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

Two former employees of a global toy and game company sought religious exemptions from the company’s COVID-19 vaccination policy. Both had worked remotely during the pandemic and requested to continue working remotely due to their sincerely held Christian beliefs, which included objections to vaccines developed or tested using tissue from aborted fetuses and a belief that receiving the vaccine would violate their religious principles. After submitting their accommodation requests, both employees experienced workplace actions they alleged were retaliatory and discriminatory. These included formal investigations and written warnings for alleged prior mask policy violations, exclusion from promotion opportunities, reassignment of roles, dissemination of personal medical information, and changes to established workplace practices. Both resigned, asserting that these actions compelled their departures.The plaintiffs initiated legal action in Rhode Island state court, raising claims under Title VII of the Civil Rights Act, the Rhode Island Civil Rights Act, and the Rhode Island Fair Employment Practices Act. The case was removed to the United States District Court for the District of Rhode Island, which granted the employer’s motion to dismiss. The district court determined that the plaintiffs’ objections to vaccination were not based on religion, characterizing their beliefs as moral rather than religious, and held that the complaint failed to allege sufficiently adverse employment actions or a causal connection between the plaintiffs’ accommodation requests and any adverse action.The United States Court of Appeals for the First Circuit reviewed the case. It held that the plaintiffs plausibly alleged that their refusal to take the COVID-19 vaccine was based on bona fide religious beliefs, as recognized in recent circuit precedent. The court concluded that the amended complaint sufficiently pleaded plausible claims of retaliation and religious discrimination under federal and state law. Accordingly, the First Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "DeAngelis v. Hasbro, Inc." on Justia Law

The case concerns a defendant who was serving a term of supervised release following a federal conviction for fentanyl-related offenses. During his supervision, police responded to a domestic disturbance at his apartment, where his wife reported that, after an argument, the defendant struck her and was told to leave. When she locked him out, she stated that he kicked the apartment door, damaging it, re-entered, and took her cell phone. Police and a responding officer documented the damage to the door. The defendant was subsequently charged in state court with vandalism, among other offenses, and federal probation officers sought revocation of his supervised release based on these new alleged criminal acts.The United States District Court for the District of Massachusetts held revocation hearings, during which both documentary evidence, such as police reports and affidavits, and live testimony from the responding officer were presented. The defendant objected to the admission of hearsay statements from his wife, arguing he was entitled to confront her and that the statements were unreliable. The district court found that the interest of justice did not require her appearance, determined her statements were sufficiently reliable, and credited the corroborating testimony of the police officer. The court concluded that the defendant had, by a preponderance of the evidence, committed vandalism under Massachusetts law and revoked his supervised release.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s legal conclusions de novo and factual findings for clear error. The appellate court held that the district court properly admitted the hearsay evidence, conducted the required balancing under Rule 32.1(b)(2)(C), and made supported findings regarding the elements of vandalism. The appellate court concluded there was neither legal error nor clear error and affirmed the revocation of supervised release. View "United States v. Camillo" on Justia Law

A former Boston police officer alleged that the Boston Police Department (BPD) retaliated against her after she reported a fellow officer for rape in 2009. Following her report, both she and the accused officer were placed on leave, and subsequent criminal and internal investigations found her allegations unsubstantiated. She later made additional complaints of misconduct by BPD officials, which were also found unsubstantiated. In response, BPD’s Internal Affairs Department sustained numerous disciplinary charges against her, and she resigned with these charges pending. After her resignation, she applied for various jobs, authorizing prospective employers to request her employment and disciplinary records from BPD. Additionally, BPD included her name and reason for departure in a list provided to the Washington Post in response to a public records request.The Massachusetts Superior Court dismissed her three successive lawsuits against BPD, primarily for procedural reasons, with the last dismissal in 2017 operating as an adjudication on the merits. In federal court, claims based on alleged retaliatory acts before February 2, 2017, were precluded due to the prior state court judgment. The U.S. District Court for the District of Massachusetts allowed her Title VII retaliation claims to proceed only as to BPD’s actions after that date, specifically regarding the release of her records to prospective employers and the Washington Post.The United States Court of Appeals for the First Circuit affirmed the district court’s grant of summary judgment for BPD. The court held that no reasonable jury could find that retaliation was the but-for cause of BPD’s release of employment information, since Doe had authorized those disclosures and there was no evidence of deviation from standard procedure or retaliatory motive. The court also held that BPD’s response to the public records request was legally required and contained accurate information. View "Doe v. City of Boston" on Justia Law

