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

The First Circuit affirmed the district court's order entering summary judgment in favor of Defendant with respect to Plaintiff's assertion that he was wrongfully deprived of thousands of dollars in commissions he alleged he was due, holding that there was no error.After he resigned, Plaintiff brought suit against Defendant, his former employer, asserting claims for nonpayment of wages under the Act, breach of contract, unjust enrichment, and quantum meruit. Defendant successfully removed the action to federal district court, which granted summary judgment in favor of Defendant. The First Circuit affirmed, holding that the district court (1) did not err in granting in part Defendant's motion to strike certain portions of his response to the summary judgment motion; and (2) did not err in granting summary judgment against Plaintiff on his claims. View "Klauber v. VMware, Inc." on Justia Law

The First Circuit affirmed the sentence imposed upon Defendant in connection with his conviction of conspiracy to possess with the intent to distribute a controlled substance and conspiracy to import a controlled substance into the United States, holding that the district court did not abuse its discretion in imposing a 262-month sentence.On appeal, Defendant argued that the district court erred by applying a four-level leadership enhancement, failing properly to consider the factors set forth in 18 U.S.C. 3553 regarding his cooperation with the government, and imposing a much longer sentence than several co-defendants. The First Circuit affirmed, holding that Defendant's sentence of 252 months' imprisonment was both procedurally and substantively reasonable. View "United States v. Coplin-Benjamin" on Justia Law

The First Circuit affirmed the judgment of the circuit court convicting Defendants of drug conspiracy crimes for their roles in a drug-trafficking case, holding that Defendants were not entitled to relief on their allegations of error.After a joint jury trial, co-defendants Katerin Martinez-Alberto and Alexandria Andino-Rodriguez were convicted for their roles in an underlying trafficking venture. The First Circuit affirmed, holding (1) any error in the trial court's evidentiary rulings was harmless; (2) there was no plain error in the jury instructions; and (3) the trial court did not commit clear error in determining that Andino-Rodriguez did not carry her burden to demonstrate she was entitled to the downward adjustment she sought. View "United States v. Andino-Rodriguez" on Justia Law

The First Circuit vacated the judgment of the district court in favor of Philadelphia Indemnity Insurance Company in this action seeking a declaration that BAS Holding Corporation breached a condition of the parties' insurance contract, holding that the district court's findings providing grounds for summary judgment were insupportable.After an arsonist destroyed a building owned by BAS and purportedly insured against loss by Philadelphia, the insurer sought an examination under oath (EUO) of George Carney, BAS's president and owner. Philadelphia then denied coverage on the grounds that BAS refused to provide Carney for an EUO, in violation of its obligations under the relevant insurance policy. Philadelphia then brought this action. The district court granted summary judgment for Philadelphia on the ground that BAS failed to cooperate by refusing to submit to the EUO. The First Circuit vacated the judgment, holding that where the evidence unequivocally showed the BAS never willfully and inexcusably refused to provide Carney for the EUO, and therefore summary judgment was improper. View "Philadelphia Indemnity Insurance Co. v. BAS Holding Corp." on Justia Law

The First Circuit affirmed the judgment of the district court dismissing this case on res judicata grounds, holding that Plaintiff's malicious prosecution claim was precluded under the doctrine of res judicata.At issue in this case arising from a dispute related to a foreclosure action was whether a prior dismissal with prejudice of a complaint filed by Plaintiff in 2017 precluded the claim brought in this 2020 case. The district court concluded that because the prior dismissal had been with prejudice, it constituted a final judgment on the merits, therefore having preclusive effect. The First Circuit affirmed, holding that Plaintiff's malicious prosecution claim was barred by res judicata and that Plaintiff was not entitled to relief on his allegations of error. View "Rivera-Rosario v. LSREF2 Island Holdings, Ltd., Inc." on Justia Law

