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

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In this case, the plaintiff, Virginia Cora Ward, the administratrix of the estate of Edmund Edward Ward, appealed against the verdict in favor of Dr. Ernst J. Schaefer. Edmund Edward Ward, who suffered from a rare genetic deficiency that caused his body to refrain from producing a critical blood enzyme, was a subject of experimental enzyme therapy developed by Dr. Schaefer and others. The plaintiff claimed that Dr. Schaefer fraudulently induced Ward to participate in the experimental protocol and failed to obtain informed consent for his participation. However, the jury disagreed and returned a verdict in favor of Dr. Schaefer.On appeal, the United States Court of Appeals for the First Circuit affirmed the judgment of the lower court. The appellate court found that the district court did not err in excluding the patent for the experimental drug from evidence, as its probative value was substantially outweighed by the potential for confusion. Further, the court found no error in the jury instructions provided by the district court regarding the nature of the doctor-patient relationship and the application of the doctrine of res ipsa loquitur. The court concluded that the jury instructions sufficiently conveyed the legal standards to be applied, and the plaintiff failed to show that the occurrence of a medical condition during the experimental protocol implied that the protocol caused the condition. View "Ward v. Schaefer" on Justia Law

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Ricardo Jose Pineda-Maldonado, a native and citizen of El Salvador, sought review of a decision by the Board of Immigration Appeals (BIA) that denied his application for asylum and claims for withholding of removal and protection under the Convention Against Torture (CAT). He entered the United States without inspection in 2016, following threats and physical harm from "cattle thieves" who had previously murdered his father over a gambling-related financial debt. The cattle thieves subsequently targeted Pineda-Maldonado and his brother for the father's debt and also out of fear that they would seek reprisals for their father's murder. The United States Court of Appeals for the First Circuit determined that the BIA's denial of Pineda-Maldonado's claims was not supported by substantial evidence and failed to adequately assess the evidence presented. The court found that the BIA had failed to consider whether the threats Pineda-Maldonado received constituted past or potential future torture, and also failed to find the required nexus between the persecution Pineda-Maldonado experienced and his family status. The court granted the petition, vacated the BIA's decision, and remanded the case for further proceedings. View "Pineda-Maldonado v. Garland" on Justia Law

Posted in: Immigration Law
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In this case, the United States Court of Appeals for the First Circuit considered an appeal from a ruling by the United States District Court for the District of Puerto Rico concerning the restructuring of debts of the Commonwealth of Puerto Rico's public power company (PREPA) under Title III of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA). The appellants, GoldenTree Asset Management and Syncora Guarantee (the "Bondholders"), held around $1 billion of PREPA's roughly $8 billion in bonds and sought relief from the automatic stay on actions against PREPA's estate, hoping to appoint a receiver for PREPA.The Bondholders argued that the automatic stay lifted by operation of law, because the district court denied their latest motion for relief without first noticing and holding a hearing within the timeframe prescribed by 11 U.S.C. § 362(e)(1). However, the appellate court held that the Bondholders waived their right to a prompt notice and hearing on that motion for relief. The court reasoned that the Bondholders accepted a litigation schedule that postponed any hearing on their request for leave to seek the appointment of a receiver until after a parallel proceeding about whether—and to what extent—the Bondholders had any collateral to protect in the first place. The court therefore affirmed the judgment of the Title III court. View "GoldenTree Asset Management LP v. Financial Oversight and Management Board" on Justia Law

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The United States Court of Appeals for the First Circuit reversed a lower court's dismissal of a lawsuit brought by the government of Mexico against several U.S. gun manufacturers and a gun distributor. The lawsuit alleges that these companies facilitated illegal gun trafficking into Mexico, causing significant harm to the country. The lower court had dismissed the case based on the Protection of Lawful Commerce in Arms Act (PLCAA), which generally prohibits lawsuits against gun manufacturers and sellers for harm caused by the criminal misuse of their products. On appeal, the First Circuit held that the PLCAA does apply to lawsuits initiated by foreign governments for harm suffered outside the United States. However, the court also found that Mexico's lawsuit plausibly alleges a type of claim that is statutorily exempt from the PLCAA's general prohibition, specifically, that the defendants knowingly violated federal and state statutes applicable to the sale or marketing of firearms, and that this violation was a proximate cause of the harm Mexico suffered. The case was remanded back to the lower court for further proceedings. View "Estados Unidos Mexicanos v. Smith & Wesson Brands Inc." on Justia Law

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The United States Court of Appeals for the First Circuit upheld a district court's decision concerning a wage dispute between an employee and his former employer. The employee, Paulo Trindade, claimed that his former employer, Grove Services, Inc., breached their contract and violated the Massachusetts Wage Act by short-changing him on his sales commission compensation. Grove Services challenged the timeliness of Trindade's Wage Act claim relating to the 2016 commission, but the court agreed with the district court that the claim related back to his original complaint, making it timely. The First Circuit also upheld the district court's damages award. Trindade was awarded $330,597 in damages, which included compensation for late and unpaid wages for the 2016 commission, subject to mandatory trebling under the Wage Act, and damages for the 2014 breach of contract. View "Trindade v. Grove Services, Inc." on Justia Law

