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

In these consolidated appeals brought in connection with a federal investigation of an organization that operated in Puerto Rico's prisons and was allegedly involved in carrying out murders-for-hire and trafficking drugs, the First Circuit held that one challenge raised on appeal required a limited remand to the district court and that Appellants were not entitled to further relief.Each of the six appellants in this case was convicted of conspiracy to violate the Racketeer Influenced and Corrupt Organization Act and conspiracy to possess with intent to distribute a controlled substance. The First Circuit granted a limited remand and otherwise affirmed, holding (1) the argument brought by three appellants that hearsay statements by alleged coconspirators were admitted into evidence at trial, in violation of United States v. Petrozziello, 548 F.2d 20 (1st Cir. 1977), required a remand for further fact-finding as to whether the statements were made in furtherance of the alleged conspiracy; (2) Appellants' sufficiency of the evidence challenges failed; and (3) Appellants were not entitled to relief on their remaining allegations of error. View "United States v. Ramos-Baez" on Justia Law

The First Circuit affirmed the judgment of the district court denying Petitioner's petition seeking habeas relief on ineffective assistance of counsel claims, holding that there was no error in the proceedings below.Petitioner was convicted in a Massachusetts state court of three counts each of rape, rape of a child, and assault and battery with a dangerous weapon. The appeals court affirmed the trial court's denial of Petitioner's petition for a new trial. Petitioner then sought habeas relief in a federal district court, claiming that he was denied the constitutionally affective assistance of counsel. The district court denied relief. The First Circuit affirmed upon applying the deference required by the Antiterrorism and Effective Death Penalty Act, holding that Petitioner failed to establish that he was entitled to habeas relief. View "Quintanilla v. Marchilli" on Justia Law

The First Circuit affirmed the decision of the Department of the Interior's Bureau of Indian Affairs (BIA) to take two parcels of land in Massachusetts into trust for the Mashpee Wampanoag Indian Tribe, holding that the BIA's application of its legal interpretation to the facts was not arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.Appellants brought this action challenging the Interior's 2021 record of decision reaffirming its 2015 decision to take the land into trust for the Tribe, arguing that the Tribe did not qualify as a "tribe" within the meaning of the Indian Reorganization Act, that the Tribe was not "under Federal jurisdiction," and that the parcel of land was not eligible activities under the Indian Gaming Regulatory Act. The district court granted summary judgment for the Interior and the Tribe. The First Circuit affirmed, holding that Appellants were not entitled to relief on any of their allegations of error. View "Littlefield v. U.S. Dep't of the Interior" on Justia Law

The First Circuit affirmed the judgment of the district court determining that Anonymous Appellant (AA) should be civilly committed upon the expiation of his prison sentence, holding that AA was not entitled to relief on his allegations of error.Seventy-three-year-old AA had a history of incarceration spanning more than five decades. During his incarceration AA began to exhibit psychotic symptoms and was diagnosed with having schizoaffective disorder, bipolar type, and antisocial personality disorder. Based on the concerns of a risk-assessment panel the government filed a petition for the civil commitment of AA pursuant to 18 U.S.C. 4246. The district court granted the petition. The First Circuit affirmed, holding that there was no error in the proceedings below. View "United States v. Anonymous Appellant" on Justia Law

