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

Two individuals each owned companies that distributed snack foods for a larger food company. Years earlier, they had joined a class action lawsuit claiming that the company misclassified them as independent contractors rather than employees. That class action ended in a settlement, which included an optional provision: class members could agree to arbitrate future disputes in exchange for an additional payment. Both individuals opted into that provision and accepted the payment, thereby agreeing to resolve future disputes through arbitration.Several years later, the two individuals brought a new lawsuit in the United States District Court for the District of Massachusetts, again asserting claims related to alleged misclassification and seeking damages. The defendant company moved to stay the case and compel arbitration under the Federal Arbitration Act (FAA), citing the prior agreement. The plaintiffs opposed, arguing that they were exempt from the FAA as transportation workers under Section 1. The district court rejected that exemption argument, but did not order arbitration. Instead, it stayed and administratively closed the case without entering judgment, stating it was not compelling arbitration but was closing its doors to further proceedings.The United States Court of Appeals for the First Circuit reviewed the district court’s handling. The court held that, although the district court did not expressly deny the motion to compel arbitration, its actions amounted to a denial, and thus appellate jurisdiction existed under 9 U.S.C. § 16(a)(1)(B). The First Circuit vacated the district court’s order and remanded the case for further proceedings, directing the district court to determine whether the motion to compel arbitration should be granted or denied and to explain its reasoning. The court also clarified that, under the parties’ agreement, any compelled arbitration must proceed on an individual, not class, basis. View "Perruzzi v. The Campbell's Company" on Justia Law

Two individuals entered into a loan agreement and mortgage with a bank in Puerto Rico, using their home as collateral. After a decade, they faced financial difficulties and stopped making payments. The bank denied a request to modify the loan but proposed a short sale. The bank then initiated foreclosure proceedings in Puerto Rico’s Court of First Instance, resulting in a judgment against the borrowers. Multiple short sale offers were rejected until one was conditionally accepted, but the sale did not close in time and the home was foreclosed. Subsequently, the bank garnished funds from the borrowers, who then filed for Chapter 13 bankruptcy.The United States Bankruptcy Court for the District of Puerto Rico confirmed the borrowers’ Chapter 13 plan, noting their intent to pursue claims against the bank. The borrowers filed an adversary proceeding seeking damages and other relief. The bank moved to dismiss the adversary complaint, but the bankruptcy court denied this motion, allowing the case to proceed. The borrowers later filed a similar complaint in the United States District Court for the District of Puerto Rico and moved to withdraw the adversary proceeding to the district court. The district court denied the withdrawal as untimely and dismissed the separate federal case. After the borrowers completed their bankruptcy plan and received a discharge, the bankruptcy court dismissed the adversary proceeding for lack of subject matter jurisdiction.On appeal, the United States Court of Appeals for the First Circuit held that the bankruptcy court erred in finding it automatically lost jurisdiction over the adversary proceeding post-discharge. The appellate court vacated and remanded the case for further proceedings, instructing the lower courts to reassess jurisdiction and properly address the borrowers’ motion for withdrawal and their jury trial request. View "Guallini-Indij v. Banco Popular de Puerto Rico" on Justia Law

