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

The case revolves around Carlos Rubén Boyrie-Laboy, a Puerto Rico Police officer, who was convicted under 18 U.S.C. §§ 1951, 371, and 641 for his involvement in a conspiracy to commit robbery and theft of government property. Boyrie-Laboy was part of the Humacao Drugs Division, responsible for seizing illegal weapons, drugs, and other contraband. In 2015, Officer Gabriel Maldonado-Martínez joined the division and began working with Boyrie-Laboy. Maldonado-Martínez later became an undercover FBI informant to identify corrupt police officers. Boyrie-Laboy was involved in two thefts of fireworks and was present during two FBI operations designed to catch corrupt officers. However, he did not accept any stolen goods or money from these operations.The government indicted Boyrie-Laboy and three other officers based on these activities. Boyrie-Laboy was charged with conspiracy to commit robbery, conspiracy to steal and convert government property, and theft and conversion of government property. He proceeded to a five-day jury trial, where the jury found him guilty on all counts. Boyrie-Laboy appealed the convictions, arguing that there was insufficient evidence to support them.The United States Court of Appeals for the First Circuit reviewed the case. Boyrie-Laboy's counsel had declined the opportunity to move for a judgment of acquittal twice during the trial and did not make a post-trial motion for judgment of acquittal. As a result, the court applied the "clear and gross injustice" standard of review. The court found that the evidence sufficiently supported the jury's findings and that upholding Boyrie-Laboy's convictions did not result in a clear and gross injustice. Therefore, the court affirmed the convictions. View "United States v. Boyrie-Laboy" on Justia Law

The plaintiff, Brendan Hoover, was struck in the head by a descending elevator gate while working at a Hyatt Hotel. He filed a lawsuit against Hyatt Hotels Corporation and Otis Elevator Company, alleging negligence due to the visibly worn-down condition of the elevator's rubber "astragal," which he claimed caused his injury. Both defendants moved for summary judgment, arguing that Hoover's claim was based on unsupported conjecture.The district court granted summary judgment for Hyatt and Otis, holding that even if the contested expert evidence was admissible, Hoover failed to present anything other than speculation about an observable defect. The court did not rule on the admissibility of the expert evidence.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court's decision. The court found that Hoover failed to provide sufficient evidence to support his claim that the worn-down condition of the elevator's rubber "astragal" caused his injury. The court also noted that Hoover's expert witness did not provide an adequate foundation for a jury to find that Hyatt and Otis negligently failed to maintain the astragal, resulting in its mis-performance that caused Hoover's injury. View "Hoover v. Hyatt Corporation" on Justia Law

Daniel Richard Mahoney, a U.S. Navy veteran, appealed to the United States Court of Appeals for the First Circuit after the Board for Correction of Naval Records (BCNR) denied his 2018 petition to upgrade his 1989 other than honorable discharge status. Mahoney served two periods in the Navy, the first from 1985 to 1988, which resulted in an honorable discharge, and the second from 1988 to 1989, which resulted in the other than honorable discharge. During his second period of service, Mahoney received several non-judicial punishments for unauthorized absences, drunkenness, and wrongful use of a controlled substance. He was diagnosed with alcohol dependency and received treatment, but continued to struggle with alcohol abuse.The BCNR denied Mahoney's petition to upgrade his discharge status, determining that he had failed to provide "substantial evidence" of "probable material error or injustice" to overcome the BCNR's presumption that military officers "have properly discharged their official duties." The BCNR concluded that Mahoney's PTSD did not mitigate the drug-related misconduct which led to his discharge.Mahoney then filed a complaint against Carlos Del Toro, U.S. Secretary of the Navy, in the District Court for the District of Massachusetts, requesting judicial review of the BCNR's decision. The district court concluded that the BCNR's decision was not arbitrary or capricious, an abuse of discretion, or contrary to law, and denied Mahoney's motions while granting Del Toro's cross-motion. Mahoney subsequently appealed to the First Circuit.The First Circuit affirmed the district court's decision, holding that the BCNR's decision was not arbitrary or capricious, an abuse of discretion, unsupported by substantial evidence, or contrary to law. The court found that the BCNR had reasonably determined that Mahoney's PTSD did not mitigate the drug-related misconduct leading to his discharge, and that his account of the positive urinalysis was not credible. The court also rejected Mahoney's argument that the BCNR had failed to apply the liberal consideration standard to his entire claim, finding that the BCNR had indeed applied the standard and had reasonably concluded that Mahoney's PTSD did not warrant changing his discharge characterization. View "Mahoney v. Del Toro" on Justia Law

