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

In this installment of a series of cases before the Court regarding the Puerto Rico Oversight, Management, and Economic Stability Act, 48 U.S.C. 2101-2241, the First Circuit dismissed the appeal, holding that this Court lacked jurisdiction over the appeal.After the court overseeing Title III proceedings confirmed a plan of adjustment for the Commonwealth's debts, Appellants challenged the Title III court's findings of fact and conclusions of law, making arguments focused on obtaining retirement benefits that Appellants believed they were entitled to. The First Circuit dismissed the appeal, holding that the arguments offered by Appellant to support the First Circuit's jurisdiction in this appeal were unavailing. View "Financial Oversight & Management Bd. v. Cooperativa de Ahorro y Credito" on Justia Law

The First Circuit reversed the judgment of the federal district court imposing Fed. R. Civ. P. 11 sanctions against attorney Michael McArdle, counsel on a state court complaint, holding that the district court erred in imposing Rule 11 sanctions against McArdle based on the amended complaint and that Rule 11's procedural requirements were not met in this case.Nicholas Triantos, a lawyer, sued several defendants in Massachusetts Superior Court asserting various claims arising out of a foreclosure on his property. McArdle was counsel of record for Triantos and signed the state court complaint. After the case was removed to federal district court McArdle did not enter a notice of appearance. Triantos himself entered a pro se notice of appearance and signed and filed an amended complaint. The district court later dismissed the amended complaint for failure to state a claim. Appellant moved for sanctions against Triantos and McArdle under Rule 11, which the district court granted. McArdle moved for relief from this order under Rule 60(b), but the district court summarily denied the motion. The First Circuit reversed, holding that the district court made two errors in imposing Rule 11 sanctions against McArdle and that McArdle's Rule 60(b) motion should have been granted. View "Guaetta & Benson, LLC v. McArdle" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Employer and dismissing all of Employee's claims alleging retaliatory behavior under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-2 et seq., discrimination and retaliation under the Uniformed Services Employment and Reemployment Rights Act, 38 U.S.C. 4301 et seq., and violations of Puerto Rico Law 115, holding that there was no error or abuse of discretion.The district court granted Employer's motion for summary judgment, finding that Employee failed to make a prima facie showing of retaliation and, in the alternative, failed to rebut Employer's explanations for why the behavior in question was non-discriminatory in nature. The First Circuit affirmed, holding (1) there was no abuse of discretion in the district court's conclusion that Employee's statement in opposition to Employer's statement of uncontested material facts was noncompliant with Local Rule 56; (2) the district court properly found that Employee failed to make out a prima facie case for retaliation under Title VII; and (3) the dismissal of Employee's antiretaliation law claims was proper. View "Rodriguez-Severino v. UTC Aerospace Systems" on Justia Law

The First Circuit affirmed Defendant's conviction of enticement of a fifteen-year-old minor for unlawful sexual activity, in violation of 18 U.S.C. 2422(b), and transportation of a minor to engage in criminal sexual activity, in violation of 18 U.S.C. 2423(a), holding that there was no error.On appeal, Defendant asserted numerous challenges to the criminal judgment related to the district court's evidentiary rulings and argued that the evidence was insufficient to support his conviction. The Supreme Court affirmed, holding (1) there was no error in the district court's denial of Defendant's motion to suppress; (2) a defendant can be found to persuade, entice, or induce a victim in violation of section 2422 despite purported evidence that the victim agreed to engage in sexual activity; and (3) Defendant's remaining claims failed. View "United States v. Greaux-Gomez" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant of all counts in a 41-count indictment charging him with sexual exploitation of a child and possessing, promoting, and distributing child pornography and sentencing him to a term of eighty years' imprisonment, holding that Defendant's arguments on appeal were unavailing.On appeal, Defendant argued that the total length of his term-of-hears sentence violated the constitutional prohibition on cruel and unusual punishment contained in the Eighth Amendment to the United States Constitution. The First Circuit affirmed, holding that Defendant's eighty-year sentence for dozens of child pornography offenses did not reach the level of gross disproportionality. View "United States v. Raiche" on Justia Law

