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

The First Circuit affirmed Defendant's twenty-four-month sentence for violating conditions of his supervised release, holding that the sentence was neither procedurally nor substantively unreasonable.In 2014, Defendant pleaded guilty to being a prohibited person in possession of a firearm and was sentenced to sixty months in prison, followed by three years of supervised release. After Defendant reentered the community on supervised release he was arrested on firearms charges. The new arrest triggered revocation proceedings in his supervised release case. After a final revocation hearing, the district court found that Defendant violated the conditions of his supervised release and sentenced him to twenty-four months' imprisonment. The First Circuit affirmed, holding (1) Defendant was not entitled to relief on his claims of procedural error; and (2) Defendant's sentence was substantively reasonable. View "United States v. Colon-De Jesus" on Justia Law

The First Circuit reversed the decision of the district court granting summary judgment for Appellants on their claim brought under Title IX of the Education Amendments of 1972, holding that the district court should not have dismissed the Title IX claim.MG, a minor child, alleged that he was harassed by fellow students while he was attending Brooke Charter School East Boston. Appellants - MG's mother, on behalf of herself, MG, and his four minor siblings - brought suit against the school asserting claims under Title IX, the Equal Protection Clause of the Fourteenth Amendment, and Massachusetts state law. The federal district court granted summary judgment for the school on all claims. The First Circuit reversed the summary judgment on Appellants' Title IX claim and remanded the case, holding that genuine issues of material fact precluded summary judgment on the Title IX claim. View "Grace v. Board of Trustees" on Justia Law

The First Circuit vacated the judgment of the district court convicting Defendant on federal drug- and gun-related charges, holding that the district court erred by failing to suppress incriminating statements Defendant made to law enforcement because the government failed to satisfy its burden to show that Defendant validly waived his rights under Miranda v. Arizona, 384 U.S. 436 (1966).Defendant was charged with conspiracy to distribute and to possess with intent to distribute heroin, cocaine, cocaine base, and fentanyl; possession with intent to distribute those drugs; and being a felon in possession of a firearm. Defendant filed a motion to suppress statements he made to law enforcement immediately following his arrest, arguing that the statements were obtained in violation of his Miranda rights. The district court denied the motion to suppress, concluding that Defendant understood his Miranda rights and knowingly, intelligently and voluntarily waived them. The First Circuit reversed, holding that the government failed to show that Defendant validly waived his Miranda rights, and this error was not harmless. View "United States v. Donald" on Justia Law

In this action arising out of the curtailment of classes and services at the University of Rhode Island (URI) during the COVID-19 pandemic, the First Circuit affirmed the judgment of the district court dismissing some of Plaintiffs' claims early in the litigation and granting summary judgment in favor of Defendant on the remaining claims, holding that the district court did not err.Plaintiffs, students who remained enrolled at URI during the pandemic, filed separate putative class actions against URI alleging breach of contract and unjust enrichment. Specifically, Plaintiffs argued that URI had breached its contract when it stopped providing in-person, on-campus instruction. The district court dismissed certain claims and then, following the completion of discovery, granted summary judgment on the remaining claims. The First Circuit affirmed, holding that Plaintiffs failed to make out a genuine issue of material fact as to whether URI had either an express or implied contract to provide in-person services and activities. View "Burt v. Bd. of Trustees of University of R.I." on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant, following a jury trial, of four counts of wire fraud, in violation of 18 U.S.C. 1343, and one count of making false statements to a financial institution, in violation of 18 U.S.C. 1014, holding that Defendant was not entitled to relief on his claims of error.Specifically, the First Circuit held (1) there was sufficient evidence presented to the jury of Defendant's intent to defraud for his wire convictions; (2) there was sufficient evidence of Defendant's intent to influence a financial institution; and (3) there was no adequate record with which to determine the effectiveness of counsel's decisions, and therefore, Defendant's ineffective assistance of counsel claims were dismissed without prejudice. View "United States v. Buoi" on Justia Law

