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

In this dispute over an award of attorneys' fees under 42 U.S.C. 1988, the First Circuit identified only one defect in the award, thus vacating the existing fee award in the amount of $20,243 and remanding to the district court to enter a modified fee award in the amount of $18,218, holding that the district court abused its discretion in part.The underlying case revolved around a parcel of real property in Puerto Rico formerly owned by Plaintiff. Defendants, including the Puerto Rico Highway and Transportation Authority, moved for summary judgment for Plaintiff's failure to seek just compensation in the Puerto Rico courts before raising a federal takings claim. The district court granted the motion. As to attorney's fees, the district court found that the federal takings claim was frivolous and awarded payment of fees in the amount of $20,243. The First Circuit vacated the award, holding that the time expended in connection with a non-frivolous supplemental tort claim should have been deducted from the fee award. View "Efron v. Mora Development Corp." on Justia Law

The First Circuit affirmed the order of the federal district court rejecting a challenge to the ruling by a Maine Department of Education hearing officer that the Falmouth School District violated the Individuals with Disabilities Act (IDEA), holding that the district court's challenged rulings were not in error.The hearing officer in this case concluded that Falmouth was required to reimburse the Does for the cost of their son's tuition at a private school because their son had been denied a free appropriate public education during the time periods in question. Falmouth brought this action under the IDEA, challenging the hearing officer's rulings. The Does answered and brought counterclaims against Falmouth under the Rehabilitation Act and Americans With Disabilities Act. The district court granted judgment to the Does and then dismissed the counterclaims. The First Circuit affirmed, holding that the district court did not err or abuse its discretion in the proceedings below. View "Falmouth School Dep't v. Doe" on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment in favor of Defendants and dismissing Plaintiffs' hybrid breach of contract and fair representation claim, their Takings Clause claim, and their claim for declaratory relief, holding that there was no error or abuse of discretion.Plaintiffs, five sergeants in the City of Cranston Police Department, brought this lawsuit against the City of Cranston, the International Brotherhood of Police Officers, Local 301 (the Union), and Matthew Josefson. Plaintiffs were promoted to the rank of sergeant during the time period between Josefson's demotion and reinstatement and then, after Josefson's reinstatement, moved down one position in sergeant rank seniority. Plaintiffs brought suit, alleging several claims. The district court granted summary judgment for Defendants on all claims. The First Circuit affirmed, holding that Plaintiffs' claims failed. View "Barth v. City of Cranston" on Justia Law

The First Circuit vacated Defendant's conviction of attempting to persuade, induce, or entice a minor to engage in criminal sexual activity, holding that the trial was tainted by the erroneous limitation of Defendant's expert testimony.On appeal, Defendant argued that the evidence was constitutionally insufficient to convict him of the charged crimes and that the district court erred in barring his expert witness from testifying about whether Defendant's actions fit the mold of a sexual predator. The First Circuit vacated the judgment below, holding that the district court (1) did not err in denying Defendant's motion for a judgment of acquittal; but (2) erroneously excluded a portion of the testimony of Defendant's proposed expert, and the error was not harmless. View "United States v. Soler-Montalvo" on Justia Law

The First Circuit denied Petitioners' petition for review in this action challenging a final rule promulgated by the Drug Enforcement Administration (DEA) that set the framework through which applicants may register to lawfully manufacture and cultivate cannabis for research purposes, holding that Petitioners were not entitled to relief on their claims.Petitioners - Dr. Lyle Craker, a botany professor, and Scottsdale Research Institute (SRI), a clinical research company - brought this action raising two perceived procedural defects with the DEA's notice of proposed rulemaking that would demand that the final rule be set aside. The First Circuit denied relief, holding (1) Petitioners were not entitled to relief on their claim that the APA required the DEA to include more detail about the legal basis of the proposed rule; (2) the proposed rule did not exceed the DEA's rulemaking authority; (3) Petitioners' challenge to the DEA's definition of "medicinal cannabis" was unavailing; and (4) the DEA's new regulatory framework for registrations was not arbitrary, capricious, or otherwise contrary to law. View "Craker v. U.S. Drug Enforcement Administration" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing this complaint against Karoypharm Therapuetics, Inc. and its corporate officers (collectively, Defendants) alleging securities fraud in violation of sections 10(b) and 20(a) of the Securities Exchange Act, 15 U.S.C. 78j(b) and 78t(a), and Securities and Exchange Commission (SEC) Rule 10-b, 18 C.F.R. 240.10b-5, holding that the district court correctly dismissed the complaint for failure to state a claim.Plaintiff-investors brought this action following a decline in Karyopharm's stock price, alleging that Karyopharm materially misled them as to the safety and efficacy of the company's cancer-fighting drug candidate selinexor. The district court dismissed the complaint for failure to state a claim, concluding that Plaintiffs failed adequately to plead scienter with respect to Defendants' statements about a certain study of the drug as a treatment for pinta-refractory multiple myeloma. The First Circuit affirmed on other grounds, holding that Plaintiffs did not plausibly allege an actionable statement or omission with respect to the trial disclosures, and therefore, dismissal was appropriate. View "Thant v. Karyopharm Therapeutics Inc." on Justia Law

