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

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

The First Circuit affirmed the order of the district court dismissing Petitioner's petition for habeas corpus on the grounds that it was time-barred, holding that there was no error.In May 1974, Petitioner was convicted of two counts each of unnatural and lascivious acts and unarmed robbery. In November of that same year and then again in 2002 Petitioner was convicted of other rape, kidnapping, and robbery charges. Based on the 2002 convictions along with the May and November 1972 convictions, Petitioner was convicted of being a habitual criminal and sentenced to life in prison. In 2020, Petitioner filed his petition for a writ of habeas corpus, alleging a claim of actual innocence. The district court dismissed the petition. The First Circuit affirmed, holding that Petitioner's petition was untimely and Petitioner did not qualify for any exception to the the limitation periods set out in 28 U.S.C. 2244(d)(1). View "McCants v. Alves" on Justia Law

The First Circuit affirmed the decision of the district court denying Defendants' motion to dismiss the underlying case or, in the alternative, to compel arbitration under section 1 of the Federal Arbitration Act (FAA), holding that Defendants were not entitled to reversal.Plaintiffs, who distributed Defendants' baked goods along routes in Massachusetts, brought this action alleging that Defendants misclassified them as independent contractors and seeking unpaid wages, overtime compensation, and other damages. Defendants filed a motion to dismiss or, in the alternative, to compel arbitration under the FAA. The district court denied the motion, concluding that Plaintiffs fell within the FAA's section 1 exemption from the FAA's purview "contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce." The First Circuit affirmed, holding (1) two of Defendants' arguments were waived; and (2) Defendants were not entitled to relief on the merits of their remaining arguments. View "Canales v. CK Sales Co., LLC" on Justia Law

The First Circuit affirmed the sentence of reimprisonment imposed upon the fourth revocation of Appellant's supervised release but vacated the subsequent term of supervised release to follow, holding that the district court erred in imposing additional supervised release.Appellant pleaded guilty to being a felon in possession of a firearm in violation of 18 U.S.C. 922(g)(1), 924(a)(2). After he was initially released from prison, Appellant violated the terms his supervised release, and his supervised release was revoked. Thereafter, Appellant three times more violated the terms of his supervised release. In the latest revocation, the district court imposed the statutory maximum sentence of two years' imprisonment, followed by one additional year of supervised release. The First Circuit vacated the judgment in part, holding (1) Appellant did not preserve any argument regarding the district court's sentence of imprisonment under 18 U.S.C. 3583(e)(3); and (2) the district court erred under 18 U.S.C. 3583(h) by imposing additional supervision. View "United States v. Ruiz-Valle" on Justia Law

The First Circuit affirmed the district court's default judgment in a tort action brought against the owner of a boat that Plaintiff was working on at the time of his injury, holding that the district court did not err in granting default judgment and denying Appellant's request for leave to file a late claim under Supplemental Rule F of the Federal Rules of Civil Procedure.Appellant, a commercial fisherman, filed a complaint in a Massachusetts state court alleging that he was injured while working on a vessel owned by G&J Fisheries, Inc. and that G&J was liable for unseaworthiness and negligence under the Jones Act, 46 U.S.C. 30104. G&J filed a complaint in the federal district court seeking exoneration from liability under 46 U.S.C. 30501-12 and Supplemental Rule F. The district court enjoined all other lawsuits against G&J pursuant to Supplemental Rule F(3) and then granted default judgment for G&J on the grounds that Appellant failed to file a claim as required under the rule. The First Circuit affirmed, holding that the district court did not err in granting default judgment and in denying Appellant's request to file a late claim under Supplemental Rule F(4). View "G&J Fisheries, Inc. v. Costa" on Justia Law

The First Circuit affirmed the judgment of the district court sentencing Defendant to forty-five years of imprisonment in connection with his plea of guilty to one count each of attempted sexual exploitation of a minor and committing a felony involving a minor while required to register as a sex offender, holding that there was no error.The district court's sentence was composed of a thirty-five-year mandatory minimum on the attempted sexual exploitation of a minor count based on two prior state convictions relating to "the sexual exploitation of children" and a ten-year consecutive mandatory minimum on the remaining count. On appeal, Defendant argued that the thirty-five-year mandatory minimum did not apply because the phrase "relating to the sexual exploitation of children" means only the production of child pornography. The First Circuit affirmed, holding (1) the plain text of "relating to the sexual exploitation of children" unambiguously refers to any criminal sexual conduct involving children; and (2) Defendant's remaining arguments failed. View "United States v. Winczuk" on Justia Law

The First Circuit denied Petitioner's petition for review of the decision of the Board of Immigration Appeals (BIA) affirming the immigration judge's (IJ) denial of his applications for asylum and withholding of removal under sections 208(b)(1)(A) and 241(b)(3)(A) of the Immigration and Nationality Act, holding that Petitioner was not entitled to relief on his claims of error.Petitioner, a Guatemalan citizen, entered the United States illegally in 2016. After DHS charged him with being subject to removal Petitioner filed applications for asylum, withholding of removal, and protection under the Convention Against Torture. The IJ denied relief from removal, and the BIA affirmed. The First Circuit denied in part and dismissed in part Petitioner's petition for review, holding (1) Petitioner's unexhausted claim must be dismissed for lack of jurisdiction; and (2) substantial evidence supported the BIA's determination, and the agency committed no errors of law in that ruling. View "Santos Garcia v. Garland" on Justia Law

The First Circuit denied Petitioner's petition challenging a final administrative removal order on grounds that Petitioner derived United States citizenship as a child, holding that there was no error.Petitioner, who was born in India, entered the U.S. as a child without lawful immigration status. Petitioner was later convicted by a Massachusetts state court of second-degree murder and sentenced in life in prison. After Petitioner was granted parole, the Department of Homeland Security (DHS) charged him with being removable for having been convicted of an aggravated felony. In response, Petitioner asserted that he was not removable because he had derived U.S. citizenship from his mother pursuant to former section 321(a) of the Immigration and Nationality Act. DNA rejected Petitioner's reading of former section 321(a) and ordered him removed. The First Circuit denied Petitioner's petition for review, holding that his arguments contesting removability were unavailing. View "Sharma v. Garland" on Justia Law

The First Circuit affirmed the denial of Appellant's request for an award of attorney's fees and the costs of translation services, holding that there was no error.Appellant brought an action against her husband, Appellee, in federal court, alleging causes of action for divorce, custody, child support, alimony. Appellee moved to dismiss the claims for lack of jurisdiction. The Court of First Instance granted the motion to dismiss. Thereafter, Appellee filed a petition under the International Child Abduction Remedies Act and the Hague Convention requesting that the district court order the return of the parties' minor children to their "habitual residence" in Colombia for resolution of the custody proceedings under Colombia law. The court of appeals reversed the judgment in Appellant's action, holding that the Court of First Instance erred by dismissing the complaint in its totality. The district court then dismissed Appellee's action on abstention grounds. Appellant subsequently sought an award of attorney fees and costs for translation services. The district court denied Appellant's requests. The First Circuit affirmed, holding that the district court did not abuse its discretion in denying Appellant's requests for attorney's fees and costs of translation services. View "Mata-Cabello v. Thula" on Justia Law