The case involves Ricardo Perez-Delgado, who was sentenced to forty years in prison for his role in a violent robbery that resulted in the death of a businessman. The sentence was significantly higher than the guideline sentencing range (GSR), which had a maximum of thirty years and five months. Perez-Delgado appealed, arguing that the district court did not adequately explain its rationale for imposing a sentence nearly a decade over the top of the GSR.The district court had adopted the probation office's GSR calculation and considered the relevant statutory factors, Perez-Delgado's background, the nature and circumstances of the offense, and the arguments of both parties. However, the court's explanation for the upward variance was limited to a single sentence stating that the recommended sentence did not reflect the seriousness of the offense, promote respect for the law, protect the public from further crimes by Perez-Delgado, or address issues of deterrence and punishment.The United States Court of Appeals for the First Circuit agreed with Perez-Delgado's argument. The court found that the district court's explanation was insufficient to justify the significant upward variance from the GSR. The court noted that the greater the variance, the greater the explanation must be. The court vacated Perez-Delgado's sentence and remanded the case for resentencing, instructing the district court to provide an individualized explanation proportional to the length of the variance if it decided to upwardly vary again. View "United States v. Perez-Delgado" on Justia Law

The defendant, Heclouis Nieves-Díaz, was on supervised release for a federal drug conviction when he was convicted of possession of ammunition as a convicted felon, illegal possession of a machine gun, and possession with intent to distribute cocaine. He received an 84-month prison term for each conviction, to be served concurrently. His supervised release was also revoked, resulting in an additional 18-month prison term to be served consecutively to his 84-month sentences.Nieves had previously pleaded guilty to one count of drug conspiracy and was sentenced to 80 months of imprisonment and 96 months of supervised release. His term of supervised release was twice revoked. While on his third term of supervised release, Nieves was arrested following a search of an apartment where he was residing. The search yielded cocaine, marijuana, approximately 149 rounds of .223 caliber ammunition, and a device that could convert a Glock pistol into a fully automatic weapon.Nieves appealed his 84-month sentences and the revocation sentence. He argued that the District Court improperly calculated his Guidelines Sentencing Range (GSR) for each of the underlying offenses and that the court's application of a four-level enhancement was incorrect.The United States Court of Appeals for the First Circuit found that the District Court did err in applying the four-level enhancement, as the record did not support the determination that the ammunition in this case had the required potentially facilitative effect. Therefore, the court vacated the District Court's sentences and remanded for resentencing. However, the court affirmed the revocation sentence, finding it both procedurally and substantively reasonable. View "United States v. Nieves-Diaz" on Justia Law

In 2015, Universitas Education, LLC initiated a lawsuit against Jack E. Robinson, III, alleging violations of the Racketeer Influenced and Corrupt Organizations Act. Robinson defended himself until his death in November 2017. After Robinson's death, the focus of the case shifted to finding a proper party to substitute as a representative of his estate. Universitas identified Lillian Granderson, Robinson's mother, as a suitable substitute and filed motions to substitute her into the case and to enter default judgment against her. The district court granted both motions.On appeal, Granderson argued that the district court erred in granting Universitas' motion to substitute and motion for default judgment. The United States Court of Appeals for the First Circuit affirmed the district court's decision to substitute Granderson into the case, but vacated the default judgment. The court found that Granderson had defended the case and no entry of default had been entered against her, which was a requirement for a default judgment. The case was remanded back to the district court for further proceedings consistent with the appellate court's opinion. View "Universitas Education, LLC v. Granderson" on Justia Law

Edgar Centariczki, the defendant, pleaded guilty to aiding and abetting the distribution of methamphetamine and fentanyl in 2021. He was sentenced to time served (two days) and three years of supervised release. His case was transferred to the District of Maine, where he resided. Between June and October of 2021, Centariczki tested positive for marijuana and cocaine multiple times and missed several probation office appointments. Despite warnings from the court, he continued to violate the terms of his supervised release, leading to his arrest in November. In January 2022, a revocation hearing was held due to multiple violations, including drug and alcohol use and failures to report to probation office appointments.The District Court for the District of Maine held a final revocation hearing in February 2023. The court calculated a guideline sentencing range of four to ten months, with thirty months of supervised release. However, the government advocated for an above-guidelines sentence of eighteen months' incarceration with no supervised release to follow, arguing that Centariczki had received multiple chances to seek drug treatment and yet continued to violate the terms of his probation. The court agreed and sentenced Centariczki to eighteen months' incarceration with no supervised release to follow.Centariczki appealed to the United States Court of Appeals for the First Circuit, arguing that his sentence was substantively unreasonable because the district court lacked a sufficiently above-guidelines plausible rationale for imposing an eighteen-month sentence. The Court of Appeals disagreed, holding that the district court's rationale was plausible and its sentence was reasonable. The court noted that Centariczki's repeated violations of his supervised release terms and the multiple second chances afforded to him by the court and probation officer justified the above-guidelines sentence. The court affirmed the district court's decision. View "US v. Centariczki" on Justia Law

