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

During the 2023–2024 academic year, students at a private university in Massachusetts engaged in a series of pro-Palestinian protests following violence in the Middle East. The protests included rallies, walkouts, chalk messages, and an encampment near the campus Hillel center. Some Jewish and Israeli students reported feeling unsafe or unwelcome, and a few specific incidents were alleged, such as being blocked from campus areas or subjected to hostile remarks. The university responded by revising protest policies, suspending student groups, and eventually clearing the encampment, but did not discipline all protestors or end the demonstrations immediately.The United States District Court for the District of Massachusetts dismissed the plaintiffs’ suit, which alleged violations of Title VI of the Civil Rights Act, the Ku Klux Klan Act, and state law, for failure to state a claim. The court found that the plaintiffs had not plausibly alleged actionable harassment or that the university was deliberately indifferent to any such harassment. The court also declined to exercise supplemental jurisdiction over the state-law claims.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The First Circuit held that most of the protestors’ conduct constituted protected speech under the First Amendment and did not amount to actionable harassment under Title VI. The court further found that the university was not deliberately indifferent, as it took a series of escalating actions in response to the protests. The court also concluded that the plaintiffs failed to state a claim under the Ku Klux Klan Act because they did not plausibly allege a conspiracy with the purpose of depriving Jewish or Israeli students of their rights. The dismissal of the state-law claims was affirmed, and the court found no abuse of discretion in denying further leave to amend the complaint. View "StandWithUs Center for Legal Justice v. MIT" on Justia Law

Puerto Rico Telephone Company (PRTC) sought to confirm an arbitration award against WorldNet Telecommunications in federal court under section 9 of the Federal Arbitration Act (FAA). PRTC relied on then-existing First Circuit precedent, which allowed federal courts to exercise subject-matter jurisdiction over such applications if the underlying dispute involved a federal question. After the district court dismissed PRTC’s action for lack of Article III standing, PRTC appealed.The United States District Court for the District of Puerto Rico dismissed the case, finding that PRTC had not shown the necessary injury-in-fact to establish standing under Article III of the Constitution. PRTC then appealed to the United States Court of Appeals for the First Circuit. While the appeal was pending, the United States Supreme Court decided Badgerow v. Walters, which held that federal courts lack subject-matter jurisdiction over applications to confirm or vacate arbitration awards under sections 9 and 10 of the FAA, except in circumstances not present in this case. PRTC requested that the First Circuit vacate the district court’s judgment and direct dismissal without prejudice for lack of subject-matter jurisdiction, so that PRTC could pursue relief in the Commonwealth courts. WorldNet argued that the First Circuit should instead affirm the district court’s dismissal on standing grounds.The United States Court of Appeals for the First Circuit held that, in light of Badgerow v. Walters, federal courts do not have subject-matter jurisdiction over PRTC’s application to confirm the arbitration award under section 9 of the FAA. The First Circuit vacated the district court’s judgment and remanded with instructions to dismiss the case without prejudice for lack of subject-matter jurisdiction. The court did not address the standing issue. View "Puerto Rico Telephone Co. v. Worldnet Telecommunications, LLC" on Justia Law

