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

A former college track and field coach used his position to obtain nude and semi-nude photographs from female student-athletes. While coaching at a university, he would ask athletes for their phones under the pretense of filming their form, then search for and secretly send intimate images to himself. After leaving the university, he created anonymous social media accounts to contact former athletes, falsely claiming he found their photos online and offering to help remove them, while actually using the images he had previously stolen. He also created fake online personas to solicit additional images under the guise of a body development study and conspired with others to hack into women’s Snapchat accounts, obtaining more private images. In total, he obtained images from fifty-one women and attempted to obtain them from at least seventy-two others.A grand jury indicted him on multiple counts, including wire fraud, cyberstalking, and computer fraud. He was released pending trial with conditions, but violated them by again soliciting images online. The United States District Court for the District of Massachusetts calculated a guideline sentencing range of twenty-seven to thirty-three months, but imposed an upwardly variant sentence of sixty months, citing the number of victims, the nature of the offenses, the abuse of trust, and his conduct while on release. The court rejected the government’s request for an even higher sentence.On appeal, the United States Court of Appeals for the First Circuit reviewed the procedural and substantive reasonableness of the sentence. The court held that the district court did not commit procedural error, adequately considered the relevant sentencing factors, and provided a plausible and defensible rationale for the upward variance. The First Circuit affirmed the sixty-month sentence, finding it reasonable in light of the seriousness of the offenses, the impact on the victims, and the risk of recidivism. View "United States v. Waithe" on Justia Law

Dinelson Hernandez-Rodriguez was stopped by a Connecticut state trooper while driving a vehicle that was under surveillance by the Drug Enforcement Administration (DEA) as part of a lengthy investigation into a Boston-based drug trafficking operation. The DEA had linked the vehicle and its occupants to the transport of cocaine from New York to Boston and the return of drug proceeds to New York. On the day of the stop, DEA agents observed Hernandez-Rodriguez interacting with suspected co-conspirators and driving the vehicle away from a location associated with drug activity. After the stop, a search of the vehicle uncovered $240,240 in a hidden compartment.The United States District Court for the District of Massachusetts denied Hernandez-Rodriguez’s motion to suppress the cash, finding that the warrantless search was justified under the automobile exception to the Fourth Amendment because there was probable cause to believe the vehicle contained evidence of a crime. The court found that the DEA’s extensive investigation, surveillance, and intercepted communications provided sufficient grounds for probable cause. Following a jury trial, Hernandez-Rodriguez was convicted of conspiracy to distribute cocaine and sentenced to sixty-eight months in prison.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s factual findings for clear error and its legal conclusions de novo. The appellate court held that the collective knowledge of the DEA agents, imputed to the state trooper who conducted the stop, established probable cause to search the vehicle under the automobile exception. The court rejected the argument that the search was based on a mere “hunch,” finding that the facts supported a fair probability that evidence of a crime would be found. The First Circuit affirmed the district court’s denial of the motion to suppress. View "United States v. Hernandez-Rodriguez" on Justia Law

A coastal town in Maine, known for its small population and proximity to a national park, experienced a significant increase in cruise ship tourism, with large vessels bringing thousands of passengers daily. In response to concerns about congestion, public safety, and the impact on local amenities, residents approved an ordinance capping the number of cruise ship passengers who could disembark in the town to 1,000 per day. The ordinance imposed fines for violations and was intended to address issues primarily at the waterfront and, to a lesser extent, in the downtown area.Several local businesses, a business association, and a pilots’ association challenged the ordinance in the United States District Court for the District of Maine. They argued that the ordinance was preempted by federal and state law, violated the Commerce Clause (including its dormant aspect), and infringed on due process rights. After a bench trial, the District Court largely ruled in favor of the town and an intervening resident, rejecting most claims but finding that the ordinance was preempted by federal regulations only to the extent it restricted crew members’ shore access. The court declined to enjoin the ordinance, noting the town’s intent to address this issue through further rulemaking.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s rejection of the state law preemption, federal preemption (except for the now-moot crew access issue), and due process claims. The First Circuit also affirmed the dismissal of discrimination-based Dormant Commerce Clause claims, finding no similarly situated in-state and out-of-state competitors. However, the court vacated and remanded the District Court’s dismissal of the Pike balancing Dormant Commerce Clause claim, instructing further analysis of whether the ordinance’s burdens on interstate commerce are clearly excessive in relation to its local benefits. The court dismissed as moot the appeals related to the crew access issue. View "Ass'n to Preserve and Protect Local Livelihoods v. Town of Bar Harbor" on Justia Law