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This case involves a medical malpractice suit against Hospital San Cristobal (HSC), Dr. Iris Vélez García, and Dr. Zacarías A. Mateo Minaya by the children of Ramona Rodríguez Rivera, who passed away while in the care of HSC. The plaintiffs alleged that their mother received negligent care at HSC during and following an abdominal surgery performed by Dr. Vélez and Dr. Mateo, leading to her death. The United States District Court for the District of Puerto Rico granted summary judgment in favor of the defendants.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court held that the district court did not err in excluding the plaintiffs' expert witness's testimony under Federal Rule of Evidence 702. The expert's report failed to identify the standard of care that HSC staff should have adhered to in their management of the patient's diabetes and how the staff deviated from that standard. Without this expert testimony, the plaintiffs could not establish a breach of the defendants' duty of care, a necessary element of a negligence claim. The appellate court also found no error in the district court's grant of summary judgment to the defendants as there was no evidence in the record that could show the defendants' negligence. View "Rivera Rodriguez v. Hospital San Cristobal" on Justia Law

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In the case before the United States Court of Appeals for the First Circuit, the defendant, Luis Ángel Colón-Cordero, was convicted of violating the terms of his supervised release and charged with new criminal conduct, including the possession of a firearm. The district court sentenced Colón-Cordero to an upwardly variant sentence for his new criminal conduct and a maximum term of imprisonment for violating his supervised release, which were to run consecutively. Colón-Cordero appealed, challenging the sentences as unreasonable.The appeals court vacated and remanded the case for resentencing. The court held that the district court had not adequately justified or explained its upward variance from the sentencing guidelines in the new criminal conduct case. Specifically, the appeals court found that the district court had not adequately engaged with the mitigating impact of Colón-Cordero's intellectual disability, despite this being a primary argument presented by his defense.In the case of the revocation sentence, the appeals court held that the district court's finding that Colón-Cordero was "constantly engaging in the illegal use of controlled substances" during his supervised release period was clearly erroneous. The record showed that Colón-Cordero had only tested positive for drug use twice during his release period, contradicting the district court's characterization of his drug use as constant. The court concluded that this error may have affected the sentencing outcome. The case was remanded for resentencing to a different judge. View "United States v. Colon-Cordero" on Justia Law

Posted in: Criminal Law
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In this case, defendant Samuel Arce-Ayala, a leader of a drug trafficking organization, pled guilty to federal charges related to drug trafficking and firearm possession. He believed, based on his plea agreement and statements made by his lawyer and the district court, that his federal sentence would reflect "credit" for the prison time he served for related non-federal criminal convictions. However, after entering his guilty plea, Arce-Ayala discovered that such credit could not reduce his sentence below the applicable mandatory minimum terms of imprisonment. He moved to withdraw his plea before sentencing, arguing that he didn't understand the consequences of his guilty plea, but the district court denied the motion.The United States Court of Appeals For the First Circuit vacated Arce-Ayala's criminal judgment of conviction. The court held that Arce-Ayala did not have sufficient "knowledge of the consequences of the guilty plea" because he was told by his defense counsel and the district court that the time he spent in Commonwealth custody would be credited toward his federal sentence. He did not know that the mandatory minimum prison sentence set an inviolable floor as to the amount of credit he could receive for time served on the Commonwealth sentences. As such, his plea violated a "core concern" of Rule 11, which requires a defendant to understand the consequences of a guilty plea, and must be set aside. The case was remanded back to the district court for further proceedings. View "United States v. Arce-Ayala" on Justia Law

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The United States Court of Appeals for the First Circuit ruled on a case involving a commercial real estate transaction in Puerto Rico that failed to close. The sellers of the property, located in Valle Arriba Heights, had entered into agreements to sell their respective parcels to KRB Universal Investments, LLC, which later assigned its rights under the agreements to CPC Carolina PR, LLC ("CPC"). The conditions of the sale included the cancellation of restrictive covenants that limited the use of the property to residential purposes. CPC intended to lease the properties to Puerto Rico CVS Pharmacy, LLC ("CVS") for commercial use. However, CVS refused to proceed with the lease due to restrictive covenants and issues with the title insurance policy. The sellers sued CPC and CVS for negligence, alleging that they had been induced into an impossible contract and that CVS's actions had contributed to vandalism on the properties. The district court granted summary judgment in favor of CPC and CVS. On appeal, the appellate court affirmed the district court's decision, holding that the sellers' claims were time-barred and that they failed to establish the necessary elements of their negligence claims. View "Hamdallah v. CPC Carolina PR, LLC" on Justia Law

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The United States Court of Appeals for the First Circuit considered a case where Lawrence General Hospital (LGH) sued Continental Casualty Company for denying coverage for losses LGH alleges it suffered during the COVID-19 pandemic. LGH argued that its insurance policy with Continental covered the losses under two types of coverage: coverage for "direct physical loss of or damage to property" and a Health Care Endorsement covering losses and costs incurred due to compliance with government decontamination orders.Applying Massachusetts state law, the court ruled that LGH failed to state a claim that the SARS-CoV-2 virus caused "direct physical loss of or damage to its property," affirming the lower court's dismissal of this claim. However, the court found that LGH was subject to decontamination orders due to COVID-19 and thus had a valid claim for coverage under the Health Care Endorsement. As such, the court reversed the lower court's dismissal of this claim and remanded the case for further proceedings. View "Lawrence General Hospital v. Continental Casualty Co." on Justia Law