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

In 2023, Shaiquan Moran-Stenson pled guilty to unlawfully possessing ammunition as a felon, violating 18 U.S.C. § 922(g)(1). The U.S. District Court for the District of Maine enhanced his base offense level under the United States Sentencing Guidelines § 2K2.1(a)(4)(A), citing a prior Maine drug trafficking conviction. Moran-Stenson objected, arguing that his Maine conviction did not qualify as a predicate offense for the enhancement.The U.S. District Court for the District of Maine overruled Moran-Stenson's objection, applying the modified categorical approach to determine that his Maine drug trafficking conviction was a predicate offense. The court found that the Maine statute was divisible and that the specific drug involved, cocaine base, was a federally controlled substance. Consequently, the court sentenced Moran-Stenson to seventy-seven months in prison, followed by three years of supervised release.On appeal, the United States Court of Appeals for the First Circuit reviewed whether the district court correctly applied the modified categorical approach. The appellate court affirmed the district court's decision, holding that the Maine statute's "scheduled drugs" component was divisible. The court concluded that the specific drug trafficked, cocaine base, was an element of the offense, allowing the use of the modified categorical approach. The court found that Moran-Stenson's prior conviction for trafficking cocaine base qualified as a predicate controlled substance offense under § 2K2.1(a)(4)(A), justifying the sentencing enhancement. View "United States v. Moran-Stenson" on Justia Law

Amy Rae, a school nurse employed by Woburn Public Schools (WPS), alleged that she faced retaliatory harassment due to her advocacy for students with disabilities and complaints about her own mistreatment. Rae claimed that the harassment, primarily by Kennedy Middle School Principal Carl Nelson, began in 2011 and continued for over a decade. She filed a lawsuit in November 2022, asserting claims under Section 504 of the Rehabilitation Act, Title II of the Americans with Disabilities Act (ADA), Massachusetts's antidiscrimination statute (Chapter 151B), and for intentional infliction of emotional distress.The United States District Court for the District of Massachusetts dismissed Rae's complaint on May 5, 2023, ruling that she failed to state any claims for which relief could be granted. The court found that Rae could not rely on the continuing violations doctrine to save her untimely discrimination claims and dismissed her timely state and federal discrimination claims on other grounds.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court's dismissal de novo. The appellate court agreed that Rae could not invoke the continuing violations doctrine to rescue her time-barred claims, as her allegations included discrete acts of retaliation that accrued separately. The court also affirmed the district court's dismissal of Rae's timely ADA, Section 504, and Chapter 151B claims, concluding that Rae did not plausibly allege severe or pervasive harassment necessary to sustain a retaliatory harassment claim. The court noted that Rae's allegations of two incidents within the actionable period were insufficient to meet the standard for severe or pervasive harassment. Thus, the appellate court affirmed the district court's decision to dismiss Rae's complaint. View "Rae v. Woburn Public Schools" on Justia Law

Xiomara Santiago was hired as the Deputy Director for the Head Start Program in Utuado, Puerto Rico. Following a mayoral election, the new mayor, Jorge Pérez, terminated her employment. Santiago claimed her dismissal violated her Fourteenth Amendment due process rights and was politically motivated, violating her First Amendment rights. She sought a preliminary injunction to be reinstated.The United States District Court for the District of Puerto Rico held hearings and ultimately denied Santiago's request for a preliminary injunction. The court concluded that Santiago had not shown a likelihood of success on the merits of either her due process or political discrimination claims. The magistrate judge's Report & Recommendation, which the district judge adopted, found that Santiago's initial hire was contrary to Puerto Rico law, meaning she did not have a property interest in her employment. Additionally, the court found insufficient evidence to support her claim of political discrimination.The United States Court of Appeals for the First Circuit reviewed the district court's decision. The appellate court affirmed the lower court's ruling, agreeing that Santiago had not demonstrated a likelihood of success on the merits of her claims. The court noted that Santiago's argument regarding the incorrect application of Puerto Rico law was waived because it was raised for the first time on appeal. Furthermore, the court found no clear error in the district court's assessment that Santiago's political affiliation was not a substantial factor in her termination. The court concluded that the district court did not abuse its discretion in denying the preliminary injunction. View "Santiago v. Municipality of Utuado" on Justia Law

