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

In this suit brought under the Racketeering Influence and Corrupt Organizations Act (RICO), the First Circuit remanded this matter for further review, holding that the district court erred in dismissing the complaint based on the doctrine of forum non conveniens.Medtronic Medical CR SRL, a Costa Rica limited liability company, brought suit under RICO alleging that Defendants, Puerto Rico residents, orchestrated fraudulent schemes. The district court granted Defendants' motion to dismiss based on the doctrine of forum non conveniens, concluding that Costa Rica was an adequate alternative forum. The First Circuit remanded the case, holding that intervening and developing circumstances required reconsideration of the most efficient, prudential path forward. View "Medtronic Medical CR SRL v. Feliciano-Soto" on Justia Law

The First Circuit affirmed the judgment of the district court determining that Act 90, passed by the Legislative Assembly of Puerto Rico in 2019, was preempted by federal law, holding that the district court did not err.Act 90 requires that Medicare Advantage plans compensate Puerto Rico healthcare providers in Puerto Rico at the same rate as providers are compensated under traditional Medicare. Plaintiffs, several entities that managed Medicare Advantage plans, filed suit seeking a declaratory judgment and an injunction barring the "mandated price provision," arguing that the Medicare Advantage Act preempted the challenged provision and that provision was unconstitutional. The district court ruled in favor of Plaintiffs. The First Circuit affirmed, holding that Act 90's mandated price provision was preempted by federal law. View "Medicaid & Medicare Advantage Products Ass'n of Puerto Rico, Inc. v. Emanuelli-Hernandez" on Justia Law

The First Circuit denied Petitioner's petition for review of an immigration judge's (IJ) denial of his application for withholding of removal, holding that the Petitioner's arguments were unavailing.Petitioner, a native and citizen of El Salvador, was subject to removal. Petitioner expressed fear of persecution or torture with the asylum officer. The asylum officer rejected Petitioner's reasonable fear claim, concluding that there was insufficient evidence to find that Petitioner had been attacked because of a protected ground. The IJ upheld the asylum officer's decision. The First Circuit affirmed, holding that the IJ did not err by dismissing Petitioner's gang-related claim. View "Reyes-Ramos v. Garland" on Justia Law

The First Circuit vacated the judgment of the district court granting summary judgment in favor of Unitil Service Corporation and dismissing the complaint brought by the Department of Labor (DOL) seeking overtime compensation under the Fair Labor Standards Act's (FLSA) for hours worked in excess of forty hours per week for dispatchers and controllers (collectively, Employees) employed by Unitil, holding that the district court erred.In entering its judgment, the district court concluded that Employees were administrative, exempt from the FLSA, and thus not entitled to overtime pay because their "primary duty" was "directly related" to the general business operations of Unitil Service's customers. On appeal, Unitil argued that Employees were exempt administrative employees under federal law and, as such, were not entitled to overtime payments. The First Circuit vacated the judgment below, holding that the district court improperly did not apply a "relational" analysis comparing the business purpose of Unitil and/or its customers to the primary duty of Employees. View "Walsh v. Unitil Service Corp." on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant of conspiracy to commit export violations, visa fraud, making false statements to federal agents, money laundering, and smuggling, holding that the search of Defendant's laptop and cellular phone was a constitutional search.Defendant, a Chinese national, was stopped by Customs and Border Patrol agents upon his arrival to the United States after a trip to China. Agents seized Defendant's electronic devices for a further search. Defendant was indicted based on evidence during the warrantless search of his devices. The First Circuit affirmed, holding that neither probable cause nor a warrant was required for the search in this case to be lawful. View "United States v. Qin" on Justia Law

The First Circuit affirmed Defendant's sentence imposed in connection with his plea of guilty to possession with intent to distribute cocaine base and possession of a firearm and ammunition as a convicted felon, holding that there was no procedural or substantive error.As to Defendant's drug conviction, the district court imposed an eighty-seven-month term of immurement, to be followed by a sixty-month term of immurement on the firearm conviction. The First Circuit affirmed, holding (1) the district court did not commit plain error in applying a stash-house enhancement; (2) any error in awarding one criminal history point for a prior offense that was dismissed under a diversionary program was patently harmless; and (3) Defendant's sentence was substantively reasonable. View "Unites States v. Melendez-Rosado" on Justia Law

In this appeal arising out of a multidistrict litigation concerning the pharmaceutical drug ondansetron hydrochloride, better known as Zofran, the First Circuit affirmed the order of the district court granting summary judgment in favor of GlaxoSmithKline (GSK), holding that there was no error or abuse of discretion.Various plaintiffs filed separate lawsuits alleging that the use of Zofran during pregnancy caused birth defects and that GSK engaged in an intentionally misleading plan to market Zofran for pregnancy in violation of state law. The district court granted summary judgment in favor of GSK, holding that federal law preempted Plaintiffs' state law claims. The First Circuit affirmed, holding that federal law preempted Plaintiffs' state law claims that GSK should have warned both prescribing doctors and pregnant people that "animal studies showed harm to the fetus when Zofran was ingested during pregnancy." View "Perham v. GlaxoSmithKline, LLC" on Justia Law

The First Circuit affirmed the judgment of the district court entering judgment upon the jury verdict finding Defendant liable for three undue statements of a material fact in violation of Section 10(b) of the Securities Exchange Act of 1934, 15 U.S.C. 78j(b), and SEC Rule 10b-5, 17 C.F.R. 240.10b-5, holding that Defendant was not entitled to relief on his claims of error.The U.S. Securities and Exchange Commission (SEC) brought a civil enforcement action against Defendant. Defendant was found liable by a jury for three untrue statements of a material fact, and the district court judge ordered him to pay a civil penalty and enjoined him from violating Section 10(b) and Rule 10b-5 for five years. The First Circuit affirmed, holding (1) the SEC presented sufficient evidence to support the jury's determination that the statements were of fact rather than opinion, material, and made with scienter; and (2) the district court did not abuse its discretion or commit an error of law in entering the injunction. View "US Securities & Exchange Comm'n v. Lemelson" on Justia Law

The First Circuit affirmed the judgment of the federal district court dismissing Plaintiff's complaint alleging contract claims against Defendant, holding that Plaintiff insufficiently pled that her claims met the amount in controversy required by 28 U.S.C. 1332(a).Plaintiff filed a complaint against Defendant in the United States District Court for the District of Rhode Island asserting diversity jurisdiction. Plaintiff asserted claims for breach of contract, breach of implied warranty, and breach of the duty of good faith and fair dealing, alleging that her claims exceeded the statutory amount-in-controversy requirement. The district court granted Defendant's motion to dismiss for lack of jurisdiction. The First Circuit affirmed, holding that Plaintiff did not meet her burden of establishing the amount in controversy required for diversity jurisdiction. View "Andersen v. Vagaro, Inc." on Justia Law

The First Circuit affirmed the judgments of the district court dismissing part of Plaintiff's putative class action for failure to state a claim and entering summary judgment disposing of the remainder of his claims, holding that there was no error in the proceedings below.In his complaint, Plaintiff argued that an increased coverage limit on his house and premium violated the terms of his contract with Amica Mutual Insurance Company and that he and other Amica insureds paid too much to insure their homes. The district court dismissed the breach of contract and implied covenant of good faith and fair dealing claims and then granted summary judgment for Amica on the unjust enrichment, money had and received, and Mass. Gen. Laws ch. 93A claims. The First Circuit affirmed, holding that there was no reversible error in the proceedings below. View "Gottlieb v. Amica Mutual Insurance Co." on Justia Law