The First Circuit denied Petitioners' petitions seeking judicial review of two decisions by the Board of Immigration Appeals (BIA) - one affirming an immigration judge's (IJ) denial of their application for asylum, withholding of removal, and protection under the Convention Against Torture (CAT), and the other denying Petitioners' motion to reopen their proceedings, holding that Petitioners were not entitled to relief.Petitioners applied for relief from removal based on China's politics, specifically persecution by Chinese officials seeking to enforce China's Family Planning Policy, which was in effect when Petitioners first entered the United States. The IJ denied Petitioners' application, concluding that they failed to meet their burden of proof. The BIA dismissed Petitioners' appeal. The First Circuit denied Petitioners' petitions for review, holding that there was substantial evidence to support the agency's decisions in this case. View "M.S.C. v. Garland" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment in favor of Joshua Levy, Acting United States Attorney for the District of Massachusetts, in this case challenging the denial by the United States Department of Justice (DOJ) of Levy's request for information related to a federal police misconduct investigation, holding that there was no error.Anthony Gulluni, District Attorney for Hampden County, Massachusetts, sent DOJ a letter (Touhy request) requesting all Springfield, Massachusetts Police Department (SPD) reports and documents supporting DOJ's specific and general findings in an attempt to identify SPD officers who were subject to the DOJ's findings of specific instances of misconduct and general failures within SPD's practices. DOJ denied Gullini's request in accordance with Touhy regulations. Gullini appealed. The First Circuit affirmed, holding that the district court (1) did not err in applying the arbitrary and capricious standard to its review of DOJ's denial of Gullini's Touhy request; and (2) did not err in finding that DOJ's privilege grounds were not arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with the law. View "Gulluni v. Levy" on Justia Law

The First Circuit reversed the judgment of the district court concluding that the City of Malden had violated the Massachusetts Wage Act, Mass. Gen. Laws ch. 149, 148 (the Wage Act) and Mass. Gen. Laws ch. 44, 53C (the Municipal Finance Law), holding that there was no violation of the Wage Act or Municipal Finance Law in this case.Plaintiffs, City of Malden police officers, sued the City, arguing that a term in the collective bargaining agreement (CBA) that set the hourly rate for police detail work aligned with how they were historically paid and that a ten percent deduction for an administrative fee resulted in a reduction in their wages as set forth in the CBA, in violation of the Wage Act. The district court ruled that the contract term was ambiguous and, after hearing witness testimony, ruled that the City violated the Municipal Finance Law and the Wage Act. The First Circuit reversed, holding (1) the contract term was unambiguous in favor of the City; (2) any reduction in the calculated rate still resulted in a higher payout than contemplated in the CBA, and therefore, there was no Wage Act violation; and (3) the district court clearly erred in finding that the City had violated the Municipal Finance Law. View "Owens v. City of Malden" on Justia Law

The First Circuit affirmed the judgment of the district court granting Defendants' motions to dismiss the underlying lawsuit seeking money damages pursuant Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971) for alleged unconstitutional searches and seizures, holding that the district court did not err.Plaintiffs claimed three Bivens causes of action for money damages related to the searches and seizures. The district court dismissed the complaint, determining that the claims arose within a new Bivens context and that special factors counseled toward denying relief. The First Circuit affirmed, holding that Plaintiffs' claims arose in a new factual scenario of Bivens and involved special factors. View "Quinones-Pimentel v. Cannon" on Justia Law

The First Circuit affirmed Defendant's conviction of one count of possession of a firearm by a convicted felon and his sentence of seventy-two months in prison, varying upward from the applicable guideline sentencing range (GSR), holding that the district court did not err in accepting Defendant's guilty plea and that there was no error in sentencing.On appeal, Defendant argued, among other things, that the district court failed to create a sufficient record demonstrating that his guilty plea was constitutionally valid and in accordance with Fed. R. Crim. P. 11(b)(3). The First Circuit affirmed, holding (1) the district court's acceptance of Defendant's guilty plea was valid; and (2) Defendant's seventy-two-month sentence was substantively reasonable. View "United States v. Cahill" on Justia Law

The First Circuit affirmed the judgment of the district court sentencing Defendant to 120 months in prison in connection with his conviction of possession with intent to distribute and distribution of fentanyl, holding that the records supported the district court's rulings.On appeal, Defendant argued, among other things, that the district court considered impermissible evidence in determining his sentence. The First Circuit affirmed, holding (1) the district court did not clearly err in determining that Defendant was not entitled to a two-level reduction for acceptance of responsibility; (2) the district court did not err in considering Defendant's acquitted conduct at sentencing; (3) Defendant's sentence was neither implausible nor indefensible; and (4) the district court did not err in imposing a variance. View "United States v. Carvajal" on Justia Law