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

Miguel Armando Rivera Samayoa, a native and citizen of Guatemala, entered the United States in 1996 and has since resided in Massachusetts, where he fathered four U.S. citizen children. Rivera applied for cancellation of removal under the Immigration and Nationality Act, arguing that his removal would cause exceptional and extremely unusual hardship to his children, who have various health issues.The Immigration Judge (IJ) found Rivera met the first three statutory requirements for cancellation of removal but denied his application, concluding that Rivera failed to demonstrate that his removal would result in exceptional and extremely unusual hardship to his children. The IJ considered the children's ages, health, family ties, and the economic and political conditions in Guatemala, determining that the hardship they would face was not substantially beyond the ordinary hardship expected when a close family member leaves the country. The IJ also noted the possibility of Rivera's voluntary departure and potential future lawful reentry.Rivera appealed to the Board of Immigration Appeals (BIA), which adopted and affirmed the IJ's decision. The BIA agreed with the IJ's assessment of the cumulative factors and found that Rivera had not established that his children would be unable to receive necessary medical treatment whether they stayed in the U.S. or relocated to Guatemala.The United States Court of Appeals for the First Circuit reviewed the case and denied Rivera's petition. The court held that the BIA and IJ had properly considered the cumulative impact of Rivera's removal on his children and found no legal error in their decisions. The court concluded that Rivera did not meet the high burden of proving that his removal would result in exceptional and extremely unusual hardship to his children. View "Rivera Samayoa v. Bondi" on Justia Law

A graduate student and resident advisor (RA) at the University of Massachusetts, John Doe, was found responsible for sexual misconduct by the University in 2023. The University sanctioned him based on complaints from four female RAs about his interactions with them. Doe filed a federal lawsuit against the University, its trustees, and the members of the hearing panel, alleging that the University violated his First Amendment rights by punishing him for protected speech and expressive conduct. He sought a preliminary injunction, which the district court considered on a "case stated" basis, consolidating the preliminary injunction hearing with the trial on the merits.The district court ruled against Doe, finding that his First Amendment rights had not been violated. The court applied the Tinker standard, determining that the University's actions were justified because Doe's conduct caused or would cause a substantial disruption and invaded the rights of others. The court also held that the Individual Defendants were entitled to qualified immunity for monetary damages. Doe appealed the decision.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the record lacked evidence of substantial disruption to the academic environment or the complainants' jobs. The court also concluded that Doe's conduct did not constitute a pervasive pattern of unwelcome conduct. Therefore, the court held that the University's actions were not justified under the Tinker standard. However, the court affirmed the district court's ruling that the Individual Defendants were entitled to qualified immunity, as the law was not clearly established that their actions violated Doe's First Amendment rights. The judgment was reversed in part and affirmed in part. View "Doe v. University of Massachusetts" on Justia Law

From 1990 to 1999, Patrick Rose, Sr., a Boston Police Department (BPD) officer, sexually abused two children, John and Jane Doe. Rose pled guilty to 21 counts of child rape and sexual assault in April 2022. The Does, now adults, sued Rose, the BPD, and other defendants involved in the investigation and response to their abuse allegations, claiming the defendants deprived them of their Fourteenth Amendment right to bodily integrity by enhancing the danger from Rose's abuse.The United States District Court for the District of Massachusetts dismissed the case before discovery, concluding that the defendants could not be held responsible under the state-created danger doctrine because the Does did not sufficiently allege that the defendants' actions enhanced Rose's abuse and caused them harm. The court also dismissed the Does' remaining claims.The United States Court of Appeals for the First Circuit vacated the district court's decision regarding the Does' Fourteenth Amendment claims. The appellate court concluded that the Does plausibly alleged that some of the defendants' actions enhanced the danger to them, meeting the first requirement of the state-created danger test. The court remanded the case for the district court to evaluate those actions under the test's remaining requirements. The appellate court also vacated the dismissal of the claims against the City of Boston and the DCF defendants, allowing the Does to address those claims. However, the appellate court affirmed the dismissal of the Does' § 1985 claims, agreeing with the district court that the Does failed to allege membership in a protected class or class-based discrimination. View "Doe v. City of Boston" on Justia Law

Matthew Waleyko was employed as a civilian computer scientist at the Naval Undersea Warfare Center, a division of the U.S. Navy. His employment was subject to a two-year probationary period. During his tenure, he faced complaints from female coworkers, Beibhinn Gallagher and Layna Nelson, regarding his behavior and alleged misconduct. Gallagher accused him of being condescending and making her feel sexually harassed, while Nelson falsely reported that he had deleted code files. Additionally, Waleyko was investigated for being emotionally unstable after crying in his supervisor's office. Ultimately, he was asked to resign or face termination, and he chose to resign.Waleyko filed a complaint with the Department of the Navy, which was investigated by the Department of Defense's Investigations and Resolutions Directorate. After receiving an unfavorable final agency decision, he filed a lawsuit in the District of Rhode Island, alleging sex discrimination under Title VII. The district court dismissed his suit for failure to state a claim, concluding that he did not specifically describe instances of disparate treatment based on his gender.The United States Court of Appeals for the First Circuit reviewed the case de novo. The court affirmed the district court's dismissal, holding that Waleyko's complaint lacked sufficient factual matter to state a plausible claim for relief. The court found that his allegations were speculative and did not support a reasonable inference that his termination was based on his gender. The court also noted that the alleged procedural irregularities in the Navy's investigations did not demonstrate sex-based bias and that the gender-neutral terms used to describe Waleyko did not support a gender-stereotyping claim. View "Waleyko v. Del Toro" on Justia Law