The City of Boston, along with its Public Health Commission and Housing Authority, brought suit against two pharmacy benefit managers (PBMs), OptumRx and Express Scripts, alleging that the PBMs had worked with opioid manufacturers to misrepresent the risks of opioid drugs. The City claimed that this conduct violated Massachusetts public nuisance law and resulted in harm to the City. The PBMs removed the case to federal court and argued that the suit was untimely because it was brought after the three-year statute of limitations had expired. The City responded by asserting that its complaint sufficiently alleged a continuing nuisance and that the statute of limitations should be tolled due to the PBMs’ fraudulent concealment of their wrongdoing.The United States District Court for the District of Massachusetts granted the PBMs’ motion to dismiss, finding that the City either knew or should have known of its injuries and of the PBMs’ alleged role before 2021, based on public records and prior litigation, and thus failed to file suit within the statutory period. The district court further ruled that the City had not adequately pled a continuing nuisance, as it did not allege any specific, recent unlawful acts within the limitations period, and rejected the City’s claim of fraudulent concealment, determining that the City had the means to discover the facts needed for its claim. The district court also denied a motion by the PBMs to disqualify the City's law firm, Motley Rice.On appeal, the United States Court of Appeals for the First Circuit affirmed both the dismissal of the City’s state law claim and the denial of the motion to disqualify Motley Rice. The court held that the action was time-barred and that the City had not met the requirements for tolling the statute of limitations or for pleading a continuing nuisance under Massachusetts law. View "The City of Boston v. OptumRx, Inc." on Justia Law

Steven and Virginia Savage were officers and sole shareholders of a company that designed and installed digital planetarium equipment. When their company experienced financial distress, they used personal funds and credit cards to support business operations, but the company eventually defaulted on a large loan personally guaranteed by the Savages. In the year preceding their bankruptcy filing, the Savages received over $700,000 from the company, which they failed to fully disclose in their bankruptcy filings. Their bankruptcy schedules did not mention this income, and significant portions of the transferred funds were not satisfactorily explained, especially regarding rent payments from the company to the Savages and the use of those funds.After the company and the Savages filed for bankruptcy, the creditor, Coastal Capital, objected to the Savages’ discharge in their Chapter 7 proceedings. The United States Bankruptcy Court for the District of New Hampshire held a bench trial and found that, although the Savages explained most of the company funds they received, they failed to account for over $56,000. The court denied the Savages a discharge under 11 U.S.C. § 727(a)(5) for failing to satisfactorily explain the loss or deficiency of assets. The Savages’ post-trial motions were denied, and the United States District Court for the District of New Hampshire affirmed the bankruptcy court’s ruling.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s judgment. The court held that § 727(a)(5) does not require a “substantial” loss of assets to deny discharge, nor does it require that the unaccounted-for funds be enough to pay all liabilities. It also found no clear error in the bankruptcy court’s factual determinations and rejected the Savages’ arguments regarding destruction of evidence and the sufficiency of their explanations. The denial of discharge was affirmed. View "Coastal Capital, LLC v. Savage" on Justia Law

A nurse employed by Puerto Rico’s State Insurance Fund Corporation reported sexual harassment by a coworker in 2020 and subsequently filed an administrative charge of discrimination and retaliation. After dropping her sexual harassment claim, she pursued a retaliation claim, arguing that she endured a hostile work environment and was involuntarily transferred to a different office. The incidents underlying her claim included several allegedly meritless disciplinary actions and the eventual transfer.The United States District Court for the District of Puerto Rico granted a preliminary injunction separating her from the coworker and, after trial, a jury found in her favor on the retaliation claim, awarding $300,000 in damages. The district court later denied her request for a permanent injunction seeking reassignment to her former office and expungement of disciplinary records. The court awarded her approximately $301,000 in attorney fees and costs, but she challenged the amount as insufficient. Finally, although the defendant did not appeal the judgment or fee award, the district court stayed execution of both under Puerto Rico law, pending approval of a payment plan by the Secretary of Justice.The United States Court of Appeals for the First Circuit affirmed the denial of permanent injunctive relief and the attorney fee award, finding that the district court did not abuse its discretion on either point and that the fee reductions and denial of injunctive remedies were reasonable. The Court of Appeals also vacated the stay of execution of judgment and fees, holding that Puerto Rico’s statutory payment plan requirement could not delay enforcement of a federal judgment under Title VII. The case was remanded for further proceedings consistent with these rulings. View "Garcia Colon v. State Insurance Fund Corporation" on Justia Law