In late 2020 and early 2021, Massachusetts law enforcement investigated a suspected drug trafficking organization operating in the South Shore area. The investigation focused on two apartments believed to be used for storing and distributing drugs, and a blue Jeep Grand Cherokee linked to the organization. On January 11, 2021, officers executed state search warrants at both apartments, recovering large quantities of narcotics, cash, firearms, and drug-trafficking equipment. Earlier that day, officers conducted a warrantless stop of the Jeep, driven by Aderito Patrick Amado, and found additional drugs and cash. Amado was charged with conspiracy to possess with intent to distribute fentanyl, fentanyl analogue, and cocaine; three counts of possession with intent to distribute those substances; two counts of being a felon in possession of firearms; and one count of possessing firearms in furtherance of drug trafficking.The United States District Court for the District of Massachusetts denied Amado’s motion to suppress evidence from the Jeep, finding that officers had reasonable suspicion for the stop. After a nine-day trial, a jury convicted Amado on all counts except one firearm-in-furtherance charge. The district court sentenced him to a total of 384 months’ imprisonment, within the advisory Guidelines range, and ten years of supervised release. Amado appealed, challenging the denial of his suppression motion, the application of an obstruction-of-justice enhancement, his designation as a career offender, and the substantive reasonableness of his sentence compared to a co-defendant’s shorter term.The United States Court of Appeals for the First Circuit affirmed the district court’s rulings. The court held that reasonable suspicion supported the stop of the Jeep, the obstruction-of-justice enhancement was warranted due to Amado’s perjury at trial, and the career-offender designation was proper and did not affect the advisory range. The court also found no substantive sentencing error, noting material differences between Amado and his co-defendant. The convictions and sentence were affirmed. View "United States v. Amado" on Justia Law

A management company brought suit in federal court against a contractor and its surety, seeking to recover financial losses allegedly suffered by several subcontractors after the contractor and surety failed to pay for work performed on post-hurricane rebuilding projects in Puerto Rico and the Virgin Islands. The management company’s claims were based on assignments it had received from the subcontractors, who were not themselves parties to the suit. The complaint asserted that federal diversity jurisdiction existed because the management company was completely diverse from the defendants and the amount in controversy exceeded $75,000.The United States District Court for the District of Puerto Rico stayed the case, requiring the plaintiff to pursue certain remedies in local courts first. On appeal, the United States Court of Appeals for the First Circuit identified a potential jurisdictional defect: the complaint did not allege the citizenship of the subcontractors, whose assignments formed the basis of the claims. The appellate court remanded the case to the district court to determine whether the subcontractors were completely diverse from the defendants and whether the assignments were collusive attempts to manufacture federal jurisdiction.After remand, the district court found that the plaintiff had failed to provide sufficient evidence to establish the subcontractors’ citizenship or to show that the assignments were not collusive. The First Circuit held that the plaintiff, as the party invoking federal jurisdiction, bore the burden of establishing complete diversity and the validity of the assignments for jurisdictional purposes. Because the plaintiff failed to meet this burden, the First Circuit remanded with instructions to dismiss the complaint for lack of subject matter jurisdiction. Costs were awarded to the appellees. View "Gore and Assoc. Mgmt. Co., Inc. v. SLSCO Ltd." on Justia Law

Víctor Miguel Duluc-Méndez was convicted for his role in a 2013 carjacking in Puerto Rico that resulted in the death of the vehicle’s driver. Duluc and a juvenile accomplice forcibly took a car, detained the driver, withdrew money from his account, and later, the juvenile fatally shot the driver. Duluc was apprehended shortly after and admitted to the carjacking, though he denied knowledge of the juvenile’s intent to kill. He pleaded guilty to the carjacking charge, and the United States District Court for the District of Puerto Rico sentenced him to 240 months in prison.After serving about ten years, Duluc moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing his mother’s deteriorating health and his siblings’ inability to care for her, supported by letters from his family. He also emphasized his substantial post-conviction rehabilitation, including completion of over a thousand hours of programming, leadership roles, and strong recommendations from prison staff and fellow inmates. The government opposed the motion, arguing that Duluc had not shown he was the only available caregiver and that rehabilitation alone was insufficient for compassionate release. The district court denied the motion in a brief order, finding Duluc’s family circumstances unconvincing and citing his criminal record, without addressing his rehabilitation arguments.The United States Court of Appeals for the First Circuit reviewed the denial. The court held that the district court abused its discretion by failing to consider Duluc’s argument that his rehabilitation, combined with his family circumstances, could constitute “extraordinary and compelling reasons” for release. The appellate court vacated the district court’s order and remanded the case for further proceedings, instructing the lower court to consider Duluc’s rehabilitation in its analysis. View "United States v. Duluc-Mendez" on Justia Law

