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

The First Circuit affirmed the judgment of the district court granting summary judgment to Defendants and dismissing Plaintiff's complaint alleging that he contracted paralytic shellfish poisoning (PSP) after eating a contaminated shrimp at a Puerto Rican restaurant, holding that the district court properly granted summary judgment to Defendants.Plaintiff and several members of his family sued the Puerto Rican restaurant at which he ate and the food distributors that handled the shrimp before its approval at the Restaurante El Nuevo Amanecer in Barranquitas, Puerto Rico, caused his severe illness, which led to him developing complete quadriplegia. The district court granted summary judgment for Defendants, concluding that Plaintiff had failed to present sufficient evidence to establish that his illness was connected to Defendants' acts or omissions. The First Circuit affirmed, holding that the district court properly granted summary judgment in favor of Defendants. View "Gonzalez-Caban v. JR Seafood Inc." on Justia Law

The First Circuit denied Petitioner's petition for review of the ruling of the Board of Immigration Appeals (BIA) vacating the immigration judge's (IJ) decision granting Petitioner's application for cancellation of removal and ordering Petitioner removed, holding that the BIA did not commit reversible legal error.Petitioner, a native and citizen of Guatemala, conceded that he was removable from the United States but sought cancellation of removal predicated on the impact his removal would have on his young children. The IJ granted the application, concluding that Petitioner established the requisite extreme hardship. The BIA reversed, holding that the IJ incorrectly concluded that the hardships presented were sufficient to satisfy the applicable standard. The First Circuit affirmed, holding that Petitioner failed to show that the BIA misconstrued or overlooked relevant evidence and that there was no evidence that the BIA applied an improper standard. View "Domingo-Mendez v. Garland" on Justia Law

On the government's appeal from the district court's grant of Appellant's motion for compassionate release the First Circuit reversed, holding that remand was required for further review.Nearly thirty years ago, Appellant was convicted of several crimes stemming from his role in a 1991 car bombing and sentenced to life imprisonment. The district court later concluded that a sentencing error constituted an "extraordinary and compelling" reason to grant compassionate release and reduced Appellant's sentence to forty-one years, crediting time served. The First Circuit reversed, holding that remand was required for further proceedings with the benefit of guidance of United States v. Ruvalcaba, 46 F.4th 14 (1st Cir. 2022). View "United States v. Trenkler" on Justia Law

The First Circuit vacated the judgment the Board of Immigration Appeals (BIA) affirming the denial of Appellant's request for withholding of removal under 8 U.S.C. 1231(b)(3) and protection under the Convention Against Torture (CAT), 8 C.F.R. 1208. 16(c)-1208.18 and the denial of her motion to remand, holding that the BIA abused its discretion in denying Appellant's motion to remand.Appellant, a citizen and native of El Salvador, pursued withholding of removal under 8 U.S.C. 1231(b)(3) and protection under the CAT. An immigration judge (IJ) denied Appellant's claims on the basis that she was not credible. On appeal, Appellant sought to, among other things, remand her case for consideration of new evidence that she claimed had not been previously available. The BIA upheld the IJ's adverse credibility finding and affirmed the denial of relief. The First Circuit vacated the BIA's decision and remanded the case, holding that the BIA abused its discretion in determining that the new evidence was not likely to change the result in this case. View "Rivera-Medrano v. Garland" on Justia Law

The First Circuit affirmed the order of the district court entering judgment against Hospital San Antonio, Inc. (HSA) and denying HSA's subsequent motion for relief under Fed. R. Civ. P. 60(b), holding that the district court did not err or abuse its discretion in the challenged rulings.Plaintiffs brought a medical malpractice suit against Defendants, healthcare providers and their insurance carriers, alleging that the birth injuries suffered by their daughter and her subsequent death resulted from Defendants' negligence. The district court entered a partial judgment against defendant HSA and dismissed the claims against the remaining defendants. While its appeal was pending, HSA filed a motion for relief under Rule 60(b), which the district court denied. The First Circuit affirmed the final judgment of the district court and the denial of Plaintiffs' Rule 60(b) motion, holding that HSA did not benefit from the liability limits in P.R. Laws Ann. Tit. 32, 3077, which waives Puerto Rico's sovereign immunity and establishes liability caps in certain circumstances. View "Oquendo-Lorenzo v. Hospital San Antonio, Inc." on Justia Law

