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

The First Circuit vacated the judgment of the district court denying Defendant's prisoner-initiated motion for compassionate release, holding that because the district court did not undertake an evaluation of the 18 U.S.C. 3553(a) factors remand was necessary.Defendant was found guilty by a jury of conspiracy to distribute five kilograms or more of heroin, cocaine, cocaine base and marijuana. The district court sentenced Defendant to a term of life imprisonment. After Congress passed the First Step Act amending the compassionate-release statute Defendant moved for either compassionate release or a sentence reduction. The district court denied relief. The First Circuit vacated the judgment below, holding (1) the district court abused its discretion in concluding that Defendant's compassionate-release motion could not proceed as a matter of law; and (2) this Court declines Defendant's request to grant his motion for compassionate release. View "United States v. Quiros-Morales" on Justia Law

The First Circuit dismissed as moot the appeal brought by the Milk Industry Regulatory Office of the Commonwealth of Puerto Rico (ORIL) challenging two bankruptcy court orders, holding that the action became moot prior to the judgment of the Bankruptcy Appellate Panel (BAP) for the First Circuit affirming the bankruptcy court orders on the merits.The first order at issue granted Luis Manuel Ruiz Ruiz permission to enter a lease in the course of his bankruptcy proceedings, and the second order denied ORIL's motion for reconsideration of that permission. The BAP affirmed the orders on the merits. The First Circuit dismissed ORIL's appeal as moot, vacated the judgment of the BAP, and remanded the case to the BAP with instructions to dismiss ORIL's appeal as moot, holding (1) this case was moot, and there was no exception to the mootness doctrine to save this appeal from dismissal; and (2) the balance of the equities weighed against vacated of the bankruptcy court orders at issue. View "Milk Industry Regulatory Office v. Ruiz Ruiz" on Justia Law

The First Circuit affirmed the decision of the district court entering summary judgment for Sheet Metal Workers' National Pension Fund (Fund) in this suit brought by David Field for plan benefits pursuant to ERISA section 502(a)(1)(B), 29 U.S.C. 1132(a)(1)(B), holding that Field was not entitled to relief on his allegations of error.Field brought suit for plan benefits arguing that the Fund wrongfully terminated his previously granted disability benefit payments based on findings made by the Appeals Committee of the Board of Trustees of the Fund that Field had engaged in disqualifying employment and had not completed sufficient hours of covered employment to become eligible for the benefit. The district court granted summary judgment for the Fund, concluding that the Appeals Committee did not abuse its discretion and was not arbitrary or capricious in terminating Field's disability benefit payments. The First Circuit affirmed, holding that the Committee acted reasonably and with support by substantial evidence on the record as a whole. View "Field v. Sheet Metal Workers' Nat'l Pension Fund" on Justia Law

The First Circuit vacated the decision of the federal district court revoking Defendant's term of supervised release and ordering him to return to prison for an additional two years, holding that resentencing was required on the proper record.Defendant was convicted of a drug crime, sentenced, and placed on supervised release. The district court later revoked Defendant's supervised release term on ordered him returned to prison for two years, finding that Defendant made unlawful death threats in violation of a condition of his release. The First Circuit affirmed the order revoking Defendant's term of supervision but vacated Defendant's revocation sentence and remanded the case for resentencing, holding that the district court erred by admitting certain testimony and that the error may have affected the court's decision to impose an upwardly variant sentence. View "United States v. Navarro-Santisteban" on Justia Law

The First Circuit vacated Defendant's new sentence after concluding that it could sua sponte consider a claim of error not timely raised by Defendant, holding that the district court committed plain error during sentencing.Defendant pled guilty to two carjacking offenses and a firearm count. The district court varied upward and imposed concurrent sentences of eighty-seven months on the carjacking counts and a consecutive sentence of 108 months on the firearm count. The First Circuit remanded for resentencing. The district court ultimately imposed concurrent sentences of 132 months' imprisonment on the carjacking counts and a consecutive sentence of 108 months' imprisonment on the firearm count. The First Circuit vacated the sentence, holding (1) this Court may sua sponte raise an error that constitutes a violation of the mandate rule; and (2) the resentencing court in this case committed plain error under this Court's holding in United States v. Ticchiarelli, 171 F.3d 24 (1st Cir. 1999). View "United States v. Cheveres-Morales" on Justia Law

