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

Former executives of medical device manufacturer Acclarent, Inc., William Facteau and Patrick Fabian, were found guilty of multiple misdemeanor violations of the Federal Food, Drug, and Cosmetic Act (FDCA) for commercially distributing an adulterated and misbranded medical device. They appealed their convictions, claiming First Amendment violations, due process violations, and insufficiency of evidence. The United States Court of Appeals for the First Circuit rejected all of these claims and affirmed the convictions. The court held that the use of promotional speech as evidence of a device's intended use did not implicate the First Amendment. The court also found that the term "intended use" was not unconstitutionally vague and that Facteau and Fabian had fair warning of the conduct prohibited under the FDCA. Finally, the court found that the evidence was sufficient to support the convictions and that Fabian's fine did not violate the Eighth Amendment. View "United States v. Facteau" on Justia Law

In this case, Ángel Menéndez-Montalvo, while serving a term of supervised release arising from his conviction for a federal firearm offense, violated the conditions of his release by breaching Article 3.1 of Puerto Rico's Domestic Violence Law. The United States Court of Appeals for the First Circuit had to determine whether a violation of Article 3.1 is a "crime of violence" as used in section 7B1.1(a)(1) of the United States Sentencing Guidelines. The court found that it is not because Puerto Rico courts have applied the law to encompass less-than-violent force. As such, the court vacated Menéndez's sentence because the district court had held to the contrary in calculating a sentencing range that was higher than it should have been. The court further clarified that its decision does not prevent the district court from considering Menéndez's conduct while on supervised release as it bears on the factors specified in 18 U.S.C. § 3583(e). The case was remanded to the district court for further proceedings consistent with this opinion. View "US v. Menendez-Montalvo" on Justia Law

In a drug trafficking case, the defendant, Amanda Cowette, appealed the district court's denial of her motion to suppress statements she made to law enforcement officers on July 16 and 17, 2018. Cowette argued that she unequivocally invoked her Fifth Amendment right to counsel and any subsequent questioning by law enforcement officers was in violation of that right. She contended that the district court's ruling to the contrary was in error. The United States Court of Appeals for the First Circuit agreed with Cowette and held that she properly invoked her Fifth Amendment right to counsel. The court found that the phrase "I guess" used by Cowette did not create any ambiguity in her clear invocation of her right to counsel. The court vacated the decision of the district court in part, affirmed in part, and remanded for proceedings consistent with this opinion. View "US v. Cowette" on Justia Law

In the case before the United States Court of Appeals for the First Circuit, a collective of long-haul truck drivers, led by Juan Carlos Montoya, contended that their employer, CRST Expedited and CRST International (collectively referred to as "CRST"), violated the Fair Labor Standards Act (FLSA) by not compensating them for time spent in a truck's sleeper berth exceeding eight hours within a 24-hour period. CRST operates a "team driving model" where two drivers alternate between driving and resting in the sleeper berth of the truck, allowing the vehicle to be in near-continuous motion. The drivers argued that the time spent in the sleeper berth was "on duty" time, as defined by Department of Labor regulations, and thus should be compensated as work. The district court granted summary judgment for the drivers, determining that such time was indeed compensable work. The Court of Appeals affirmed this decision, holding that the time drivers spend in the sleeper berth that exceeds eight hours per day is compensable work under the FLSA. The Court reasoned that the drivers' confinement to the sleeper berth, the importance of continuous travel to CRST's business model, and the potential burdens placed on the drivers suggest that the time predominantly benefits the employer. Furthermore, the Court interpreted the Department of Labor regulations to allow an employer to exclude a sleeping period of no more than eight hours from hours worked in a 24-hour period. View "Montoya v. CRST Expedited, Inc." on Justia Law