The First Circuit affirmed the judgment of the district court granting United States Liability Insurance Group's (USLI) motion to dismiss this lawsuit brought by Nahant Preservation Trust, Inc. to secure insurance coverage in connection with defense costs and indemnification arising from a state court action brought by Northeastern University, holding that there was no error.Northeastern sued Nahant in state court seeking a declaratory judgment regarding its rights concerning certain land. Nahant, which carried liability insurance through USLI, did not notify USLI of the suit until it wrote to USLI seeking coverage for defense costs. USLI refused to provide coverage on the grounds that Nahant had provided untimely notice of the claim. Thereafter Nahant sued USLI seeking, among other things, a declaratory judgment regarding USLI's duty to defend and indemnify. The First circuit granted USLI's motion to dismiss, concluding that the "exclusion agreement" signed by the parties excluded coverage. The First Circuit affirmed, holding that the district court properly accepted USLI's plausible reading of the exclusion amendment. View "Nahant Preservation Trust, Inc. v. Mount Vernon Fire Insurance Co." on Justia Law

The First Circuit affirmed the judgment of the district court denying intervenor Eugene Volokh's motion challenging the district court's decision allowing John Doe, a former New Hampshire police officer, to proceed pseudonymously in challenging the inclusion of his name on the State of New Hampshire's Exculpatory Evidence Schedule (EES), holding that the district court did not abuse its discretion.New Hamsphire's Department of Justice maintained the EES, a list identifying law enforcement officers who had engaged in "misconduct reflecting negatively on their credibility or trustworthiness." Doe brought this action seeking damages and an injunction removing his name from the list. Doe sought to proceed as "John Doe," a pseudonym, but Volokh moved to intervene, challenging the decision to retain Doe's anonymity. The district court granted Volokh's motion to intervene but denied his motion to unseal and challenge pseudonymity. The First Circuit affirmed, holding that the district court correctly applied the presumptive right of the public to know Doe's name and did not abuse its discretion in concluding that Doe rebutted that presumption. View "Doe v. Volokh" on Justia Law

The First Circuit affirmed Defendant's convictions, entered after a jury trial, for distribution of controlled substances and possession of controlled substances with intent to distribute, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that statements made by the prosecutor during closing argument were improper, depriving him of his right to a fair trial, and that the district court erred by denying his motion to suppress drug evidence obtained during a search, pursuant to a warrant, of his residence. The First Circuit affirmed, holding that (1) Defendant's substantial rights were not affected by the prosecutor's alleged improper comments; and (2) there was no error in the denial of Defendant's motion to suppress. View "United States v. Perez Soto" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant, following a jury trial, of various firearm and controlled substance offenses, holding that none of Defendant's challenges on appeal had merit.Specifically, the First Circuit held (1) the district court correctly concluded that the search warrant leading to Defendant's arrest was clearly supported by probable cause, and therefore, there was no error in the denial of Defendant's motion to suppress; (2) the district court did not err in concluding that the evidence was sufficient to support Defendant's convictions on the firearm charges; and (3) the district court's seventy-two-month sentence on count one was substantively reasonable. View "United States v. Sylvestre" on Justia Law

The First Circuit affirmed the order of the district court dismissing Plaintiffs' claims that the closure of in-person education due to the COVID-19 pandemic deprived children of the free appropriate public education to which they were entitled and deprived and parents of their right to participate in their children's education, holding that none of Plaintiffs' claims were cognizable in federal court.Plaintiffs, three children with disabilities and their parents on behalf of a putative class, sued the Governor of Massachusetts, the Commissioner of Schools for Massachusetts, the Massachusetts Department of Elementary and Secondary Education, and several school districts and their superintendents, claiming that the closure of in-person education during the COVID-19 pandemic violated Plaintiffs' rights under the IDEA and that Defendants illegally discriminated against Plaintiffs on the basis of disability in violation the Americans with Disabilities Act and 42 U.S.C. 1983. The district court granted Defendants' motion to dismiss. The First Circuit affirmed, holding that Plaintiffs' claims were properly dismissed in full either because Plaintiffs lacked standing to request the relief they sought, because the claims were moot, and/or because Plaintiffs failed to exhaust administrative remedies. View "Roe v. Healey" on Justia Law