A husband and wife brought a lawsuit after the wife suffered a pelvic fracture during a forceps-assisted delivery performed by a doctor at a women’s health group. They alleged that the doctor failed to obtain the wife’s informed consent by not disclosing the risks associated with the procedure. The plaintiffs claimed that this omission violated Massachusetts law and sought damages for the resulting injury.The United States District Court for the District of Massachusetts handled the case initially. During pretrial proceedings, the defendants moved to strike the plaintiffs’ expert witnesses, arguing that the plaintiffs had not made their experts available for deposition as required by the Federal Rules of Civil Procedure. The plaintiffs did not respond to this motion, and the District Court granted it, excluding the expert testimony. The plaintiffs later failed to appear at a pretrial conference, citing email issues, and only addressed the missed conference, not the exclusion of their experts. The District Court declined to vacate its order striking the experts, finding the plaintiffs’ delay and lack of explanation unjustified. Subsequently, the District Court granted summary judgment to the defendants, concluding that expert testimony was necessary to support the informed consent claim under Massachusetts law.On appeal, the United States Court of Appeals for the First Circuit reviewed the District Court’s decisions. The appellate court held that the District Court did not abuse its discretion in refusing to reconsider the order striking the expert witnesses, given the plaintiffs’ prolonged inaction and failure to address the underlying issues. The First Circuit also held that, under Massachusetts law, expert testimony was required to establish that the risk of pelvic fracture from a forceps-assisted delivery was more than negligible, and thus, summary judgment for the defendants was appropriate. The judgment of the District Court was affirmed. View "Meka v. Haddad" on Justia Law

Three nonprofit organizations brought suit challenging an executive order that denies U.S. citizenship to children born in the United States whose fathers are neither citizens nor lawful permanent residents, and whose mothers are present in the country either unlawfully or only temporarily. The organizations alleged that they have members who are expecting children affected by the order, and sought declaratory and injunctive relief, arguing that the order violates the Citizenship Clause of the Fourteenth Amendment and the Immigration and Nationality Act.The United States District Court for the District of New Hampshire found that the plaintiffs had standing and a cause of action for injunctive relief. The court determined that the plaintiffs were likely to succeed on the merits of their constitutional and statutory claims, and that the equitable factors favored granting relief. It issued a preliminary injunction barring enforcement of the executive order against the plaintiffs and their members, but not against nonparties. The government appealed the scope and propriety of the injunction.The United States Court of Appeals for the First Circuit reviewed the preliminary injunction for abuse of discretion, with de novo review of legal issues and clear error review of factual findings. The court affirmed the district court’s determination that the plaintiffs had standing and were likely to succeed on the merits of their claims under the Citizenship Clause and 8 U.S.C. § 1401. However, the First Circuit vacated the injunction to the extent that it ran directly against the President and the agencies themselves, holding that injunctive relief should be limited to agency officials. The court affirmed the injunction as applied to the organizations’ members who are likely to be harmed, and remanded for further proceedings consistent with its opinion. View "New Hampshire Indonesian Community Support v. Trump" on Justia Law

The case concerns challenges to Executive Order No. 14160, issued in January 2025, which seeks to deny birthright citizenship to children born in the United States after its effective date if their fathers are not U.S. citizens or lawful permanent residents and their mothers are either unlawfully or temporarily present in the country. Plaintiffs include individual immigrants, nonprofit organizations, and a coalition of states and local governments. They allege that the Executive Order violates the Citizenship Clause of the Fourteenth Amendment, 8 U.S.C. § 1401(a), the equal protection component of the Fifth Amendment, the Separation of Powers doctrine, and the Administrative Procedure Act. The plaintiffs seek declaratory and injunctive relief to prevent enforcement of the Order.The United States District Court for the District of Massachusetts granted preliminary injunctions to both sets of plaintiffs, finding they were “exceedingly likely” to succeed on their claims under the Citizenship Clause and § 1401(a). The injunctions barred federal agencies and officials from enforcing the Executive Order against the plaintiffs and, in the case brought by the states, issued a nationwide injunction to provide complete relief. The government appealed, challenging the plaintiffs’ standing, the scope of the injunctions, and the merits of the constitutional and statutory claims.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court’s findings that the plaintiffs have Article III standing and are likely to succeed on the merits. The First Circuit held that the Executive Order’s denial of birthright citizenship to children born in the United States under the specified circumstances violates both the Citizenship Clause of the Fourteenth Amendment and 8 U.S.C. § 1401(a), as interpreted by United States v. Wong Kim Ark and subsequent precedent. The court affirmed the preliminary injunctions in part, vacated them in part as to agency defendants, and remanded for further proceedings consistent with its opinion. View "Doe v. Trump" on Justia Law