The case concerns an individual who was convicted under federal law for possessing a firearm after having previously been convicted of a misdemeanor crime of domestic violence. The predicate offense was a 2010 conviction under Maine law for simple assault against his then-wife, to which he pleaded no contest after the original charge of "Domestic Violence Assault" was reduced. Several years later, he was charged federally after he admitted to police that he owned a firearm. At his federal trial, he stipulated to many elements of the offense but sought to introduce evidence that he believed, based on his plea arrangement and representations by the prosecution and his attorney in state court, that he was legally allowed to possess a firearm.Initially, the United States District Court for the District of Maine convicted him, but the United States Court of Appeals for the First Circuit vacated that conviction after the Supreme Court decided Rehaif v. United States, which clarified the knowledge requirement for firearms offenses. On remand, he was retried and again convicted, but a First Circuit panel vacated the conviction due to errors in jury instructions. Sitting en banc, the First Circuit clarified the applicable knowledge standard, vacated the conviction, and remanded for another trial. On further remand, the District Court denied his Second Amendment challenge to the statute, excluded his proffered evidence regarding his belief about firearm possession, and again convicted him after a jury trial.The United States Court of Appeals for the First Circuit held that 18 U.S.C. § 922(g)(9), which prohibits firearm possession by those convicted of misdemeanor crimes of domestic violence, does not violate the Second Amendment, either facially or as applied, in light of the Supreme Court’s guidance in United States v. Rahimi. The court also held that the District Court did not abuse its discretion in excluding evidence of the defendant’s belief about the lawfulness of his conduct, as the statute does not require knowledge that firearm possession is unlawful, only knowledge of the facts that make one ineligible. The conviction and denial of the motion to dismiss were affirmed. View "US v. Minor" on Justia Law

A lawful permanent resident who had lived in the United States for nearly twenty years was twice convicted in Massachusetts for violating a statute that prohibits “open and gross lewdness and lascivious behavior.” Following his second conviction, the government initiated removal proceedings, arguing that his convictions constituted two “crimes involving moral turpitude” (CIMTs) under federal immigration law. The resident contested this classification, contending that the Massachusetts statute did not require lewd intent and thus did not categorically define a CIMT.An Immigration Judge denied the resident’s motion to terminate proceedings and ordered him removed, finding that the statute was categorically a CIMT. The resident appealed to the Board of Immigration Appeals (BIA), which affirmed the order of removal. The BIA concluded that the statute necessarily required lewd intent and thus qualified as a CIMT.The United States Court of Appeals for the First Circuit reviewed the BIA’s decision. The court applied the categorical approach, examining whether the Massachusetts statute required proof of lewd intent as an element for every conviction. The First Circuit determined that a conviction under the statute did not require a finding of lewd intent or sexual motivation; instead, it could be satisfied by intentional, open exposure that caused shock or alarm, even without a lewd purpose. The court found a realistic probability that Massachusetts would apply the statute to conduct not involving moral turpitude.The First Circuit held that the Massachusetts statute is not categorically a crime involving moral turpitude because it does not require proof of lewd intent. The court concluded that the BIA erred as a matter of law and reversed the removal order. The petition for review was granted, the BIA’s decision was reversed, and the matter was remanded for further proceedings. View "Cabral Fortes Tomar v. Bondi" on Justia Law