Sara Caruso, a flight attendant for Delta Air Lines, failed a breathalyzer test on August 4, 2018, after a layover in Dallas, Texas. Caruso claimed she was drugged and sexually assaulted by Delta First Officer James Lucas the night before. The Dallas Police Department found insufficient evidence to support her claim, and Delta also took no action against Lucas after its investigation. Caruso completed an alcohol rehabilitation program and sought accommodations from Delta for PTSD related to the alleged assault. Although Delta and Caruso initially agreed on accommodations, Caruso resigned after a month back at work.Caruso sued Delta in Massachusetts state court, alleging violations of Massachusetts General Laws chapter 151B, Title VII of the Civil Rights Act of 1964, and the Americans with Disabilities Act (ADA). The case was removed to the U.S. District Court for the District of Massachusetts, which granted summary judgment for Delta on all counts. The court found no causal connection between Delta's actions and the alleged harassment and determined that Delta responded reasonably to the allegations. Additionally, Caruso's disability discrimination claims failed because she did not engage in an interactive process in good faith with Delta to develop reasonable accommodations.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The court held that Caruso failed to show a causal connection between Delta's actions and the alleged harassment, and that Delta's investigation and response were reasonable. The court also found that Caruso did not cooperate in the interactive process for her disability accommodations, and her retaliation claims were either waived or undeveloped. Thus, the summary judgment for Delta was affirmed on all counts. View "Caruso v. Delta Air Lines, Inc." on Justia Law

Edson Pires Rosa, a citizen of Cape Verde, entered the U.S. on a visitor visa in 2015, which expired later that year. His mother, a lawful permanent resident, filed a petition for him, which was approved, but his subsequent application for adjustment of status was denied. In 2019, Rosa was accused of participating in a sexual assault, leading to a police report and a pending criminal charge. Despite his denial of the allegations, he was placed in removal proceedings for overstaying his visa. Rosa applied for asylum, withholding of removal, and voluntary departure.The Immigration Judge (IJ) initially denied Rosa's asylum and withholding of removal applications but granted voluntary departure. Rosa appealed the denial of asylum and withholding of removal to the Board of Immigration Appeals (BIA), which remanded the case to consider his adjustment of status application after his mother became a U.S. citizen. On remand, a new IJ denied his adjustment of status and voluntary departure requests, citing the pending criminal charge as a significant negative factor. Rosa appealed to the BIA, which upheld the IJ's decision, finding no error in the reliance on the police report and pending charge.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the BIA erred in deeming Rosa's challenge to the voluntary departure denial as waived and vacated the BIA's decision on both adjustment of status and voluntary departure. The court remanded the case to the BIA to reconsider these issues, particularly whether the police report and pending charge alone could justify the denial of discretionary relief without corroborating evidence, as required by precedent. View "Rosa v. Garland" on Justia Law

Fredly Charles, a native and citizen of Haiti, was admitted to the United States in 2007 and became a lawful permanent resident on a conditional basis in 2009. He lost this status in 2012, and in 2019, the Department of Homeland Security charged him with removability. Charles conceded removability but applied for cancellation of removal, adjustment of status, and protection under the Convention Against Torture, arguing that his removal would cause exceptional hardship to his U.S. citizen children and parents. An Immigration Judge denied his applications in 2019, and the Board of Immigration Appeals (BIA) dismissed his appeal in 2020.Charles submitted three motions to reopen his immigration proceedings. The first two motions, filed in 2020, were denied by the BIA, which found that he had not demonstrated the required exceptional hardship or materially changed conditions in Haiti. His third motion, filed in 2022, cited the birth of his daughter with serious medical conditions as new evidence. The BIA denied this motion as untimely and numerically barred, stating that Charles had not provided sufficient evidence to warrant reopening his case sua sponte.The United States Court of Appeals for the First Circuit reviewed the BIA's denial of Charles' third motion to reopen. The court noted that it has jurisdiction to review refusals to reopen sua sponte only if the BIA commits legal error. The court found no indication that the BIA ignored relevant evidence about Charles' daughter's medical condition and concluded that the BIA did not arbitrarily depart from its prior practices. Consequently, the court dismissed Charles' challenge to the BIA's denial of his motion to reopen. View "Charles v. Garland" on Justia Law

The plaintiff, Lupe Stratton, worked at Bentley University from August 2016 to July 2018. She alleged that her supervisors discriminated against her based on her gender, race, disability, and Guatemalan origin. After she complained to Bentley's human resources department, she was placed on a performance improvement plan, which she claimed was retaliatory. Stratton also contended that Bentley interfered with her right to medical leave and failed to provide reasonable accommodations for her disability. She resigned, claiming her workplace had become intolerable.The United States District Court for the District of Massachusetts granted summary judgment in favor of Bentley University on all of Stratton's claims. The court found that Stratton did not suffer an adverse employment action that could support her discrimination claims and that her retaliation claims failed because she could not establish a causal connection between her complaints and the adverse actions. The court also held that Bentley had provided reasonable accommodations for Stratton's disability and had not interfered with her FMLA rights.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court agreed that Stratton did not experience an adverse employment action that could support her discrimination claims, as her working conditions were not so intolerable as to constitute a constructive discharge. The court also found that Stratton's retaliation claims failed because she could not show that her complaints were the but-for cause of the adverse actions. Additionally, the court held that Bentley had provided reasonable accommodations for Stratton's disability and had not interfered with her FMLA rights. The court clarified the relevant law governing Title VII retaliation claims in the circuit. View "Stratton v. Bentley University" on Justia Law

