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

The plaintiff was indicted by a Rhode Island grand jury, along with several co-defendants, on charges related to an alleged mortgage fraud conspiracy. He filed multiple motions to dismiss the charges in Rhode Island Superior Court, arguing that the indictment was tainted by prosecutorial misconduct and the presentation of misleading or missing evidence. After evidentiary hearings, a Magistrate denied his motions, and an Associate Justice of the Superior Court, on de novo review, adopted the Magistrate’s decision and added that the plaintiff had not shown sufficient prosecutorial misconduct to justify dismissal. The plaintiff did not appeal this ruling. Later, the charges against him were dismissed by the state as part of a plea agreement with a co-defendant.Subsequently, the plaintiff filed a malicious prosecution suit in the United States District Court for the District of Rhode Island against state law enforcement defendants. The defendants moved for summary judgment, arguing that collateral estoppel barred the plaintiff from relitigating whether the indictment was procured by fraud or misconduct, since that issue had already been decided in state court. The plaintiff responded only that the issues were not identical, and did not contest the “final judgment” or “full and fair opportunity to litigate” elements of collateral estoppel.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the plaintiff had waived his arguments regarding the “final judgment” and “full and fair opportunity” elements by failing to raise them in the district court, and that no exceptional circumstances justified excusing this waiver. The First Circuit affirmed the district court’s grant of summary judgment to the defendants, holding that collateral estoppel applied and barred the plaintiff’s malicious prosecution claim. Costs were awarded to the defendants. View "Shabshelowitz v. Rhode Island Department of Public Safety" on Justia Law

In March 2025, the President issued an executive order directing federal officials to eliminate non-statutory functions and reduce statutory functions of three federal agencies: the Institute of Museum and Library Services (IMLS), the Minority Business Development Agency (MBDA), and the Federal Mediation and Conciliation Service (FMCS). These agencies, established and funded by Congress, provide grants and services to states and other entities. Following the executive order, the agencies terminated, reassigned, or placed on leave nearly all employees and canceled numerous grants, which plaintiffs—twenty-one states—alleged caused immediate and ongoing harm, including loss of services, forced layoffs, and canceled programming.The United States District Court for the District of Rhode Island granted a preliminary injunction, finding that the plaintiffs had suffered and would continue to suffer concrete injuries due to the agencies’ actions. The court determined that the agencies’ actions likely violated the Administrative Procedure Act and constitutional provisions, including the Take Care Clause and separation of powers. The injunction barred implementation of the executive order as to the three agencies, required reversal of actions taken to implement the order, restoration of employees, and resumption of grant funding, while allowing for efficiency measures not motivated by the executive order. The district court denied the government’s request for a stay of the injunction pending appeal.The United States Court of Appeals for the First Circuit reviewed only the government’s motion for a stay pending appeal. The court denied the stay, holding that the government failed to make a strong showing of likely success on the merits, particularly because it did not adequately challenge the district court’s constitutional analysis and had not preserved certain arguments. The court also found that the balance of harms and public interest did not favor a stay. View "Rhode Island v. Trump" on Justia Law

Melissa Allen experienced multiple seizures at home and was taken to Lowell General Hospital, where she was found to be seven months pregnant and suffering from severe hypertension. Dr. Fernando Roca, an obstetrician affiliated with Lowell Community Health Center (LCHC), determined an emergency caesarian section was necessary. After the procedure, Allen suffered a devastating neurological injury and died eleven days later at a Boston hospital. The cause of death was listed as intracranial hemorrhage and eclampsia.Brad O'Brien, as personal representative of Allen’s estate, initially filed a wrongful death medical malpractice suit in Massachusetts state court against Dr. Roca and the hospital. At the time of the incident, Dr. Roca was employed by LCHC, a federally funded health center deemed under the Public Health Service Act (PHSA) to have federal employee status for certain purposes. The United States substituted itself as defendant and removed the case to the United States District Court for the District of Massachusetts, which dismissed the suit as time-barred under the Federal Tort Claims Act (FTCA). On O'Brien’s first appeal, the United States Court of Appeals for the First Circuit vacated the substitution order due to reliance on the wrong statutory basis and remanded for further proceedings. On remand, the district court again substituted the United States as defendant and dismissed the complaint.The United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the district court’s decision. The court held that the Secretary’s regulation allowing for “pre-deeming” FTCA coverage in certain hospital on-call scenarios was consistent with the PHSA, and that Dr. Roca’s treatment of Allen fell within this coverage. The court also held that O’Brien’s claim was untimely under the FTCA’s statute of limitations and that the FTCA’s savings clause did not apply. The judgment of dismissal was affirmed. View "O'Brien v. United States" on Justia Law