The First Circuit affirmed the decisions of the district court granting partial summary judgment to defendant-physicians and denying Plaintiffs' motion for reconsideration in light of the decision in Oquendo-Lorenzo v. Hospital San Antonio, Inc., 256 F. Supp. 3d 103 (D.P.R. 2017), holding that the district court did not err or abuse its discretion.Plaintiffs filed this suit on behalf of themselves, their conjugal partnership, and their minor daughter, C.A.K., alleging that Defendants breached their duty of care and departed from medical standards when treating C.A.K. in the emergency room of San Antonio Hospital. The district court granted partial summary judgment for Defendants, concluding that they were absolutely immune from liability for negligence under recent amendments to Article 41.050 of the Puerto Rico Insurance Code. After Oquendo-Lorenzo was subsequently decided, Plaintiffs moved for reconsideration. The district court denied the motion. The First Circuit affirmed the district court's judgment and order denying the motion to reconsider, holding that there was no error or abuse of discretion. View "Kenyon v. Gonzalez-Del Rio" on Justia Law

The First Circuit vacated the judgment of the district court denying Plaintiff's motion for leave to proceed under a pseudonym, holding that the district court did not apply the appropriate standard for adjudicating such motions.Plaintiff filed suit against Massachusetts Institute of Technology (MIT) alleging breach of contract, promissory estoppel, and denial of basic fairness related to the investigation of Plaintiff for sexual harassment while he was a student at MIT. In his complaint, Plaintiff challenged the findings of the Committee on Discipline and the ensuing sanction of expulsion. On the same day he filed suit Plaintiff filed an ex parte motion to proceed by pseudonym. The district court denied the motion in a minute order. The First Circuit vacated the order, holding that the district court did not apply the appropriate standard for adjudicating motions for leave to proceed under pseudonyms, requiring remand. View "Doe v. Mass. Institute of Technology" on Justia Law

The First Circuit affirmed the judgment of the district court awarding plaintiff Elba I. Falto De Roman only nominal damages against the Municipal Government of Mayguez and against its mayor, Jose Guillermo Rodriguez, on her complaint filed after was terminated from her position without having been afforded a due process hearing, holding that there was no error.Plaintiff brought this action alleging, among other things, that Defendants violated her Fourteenth Amendment right to due process by terminating her without a hearing. After a trial on the issue of whether Plaintiff was entitled to damages as a result of not receiving a hearing, the jury found Defendants not liable for damages and awarded nominal damages of $1 in favor of Plaintiff. The district court denied Plaintiff's subsequently-filed motion for judgment as a matter of law or, alternatively, for a new trial. The First Circuit affirmed, holding (1) Plaintiff waived her challenge to the district court's denial of her motion for judgment; and (2) Plaintiff did not meet the high bar for a new trial. View "Falto-de Roman v. Municipal Government of Mayaguez" on Justia Law

The Supreme Court remanded this immigration case to the Boards of Immigration Appeals (BIA) after it affirmed an immigration judge's (IJ) decision to deny Petitioner's applications for relief from removal based on two marijuana offenses found by the IJ and the BIA to be "particularly serious" pursuant to 8 U.S.C. 1158(b)(2)(A)(ii) and 1231(b)(3)(B)(ii), holding that remand was required.The IJ found Petitioner removable based on two Massachusetts state court convictions involving marijuana. The BIA upheld the IJ's determination that Petitioner was ineligible for asylum and withholding of removal for having been convicted of a particularly serious crime. The Supreme Court granted Petitioner's petition for review, holding that there was not a sufficient rational explanation to explain the BIA's conclusion that Petitioner's minor marijuana offenses were particularly serious crimes and that remand was required. View "Dor v. Garland" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing the complaint brought by two retirement funds in this putative securities fraud class action against CVS Health Corporation and the court's subsequent denial of Plaintiffs' motion to reconsider, holding that there was no error.In this action arising out of difficulties CVS Health experienced in the wake of its acquisition of Omnicare, Inc., Plaintiffs alleged that CVS Health's executives and its newly-acquired subsidiary used false statements and misleading nondisclosures to conceal from investors the disintegration of Omnicare's customer base. The complaint included claims for violations of the Securities Exchange Act and its implementing rule. The district dismissed the complaint after finding that it failed to allege any materially false or misleading statements and denied Plaintiffs' ensuing motion to reconsider. The Supreme Court affirmed, holding that the district court did not abuse its discretion or commit legal error in dismissing Plaintiffs' complaint and denying the motion to reconsider. View "City of Miami Fire Fighters' & Police Officers' Retirement Trust v. CVS Health Corp." on Justia Law