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

Marilyn Besosa-Noceda moved from Puerto Rico to Texas with her daughter, whose biological father, Emmanuel Santiago-Melendez, objected to the relocation and subsequently filed criminal charges against Besosa, alleging she deprived him of access to his child. Santiago’s complaint led to Besosa’s arrest in Texas and extradition to Puerto Rico. Ultimately, the criminal charges were dismissed after Besosa demonstrated a lack of probable cause.After the dismissal, Besosa filed suit in the United States District Court for the District of Puerto Rico against the police officer who received Santiago’s complaint, the prosecutor who authorized the criminal charges, and the prosecutor’s supervisor. She alleged malicious prosecution under 42 U.S.C. § 1983 and Commonwealth law, claiming her constitutional rights were violated by the initiation of legal process unsupported by probable cause. The defendants moved for summary judgment, which the district court granted. The court found the arrest warrant was issued by a judge based on probable cause and was not obtained through false statements or omissions. The district court also rejected Besosa’s claim that her absence from the probable cause hearings violated her rights, finding no entitlement under Commonwealth law to be present at such hearings.On appeal, the United States Court of Appeals for the First Circuit reviewed Besosa’s arguments, including a challenge to an unresolved discovery dispute and the merits of the summary judgment ruling. The First Circuit held that Besosa failed to invoke the proper procedural mechanism to delay summary judgment pending discovery and that she did not present evidence showing the defendants knowingly provided false information or recklessly disregarded the truth when seeking the arrest warrant. The First Circuit affirmed the district court’s grant of summary judgment for the defendants. View "Besosa-Noceda v. Capo-Rivera" on Justia Law

In early 2025, the National Institutes of Health (NIH), an agency within the Department of Health and Human Services (HHS), issued a Supplemental Guidance that implemented a uniform 15% cap on indirect cost reimbursement for all NIH-funded research grants, effective almost immediately. Indirect costs, which include necessary administrative and facility expenses not attributable to a single research project, had previously been negotiated individually with grant recipients according to established regulations and memorialized in negotiated indirect cost rate agreements (NICRAs). The new policy would substantially reduce the reimbursement many recipients, such as universities and hospitals, could receive under existing and future grants.Shortly after the guidance was issued, a coalition of states, medical associations, and higher education organizations challenged the NIH’s action in the United States District Court for the District of Massachusetts. The district court first granted temporary restraining orders to prevent implementation of the guidance, then issued a nationwide preliminary injunction. After further proceedings, the district court converted this into a permanent injunction and vacated the Supplemental Guidance, concluding that the NIH’s action likely violated a congressional appropriations rider and HHS regulations, and finding the action arbitrary, capricious, and procedurally improper.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s decision. The court held that the district court had jurisdiction because the plaintiffs challenged an agency-wide policy rather than seeking contract damages, which would fall under the exclusive jurisdiction of the Court of Federal Claims. The appellate court further held that the NIH’s Supplemental Guidance violated the statutory appropriations rider and HHS regulations governing indirect cost reimbursement, including the requirements for deviations from negotiated rates. The First Circuit affirmed the permanent injunction and vacatur of the Supplemental Guidance. View "Commonwealth of Massachusetts v. National Institutes of Health" on Justia Law

In this case, the petitioner was convicted of first-degree murder and robbery for an offense committed at age 17, resulting in a mandatory sentence of life imprisonment without parole under Massachusetts law. Decades later, following developments in constitutional law, the Massachusetts Supreme Judicial Court held that life-without-parole sentences for juveniles were unconstitutional and ordered that such sentences be modified to life with the possibility of parole. As a result, the petitioner’s sentence was changed; he became parole eligible, was granted parole, and was released.After this modification, the petitioner sought to file a second habeas corpus petition in federal court under 28 U.S.C. § 2254. The United States District Court for the District of Massachusetts ruled that this petition was “second or successive” under 28 U.S.C. § 2244(b) and thus subject to its “gatekeeping” requirements, concluding that the addition of parole eligibility did not constitute a new judgment for purposes of federal habeas law.On appeal, the United States Court of Appeals for the First Circuit reviewed de novo whether the sentence modification constituted a new judgment. The court held that the change from life without parole to life with parole eligibility was a material change, making the sentence a new judgment under federal law. The court reasoned that, because the petitioner’s current custody was authorized by this new judgment, his second-in-time habeas petition did not trigger the restrictions of § 2244(b).Therefore, the First Circuit reversed the district court’s decision, holding that the petitioner need not obtain pre-authorization to file his habeas petition, and remanded for further proceedings. View "Donovan v. Massachusetts Parole Board" on Justia Law