The First Circuit denied Petitioner's petition for review of the decision of the Board of Immigration Appeals (BIA) affirming the decision of the immigration judge (IJ) to deny Petitioner's application for asylum, withholding of removal, and protection under the Convention Against Torture (CAT), holding that the IJ's and BIA's decisions were supported by substantial evidence.Petitioner, a member of Ecuador's Quchua indigenous group, went before the IJ seeking to avoid removal through applications for asylum, withholding of removal, and CAT protection. The IJ denied all three forms of relief and ordered Petitioner's removal to Ecuador. The BIA affirmed the IJ's denial of relief on the merits. The First Circuit affirmed, holding that Petitioner's application for asylum was appropriately denied, and therefore, withholding of removal was also appropriately denied. View "Caz v. Garland" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Investors' securities fraud claims, with one exception with respect to one particular statement for which the Court concluded that Investors' pleadings adequately stated a claim, holding that the district court correctly dismissed Investors' remaining fraud claims.Investors brought this class action following a significant drop in Biogen Inc.'s stock price, alleging violations of sections 10(b) and 20(a) of the Securities Exchange Act of 1934. Investors specifically alleged that Defendants' statements regarding its Alzheimer's disease drug's clinical trials were misleading. The district court granted Defendants' motion to dismiss, concluding that Investors failed adequately to allege a materially false or misleading statement or omission, loss causation, and scienter. The First Circuit (1) reversed the judgment of the district court dismissing the section 10(b) and section 20(a) claims predicated upon a certain statement, holding that dismissal was not warranted as to this issue; and (2) otherwise affirmed the dismissal of the remaining fraud claims, holding that the district court did not err as to these claims. View "Shash v. Biogen Inc." on Justia Law

The First Circuit affirmed the judgment of the bankruptcy court denying Debtor a discharge pursuant to 11 U.S.C. 727(a)(3) for Debtor's failure to keep or preserve records and declined to decide whether a denial was warranted under 11 U.S.C. 727(a)(4) holding that the bankruptcy court properly denied a discharge under section 727(a)(3).Plaintiff filed a Chapter 7 bankruptcy petition. Defendant, who held an unsatisfied judgment against Plaintiff, commenced an adversary proceeding seeking to deny Plaintiff a discharge on five separate grounds. The bankruptcy court denied Plaintiff a discharge pursuant to section 727(a)(3) and also found that the discharge should be denied under section 727(a)(4). The First Circuit affirmed, holding that the bankruptcy court properly denied a discharge pursuant to section 727(a)(3). View "Hernandez v. Shove" on Justia Law

The First Circuit affirmed in part and vacated in part the judgment of the district court denying Appellants' request for preliminary injunctive relief from the COVID-19 vaccine policy of Woods Hole, Martha's Vineyard and Nantucket Steamship Authority, holding that remand was required.At issue was Executive Order No. 595, which the Governor of the Commonwealth of Massachusetts issued in response to the COVID-19 pandemic. In response to the order, the Authority issued its own vaccine policy requiring all Authority employees to be fully vaccinated. Appellants, Authority employees, submitted timely requests for religious exemptions from the policy, but the requests were denied. Appellants brought this action under 42 U.S.C. 1983 claiming Appellees denied their rights under the Free Exercise Clause of the First Amendment and also pleading state-law claims. The district court denied relief. The First Circuit affirmed in part and vacated in part, holding that the district court's "likelihood of success" ruling was erroneous. View "Brox v. Woods Hole" on Justia Law

The First Circuit granted the government's petition for rehearing en banc in these consolidated appeals regarding Defendants' 2016 convictions for violating the Maritime Drug Law Enforcement Act, 46 U.S.C. 70501 et seq. (MDLEA), holding that 46 U.S.C. 70503(e)(1) does not limit the subject matter jurisdiction of federal courts under Article III of the United States Constitution.Defendants pleaded guilty unconditionally to the underlying charges, but a panel of the First Circuit vacated the convictions and ordered the underlying charges dismissed. The government petitioned for rehearing en banc. The First Circuit granted the petition, vacated the panel's ruling, and affirmed Defendant's convictions, holding that section 70503(e)(1) merely limits the substantive reach of the MDLEA and that Defendants' claims on appeal failed. View "United States v. Davila-Reyes" on Justia Law