On December 15, 2021, Nashalie Rodríguez-Bermúdez was charged with possession with intent to distribute five kilograms or more of cocaine and conspiracy to possess with intent to distribute the same. Rodríguez entered a straight plea on July 7, 2022, and was sentenced by the federal District Court for the District of Puerto Rico on March 3, 2023, to 46 months of incarceration with five years of supervised release. Rodríguez appealed the sentence, arguing that the district court erred in its sentencing process.The District Court for the District of Puerto Rico received a presentence investigation report (PSR) and sentencing memoranda from both the defense and the government. The PSR recommended a four-point minimal participant adjustment, resulting in a Guidelines range of 46 to 57 months. The defense argued for a time-served sentence, while the government recommended 57 months, or alternatively, 48 months. During the sentencing hearing, the district court declined to definitively determine the applicable Guidelines range, stating that the sentence would be the same regardless of whether Rodríguez was a minimal participant.The United States Court of Appeals for the First Circuit reviewed the case and found that the district court committed procedural error by failing to adequately explain why the 46-month sentence was appropriate irrespective of the applicable Guidelines range. The appellate court noted that the district court's reliance on the high end of the defense's proposed Guidelines range without a clear explanation of how the other § 3553(a) factors supported the sentence was insufficient. Consequently, the First Circuit vacated the sentence and remanded the case for resentencing, emphasizing the need for a clear and adequate explanation for the chosen sentence. View "United States v. Rodriguez-Bermudez" on Justia Law

Three appellants, Anthony Rivera-Rivera, Victor M. Hernández-Carrasquillo, and Jimmy Ríos-Alvarez, were convicted of armed carjacking and using a firearm in a crime of violence. They were part of a group that committed a violent home invasion targeting a family. During the invasion, the group assaulted the family members, causing serious injuries, and stole valuables. Two members of the group took the family's car to withdraw money from an ATM, while the appellants stayed behind to guard the family.The United States District Court for the District of Puerto Rico held a joint trial for the appellants. The jury found them guilty on both counts. The appellants filed motions for judgment of acquittal, which the court denied, concluding that the government had presented sufficient evidence for a rational factfinder to find each appellant guilty beyond a reasonable doubt. Rivera and Hernández also filed motions to dismiss the indictment due to delayed Brady disclosures, which the court denied. Additionally, Rivera and Hernández sought severance from Ríos to call him as a witness, but the court denied this motion as well.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the convictions, finding sufficient evidence to support the jury's verdicts. The court held that the appellants had knowledge of the carjacking and took affirmative acts to further the crime. The court also found no abuse of discretion in the district court's denial of the motions to dismiss the indictment and for severance. The court rejected Rivera's Confrontation Clause claims and upheld the sentences for Rivera and Hernández, finding them procedurally and substantively reasonable. View "United States v. Rivera-Rivera" on Justia Law

Between February 2014 and December 2015, United States Postal Inspection Service (USPIS) agents in Puerto Rico identified a pattern of suspicious packages being sent between Puerto Rico and New York. Upon inspection, these packages were found to contain cocaine and large sums of money concealed in household items. The investigation led to Miguel A. Reyes-Ballista (Reyes) and two co-conspirators. Reyes was indicted and, after a six-day trial, a jury convicted him of participating in two conspiracies to possess with intent to distribute cocaine and three counts of possession with intent to distribute cocaine.Reyes was sentenced to 170 months in prison with four years of supervised release. He appealed his convictions, arguing that the government provided insufficient evidence to support the jury's verdict. Reyes also sought a new trial, claiming ineffective assistance of counsel due to inadequate communication with his attorney and poor performance at trial, which he argued violated his Sixth Amendment right to counsel.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the evidence presented at trial, including testimony from co-conspirators, surveillance footage, and fingerprint evidence, was sufficient to support Reyes's convictions for conspiracy. The court noted that Reyes's arguments regarding the credibility of witnesses and the lack of direct evidence placing him inside the post office did not undermine the jury's verdict. The court also dismissed Reyes's Sixth Amendment claim as premature, indicating that such claims are typically better suited for collateral proceedings where a more developed record can be established.The First Circuit affirmed Reyes's convictions and dismissed his Sixth Amendment claim without prejudice, allowing him the opportunity to raise the issue in a future collateral proceeding. View "United States v. Reyes-Ballista" on Justia Law