In October 2016, parents sought emergency medical care for their nineteen-month-old son, who was experiencing convulsions and seizures. The child was treated at three different medical facilities in Puerto Rico, including by Dr. Fernando Vega-Moral at HIMA San Pablo Bayamón hospital. After being transferred between hospitals, the child suffered cardiac arrest and died. The parents, along with other family members, initially filed a medical malpractice and negligence suit in Puerto Rico Commonwealth court against the medical centers and unnamed doctors, but did not specifically name Dr. Vega. That case was dismissed without prejudice in May 2018.Subsequently, in May 2019, the parents filed a new lawsuit in the United States District Court for the District of Puerto Rico, this time naming Dr. Vega and others as defendants and asserting claims under Puerto Rico’s tort statutes. The district court dismissed some defendants and granted summary judgment to Dr. Vega, finding that the claims against him were time-barred. The court determined that, although the parents’ initial Commonwealth complaint was timely due to extensions following Hurricane María, the federal complaint did not toll the statute of limitations as to Dr. Vega because he was not named in the earlier suit. The court also denied the parents’ motion for reconsideration, holding that their new arguments and evidence should have been presented earlier.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s rulings. The First Circuit held that Dr. Vega properly raised the statute of limitations defense and that, under Puerto Rico law, the burden shifted to the parents to show that the limitations period was tolled as to Dr. Vega. The parents failed to provide competent evidence to meet this burden. The court also found no abuse of discretion in denying reconsideration, as the parents’ new arguments and evidence were untimely. View "Cruz-Cedeno v. Vega-Moral" on Justia Law

While serving a ten-year sentence in Rhode Island Department of Corrections (RIDOC) custody, Jerry Cintron, who suffers from opioid use disorder, relapsed and overdosed on a fentanyl-laced pill. After the incident, RIDOC officials sanctioned him with a total of 450 days in solitary confinement for various infractions related to the overdose and alleged trafficking. During this period, Cintron experienced severe mental and physical deterioration, including significant weight loss, self-injurious behavior, and psychiatric symptoms. He repeatedly informed RIDOC officials of his worsening condition and requested relief, but his pleas were denied or ignored, and his conditions remained unchanged.Cintron filed a lawsuit in the United States District Court for the District of Rhode Island under 42 U.S.C. § 1983, alleging violations of his Eighth Amendment rights due to deliberate indifference by RIDOC officials. The defendants moved for judgment on the pleadings, arguing that Cintron’s claims failed on the merits and that they were entitled to qualified immunity. The district court denied the motion as to the Eighth Amendment claim, allowing it to proceed against all defendants, and the defendants appealed.The United States Court of Appeals for the First Circuit reviewed the case and held that Cintron’s complaint plausibly alleged an Eighth Amendment violation by three RIDOC officials—Aceto, Corry, and Kettle—who were aware of his deterioration and had authority to intervene but failed to do so. The court found that, as of 2019, it was clearly established that prolonged social, sensory, and sleep deprivation in solitary confinement could constitute cruel and unusual punishment, and that officials could not respond with deliberate indifference. The court affirmed the district court’s denial of qualified immunity for these three officials, reversed as to the other defendants, and remanded for further proceedings on declaratory and injunctive relief. View "Cintron v. Bibeault" on Justia Law

In February 2023, police officers arrested Charlie Vick for domestic assault and battery involving a firearm. After his arrest, officers discovered that the car he had been driving was uninsured, unregistered, and had invalid license plates. They waited until Vick's uncle attempted to drive the car away and then stopped him shortly after he exited the parking lot. The officers impounded the car and conducted an inventory search, which revealed a gun. Vick was subsequently charged with being a felon in possession of a firearm.The United States District Court for the District of Massachusetts ruled that the officers had staged the impounding and that their sole motive for the search was investigatory. Consequently, the court ordered the suppression of the evidence found during the search. The government appealed, arguing that the district court should not have considered the officers' subjective motives and that the court's finding of a sole investigatory motive was clearly erroneous.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed with the government that the district court's finding of a sole investigatory motive was clearly erroneous. The appellate court noted that the officers had an objectively reasonable basis for impounding the car, as it was unregistered, uninsured, and had invalid plates, making it a safety hazard. The court also found that the officers' decision to impound the car was lawful under the community caretaking exception to the Fourth Amendment's warrant and probable cause requirements. Consequently, the appellate court reversed the district court's grant of the motion to suppress and remanded the case for further proceedings. View "US v. Vick" on Justia Law

Two cousins, Jairo Huertas-Mercado and Erick Pizarro-Mercado, were involved in a series of violent crimes in Puerto Rico, including six carjackings and two kidnappings, one of which resulted in death. The crimes occurred between May and June 2018, and involved the use of firearms and threats of violence. The victims included a security guard, a family on a road trip, a surfer, a couple, a churchgoer, and a well-known local singer, Bryant Myers, who was kidnapped along with his mother.The case was first brought to the United States District Court for the District of Puerto Rico, where Huertas was initially indicted in July 2018. Over time, the indictment was superseded three times, adding more charges and defendants, including Pizarro. The pretrial process was prolonged due to ongoing investigations, plea negotiations, and the COVID-19 pandemic. The death penalty review process also contributed to the delay. Ultimately, the trial began in September 2022, more than four years after the initial indictment.The United States Court of Appeals for the First Circuit reviewed the case. Huertas argued that his constitutional right to a speedy trial was violated due to the 51-month delay between his indictment and trial. The court applied the Barker v. Wingo balancing test and found that while the delay was lengthy, it was justified by valid reasons, including the complexity of the case, the need for thorough investigation, and the impact of the pandemic. Huertas' failure to assert his right to a speedy trial and the lack of demonstrated prejudice to his defense also weighed against him.Both defendants challenged the sufficiency of the evidence for their convictions, particularly the carjacking charges. The court found that the evidence, including witness testimonies and admissions by Huertas, was sufficient to support the jury's verdict. The court also rejected Huertas' double jeopardy claim, noting that the lesser included offense was dismissed before sentencing.Finally, Pizarro's argument that his life sentence was unreasonable was reviewed. The court found that the sentence was within the guideline range and justified by the severity of the crimes, affirming the district court's decision. The appeals court ultimately affirmed the convictions and sentences of both defendants. View "US v. Huertas-Mercado" on Justia Law