After entering the United States in 2021 from Brazil, the petitioner was apprehended by U.S. authorities and charged with removability. She applied for asylum, withholding of removal, and protection under the Convention Against Torture, claiming she feared returning to Brazil due to past abuse by her former partner. The abuse, according to her testimony, included two specific incidents of physical aggression, threats to her life, and ongoing harassment after separation. She cited her young age during the abuse and asserted that her fear of return stemmed solely from her ex-partner's conduct.An Immigration Judge denied all forms of relief, finding that the petitioner failed to establish either past persecution or a well-founded fear of future persecution. The judge also concluded that the alleged harm did not rise to the level of torture for CAT protection. The Board of Immigration Appeals affirmed, agreeing that the physical mistreatment described was not sufficiently frequent or severe to constitute persecution and that the petitioner’s proposed social groups were too amorphous to support her claims.The United States Court of Appeals for the First Circuit reviewed the agency’s decisions as a unit. Applying the substantial evidence standard for factual findings and de novo review for legal conclusions, the court held that the agency did not err in finding no past persecution, noting the incidents were isolated, did not result in serious injury, and that the petitioner remained in Brazil for years without further harm. The court also found substantial evidence supported the conclusion that she lacked a well-founded fear of future persecution. The court denied the petition for review, holding that the petitioner was ineligible for asylum, humanitarian asylum, withholding of removal, and CAT protection. View "Da Silva-Queiroga v. Bondi" on Justia Law

In the 1990s, Anthony M. Shea was involved in a series of bank and armored-car robberies in New Hampshire. In 1997, following a federal jury trial in the United States District Court for the District of New Hampshire, Shea was convicted on fourteen counts, including two counts of using or carrying a firearm during and in relation to a crime of violence under 18 U.S.C. § 924(c), and was sentenced to life imprisonment. The § 924(c) convictions were based on underlying predicate offenses, including substantive Hobbs Act robbery, conspiracy to commit Hobbs Act robbery, and bank robbery with a dangerous weapon. The jury returned a general verdict, finding Shea guilty of all counts.After his convictions were affirmed on direct appeal by the United States Court of Appeals for the First Circuit, Shea filed a motion under 28 U.S.C. § 2255 seeking to vacate his § 924(c) convictions and to be resentenced, arguing that subsequent Supreme Court decisions, particularly United States v. Davis and Johnson v. United States, rendered his predicate conspiracy offenses invalid for purposes of § 924(c). The District Court denied relief as to the § 924(c) convictions, finding any error in the jury instructions harmless, but granted resentencing because Shea’s "career offender" designation was no longer applicable.On appeal, the United States Court of Appeals for the First Circuit reviewed both the partial denial of Shea’s § 2255 motion and the amended judgment after resentencing. The First Circuit held that the District Court did not err in its harmless error analysis, finding that even though the jury was instructed on both valid and invalid predicate offenses, the valid predicates were so interrelated and coextensive with the invalid ones that the instructional error did not have a substantial and injurious effect on the verdict. The First Circuit affirmed both the denial of relief as to the § 924(c) convictions and the amended judgment. View "Shea v. United States" on Justia Law

A witness was subpoenaed to testify in a federal criminal trial in the United States District Court for the District of Maine. After answering a few questions, she invoked her Fifth Amendment privilege against self-incrimination, refusing to answer further questions from the government. The government then sought and obtained an order from the District Court granting her statutory immunity under 18 U.S.C. §§ 6002-6003, which precluded the use of her compelled testimony or information derived from it against her in any criminal case, except for prosecution for perjury, giving a false statement, or failing to comply with the order. Despite this grant of immunity and a direct order from the court, the witness continued to refuse to testify.Following her refusal, the District Court found her in criminal contempt and issued an order accordingly. Her attorney argued that the statutory immunity provided was not as broad as her Fifth Amendment privilege, specifically asserting that the immunity did not protect her from potential prosecution for perjury based on her compelled testimony. The District Court rejected this argument, clarifying that the immunity was coextensive with the Fifth Amendment privilege as it protected against self-incrimination for prior acts but did not extend to potential perjury in the immunized testimony itself.The United States Court of Appeals for the First Circuit reviewed the District Court’s criminal contempt order for abuse of discretion, reviewing factual findings for clear error and legal questions de novo. The First Circuit held that the statutory immunity granted under 18 U.S.C. §§ 6002-6003 was indeed coextensive with the Fifth Amendment privilege against self-incrimination, except for future perjury or false statements given under immunity. Accordingly, the Court of Appeals affirmed the District Court’s order of criminal contempt. View "United States v. McBreairty" on Justia Law