The case involves Caitlin Corrigan, a graduate student at Boston University (BU), who sued the university under the Americans with Disabilities Act (ADA) for implementing a mandatory COVID-19 testing program. Corrigan claimed that due to a chronic medical condition, she could not comply with the program and that requiring her compliance would violate the ADA. BU rejected her proposed exemption, leading to her suspension for the fall semester. However, before the district court could reach the merits of Corrigan's claims, BU ended its mandatory testing program, leading the court to dismiss Corrigan's suit for lack of subject-matter jurisdiction, arguing that it had become moot.BU moved to dismiss Corrigan's suit for lack of subject-matter jurisdiction, and the district court granted the motion, applying mootness principles. The court determined that since BU had ended its mandatory testing program, an order requiring BU to provide Corrigan with a reasonable accommodation to the program would have no effect. The court also found that Corrigan's claim was not inherently transitory and that BU was unlikely to subject Corrigan to mandatory testing again. The court held that the monetary relief that Corrigan sought was legally insufficient to support a claim of jurisdiction.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court concluded that the district court appropriately applied mootness principles to dismiss Corrigan's suit and that Corrigan had not shown that her case comes within an applicable exception to those mootness principles. The court rejected Corrigan's arguments that the district court misread the mootness exceptions, misconstrued the facts, and ignored the import of the ADA's scheme for providing prospective relief. View "Corrigan v. Boston University" on Justia Law

The case involves Francis M. Reynolds, who was convicted of three counts of obstruction of a United States Securities and Exchange Commission proceeding and one count of securities fraud. The District Court sentenced him to seven years of imprisonment plus three years of supervised release, ordered him to pay restitution to the victims of his fraud in the amount of $7,551,757, a special assessment of $400, and to forfeit $280,000 to the United States. Reynolds appealed his conviction, but he died while the appeal was pending.Reynolds was convicted in the United States District Court for the District of Massachusetts. He appealed his conviction to the United States Court of Appeals for the First Circuit. While the appeal was pending, Reynolds died. The government suggested that the court should either dismiss the appeal as moot or follow the practice of the Supreme Judicial Court of Massachusetts and dismiss the appeal as moot while instructing the District Court to add a notation in the record.The United States Court of Appeals for the First Circuit had to decide whether to apply the doctrine of abatement ab initio, which holds that when a criminal defendant dies during the pendency of a direct appeal from his conviction, his death abates not only the appeal but also all proceedings had in the prosecution from its inception. The court decided to apply the doctrine, aligning itself with other federal courts of appeals and its own past decisions. The court dismissed the appeal and remanded the case to the District Court to vacate the convictions and dismiss the indictment. The court also instructed the District Court to vacate the orders of restitution and criminal forfeiture that were imposed in this case, as well as the special assessment. View "United States v. Reynolds" on Justia Law

Frederic P. Zotos, an attorney residing in Cohasset, Massachusetts, filed a qui tam complaint against the Town of Hingham and several of its officials. Zotos alleged that the town and its officials posted speed limit signs and advisory speed plaques that did not comply with applicable federal and state laws and regulations. He further claimed that the town applied for and received reimbursements for these signs and plaques from both the federal government and the Commonwealth of Massachusetts. Zotos asserted that the town fraudulently induced the federal government to pay it roughly $3,300,000 and the Commonwealth to pay it approximately $7,300,000.The United States District Court for the District of Massachusetts dismissed Zotos's complaint for failure to state a claim upon which relief could be granted. The court concluded that the qui tam action was not barred by either claim or issue preclusion. However, it found that Zotos's claims fell short of the False Claims Act (FCA) and Massachusetts False Claims Act's (MFCA) requirements. Specifically, it ruled that Zotos failed to sufficiently plead that the alleged misrepresentations were material to the federal government's and the Commonwealth's respective decisions.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court found that Zotos's complaint did not adequately allege that the defendants' purported misrepresentations were material. It noted that the essence of the bargain under the Federal-Aid Highway Program (FAHP) and the Chapter 90 program was that the defendants incurred permissible costs on projects that were duly reimbursed. The court concluded that Zotos's allegations amounted to ancillary violations that, without more, were insufficient to establish materiality. View "United States ex rel. Zotos v. Town of Hingham" on Justia Law