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

In this case before the United States Court of Appeals for the First Circuit, five groups of current and former public employees in the Commonwealth of Puerto Rico (the "Commonwealth") appealed an order by the court overseeing the Commonwealth-wide debt restructuring litigation (the "Title III court") on their motions to secure administrative-expense priority for their back pay claims. The back pay claims arose from allegations that their public employers failed to adjust their wages upward, a violation of Puerto Rico law. The Title III court had previously rejected efforts to assert administrative-expense priority for back pay for work performed before the commencement of the Commonwealth's debt restructuring case under Title III of the Puerto Rico Oversight, Management, and Economic Stability Act ("PROMESA").The appellate court affirmed the Title III court's decision. The appellate court agreed that the pre-petition work claims did not qualify for administrative-expense priority under § 503(b)(1)(A)(ii) of the Bankruptcy Code, which is incorporated into PROMESA, because they were not "wages and benefits awarded pursuant to a judicial proceeding . . . as back pay attributable to any period of time occurring after commencement of the case under this title." The appellate court also held that the Title III court did not abuse its discretion in deferring its decision on administrative-expense status for back pay claims concerning work performed post-petition but for which there has not yet been any judgment in the underlying commonwealth court and agency proceedings. View "Abraham Gimenez Plaintiff Group v. FOMB" on Justia Law

In this case, the United States Securities and Exchange Commission (SEC) sought to recover approximately $3.3 million from Raimund Gastauer, a German citizen residing in Germany, alleging that Gastauer received the money from his son, who had obtained the money through securities fraud in the United States. Gastauer challenged the jurisdiction of the United States District Court for the District of Massachusetts over him, contending that he had no relevant contacts with the United States. The district court, however, ruled it could assert jurisdiction over Gastauer because it had jurisdiction over his son, the primary defendant. The judgment ordered Gastauer to pay the $3.3 million, plus prejudgment interest, to the SEC.Gastauer appealed, and the United States Court of Appeals for the First Circuit reversed the district court's decision. The appellate court rejected the SEC's argument that a court may impute the jurisdictional contacts of a primary defendant to a relief defendant who received ill-gotten funds from the primary defendant. It held that such an approach would violate the relief defendant's due process rights, particularly where, as here, the relief defendant had no relevant contacts with the United States and was not accused of any wrongdoing. The appellate court also underscored that the relief defendant's status as a foreign resident further cautioned against an expansive view of the district court's jurisdiction, given the potential risks to international comity. The appellate court remanded the case to the district court for further proceedings consistent with its opinion. View "SEC v. Gastauer" on Justia Law

In this case, decided by the United States Court of Appeals for the First Circuit, the dispute involved Aeroballoon USA, Inc., and its owner Douglas Hase (collectively, Aeroballoon/Hase), and Jiajing (Beijing) Tourism Co., Ltd. (Jiajing). In 2016, Jiajing contracted Aeroballoon for two tethered helium balloons at a total price of $1.8 million. Despite Jiajing making regular payments totaling $1,018,940, Aeroballoon failed to deliver the balloons. An arbitration panel awarded Jiajing $1,410,739.01 plus interest for Aeroballoon's breach of contract. Following the award, Hase dissolved Aeroballoon and Jiajing subsequently filed a complaint seeking enforcement of the arbitration award.The case focused on two counts: fraudulent transfers in violation of the Massachusetts Uniform Fraudulent Transfer Act (UFTA) and unfair business practices under Chapter 93A of the Massachusetts General Laws. The jury awarded Jiajing $1.6 million for each count. The district court later reduced the damages to $1.113 million for each count, a decision unchallenged by either party.The Court of Appeals affirmed the lower court's decision. The court held that the evidence was sufficient to support a finding that Aeroballoon had engaged in fraudulent transfers of at least $1.113 million. The court further held that even a single fraudulent transfer is sufficient to create liability under Chapter 93A, thereby affirming the verdict on the claim of unfair business practices. The court also awarded costs to Jiajing. View "Jiajing (Beijing) Tourism Co. Ltd. v. AeroBalloon USA, Inc." on Justia Law