Two long-time residents of Nashua, New Hampshire, sought to fly various flags on a designated "Citizen Flag Pole" located at City Hall Plaza. The City had previously allowed private citizens and groups to fly flags representing diverse causes and cultural events on this pole, with minimal oversight and no substantive review of flag content. After one of the plaintiffs flew a "Save Women's Sports" flag, the City received complaints, revoked permission, and removed the flag, stating that it was discriminatory toward the transgender community. Subsequently, the City adopted a written policy in 2022 asserting that the flagpole’s use constituted government speech and reserving the right to deny flags not aligned with City policies.The plaintiffs filed suit in the United States District Court for the District of New Hampshire, alleging violations of the First and Fourteenth Amendments and seeking a preliminary injunction to prevent viewpoint-based denials of flag applications. Before the City filed its opposition, it enacted a new policy to exercise exclusive government control over the flagpoles. The magistrate judge recommended denying the injunction, finding the flag program to be government speech, and the district court adopted that recommendation and denied relief. The plaintiffs then appealed to the United States Court of Appeals for the First Circuit.The First Circuit reviewed the district court’s denial for abuse of discretion and legal conclusions de novo. Applying the government speech test from Shurtleff v. City of Boston, the court held that Nashua’s Citizen Flag Pole program was not government speech, but rather operated as a forum for private expression. Because Nashua conceded that, absent a government speech determination, its actions constituted impermissible viewpoint discrimination, the First Circuit reversed the district court. The case was remanded with instructions to enter interim declaratory relief in favor of the plaintiffs. View "Scaer v. City of Nashua" on Justia Law

Three Guatemalan citizens—an adult couple and their minor child—entered the United States in September 2021 and were subsequently served with Notices to Appear, charging them with removability under the Immigration and Nationality Act. The adults filed applications for asylum, withholding of removal, and relief under the Convention Against Torture (CAT), naming their daughter as a derivative beneficiary, while the daughter filed her own applications for the same relief. Their claims centered on threats and an attack they experienced in Guatemala related to their ownership of a hardware store, as well as concerns about general criminality and safety for their family.After a merits hearing, the Immigration Judge (IJ) found the petitioners credible but concluded that they had not met their burdens for any form of relief. The IJ determined that the evidence showed only isolated incidents rather than a pattern of persecution, and that the threats were linked solely to their business. The IJ held that their proposed particular social groups—“Guatemalan small business owners” and the “Lopez-Ramos-Hernandez nuclear family”—were not cognizable, and that there was no nexus between the harm suffered and a protected ground. The IJ also found that the petitioners had not shown a reasonable fear of future persecution, nor that they could not safely relocate within Guatemala. Consequently, the IJ denied their claims for asylum, withholding of removal, and CAT protection.The petitioners appealed to the Board of Immigration Appeals (BIA), which affirmed the IJ’s decision without opinion, making the IJ’s decision the final agency determination. Upon review, the United States Court of Appeals for the First Circuit held that substantial evidence supported the agency’s factual findings and that no error of law occurred. The court denied the petition for review, upholding the denial of asylum, withholding of removal, and CAT protection. View "Ramos-Hernandez v. Bondi" on Justia Law

