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

The First Circuit affirmed the judgment of the district court denying Defendant's request for immediate release and reducing his sentence from 240 to 180 months, holding that there was no error or abuse of discretion.In 2021, after the First Circuit affirmed Defendant's conviction and sentence, Defendant filed a motion for a reduction of his prison sentence under 18 U.S.C. 3582 (c)(1)(A), as revised by the First Step Act, which went into effect approximately six months after Defendant was sentenced and created a new regime in which prisoners could seek compassionate release. The district court ultimately granted Defendant's request for a sentence reduction but not immediate release. The First Circuit affirmed, holding that the district court did not run afoul of this Court's guidance in evaluating Defendant's compassionate release motion. View "United States v. Gonzalez" on Justia Law

The First Circuit vacated the judgment of the trial court against Plaintiff and a third-party defendant, holding that because the parties were unable to establish that no defendant shared state citizenship with any plaintiff remand was required.Plaintiff brought this lawsuit in federal district court, and Defendants counterclaimed. No party presented a possible basis for federal jurisdiction other than diversity jurisdiction under 28 U.S.C. 1332. After six years of litigation, a trial was held, and the trial court entered a eight-figure judgment against Plaintiff and a third-party defendant. The First Circuit vacated the judgment, holding that the parties have been unable to establish that no defendant shares state citizenship with any plaintiff, and therefore, remand was required so the parties can demonstrate that there is complete diversity. View "BRT Management LLC v. Malden Storage LLC" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Triple-S Management Corporation and Triple-S Vida, Inc. (collectively, Triple-S) and dismissing this case brought by Dora Bonner, holding that the district court did not abuse its discretion in denying Bonner's discovery-related motions and did not err in considering the evidence at the summary judgment stage.Bonner brought several claims alleging that Triple-S denied her millions of dollars of proceeds from certain certificates and devised a scheme to defraud her. After denying Bonner's motion to compel discovery and extend the discovery deadline, the district court concluded that Triple-S had established as a matter of law that the persons behind the fraudulent scheme were not related to Triple-S. The First Circuit affirmed, holding that the district court (1) did not abuse its discretion in denying the motion to compel and motion for consideration; and (2) properly granted summary judgment for Triple-S. View "Bonner v. Triple-S Vida, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court granting a motion to compel arbitration in this insurance dispute, holding that the district court correctly granted the motion to compel arbitration brought by the underwriters of Green Enterprises, LLC's insurance policy, all syndicates at Lloyd's of London (Underwriters).After a fire destroyed one of its plants, Green, a Puerto Rican recycling company, filed an insurance claim. Underwriters denied the claim, after which Green brought this lawsuit. Underwriters filed a motion to compel arbitration under an arbitration clause in the parties' contract. The district court granted the motion and dismissed Green's claims without prejudice. The First Circuit affirmed, holding that the district court properly granted the motion to compel. View "Green Enterprises, LLC v. Hiscox Syndicates Limited at Lloyd's of London" on Justia Law

The First Circuit affirmed the judgment of the district court refusing to extend safety valve relief to Defendant after finding that Defendant possessed a firearm during and in connection with a drug-trafficking crime, holding that there was no error in the challenged finding and Defendant's ensuing sentence.In determining that Defendant failed to satisfy his burden of satisfying five statutory requirements for safety valve relief by a preponderance of the evidence the district court found that Appellant had possessed a firearm when he sold drugs to a confidential informant and that Appellant's possession of the firearm was in connection with that drug sale. The First Circuit affirmed, holding that the district court did not err in finding Defendant ineligible for safety valve relief. View "United States v. Fitzpatrick" on Justia Law

The First Circuit reversed the judgment of the district court dismissing Plaintiff's breach of contract claim against Defendant, a digital health company, and affirmed the district court's dismissal of all other claims against Defendant and three of its board members, holding that Plaintiff plausibly stated a claim for entitlement to severance benefits.Plaintiff worked for Defendant as its CEO for one year. Thereafter, Defendant decided that it no longer wished to continue its relationship with Plaintiff, as defined in her one-year, automatically renewable employment agreement, and, after she left, refused to pay severance benefits under the agreement. In response to Plaintiff's ensuing lawsuit, Defendant argued that it did not terminate Plaintiff's employment because it merely exercised its right not to renew the agreement. The district court agreed and granted Defendant's motion to dismiss for failure to state a claim. The First Circuit (1) reversed the dismissal of Plaintiff's breach of contract claim, holding that the complaint adequately alleged that Defendant obligated itself to pay severance benefits by ending her employment under the agreement without cause before the end of the one-year term; and (2) affirmed the dismissal of all other claims against Defendant and its three board members, holding that the district court did not otherwise err. View "Sullivan v. etectRx, Inc." on Justia Law