Chang Goo Yoon, a licensed physical therapist operating clinics in Massachusetts, engaged in a scheme over four years to submit more than one million dollars in fraudulent claims to private health insurers, including Blue Cross Blue Shield and Aetna, for services he did not actually provide. He fabricated treatment notes, sometimes under another provider's name, and submitted false personal injury claims to his own car insurer, MAPFRE. Yoon manipulated patient addresses to ensure reimbursement checks were sent directly to him, avoiding detection by patients. His fraudulent conduct was eventually uncovered, and a jury convicted him on two counts of health care fraud, with Count One involving Blue Cross and Aetna, and Count Two concerning MAPFRE.The United States District Court for the District of Massachusetts presided over the trial. Before trial, Yoon moved to exclude evidence related to insurance company investigations into his billing, including a 2015 Blue Cross investigation and a 2007 Colorado licensing investigation. The district court limited the evidence to Yoon’s knowledge of the investigations, excluding their outcomes. The court also redacted key documents and provided limiting instructions to the jury. At trial, witnesses testified about insurance procedures and Yoon’s billing practices. Yoon challenged the admissibility of this evidence, as well as testimony from insurance investigators, arguing it was unduly prejudicial and improperly admitted.The United States Court of Appeals for the First Circuit reviewed Yoon’s appeal. The court affirmed the district court’s evidentiary rulings, holding that evidence of Yoon’s knowledge of prior investigations was highly probative of his specific intent and not unduly prejudicial given the safeguards imposed. The court also affirmed the application of two sentencing enhancements: one for intended loss based on the total amount billed, and another for abuse of a position of trust, finding both were supported by the record and correctly applied. Yoon’s conviction and sentence were affirmed. View "United States v. Yoon" on Justia Law

A group of individuals participated in a complex securities fraud scheme over nearly a decade, orchestrated by a central figure, with each playing specialized roles. The operation involved acquiring large volumes of penny stocks, artificially inflating their value through paid promotions, and then selling these stocks at inflated prices (“pump and dump” schemes). The participants concealed their ownership through nominee companies and offshore accounts, and maintained records in an encrypted internal system. The scheme generated over $1 billion in gross proceeds, and its participants went to great lengths to avoid detection and regulatory scrutiny.The Securities and Exchange Commission (SEC) initiated a civil enforcement action in the United States District Court for the District of Massachusetts against various defendants, including those currently appealing. Some defendants went to jury trial, while others conceded liability and proceeded to remedies. The district court admitted evidence from the internal accounting system, found the jury’s verdicts supported by sufficient evidence, and denied motions to dismiss. For those who conceded liability, the court assessed appropriate remedies, including disgorgement and civil penalties.On appeal, the United States Court of Appeals for the First Circuit reviewed the evidentiary rulings, jury instructions, and remedies imposed. The Court held that the district court properly admitted the internal accounting evidence and that the jury instructions correctly stated the law. The evidence was sufficient to support the verdicts. The Court affirmed the district court’s use of joint and several liability for disgorgement due to the appellants’ concerted wrongdoing, and held that the SEC’s calculations were a reasonable approximation of unjust gains. The First Circuit also upheld the application of the extended statute of limitations under the National Defense Authorization Act. The Court affirmed all remedies except one aspect of an injunction, which it vacated and remanded for clarification. View "Securities and Exchange Commission v. Gasarch" on Justia Law