In 2021, the Securities and Exchange Commission (SEC) sued Luis Jimenez Carrillo for securities violations he allegedly committed well after his divorce from Yolanda Sanchez-Diaz. Sanchez-Diaz was named as a relief defendant in the suit and the SEC sought to recover from her the value of a car she received four years earlier, claiming Carrillo paid for it with illicit funds. The SEC did not accuse Sanchez-Diaz of any wrongdoing but argued she had no legitimate claim to the car because she had not provided any consideration for it. The district court agreed and ordered her to pay almost $170,000, including interest.On appeal, the United States Court of Appeals for the First Circuit held that a relief defendant in an SEC enforcement action has a legitimate claim to funds if they have provided something of value in exchange and the value they provided is more than nominal in relation to the money received. In this case, the court concluded that through a 2016 child support agreement, Sanchez-Diaz provided more than nominal value in exchange for Carrillo's promise to purchase the car. The court found that the district court erred in its finding that Sanchez-Diaz provided no value at all. Accordingly, the Appeals Court reversed the district court's disgorgement order. View "SEC v. Sanchez Diaz Monge" on Justia Law

The United States Court of Appeals for the First Circuit affirmed the convictions of Rafael Cardona Sr. and Isaac Cardona for conspiracy to distribute and possess with intent to distribute cocaine and heroin. Isaac Cardona was also convicted of conspiracy to commit money laundering with intent to promote the carrying on of unlawful activity. The defendants raised several arguments on appeal.Rafael Cardona Sr. argued that his two convictions were multiplicitous in violation of the Double Jeopardy Clause. The court concluded that this argument was not reviewable because it was raised for the first time on appeal and not supported by good cause, as required under Federal Rules of Criminal Procedure 12(b)(3) and 12(c)(3).Isaac Cardona argued that the money laundering statute under which he was charged is unconstitutionally vague. The court determined that this argument was not reviewable because it was not raised before trial, as required by Rule 12(b)(3). Isaac Cardona also argued that there was insufficient evidence to support his money laundering conviction and that the court gave erroneous jury instructions on this charge. The court found sufficient evidence to support the conviction and concluded that the erroneous instructions did not affect his substantial rights.The case arose from surveillance footage, recorded communications between the defendants and other co-conspirators, and other evidence showing that the defendants conspired to distribute cocaine and heroin and that Isaac Cardona conspired to commit money laundering by using the proceeds of cocaine distribution to procure and resell heroin. View "US v. Cardona" on Justia Law

Brian Smith, a Rhode Island resident, sued Prudential Insurance Company of America for breach of fiduciary duty after the company terminated his long-term disability benefits under an insurance policy. The policy stated a three-year limitations period to file a lawsuit, which began on the date Smith was required to submit proof of his disability, not on the date Prudential allegedly breached the policy by stopping payment. Consequently, by the time Smith filed his lawsuit, the limitations period had expired. Smith appealed to the United States Court of Appeals for the First Circuit after the United States District Court for the District of Rhode Island granted summary judgment in favor of Prudential on the grounds that Smith's lawsuit was filed too late.Smith argued that enforcing the limitations scheme would violate Rhode Island public policy. While the Court of Appeals found compelling reasons to believe that the limitations scheme might indeed contravene Rhode Island public policy, they also recognized that reversing and remanding on that ground would potentially expand Rhode Island law. Consequently, the Court of Appeals decided to certify the public policy question to the Rhode Island Supreme Court. The certified question is whether, in light of specific state laws and Rhode Island public policy, Rhode Island would enforce the limitations scheme in this case to bar Smith's lawsuit against Prudential. View "Smith v. Prudential Insurance Company of America" on Justia Law