A group of out-of-state pig farmers and a pork processor challenged a Massachusetts law that prohibits the use of certain confinement methods for breeding pigs (specifically, gestation crates) and bans the sale in Massachusetts of pork products derived from pigs confined in such a manner. The plaintiffs, who operate outside Massachusetts and use these confinement methods, argued that the law discriminates against out-of-state producers and is preempted by federal statutes. The law was enacted by ballot initiative and became enforceable after the Supreme Court’s decision in National Pork Producers Council v. Ross.The United States District Court for the District of Massachusetts dismissed most of the plaintiffs’ claims, including those based on the Privileges and Immunities Clause, preemption by the Federal Meat Inspection Act (FMIA) and the Packers and Stockyards Act (PSA), the Full Faith and Credit Clause, the Due Process Clause, and the Import-Export Clause. The court allowed the dormant Commerce Clause claim to proceed, but ultimately granted summary judgment against the plaintiffs on that claim as well, after severing a provision of the law that it found discriminatory (the “slaughterhouse exemption”). The court found that the remaining provisions of the law did not discriminate against out-of-state interests and did not impose a substantial burden on interstate commerce.The United States Court of Appeals for the First Circuit affirmed the district court’s rulings. The First Circuit held that the Massachusetts law does not discriminate against out-of-state producers in purpose or effect, does not impose a substantial burden on interstate commerce under the Pike balancing test, and is not preempted by the FMIA or PSA. The court also rejected the plaintiffs’ claims under the Privileges and Immunities Clause, Full Faith and Credit Clause, Due Process Clause, and Import-Export Clause. The court found no procedural error in the district court’s handling of the case. View "Triumph Foods, LLC v. Campbell" on Justia Law

A Haitian national entered the United States on a temporary visa in 2010 and was later charged with removability for overstaying his visa. After initially obtaining temporary protected status, which was extended for several years, his status was not renewed in 2018. He was subsequently arrested multiple times in New Hampshire between 2018 and 2020 for incidents involving domestic violence and resisting arrest, though not all arrests resulted in convictions. Following his last arrest, he was detained and removal proceedings were initiated. He sought adjustment of status through his wife, as well as cancellation of removal and other forms of relief.An Immigration Judge (IJ) found him removable and denied his applications for adjustment of status and cancellation of removal. The IJ found the testimonies of the petitioner and his wife credible but inconsistent regarding the details of the arrests, and gave more weight to police reports, which were considered closer in time to the events. The IJ denied adjustment of status as a matter of discretion, citing the negative factors reflected in the police reports, and found the petitioner ineligible for cancellation of removal due to insufficient continuous physical presence, as his notice to appear was served less than two years after his arrival.The Board of Immigration Appeals (BIA) affirmed the IJ’s decision, holding that the police reports were reliable and their use was not fundamentally unfair, and that the IJ could consider evidence of criminal conduct not resulting in conviction. The BIA also found the notice to appear sufficient to stop the accrual of continuous presence. The United States Court of Appeals for the First Circuit held that the BIA erred by failing to determine whether the police reports were corroborated before giving them substantial weight in denying adjustment of status. The court vacated the BIA’s order as to adjustment of status and remanded for further proceedings, but affirmed the denial of cancellation of removal. View "Maurice v. Bondi" on Justia Law