The First Circuit affirmed Defendant's conviction of three counts of engaging in the business of dealing a firearm without a license and sentence of sixty months' imprisonment, holding that there was no error or abuse of discretion in the district court's imposition of Defendant's sentence.Defendant admitted to engaging in the business of illegally dealing firearms on three separate occasions over more than one year. The district court imposed a sixty-month sentence. Defendant appealed his sentence, arguing that his sentence was procedurally and substantively unreasonable. The First Circuit affirmed, holding that there was no error as to the procedural objections and no abuse of discretion in the length of the sentence imposed. View "United States v. Andujar-Colon" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing this case against Allscripts Healthcare Solutions, Inc. (AHS) on personal jurisdiction grounds but vacated the dismissal as to Allscripts Healthcare, LLC (Allscripts), holding that the district court improperly granted the motion to dismiss as to Allscripts.Dr. Juan M. Rodriguez-Rivera (Rodriguez) brought this action against AHS and Allscripts in Puerto Rico federal court after his electronic patient records from his medical practice were destroyed. AHS and Allscripts filed a motion to dismiss. The district court granted the motion, finding that the disputes should be arbitrated, that it lacked jurisdiction over both AHS and Allscripts, and that Rodriguez's complaint failed to state a claim as a matter of law. The First Circuit affirmed in part and vacated in part, holding (1) the district court improperly granted the motion to dismiss for lack of personal jurisdiction with respect to Allscripts; (2) whether a valid arbitration existed was a factual matter to be resolved by the district court; and (3) the district court erred in concluding that Rodriguez's complaint failed to state a claim against Allscripts. View "Rodriguez-Rivera v. Allscripts HC Sol., Inc." on Justia Law

The First Circuit dismissed this appeal from the dismissal of a 42 U.S.C. 1983 suit filed by Plaintiffs, two college students, against Defendants, their former universities and university officials, asserting constitutional challenges to the universities' COVID-19 vaccination policies, holding that Plaintiffs' claims are moot.The policies at issue required all students either to be vaccinated or to obtain an exemption to be allowed onto campus. Plaintiffs sought declaratory and injunctive relief seeking exemptions from the policies. The district court denied relief and granted Defendants' motion to dismiss. The First Circuit dismissed Plaintiffs' ensuing appeal, holding that where one student had graduated and the other student was no longer enrolled, Plaintiffs' claims were moot. View "Harris v. University of Massachusetts, Lowell" on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment dismissing Plaintiff's federal claims against Brown University and reversed the grant of summary judgment as to Plaintiff's state law claim for intentional infliction of emotional distress, holding that there were triable issues precluding summary judgment.Jane Doe, a white woman, filed a complaint against Plaintiff, an African-American man who was then a freshman at Brown University, alleging sexual misconduct. After a multi-year process leading to Plaintiff's suspension from school and his suicide attempt. A year before he graduated, Plaintiff brought this action in Rhode Island state court alleging that Brown discriminated against him and intentionally inflicted emotional distress upon him. The district court granted summary judgment for Brown. The First Circuit reversed in part, holding that Plaintiff presented evidence that would allow a jury reasonably to conclude that Brown should be held liable for the tortious conduct of its officials in intentionally causing Plaintiff severe emotional distress under Rhode Island common law. View "Doe v. Brown University" on Justia Law