In this dispute, two renewable-energy generating companies, Tyngsboro Sports II Solar, LLC and 201 Oak Pembroke Solar LLC, appealed to the United States Court of Appeals for the First Circuit after their class-action lawsuit was dismissed by the District Court for the District of Massachusetts due to lack of subject-matter jurisdiction. The plaintiffs had a longstanding disagreement with defendants, utility companies National Grid USA Service Company, Inc. and Massachusetts Electric Company, over certain tax-related fees charged to them. The plaintiffs sought redress in federal court after unsuccessful petitions to state authorities.The plaintiffs argued that the district court had jurisdiction due to the case's connection to federal tax law, however, the appellate court disagreed, stating that the plaintiffs' complaint did not bring any claim that arose under federal law. The plaintiffs had brought forth four claims against National Grid, including a request for declaratory relief, a state-law claim for a breach of the covenant of good faith and fair dealing, a state-law claim for restitution and unjust enrichment, and a state-law claim for violating a statutory requirement that public utilities assess only just and reasonable charges.The appellate court affirmed the district court's dismissal of the case, finding that the plaintiffs could not establish federal-question jurisdiction simply by asserting a state-law claim to which there was a federal defense. The court noted that the state-law claims did not necessarily raise a federal issue, and to the extent that one did, the issue was not substantial. As such, the court concluded that the district court lacked jurisdiction over the claims. View "Tyngsboro Sports II Solar, LLC v. National Grid USA Service Co., Inc." on Justia Law

In this case, a law firm, Thompson, MacColl & Bass, LLC, P.A. (TM&B), was sued by its former client, ST Engineering Marine, Ltd. (STEM), for professional negligence. STEM owned a vessel that was arrested due to several entities, including Sprague Operating Resources, LLC (Sprague), asserting maritime liens for unpaid services. STEM had sought advice from TM&B to analyze these lien claims. TM&B advised STEM that Sprague's lien was valid and should be paid. Acting on this advice, STEM paid Sprague and subsequently sued TM&B, alleging that TM&B's advice was negligent as it failed to consider the unsettled state of relevant maritime lien law.The United States Court of Appeals for the First Circuit affirmed the decision of the United States District Court for the District of Maine, which had found in favor of STEM. The Court of Appeals held that TM&B breached its duty of care to STEM by failing to conduct adequate legal research and by not appropriately counseling STEM about the uncertainty of Sprague's lien claim. The court also found that TM&B's negligence was the actual and proximate cause of STEM's loss, concluding that STEM would have prevailed in contesting Sprague's lien claim but for TM&B's erroneous advice. The court ordered TM&B to pay STEM $261,839.04 in damages. View "ST Engineering Marine, Ltd. v. Thompson, MacColl & Bass, LLC, P.A." on Justia Law

A plaintiff, Elvin Torres-Estrada, brought claims against several Federal Bureau of Investigation (FBI) agents and the United States under the Federal Tort Claims Act (FTCA) and Bivens, alleging violations of his constitutional and statutory rights. The district court dismissed his complaint, arguing that some of his claims were not filed within the required time frame and that the FTCA's discretionary function exception stripped the court of jurisdiction over his other claims. Torres-Estrada appealed the dismissal, arguing that his claims are timely, the discretionary function exception does not apply, and even if it does, it does not cover the alleged misconduct of the FBI.The United States Court of Appeals for the First Circuit held that the district court erred in its interpretation of the discretionary function exception. The court explained that this exception does not serve as a bar to FTCA tort claims that plausibly allege constitutional violations. In addition, at least two of Torres-Estrada's claims could be subject to the "continuing violation" doctrine, which means the district court erred in dismissing his claims as untimely without considering this doctrine. Given that new facts have emerged throughout the litigation, the court granted Torres-Estrada leave to amend his complaint. Therefore, the court affirmed in part, reversed in part, and remanded the case for further proceedings.The background facts of the case are that Torres-Estrada was detained at the Metropolitan Detention Center (MDC) in Guaynabo, Puerto Rico, pending prosecution for drug and money laundering offenses. During this time, he was investigated by the FBI as a potential suspect in the murder of a correctional officer at the MDC. Torres-Estrada alleges that the FBI violated his rights through various actions, including the use of informants to elicit incriminating statements about the murder, subjecting him to invasive body searches, and maintaining records falsely linking him to the murder. View "Torres-Estrada v. Cases" on Justia Law