Eleven individuals residing in the Town of Rockport, Massachusetts, challenged the creation of a new zoning overlay district that would allow high-density, multi-family housing near a commuter rail station. Some plaintiffs live adjacent to or within the boundaries of the affected overlay district. The plaintiffs argued that the adoption of the district should have required a two-thirds vote at the town meeting under state law, rather than the simple majority used, and alleged that the new zoning would negatively impact their property values and personal expectations regarding their property.After the Town held the vote and adopted the overlay district, the plaintiffs filed suit in the United States District Court for the District of Massachusetts, seeking declaratory and injunctive relief on both state statutory and federal constitutional grounds. The Town moved to dismiss the complaint, arguing the plaintiffs lacked standing. In response, the plaintiffs provided additional details in their briefing but did not amend their complaint to allege specific individualized harm. The District Court dismissed the case for lack of subject-matter jurisdiction, finding the plaintiffs had failed to allege sufficient facts to establish standing, and that neither legislative nor abutter standing applied.On appeal, the United States Court of Appeals for the First Circuit reviewed the dismissal de novo. The court held that the plaintiffs had not adequately demonstrated a concrete and particularized injury-in-fact as required by Article III. General, conclusory allegations about diminished property values and expectations were insufficient. The court also found that statutory “abutter” standing and legislative standing theories did not confer standing in federal court for these claims. The appellate court affirmed the district court’s dismissal for lack of standing and subject-matter jurisdiction. View "Kolackovsky v. Town of Rockport" on Justia Law

A federal employee working at a Veterans Affairs healthcare facility discovered that a nurse practitioner was improperly receiving overtime pay that was not actually earned and not related to COVID, contrary to requirements. The employee’s supervisors allegedly created and signed a false waiver to justify these payments, resulting in significant unearned compensation. When the employee refused to participate in the scheme and reported the conduct to the VA Office of Inspector General, he claimed to have been subjected to workplace retaliation, including a reprimand and demotion.The employee filed suit in the United States District Court for the District of Maine, asserting a qui tam false claims action against his supervisors and a retaliation claim under the False Claims Act (FCA) against the Secretary of the Department of Veterans Affairs, in his official capacity. The government intervened and successfully moved to dismiss the false claims and conspiracy counts against the supervisors. The government also sought dismissal of the retaliation claim, arguing that the employee’s exclusive remedies lay under the Whistleblower Protection Act (WPA), not the FCA. The district court, however, dismissed the retaliation claim on the ground that the FCA does not contain an express waiver of the federal government’s sovereign immunity for such claims, and thus federal courts lack subject-matter jurisdiction.On appeal, the United States Court of Appeals for the First Circuit reviewed the dismissal de novo. The court held that Congress has not expressly waived the federal government’s sovereign immunity to permit retaliation suits against federal employers under Section 3730(h) of the FCA. The court found that neither the FCA’s text nor its structure provided the required clear waiver of sovereign immunity, distinguishing such waivers present in other statutes. Accordingly, the First Circuit affirmed the district court’s dismissal for lack of subject-matter jurisdiction. View "US ex rel. Sargent v. Collins" on Justia Law

The case involves the owner of a chain of Massachusetts pizzerias who was convicted by a jury of six counts of forced labor and attempted forced labor, primarily involving undocumented immigrant kitchen workers. The government presented evidence that the owner recruited and hired undocumented workers, subjected them to poor working conditions, monitored them through cameras, underpaid them, and intimidated them with threats of deportation and physical violence. Several former employees testified about being yelled at, assaulted, and threatened, including incidents where the owner physically attacked workers who tried to leave. The workers described working long hours without breaks, fearing retaliation if they quit, and being denied pay.A grand jury indicted the defendant in the United States District Court for the District of Massachusetts. Before trial, the defense sought a lengthy continuance, citing late discovery disclosures by the government, but the district court only partially granted the request, allowing an eight-day postponement. After a ten-day trial, the jury convicted the defendant on six counts. The defendant then moved for a new trial, arguing discovery violations and insufficient time to prepare, but the district court denied this motion and sentenced him to 102 months in prison.On appeal to the United States Court of Appeals for the First Circuit, the defendant challenged the sufficiency of the evidence, evidentiary rulings, sentencing calculations, and the denial of his requests for a longer continuance and a new trial. The First Circuit held that the evidence was sufficient for a rational jury to convict on all challenged counts, found no reversible error in the district court’s evidentiary or procedural rulings, and affirmed the sentence. The court thus affirmed both the convictions and the sentence. View "United States v. Papantoniadis" on Justia Law