In the case before the United States Court of Appeals for the First Circuit, plaintiff Shawn McBreairty claimed that a local school-board policy violated his First Amendment rights by restricting what he could say at the board's public meetings. McBreairty sought a temporary restraining order and preliminary injunction against the policy. The defendants were the School Board of Regional School Unit 22 in Maine and Heath Miller, the Board's chair. The policy in question prohibited public complaints or allegations against any school system employee or student during board meetings. It also allowed the Chair to terminate any presentation that violated these guidelines or the privacy rights of others.McBreairty had been stopped from criticizing school employees during two separate board meetings. Each time, after he mentioned a teacher's name and criticized their practices, the Chair warned him to stop, the video feed was cut, and the police were contacted to remove him from the premises. He was not arrested or charged with any crime on either occasion.The District Court denied McBreairty's request for a temporary restraining order and preliminary injunction. He then appealed this decision. While this appeal was pending, the School Board amended the policy in question.The Court of Appeals vacated the decision of the District Court, not on the merits of McBreairty's First Amendment claims, but on the grounds that he lacked standing to seek the injunctive relief at issue. The Court reasoned that McBreairty did not sufficiently demonstrate an intention to engage in the allegedly restricted speech at future board meetings, which is necessary to establish a concrete, live dispute rather than a hypothetical one. The Court thus concluded that it did not have jurisdiction to hear the case under Article III of the Constitution. The case was remanded to the District Court for further proceedings. View "McBreairty v. Miller" on Justia Law

In this case, Grace Katana appealed his conviction for conspiracy to interfere with interstate commerce by robbery in violation of the Hobbs Act. He argued that the indictment accused him of conspiring to rob Joseph Wilson, while the government only proved at trial that he had planned a break-in at Wilson's home. Katana claimed that this constituted a constructive amendment to the indictment in violation of his constitutional rights, that there was a prejudicial variance from the charge in the indictment, and that there was insufficient evidence to support his conviction.The United States Court of Appeals for the First Circuit rejected Katana's arguments and affirmed his conviction. The court found that the offense charged in the indictment was the same offense on which the court instructed the jury and on which the government presented evidence. The court also held that the identity of the robbery target was not an element of a robbery or conspiracy to commit robbery under the Hobbs Act, so focusing on Wilson's home business as the target at trial did not amount to a constructive amendment. The court further concluded that Katana failed to demonstrate that any variance from the indictment was prejudicial, as the record showed he had sufficient notice of, and was able to defend himself against, the government's theory at trial. Finally, the court ruled that a rational jury could have concluded that Katana and his co-conspirators planned to rob Wilson's home business, so there was sufficient evidence to support his conviction. View "US v. Katana" on Justia Law

In a case before the United States Court of Appeals for the First Circuit, an insurance company, Berkley National Insurance Company, sued two of its insureds, Granite Telecommunications, LLC and Atlantic-Newport Realty LLC, seeking restitution for both the payment it had made to settle a personal-injury lawsuit against the insureds and the costs it had incurred to defend them against that suit. The insurer, Berkley, also sought a declaratory judgement that it had no duty to defend or indemnify the insureds with respect to the personal-injury claims that they were facing. The District Court granted partial summary judgment in favor of Berkley, ordering the insureds to pay restitution for both the insurer's defense costs and its settlement payment. The insureds appealed the judgment.The Court of Appeals reversed the District Court's order, concluding that the rulings conflicted with Massachusetts law governing when a liability insurer who has chosen to defend its insureds may seek reimbursement from them. The Court stated that under Massachusetts law, a liability insurer can only seek reimbursement for an amount paid to settle a lawsuit if the insured has agreed that the insurer may commit its own funds to a reasonable settlement with a right to seek reimbursement, or if the insurer secures specific authority to reach a particular settlement which the insured agrees to pay. The Court found that the insurer, Berkley, did not meet any of these conditions, and as a result, it could not seek reimbursement from the insureds. Consequently, the Court vacated the grant of summary judgment to the insurer and dismissed the remainder of the appeal as moot. View "Berkley National Ins. Co. v. Atlantic-Newport Realty LLC" on Justia Law