The First Circuit denied the petition for review of a decision of the Board of Immigration Appeals (BIA) denying Petitioner's application for cancellation of removal, holding that substantial evidence supported the BIA's determination that Petitioner had not shown prejudice, and the BIA committed no error of law in that ruling.Petitioner, a native of Haiti, was charged as removable under 8 U.S.C. 1227(a)(2)(C) based on a firearm conviction. Petitioner filed applications for asylum, withholding of removal, protection under the Convention Against Torture, and cancellation of removal. The immigration judge (IJ) denied relief, and the BIA upheld the IJ's determination. The First Circuit denied Petitioner's petition for review, holding that Petitioner was deserving of cancellation of removal. View "Dorce v. Garland" on Justia Law

The First Circuit affirmed the judgment of the district court sentencing Appellants to terms of imprisonment and imposing conditions of supervised release on all Appellants, including "Standard Condition of Supervised Release Number 12," holding that Appellants' constitutional challenges to Standard Condition 12 failed on the merits.Appellants - Akeem Cruz, Taylor Lovely, and Jeremiah Mitchell - pleaded guilty to drug-related crimes and were each sentenced to a term of imprisonment followed by supervised release. The district courts imposed conditions of supervised release on all Appellants, including Standard Condition 12. For the first time on appeal, Appellants argued that Standard Condition 12 was unconstitutionally vague and an unconstitutional delegation of judicial authority. The First Circuit affirmed, holding that the Standard Condition 12 is neither unconstitutionally vague, nor does it unconstitutionally delegate judicial authority to a probation officer. View "United States v. Cruz" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of the County of York and various County officials in this case alleging violation of Plaintiff's civil right, false arrest, false imprisonment, malicious prosecution, and defamation per se, holding that there was no error.Specifically, the First Circuit held (1) no reasonable jury could find facts that would lead to a determination that the officers lacked probable cause to arrest Plaintiff, and Plaintiff likewise developed no argument that his false imprisonment claims could survive a finding that probable cause existed to arrest him; (2) Plaintiff failed to raise a triable issue as to his federal and state malicious prosecution claims; (3) none of Plaintiff's constitutional claims against the officers could survive summary judgment; and (4) the district court properly rejected Plaintiff's defamation claims. View "Charron v. County of York" on Justia Law

The First Circuit affirmed Defendant's conviction for drug-trafficking and firearms charges, holding that the district court did not err in denying Defendant's motion to suppress or in finding Defendant eligible for a mandatory minimum sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924 (e).Reports of a parking-lot confrontation following a road-rage incident led law enforcement to stop Defendant in his vehicle the next day. The ensuing searches of Defendant's car and motor home led to the discovery of evidence supporting drug-trafficking and firearms charges. Defendant pleaded guilty. The First Circuit affirmed Defendant's conviction and sentence, holding (1) there was no error in the district court's denial of Defendant's motion to suppress; and (2) Defendant's sentence under the ACCA was lawfully imposed. View "United States v. Mulkern" on Justia Law

The First Circuit affirmed Defendant's conviction, entered upon his guilty plea, for one count of being a felon in possession of a firearm and sentence of fifteen years of incarceration followed by three years of supervised release, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant failed to establish plain error on his argument that his plea colloquy was facially invalid because of an omission that rendered his guilty plea unknowing and involuntary; (2) Defendant waived his right challenge the sufficiency of the indictment by pleading guilty; (3) although Defendant's challenge to the government's failure to file substantial assistance motions fell outside the scope of the appeal waiver, this Court nevertheless holds that the district court did not err in declining to hear evidence before sentencing; (4) Defendant's prior convictions under the Massachusetts drug distribution statute were properly characterized as Armed Career Criminal Act predicates; and (5) the district court did not err in deciding to proceed with sentencing despite argument from defense counsel that the government had failed to honor the terms of a cooperation agreement. View "United States v. Doe" on Justia Law