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

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

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

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

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

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

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

In this case, defendant Jason Colcord, appealed his sentence for knowingly accessing and viewing over 900 child pornography images. Colcord pled guilty to this charge and was subsequently sentenced to 145 months imprisonment, which was near the low end of his advisory guidelines sentencing range, followed by five years of supervised release. The defendant challenged his sentence on the grounds that the court's decision not to impose a downward variance was substantively unreasonable.The United States Court of Appeals for the First Circuit affirmed the lower court's decision. The court found that the district court's sentence was substantively reasonable. It noted that the district court had considered the nature of the offense, the need to protect the public, the defendant's personal history, and the need for punishment and deterrence, all of which are factors under 18 U.S.C. § 3553(a). The court rejected Colcord's argument that the district court conflated his conduct with those who committed more serious crimes depicted in the images and videos, stating that the comments were referring to Colcord's role as a consumer of child pornography.The court also rejected Colcord's argument that insufficient weight was given to his personal mitigating circumstances, stating that the district court was within its discretion to find that these factors were outweighed by the seriousness of the offense and the need to protect the public.Lastly, the court dismissed Colcord's argument that the district court should have accepted the parties' joint recommendation of a 120-month sentence. The court stated that the district court is not bound by the parties' recommendations as to the length of the sentence to be imposed. The court also found no evidence that the district court had imposed the sentence based on personal disgust towards the offense, as claimed by the defendant.Therefore, the court affirmed the district court's sentence of 145 months imprisonment followed by five years of supervised release. View "US v. Colcord" on Justia Law

Daniel Paul Sansone, the defendant-appellant, was convicted for being a felon in possession of a firearm. He was sentenced to 46 months of imprisonment, the upper end of the sentencing guideline range. Sansone challenged the procedural integrity and substantive reasonableness of his sentence. The United States Court of Appeals for the First Circuit reviewed his claims.Sansone had argued that his criminal history score was erroneously inflated due to the inclusion of his juvenile adjudications, asserting that his commitment to the Massachusetts Department of Youth Services (DYS) was not a sentence of confinement. The court rejected this argument, noting that prior case law had upheld the inclusion of such adjudications as constituting sentences of confinement.Sansone also claimed there was insufficient evidence to support the conclusion that his juvenile adjudications resulted in confinement for at least sixty days, which was necessary for the assignment of criminal history points under the United States Sentencing Guidelines (USSG). The Court of Appeals found that Sansone could not show a plain error in this regard, as the record was ambiguous and did not allow for a clear determination of the length of his confinement.Regarding the substantive reasonableness of his sentence, Sansone argued that the sentencing court had overstated the seriousness of his past criminal record and failed to adequately consider his personal history. The Court of Appeals disagreed, finding that the sentencing court had considered all relevant factors, and Sansone's real complaint was about the weight given to certain factors, not their consideration. The court upheld the sentence, affirming the district court's decision. View "US v. Sansone" on Justia Law

In a case involving an attorney father, Scott D. Pitta, and the Bridgewater-Raynham Regional School District, the United States Court of Appeals for the First Circuit affirmed the district court's dismissal of Pitta's claim that he had a First Amendment right to video record a private meeting discussing his child's Individualized Educational Program (IEP). The court found that an IEP Team Meeting does not occur in a public space, is closed to the public, and involves discussion of highly sensitive information about a student. Furthermore, the court stated that public school teachers and administrators carrying out their IEP obligations are not akin to the "public officials" in previous cases that established a First Amendment right to record. The court also noted that Pitta's claimed right to record was not linked to the public's right to receive information. Finally, the court reasoned that even if there were a First Amendment right to record such meetings, the school district's prohibition of video recording served a significant governmental interest and was narrowly tailored to promoting candid conversations and protecting sensitive information during IEP discussions. View "Pitta v. Medeiros" on Justia Law

The United States Court of Appeals for the First Circuit reviewed an appeal concerning personal jurisdiction in a case centered on foodborne illness. Anthony Cappello, a resident of New Hampshire, had consumed a salad from a New Jersey deli, which he alleged was contaminated with E. coli. Following his diagnosis, Cappello filed a lawsuit against the deli, the company that sold the lettuce to the deli (Restaurant Depot, LLC), the distributor of the lettuce (D'Arrigo Brothers, Co.), the grower of the lettuce (Adam Brothers Farming, Inc.), and one hundred John Does. Cappello later dismissed his claims against all defendants except for Restaurant Depot and D'Arrigo Brothers. Both companies moved to dismiss the case for lack of personal jurisdiction, arguing that Cappello's claims did not arise from their contacts with New Hampshire. The District Court dismissed the case, and Cappello appealed. The Court of Appeals affirmed the lower court's decision, albeit on different grounds. The court held that Cappello failed to demonstrate the necessary element of relatedness required to establish specific personal jurisdiction under the due process clause. Neither defendant's contacts with New Hampshire were instrumental in the formation or breach of the contract related to the sale of the salad, nor were they related to the tort claims. The court found that the defendants' contacts with New Hampshire were not sufficiently related to Cappello's claims to establish personal jurisdiction. View "Cappello v. Restaurant Depot, LLC" on Justia Law