omni Healthcare Inc. v. MD Spine Solutions LLC" on Justia Law