Robert Miller died at his home in Cape Cod in 2019 following an encounter with Barnstable police officers Sean Roycroft and Spencer Jackson. The officers responded to a 911 call from Miller’s girlfriend, who requested a psychiatric evaluation but did not report any crime. Upon arrival, a struggle ensued as the officers attempted to handcuff Miller, who ended up face-down on the floor with Roycroft’s arm pinned beneath him. During the struggle, Jackson delivered two punches to Miller in an effort to facilitate handcuffing. Miller’s girlfriend witnessed one of the officers drive a knee into Miller’s back and heard Miller say, “I can’t breathe” and “Amy, help me.” After Miller was handcuffed, he became unresponsive and was later pronounced dead. The medical examiner attributed the death to cardiac dysrhythmia in the setting of excited delirium, while the plaintiff’s expert opined that Miller died from prone restraint cardiac arrest due to pressure on his back.The plaintiff, Miller’s son, brought a federal excessive force claim under 42 U.S.C. § 1983 against the officers in the United States District Court for the District of Massachusetts. After discovery, the officers moved for summary judgment on qualified immunity grounds. The district judge denied summary judgment, finding that there were genuine disputes of material fact regarding whether the officers used excessive force, particularly after Roycroft freed his arm and Miller was restrained. The judge concluded that clearly established law prohibited kneeling on a restrained person’s back and that a reasonable jury could find the officers’ conduct violated Miller’s constitutional rights.On appeal, the United States Court of Appeals for the First Circuit reversed the denial of qualified immunity for the officers’ conduct while Roycroft’s arm was pinned (Phase One), affirmed the denial for conduct after Miller was restrained and a knee was placed on his back (Phase Two), and dismissed the appeal in part for fact-based arguments not suitable for interlocutory review. The case was remanded for further proceedings. View "Miller v. Roycroft" on Justia Law

Peterson’s Oil Service, Inc. supplied heating fuel to customers in Massachusetts between 2012 and 2019. The fuel contained higher-than-standard levels of biodiesel, averaging 35% between 2015 and 2018, exceeding the 5% industry standard for ordinary heating oil. Customers alleged that this biodiesel-blended fuel was incompatible with conventional heating systems, caused repeated heat loss, and resulted in permanent damage to their equipment. They brought a class action in Massachusetts state court against Peterson’s and its officers, asserting claims for breach of contract, fraud, and negligence, including allegations that Peterson’s continued supplying the fuel despite customer complaints and only later disclosed the high biodiesel content.United States Fire Insurance Company and The North River Insurance Company had issued Peterson’s a series of commercial general liability and umbrella policies. The insurers initially defended Peterson’s in the class action under a reservation of rights, then filed suit in the United States District Court for the District of Massachusetts seeking a declaration that they owed no duty to defend or indemnify Peterson’s. The insurers moved for summary judgment, arguing that the claims did not arise from a covered “occurrence” and that policy provisions limiting or excluding coverage for failure to supply applied. The district court denied summary judgment, finding a genuine dispute as to whether Peterson’s actions were accidental and holding that the failure-to-supply provisions were ambiguous and did not apply.On appeal, the United States Court of Appeals for the First Circuit affirmed. The court held that the underlying complaint alleged a potentially covered “occurrence” because it was possible Peterson’s did not intend or expect the property damage alleged. The court also held that the failure-to-supply provisions were ambiguous and, under Massachusetts law, must be construed in favor of coverage. The district court’s summary judgment rulings were affirmed. View "United States Fire Insurance Company v. Peterson's Oil Service, Inc." on Justia Law