The defendant, Michael Rand, was indicted and pleaded guilty to one count of distributing a controlled substance. His sentence was time served followed by 36 months of supervised release. Shortly thereafter, Rand violated his supervised release multiple times, leading to a revocation hearing. At the hearing, Rand was sentenced to 24 months of imprisonment followed by 24 months of supervised release. Rand appealed his sentence on the grounds that it was procedurally and substantively unreasonable. The United States Court of Appeals for the First Circuit affirmed the sentence. The court found that the district court had adequately explained its rationale for the sentence, which was based on a combination of Rand's lying and absconding shortly after his original sentence, his drug relapse, and his failure to comply with the terms of his supervised release. Lastly, the court found that the sentence fell within the broad range of reasonableness considering the totality of the circumstances. View "US v. Rand" on Justia Law

In the case before the United States Court of Appeals for the First Circuit, the defendant, Randall Crater, was convicted of wire fraud, unlawful monetary transactions, and operating an unlicensed money transmitting business based on his involvement in a cryptocurrency scheme. The trial lasted eight days and was based on Crater's management of My Big Coin (MBC), a cryptocurrency company that allegedly misrepresented itself as a gold-backed digital currency and claimed a partnership with MasterCard. The defendant appealed two of the district court's rulings.Firstly, Crater argued that the district court violated his Sixth Amendment right to compulsory process by refusing to enforce subpoenas against three federal agency witnesses due to Crater's non-compliance with the agencies' Touhy regulations. Secondly, Crater contended that the district court did not perform its gatekeeping duty by admitting testimony from the government's cryptocurrency expert without holding a Daubert hearing.However, the Court of Appeals affirmed the district court's decision, stating that Crater's arguments could not be reconciled with controlling precedent or the record in the case. The court found that Crater's failure to show how the excluded testimony of the federal agents would have been both material and favorable to his defense invalidated his Sixth Amendment claim. Furthermore, the court held that Crater's objections to the expert witness's qualifications and methodology were insufficient to necessitate a Daubert hearing. View "US v. Crater" on Justia Law

Juan Sierra-Jiménez was a felon who pled guilty to possessing a firearm. While on supervised release for a prior federal firearm offense, Sierra was arrested and found with a Glock 22 pistol, which had been modified to function as a machine gun. He was also in possession of extra ammunition and approximately five grams of a substance suspected to be heroin. Sierra was sentenced to fifty-eight months in prison and an additional consecutive eighteen-month supervised release violation sentence. Sierra appealed, arguing that the fifty-eight-month sentence was procedurally unreasonable and that the government breached the plea agreement regarding his eighteen-month sentence. The United States Court of Appeals for the First Circuit rejected Sierra's arguments and affirmed the lower court's decision. The court ruled that the district court did not clearly err in its factual findings and did not rely on the suspected heroin possession in determining Sierra's sentence. The court also found that Sierra failed to show that the government's lack of an oral recommendation for a concurrent sentence prejudiced him. View "US v. Sierra-Jimenez" on Justia Law

Paulo Trindade, a former employee of Grove Services, Inc., sued his previous employer for breach of contract and violations of the Massachusetts Wage Act, claiming he had been underpaid on his sales commission compensation for the years 2014, 2015, and 2016. Following a bench trial, the United States District Court for the District of Massachusetts ruled in part for Trindade and in part for Grove, awarding Trindade $330,597 in damages. Both parties appealed. The United States Court of Appeals for the First Circuit affirmed the lower court's judgment. The Court of Appeals agreed with the district court's conclusion that Trindade's amended complaint, which included a claim for unpaid wages for 2016, related back to his original complaint, making the claim timely under Massachusetts law. The Court of Appeals also concluded that the district court was correct in its decision to award the damages it did, including an amount for the late payment and underpayment of Trindade's 2016 commission. View "Trindade v. Grove Services, Inc." on Justia Law