In January 2015, Paula Appleton was severely injured in a car accident when a pickup truck struck her vehicle from behind. Appleton filed an insurance claim against the driver, whose policy was administered by AIG Claims, Inc. Over four years, Appleton and AIG exchanged settlement offers and attended three mediations but failed to reach a settlement. In March 2019, a Massachusetts state court jury awarded Appleton $7.5 million in damages. Appleton then sued AIG and National Union Fire Insurance Company in federal court, alleging they failed to conduct a reasonable investigation and did not extend a prompt and fair settlement offer as required by Massachusetts law.The United States District Court for the District of Massachusetts granted summary judgment in favor of the defendants. The court concluded that the defendants conducted a reasonable investigation and that their duty to extend a prompt and fair settlement offer was not triggered because the value of Appleton's damages never became clear.The United States Court of Appeals for the First Circuit reviewed the case. The court determined that a reasonable jury could find that Appleton's damages became clear in early 2018 and that the defendants failed to extend a prompt and fair settlement offer afterward. Consequently, the court vacated the district court's summary judgment ruling in part and remanded for trial on Appleton's settlement claim. However, the court affirmed the district court's grant of summary judgment on Appleton's claim that the defendants failed to conduct a reasonable investigation. View "Appleton v. National Union Fire Insurance Co." on Justia Law

In this case, the defendant, a radio talk show host and church founder, began selling bitcoin in 2014. The government investigated his bitcoin sales and charged him with conspiracy to operate an unlicensed money transmitting business, operation of an unlicensed money transmitting business, conspiracy to commit money laundering, money laundering, and tax evasion. After a jury convicted him on all counts, the district court acquitted him of the substantive money laundering count due to insufficient evidence but upheld the other convictions.The defendant appealed, arguing that the district court should not have allowed the money-transmitting-business charges to proceed to trial, citing the "major questions doctrine" which he claimed should exempt virtual currencies like bitcoin from regulatory statutes. He also contended that the evidence was insufficient to support his tax evasion conviction and that he should be granted a new trial on the money laundering conspiracy count due to prejudicial evidentiary spillover. Additionally, he argued that his 96-month sentence was substantively unreasonable.The United States Court of Appeals for the First Circuit reviewed the case. The court rejected the defendant's major questions doctrine argument, holding that the statutory definition of "money transmitting business" under 31 U.S.C. § 5330 includes businesses dealing in virtual currencies like bitcoin. The court found that the plain meaning of "funds" encompasses virtual currencies and that the legislative history and subsequent congressional actions supported this interpretation.The court also found sufficient evidence to support the tax evasion conviction, noting that the defendant had substantial unreported income and engaged in conduct suggesting willful evasion of taxes. The court rejected the claim of prejudicial spillover, concluding that the evidence related to the money laundering conspiracy was admissible and relevant.Finally, the court upheld the 96-month sentence, finding it substantively reasonable given the defendant's conduct and the factors considered by the district court. The court affirmed the district court's rulings and the defendant's convictions and sentence. View "United States v. Freeman" on Justia Law

Amber Lavigne filed a lawsuit against the Great Salt Bay Community School Board and various school staff members, alleging that they infringed on her constitutional right to parent by providing her child, A.B., with a chest binder and referring to A.B. by a different name and pronouns without informing her. Lavigne claimed that these actions were part of a school-wide policy of withholding such information from parents.The United States District Court for the District of Maine dismissed the claims against the individual defendants and later granted the Board's motion to dismiss, concluding that Lavigne had not plausibly alleged that the Board had a custom or policy of withholding information. The court found that Lavigne's allegations were based on conclusions unsupported by factual allegations and that the Board's statements did not constitute active approval of the individual defendants' actions.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that Lavigne had not plausibly alleged the existence of an unwritten policy or custom of withholding information from parents. The court noted that the Board's written policies encouraged parental involvement and that the statements made by the Board and school officials did not support the inference of an unwritten policy of withholding. The court also found that the Board's decision to renew the contract of the social worker involved did not amount to ratification of the alleged conduct. Thus, the appellate court concluded that Lavigne had failed to show that the Board was responsible for any constitutional violation. View "Lavigne v. Great Salt Bay Community School Board" on Justia Law