A native Spanish speaker with limited English proficiency responded to an online advertisement for commercial sex in November 2022. After exchanging text messages with the poster, who was actually an undercover federal agent, he arranged to meet at a hotel, bringing $200, his phone, and condoms. The agent’s messages indicated that the sex would be with minors, specifically describing two girls as ages 14 and 12. The defendant arrived at the hotel, met the agent, received a room key, and was arrested. During booking, when told he was charged with paying for sex with a minor, he expressed surprise and denied speaking to any minor. In a subsequent interview conducted in Spanish about thirty minutes later, he stated he believed he was arranging sex with an adult.A grand jury indicted him on attempted sex trafficking of a child and attempted coercion and enticement of a child to engage in prostitution. His first trial ended in a hung jury, but the second resulted in convictions on both counts. The defense argued he did not intend to have sex with a minor and misunderstood the agent’s messages due to his limited English. The district court admitted his immediate booking statement as an excited utterance but excluded his later interview statements. The court also gave jury instructions distinguishing motive from intent and explaining the interstate commerce element, using examples that paralleled the government’s evidence.The United States Court of Appeals for the First Circuit reviewed the district court’s evidentiary and instructional rulings. The appellate court held that the exclusion of the post-arrest interview statements was not an abuse of discretion, as the statements were made after a significant time lapse and under circumstances suggesting reflection. The court also found no error in the jury instructions regarding interstate commerce or the distinction between motive and intent. The convictions were affirmed. View "US v. Medina" on Justia Law

Customers of a heating oil company in Massachusetts brought a state court class action alleging that, starting in 2012, the company sold home heating oil with excessive biodiesel content, which damaged their heating equipment. The company received a demand letter and complaint in March 2019, before it was insured by the plaintiff insurance company. The insurance company began providing coverage in July 2019 under a commercial general liability policy and an umbrella policy. The policy included provisions excluding coverage for property damage known to the insured before the policy period began.After being asked to defend the company in the state class action, the insurer refused, arguing that the company’s prior knowledge of the alleged damage—based on the demand letter, complaint, and media coverage—triggered the policy’s known loss and loss-in-progress exclusions. The insurer then filed a declaratory judgment action in the United States District Court for the District of Massachusetts, seeking a ruling that it had no duty to defend or indemnify. The state court class had two subclasses: customers who received oil before July 5, 2019, and those who first received oil after that date.The district court found that the insurer had no duty to defend claims by customers who received oil before the policy period, but did have a duty to defend claims by customers who first received oil after coverage began, since the company could not have known of damage that had not yet occurred. Applying the “in for one, in for all” rule, the court held the insurer must defend the entire suit. The court denied summary judgment for the insurer on the duty to defend and granted partial summary judgment to the insured.The United States Court of Appeals for the First Circuit affirmed, holding that the policy’s known loss and loss-in-progress provisions did not bar coverage for claims by customers whose property damage began after the policy period commenced, and thus the insurer has a duty to defend the entire class action. View "Federated Mutual Insurance Co. v. Peterson's Oil Service, Inc." on Justia Law