A group of former employees at a luxury hotel in Lenox, Massachusetts brought a series of lawsuits against the hotel and its operators, alleging violations of the Fair Labor Standards Act (FLSA) and Massachusetts wage laws. The claims primarily involved misclassification as overtime-exempt, failure to pay minimum wage, mismanagement of tip pools, and other wage-related violations. One plaintiff, after successfully certifying a class of similarly situated employees, joined with others to negotiate a global settlement with the hotel’s owners.Prior to this appeal, the United States District Court for the District of Massachusetts, acting through a magistrate judge, oversaw the coordinated settlement negotiations for four related cases—three individual actions and one class action. After the parties agreed to a global settlement via email, defense counsel confirmed the deal and the court was notified. The individual cases were subsequently dismissed with prejudice. When obstacles arose regarding finalization, including Wheatleigh’s concerns over attorney fees and purported conflicts of interest for class counsel, plaintiffs moved to enforce the settlement. The district court granted the motion, enforced the settlement, and later granted preliminary and then final approval of the class-action settlement, including approval of attorney fees, expenses, and a service award.The United States Court of Appeals for the First Circuit reviewed Wheatleigh’s appeal, which challenged the district court’s rulings on standing, enforcement and approval of the settlement, class certification, and attorney fees. The First Circuit held that the district court did not err in finding Article III standing for the named plaintiff, enforcing the global settlement, approving the class-action settlement despite alleged conflicts of counsel, maintaining class certification, and awarding attorney fees. The First Circuit affirmed the judgment of the district court. View "Mongue v. The Wheatleigh Corporation" on Justia Law

In September 2022, police received a tip that the defendant was armed on the roof of a public housing building. When officers arrived and announced themselves, the defendant jumped off the roof and was found injured. He informed police that he had three firearms on the roof, where officers subsequently recovered two Glock pistols modified to fire automatically, a tactical rifle, a micro conversion kit, multiple magazines—including high-capacity ones—and 279 rounds of ammunition. At the time, the defendant was on supervised release for a prior firearm-possession conviction.The defendant pled guilty in the United States District Court for the District of Puerto Rico to possessing machine guns and being a felon in possession of firearms and ammunition. The district court calculated an advisory guidelines range of sixty-three to seventy-eight months based on the total offense level and criminal history. The defendant requested a sentence at the bottom of the range, citing improved mental health and questioning the evidence, while the government requested a sentence at the top of the range due to the defendant’s criminal history and the quantity and type of weapons and ammunition possessed. The district court imposed a ninety-six-month sentence, an eighteen-month upward variance, citing the dangerousness of the weapons, the large cache of ammunition, the defendant’s prior conviction, his commission of the offense while on supervised release, and his active surveillance of the rooftop.On appeal to the United States Court of Appeals for the First Circuit, the defendant argued his sentence was procedurally and substantively unreasonable and that the government breached the plea agreement by defending the upward variance. The First Circuit held that the district court adequately explained its reasons for the upward variance, properly considered aggravating factors not captured by the guidelines, and did not abuse its discretion. The court also found no breach of the plea agreement. The judgment was affirmed. View "United States v. Maldonado-Velazquez" on Justia Law