The appellant, Misael M. Rivera-Gerena, was aboard a vessel in U.S. waters when the Coast Guard seized 52 packages containing amphetamine and cocaine, along with an additional 448 bricks of cocaine. Rivera-Gerena was arrested and indicted. He pleaded guilty to conspiracy to possess with intent to distribute at least 150 kilograms but less than 450 kilograms of cocaine on a vessel subject to U.S. jurisdiction. The district court accepted his plea and ordered a presentence investigation report (PSI Report).The United States District Court for the District of Puerto Rico set a guideline sentencing range (GSR) of 262 to 327 months, based on the actual amount of cocaine seized. The statute of conviction carried a mandatory minimum sentence of 120 months. The government recommended a 135-month sentence, while Rivera-Gerena requested the mandatory minimum of 120 months, citing his acceptance of responsibility and other mitigating factors. The district court considered the plea agreement and the 18 U.S.C. § 3553(a) factors, including the need to promote respect for the law and protect the public. The court acknowledged Rivera-Gerena's personal circumstances but emphasized the seriousness of the offense and his criminal history. Ultimately, the court imposed a 147-month sentence, varying downward from the GSR but higher than the parties' recommendations.The United States Court of Appeals for the First Circuit reviewed the case. Rivera-Gerena argued that his sentence was procedurally flawed and substantively unreasonable, claiming the district court failed to adequately evaluate the § 3553(a) factors. The appellate court found no procedural error, noting the district court had considered all relevant factors and provided a plausible rationale for the sentence. The court also found the sentence substantively reasonable, given the seriousness of the offense and Rivera-Gerena's criminal history. The First Circuit affirmed the district court's judgment. View "United States v. Rivera-Gerena" on Justia Law

Amanda J. Bazinet, an executive office manager at Beth Israel Deaconess Hospital in Milton, Massachusetts, was terminated after the Hospital implemented a mandatory COVID-19 vaccine policy. Bazinet sought a religious exemption, citing her Christian beliefs and opposition to vaccines developed using fetal cell lines from aborted fetuses. The Hospital denied her request without engaging in an interactive process and subsequently terminated her employment.Bazinet filed a civil action alleging religious discrimination under Title VII of the 1964 Civil Rights Act and Massachusetts anti-discrimination law. The U.S. District Court for the District of Massachusetts dismissed her religious discrimination claims sua sponte, ruling that Bazinet failed to allege a sincerely held religious belief and that accommodating her would cause the Hospital undue hardship.The United States Court of Appeals for the First Circuit reviewed the case. The court found that Bazinet had sufficiently alleged a religious belief conflicting with the vaccine requirement, as her accommodation request and supporting letter detailed her religious objections. The court also determined that the sincerity of Bazinet's beliefs and the undue hardship defense required further factual development and could not be resolved at the motion to dismiss stage.The First Circuit vacated the district court's dismissal of Bazinet's religious discrimination claims and remanded the case for further proceedings, allowing the claims to proceed past the Rule 12(b)(6) stage. View "Bazinet v. Beth Israel Lahey Health, Inc." on Justia Law

Attorney James Hayes faced a four-count petition for discipline filed by the Massachusetts Bar Counsel, accusing him of fraud, violating court orders, mishandling client funds, and other dishonest conduct. These charges stemmed from his representation of a client who concealed lottery winnings to avoid child support. A hearing committee of the Massachusetts Board of Bar Overseers found merit in all counts and recommended disbarment. Hayes appealed to the Board, which upheld the committee's findings. A single justice of the Massachusetts Supreme Judicial Court (SJC) agreed and disbarred Hayes. The SJC affirmed this decision.Upon receiving the SJC's judgment, the United States Court of Appeals for the First Circuit ordered Hayes to show cause why reciprocal discipline should not be imposed. Hayes requested a hearing and argued that a term suspension, rather than disbarment, was appropriate. He contended that the SJC's decision was flawed due to errors in assessing the credibility of the principal witness, his former client, and that the SJC mischaracterized his conduct as fraudulent. Hayes also argued that the SJC typically imposes less severe discipline in similar cases and highlighted mitigating factors such as his years of good standing.The First Circuit reviewed the state court record and found no basis to depart from the SJC's findings. The court determined that the hearing committee reasonably credited the former client's testimony and that Hayes failed to show clear and convincing evidence of procedural irregularities or errors in the SJC's decision. The court concluded that Hayes did not demonstrate that less severe discipline was warranted and disbarred him from practicing law before the First Circuit. The Clerk of Court was instructed to forward a copy of the opinion to the SJC. View "In re Hayes" on Justia Law