A long-serving postal employee applied for two higher-level postmaster positions in New Hampshire. At the time of her applications, she was 58 years old and had significant experience. For the first position, she was interviewed by her supervisor but was not selected; instead, a 36-year-old man was chosen, with the supervisor citing his greater relevant experience. Several months later, she applied for a second position, was again interviewed by the same supervisor, and was again passed over in favor of a man, this time 53 years old. During the second interview, the supervisor remarked that the office had never had a female postmaster and questioned whether the applicant had the energy for the job. The applicant believed she was denied both promotions due to her age and sex, and she pursued administrative remedies before filing suit.The United States District Court for the District of New Hampshire granted summary judgment to the employer, the United States Postal Service, on all claims. The court found that the employer had provided legitimate, nondiscriminatory reasons for its decisions and that no reasonable jury could find those reasons to be pretextual. The court applied the McDonnell Douglas burden-shifting framework to both the age and sex discrimination claims.On appeal, the United States Court of Appeals for the First Circuit reviewed the summary judgment decision de novo. The court affirmed the district court’s grant of summary judgment on the age discrimination claims, holding that the plaintiff had waived any argument for a more lenient causation standard and that, under the McDonnell Douglas framework, no reasonable jury could find pretext. The court also affirmed summary judgment on the sex discrimination claim related to the first promotion. However, the court reversed summary judgment on the sex discrimination claim regarding the second promotion, finding that the supervisor’s comments during the interview created a genuine dispute of material fact as to pretext and discriminatory motive. The case was remanded for further proceedings on that claim. View "Warner v. Steiner" on Justia Law

Angel A. Perales-Muñoz was hired as a recruiter assistant by Document and Packaging Brokers, Inc. (Docupak), a contractor for the National Guard Bureau, to help recruit individuals for the Army National Guard. The Army Criminal Investigation Division (CID) began investigating possible fraud in the recruiting program, which led to Perales being indicted on multiple federal charges related to conspiracy and fraud. After two years, the government moved to dismiss the charges against Perales, and the indictments were dismissed with prejudice. Perales and his wife subsequently filed administrative claims and then a lawsuit under the Federal Tort Claims Act (FTCA), alleging that the CID’s investigation was negligent and caused them emotional distress.The United States District Court for the District of Puerto Rico reviewed the case. The government moved to dismiss, arguing that the discretionary function exception to the FTCA barred the claims, as the investigation involved policy discretion. The district court ordered limited jurisdictional discovery and referred the matter to a magistrate judge, who found that the CID’s investigation did not violate the Posse Comitatus Act or Army Regulation 195-2. The district court adopted the magistrate’s report and recommendation, dismissing the complaint for lack of subject matter jurisdiction.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s dismissal de novo. The appellate court held that the discretionary function exception applied because Perales failed to show that the CID’s investigation violated any binding federal law or regulation. The court found no violation of the Posse Comitatus Act or Army Regulation 195-2 and concluded that federal courts lacked jurisdiction over the claims. The judgment of the district court was affirmed. View "Perales-Munoz v. United States" on Justia Law

Mariano Ortiz Trejo, a native and citizen of Mexico, entered the United States without inspection in 1999, briefly returned to Mexico in 2004, and reentered the U.S. without inspection in 2005. He resides in Rhode Island with his minor son, a U.S. citizen, and the child’s mother, who is not a legal permanent resident. Ortiz Trejo works in construction and contributes to the household income. In 2015, he was served a Notice to Appear, conceded removability, and applied for cancellation of removal, arguing that his removal would cause “exceptional and extremely unusual hardship” to his son due to the child’s allergies and emotional health. He also sought voluntary departure as an alternative.The Immigration Judge of the Immigration Court found Ortiz Trejo credible but determined that he had not established the requisite hardship for cancellation of removal. The judge found that the child’s allergies were controllable, the likelihood of a severe reaction was low, and the child’s mother could provide for him, with continued access to medical care in Rhode Island. The judge admitted a psychological evaluation diagnosing the child with “Adjustment Disorder” but gave it limited weight. Cancellation of removal was denied, but voluntary departure was granted.Ortiz Trejo appealed to the Board of Immigration Appeals, which affirmed the denial of cancellation and the grant of voluntary departure. The Board found that the Immigration Judge had considered all evidence, including the psychological evaluation, and concluded that the record did not establish exceptional and extremely unusual hardship. Ortiz Trejo then petitioned for review by the United States Court of Appeals for the First Circuit.The First Circuit held that the Board did not err in its decision, finding no legal error or failure to consider key evidence. The court denied the petition for review, upholding the Board’s determination that Ortiz Trejo had not met the hardship standard required for cancellation of removal. View "Ortiz Trejo v. Bondi" on Justia Law