The First Circuit vacated Defendant's conviction for possession of a machine-gun in furtherance of a drug trafficking crime and remanded the case for a new trial as to that count, holding that the jury should have been instructed about Defendant's knowledge of the characteristics of the firearm he possessed.After a jury trial, Defendant was convicted of possession with intent to distribute controlled substances, possession of a firearm in furtherance of a drug trafficking crime, and possession of a machine-gun in furtherance of a drug trafficking crime. The First Circuit vacated the convictions in part, holding (1) the evidence was sufficient to support the convictions; (2) Defendant was not entitled to relief on his claims for pretrial and trial error; and (3) the district court improperly instructed the jury that the government was not required to prove that Defendant knew the firearm he possessed was a machine-gun. View "United States v. Perez-Greaux" on Justia Law

The First Circuit affirmed the judgment of the district court affirming U-Nest Holdings, Inc.'s motion for relief from judgment in a 2019 federal court action under Fed. R. Civ. P. 60(b)(6), holding that the district court did not err in its ruling.In 2021, U-Nest filed a case in the United States District Court for the District of Rhode Island asserting that it had been fraudulently induced to enter into a prior state court settlement agreement that was embodied in a judgment entered in 2020 in a 2019 federal court action. The federal district court stayed the 2021 action to allow U-Nest to first file a motion for relief from judgment in the 2019 action. U-Nest then filed the motion for relief from judgment, which the district court denied. The First Circuit affirmed, holding that the district court did not err in finding that U-Nest did not support its claim of fraud and/or of misrepresentation. View "U-Nest Holdings, Inc. v. Ascensus College Savings Recordkeeping Services, LLC" on Justia Law

The First Circuit affirmed the 194-month sentence imposed upon Defendant after he pled guilty to using, carrying, brandishing, and discharging a firearm in furtherance of a crime of violence, holding that the sentence was neither procedurally or substantively unreasonable.On appeal, Defendant argued, among other things, that the district court erred by making conflicting statements about his applicable guidelines sentence and that his sentence was substantively unreasonable because it was "unmoored from any particular factor." The First Circuit affirmed, holding that Defendant's 194-sentence was both procedurally and substantively reasonable. View "United States v. Melendez-Hiraldo" on Justia Law

The First Circuit denied Petitioner's petition for review of the Board of Immigration Appeals' (BIA) decision dismissing Sandra St. John's appeal from the judgment of the Immigration Judge (IJ) denying her statutory motion to reopen, holding that there was no abuse of discretion in the agency's denial of St. John's statutory motion to reopen.The Department of Homeland Security initiated removal proceedings against St. John based on her conviction for mayhem in the Commonwealth of Massachusetts. After going into ICE custody, St. John filed a motion in the Massachusetts superior court asking it to vacate her mayhem conviction and grant a new trial on ineffective assistance of trial grounds. St. John then moved for reopening of her removal proceedings on the grounds that her motion to vacate had rendered the mayhem conviction nonfinal for immigration purposes. The IJ denied the motion, and the BIA dismissed the appeal. The First Circuit denied Petitioner's petition for review, holding that the agency did not abuse its discretion in declining to reopen the order of removal based on final criminal convictions. View "St. John v. Garland" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Plaintiff's putative class action against McNeil Nutritionals, LLC and Johnson & Johnson Consumer, Inc. challenging certain statements on the packaging of Lactaid products, holding that the district court correctly dismissed the complaint.Plaintiff brought this action claiming that Lactaid's labels violated federal labeling requirements, leading Plaintiff to have been mislead into purchasing Lactaid products, which she claimed were more expensive than other lactase supplements. The district court granted Defendants' second motion to dismiss. The First Circuit affirmed, holding that Plaintiff's claims were impliedly preempted by the statutory enforcement authority of the Food and Drug Administration. View "DiCroce v. McNeil Nutritionals, LLC" on Justia Law