In December 2021, the United States District Court for the District of Massachusetts partially recognized a multi-million-dollar foreign judgment obtained by PCC Rokita, S.A. against HH Technology Corp. (HHT). Shortly thereafter, HHT executed a trust agreement and an assignment for the benefit of creditors to wind itself down. About two months later, PCC Rokita petitioned the United States Bankruptcy Court for the District of Massachusetts to involuntarily place HHT into Chapter 7 bankruptcy. The Assignee moved to dismiss the involuntary petition, submitting a list of fifteen creditors of HHT that were allegedly qualified under section 303(b) of the Bankruptcy Code.The bankruptcy court issued an order setting a deadline for additional creditors to join the involuntary petition. Only one additional creditor, Shanghai Morimatsu Chemical Equipment Co., joined before the deadline. The court denied PCC Rokita's motion for an extension and subsequently denied DFT Properties, LLC's motion to join the petition after the deadline. The bankruptcy court held an evidentiary hearing and concluded that the Petitioning Creditors failed to prove that any of the twelve challenged creditors were unqualified, leading to the dismissal of the involuntary petition.The Petitioning Creditors appealed to the Bankruptcy Appellate Panel for the First Circuit, which affirmed the bankruptcy court's decision. They then appealed to the United States Court of Appeals for the First Circuit. The First Circuit held that the bankruptcy court may set a deadline for creditors to join a pending involuntary petition and that a putative debtor need not plead defenses to the avoidability of a pre-petition preferential transfer in its answer to the involuntary petition. The court also found that any error in requiring the creditors to disprove defenses to avoidability was harmless. Consequently, the First Circuit affirmed the dismissal of the involuntary petition. View "PCC Rokita, S.A. v. HH Technology Corp." on Justia Law

A Guatemalan native, Eder Anibal Cano-Gutierrez, petitioned for review of a Board of Immigration Appeals (BIA) decision affirming an immigration judge's (IJ) denial of his applications for asylum and protection under the Convention Against Torture (CAT). Cano-Gutierrez's claims stemmed from a series of armed robberies he experienced as a teenager in Guatemala. He testified that he was robbed five times by individuals at gang-controlled checkpoints but did not suffer physical harm or receive death threats. He fled to the United States in January 2018, fearing future harm and recruitment by the robbers.The Department of Homeland Security charged Cano-Gutierrez with removability for being present in the U.S. without authorization. He conceded removability and applied for asylum, withholding of removal, and CAT protection. The IJ found his testimony credible but denied his applications, concluding that the harm he suffered did not rise to the level of persecution and that he failed to show a nexus between the harm and a protected ground. The IJ also found that he did not demonstrate a well-founded fear of future persecution or that he would be targeted by government actors or with government acquiescence.The BIA affirmed the IJ's decision, agreeing that Cano-Gutierrez did not experience persecution and failed to establish a nexus to a protected ground. The BIA also found that he did not demonstrate an objectively reasonable fear of future persecution and deemed his CAT claim waived due to lack of specific challenge.The United States Court of Appeals for the First Circuit reviewed the case and upheld the BIA's decision. The court found no error in the agency's determination that Cano-Gutierrez failed to show a nexus between the robberies and a protected ground, and thus, his asylum claim failed. The court also agreed with the BIA that the CAT claim was waived. Consequently, the petition for review was denied. View "Cano-Gutierrez v. Bondi" on Justia Law

The case involves Dr. Lisa Menninger, who was the Executive Director for Laboratory Operations at PPD Development, L.P. (PPD). Menninger claimed that PPD discriminated and retaliated against her due to her social anxiety disorder, violating the Americans with Disabilities Act (ADA) and Massachusetts antidiscrimination law. A jury found in favor of Menninger, awarding her over $24 million in damages. PPD then moved for judgment as a matter of law, a new trial, and remittitur, but the district court denied these motions.The United States District Court for the District of Massachusetts initially granted partial summary judgment for PPD, rejecting Menninger's theory that PPD could be liable solely for failing to engage in an interactive process. It also limited Menninger's disparate-treatment claims to a single adverse action. However, the court denied PPD's motion for summary judgment on other claims, allowing the case to proceed to trial. The jury found in favor of Menninger on all counts, concluding that PPD failed to provide reasonable accommodation, discriminated against her, and retaliated against her. The jury awarded substantial damages, including punitive damages.The United States Court of Appeals for the First Circuit reviewed the case. PPD argued that the evidence was insufficient to support the jury's verdict, that the jury instructions were misleading, and that the punitive damages were unsupported. The Court of Appeals found that PPD failed to properly preserve its sufficiency-of-the-evidence arguments by not specifying the grounds for its Rule 50(a) motion. The court also found no plain error in the jury instructions and concluded that the evidence supported the punitive damages award. The court affirmed the district court's judgment and its denial of PPD's posttrial motions. View "Menninger v. PPD Development, L.P." on Justia Law