A political news producer in Puerto Rico contacted a senior government official, warning that the son of the Treasury Secretary possessed damaging chat messages about the administration and might release them unless political attacks on his father ceased. The producer and the official met twice; the producer described a binder of messages and relayed demands for $300,000, renewal of two government contracts, and payments to media personalities in exchange for withholding the chats and favorable coverage. After the chats were leaked, resulting in political turmoil and resignations, the official became a confidential FBI source, recorded a second meeting, and collaborated with agents. The producer later deleted relevant messaging records from the official's phone during an FBI interview.The United States District Court for the District of Puerto Rico held a jury trial. The jury convicted the producer on three counts: attempted extortion under the Hobbs Act (18 U.S.C. § 1951), transmitting a threatening communication with intent to extort (18 U.S.C. § 875(d)), and destruction of records in a federal investigation (18 U.S.C. § 1519). The defendant moved for acquittal and a new trial, arguing insufficient evidence, prosecutorial misconduct, and errors in jury instructions. The district court denied these motions and sentenced him to fifty-one months in prison.On appeal, the United States Court of Appeals for the First Circuit reviewed sufficiency of the evidence and the alleged procedural errors. It held that the evidence was sufficient for all counts, including proof of wrongful threats and intent to extort, and that the government did not commit prosecutorial misconduct or Brady violations. The court found no reversible error in the jury instructions or limitations on cross-examination and affirmed the convictions in full. View "United States v. Diaz-Colon" on Justia Law

Two Massachusetts State Police officers, Lieutenant Daniel Griffin and Sergeant William Robertson, were implicated in a years-long scheme involving fraudulent overtime billing between 2015 and 2017. Both routinely claimed pay for hours they did not work, either by arriving late, leaving early, or “double-dipping” by billing overtime for tasks performed during regular hours. They also encouraged subordinates to engage in the same practices. The overtime funds in question were supplied through federal grants meant to support highway safety initiatives. In addition to the overtime fraud, Griffin separately engaged in wire fraud relating to private school financial aid and tax fraud connected to a private security business.The United States District Court for the District of Massachusetts presided over a jury trial, which resulted in convictions for both defendants on all counts related to wire fraud, theft of federal funds, and conspiracy. Griffin pled guilty to additional charges of wire fraud and tax falsification before trial. Sentences were imposed: Griffin received 60 months’ imprisonment, three years’ supervised release, substantial restitution, and forfeiture; Robertson received 36 months’ imprisonment, three years’ supervised release, joint and several liability for restitution, and forfeiture.Upon appeal to the United States Court of Appeals for the First Circuit, the court reviewed a broad array of challenges. The First Circuit largely affirmed the convictions, sentences, and restitution orders. It found no reversible error in the district court’s handling of the constitutional challenge, sufficiency of the evidence, guidelines calculations, sentencing disparities, and restitution. However, the Circuit Court vacated and remanded the forfeiture order against Griffin, holding that the government failed to prove by a preponderance of the evidence that the full amount of financial aid received was “traceable to” fraud, as required by statute. All other aspects of the district court’s judgment were affirmed. View "United States v. Robertson" on Justia Law

A thirteen-year-old student in Brewer, Maine, developed a relationship with a twenty-year-old man, who was a coach associated with her school. Over two years, the man sexually assaulted the student multiple times. During that period, rumors circulated at the local high school about their inappropriate relationship. The student reported these rumors to the principal, denied any truth to them, and the principal took limited follow-up action. Other school staff and a police officer had some interactions with the student and the perpetrator, but no one reported or investigated the abuse at the time. The student, now an adult, later sued various school officials, the school department, a police officer, and others, alleging they failed to protect her from abuse despite being aware of warning signs, and sought relief under federal and Maine law.At the United States District Court for the District of Maine, most claims were dismissed at the pleading stage for failing to state a claim. The remaining claims, including those brought under Title IX and 42 U.S.C. § 1983, were resolved in favor of defendants at summary judgment. The court also dismissed the claims against the unidentified police officer for lack of personal jurisdiction, denied the plaintiff’s request for more time to serve that officer, and later denied leave to amend the complaint to add the officer once identified.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court’s decisions in all respects. The First Circuit held that the plaintiff’s allegations did not plausibly establish municipal liability under § 1983, nor did they show actual knowledge by school officials sufficient to support a Title IX claim. The appellate court also found no abuse of discretion in the district court’s procedural rulings regarding service of process and amendment of the complaint. View "Hewes v. Gardiner" on Justia Law

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