The First Circuit affirmed the rulings of the district court granting Appellants attorney's fees under the the Equal Access to Justice Act (EAJA), which entitles a prevailing party in certain civil actions against the United States to remove attorney's fees unless the government's position was substantially justified or special circumstances make an award unjust, holding that there was no error.Appellants brought this challenge against the Department of Homeland Security and its agency, the United States Citizenship and Immigration Services (USCIS), after USCIS administratively closed each Appellant's application to adjust status, seeking attorney's fees under the EAJA. Determining that the government's position was substantially justified, the district court denied attorney's fees for the proceedings before the court but granted Appellants EAJA fees for the ensuing appellate proceedings that the government voluntarily dismissed. The First Circuit affirmed both rulings, holding (1) the district court did not abuse its discretion in denying EAJA fees related to the challenges before it; and (2) the district court did not err in its calculation of the EAJA award for the appellate proceedings abandoned by the government. View "Michel v. Mayorkas" on Justia Law

The First Circuit vacated the decisions of the Board of Immigration Appeals (BIA) and the immigration judge (IJ) denying Appellant's applications for asylum and withholding of removal and denied Appellant's petition for review as to Appellant's claim for protection under the Convention Against Torture (CAT), holding that remand was required for further proceedings.In denying Appellant's claims for asylum and related relief the IJ concluded that Appellant had failed to establish the requisite basis of fear of future persecution. The BIA affirmed. The First Circuit vacated the decisions in part, holding (1) Appellant was statutorily eligible for asylum on political opinion grounds; (2) because neither the IJ nor the BIA confronted the merits of Appellant's withholding of removal claim, remand was required for the IJ to assess the evidence in the first instance; and (3) the BIA's denial of Appellant's application for CAT protection was supported by substantial evidence. View "Mendez Esteban v. Garland" on Justia Law

The First Circuit vacated the judgment dismissing on claim preclusion grounds Plaintiff's claims against Eastern States Exposition alleging violations of federal copyright infringement law and the U.S. Visual Artists Rights Act, holding that the district court erred.On appeal, Plaintiff argued that the claim preclusive order gave claim preclusive effect to the dismissal in a prior action that she brought even where the dismissal rested on several grounds, not all of which would on their own render the dismissal claim preclusive. In support of her claim, Plaintiff argued that federal res judicata law recognizes the "alternative-determinations" doctrine. The First Circuit vacated the judgment dismissing the claims at issue, holding (1) the assertedly preclusive dismissal rested on one ground that, on its own, would not allow the dismissal to be claim preclusive, even though the dismissal also rested on two counts that could have; and (2) federal res judiata law recognizes the alternative-determinations doctrine, which strips a dismissal of claim preclusive effect if the dismissal rests on multiple grounds, not all of which would on their own render the dismissal claim preclusive, and the doctrine applied in this case. View "Foss v. Eastern States Exposition" on Justia Law

In this appeal arising from the prosecution of alleged misconduct related to college admissions the First Circuit affirmed John Wilson's conviction for filing a false tax return in violation of 26 U.S.C. 7206(1) and vacated Gamal Abdelaziz's and Wilson's other convictions, holding that several errors required vacatur.Among other things, the government alleged in charging Defendants that Defendants conspired with other parents to commit "honest services" fraud and property fraud, two types of mail and wire fraud. Defendants were convicted on all counts. The First Circuit vacated in part, holding (1) Defendants were not entitled to a judgment of acquittal on the basis that payments to accounts controlled by the alleged victim of a bribery scheme cannot violate 18 U.S.C. 666; (2) the "honest services" theory is invalid as a matter of law under Skilling v. United States, 561 U.S. 358 (2010); (3) the district court erred in instructing the jury that admissions slots constitute property; and (4) the government failed to prove that Defendants agreed to join an overarching conspiracy charged in the indictment and that this variance prejudiced Defendants. View "United States v. Abdelaziz" on Justia Law