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

The First Circuit affirmed Defendant's convictions for unlawfully possessing firearms and ammunition as a convicted felon and for unlawfully possessing a firearm with an obliterated serial number, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that the district court abused its discretion when it qualified Special Agent Israel Valle with the Bureau of Alcohol, Tobacco, Firearms and Explosives as an expert under Fed. R. Evid. 702 on whether the ammunition and firearms charged in the indictment had traveled in interstate commerce. The First Circuit disagreed and affirmed, holding (1) the district court did not abuse its discretion in ruling that Special Agent Valle was qualified to testify as an expert; and (2) Defendant's additional pro se arguments were without merit. View "United States v. Cortez-Oropeza" on Justia Law

In this dispute between the Maine lobster industry and the National Marine Fisheries Service (the Agency) over a rule barring frequently employed methods of lobstering the First Circuit lifted its issuance of a preliminary injunction and remanded the case for further proceedings, holding that Plaintiffs were unlikely to succeed on the merits of their claim.Plaintiffs, a union of oyster fishers and fishing companies, challenged a regulation issued by the National Marine Fisheries Service in August 2021 that prohibited lobster fishing with vertical buoy lines in certain areas during certain times of year. After the district court granted a preliminary injunction enjoining enforcement of the seasonal disclosure, the government and conservation grounds sought a stay of the order. The First Circuit first stayed the preliminary injunction and then vacated the injunction, holding that Plaintiffs were unlikely to succeed on the merits of their claim. View "District 4 Lodge of the International Ass'n v. Raimondo" on Justia Law

The First Circuit affirmed the district court's judgmentsentencing Defendant to a 188-month term of imprisonment for his conviction of conspiracy to distribute and to possess with intent to distribute on kilogram or more of heroin and 400 grams or more of fentanyl, holding that Defendant's claims did not survive scrutiny.In his complaint, Defendant argued that the district court mistakenly attributed to him the entirety of the drugs found in an apartment used by him and his coconspirators, and (2) the court erred applying the "stash house" enhancement. The First Circuit affirmed, holding (1) the evidence was sufficient to show that Defendant bore responsibility for the drugs in the apartment; and (2) the "stash house" enhancement was appropriately applied in this case. View "United States v. Soto-Villar" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's habeas petition, holding that the Massachusetts state court reasonably applied federal law in deeming the Commonwealth's proof constitutionally adequate.After a jury trial, Defendant was convicted of first-degree murder on a theory of felony murder based on a predicate of armed robbery and sentenced him to a term of life imprisonment on the felony murder charge. The Massachusetts Supreme Judicial Court (SJC) affirmed the conviction. Petitioner sought federal habeas review in the federal district court. The district court denied the petition. The First Circuit affirmed, holding that the district court did not err in denying Appellant's application for habeas relief. View "Webster v. Gray" on Justia Law

The First Circuit denied an emergency stay sought by Plaintiffs of a disclosure order in this challenge to the Maine vaccine mandate for healthcare workers as it stood on October 19, 2021, holding that Plaintiffs were not entitled to the stay.For this first ten months of this case Plaintiffs were allowed to proceed under pseudonyms. Upon a motion by intervenor press/media organizations, the district court ordered Plaintiffs to file an amended complaint identifying by name the individual plaintiffs, finding that Plaintiffs did not meet their burden of rebutting the presumption against parties proceeding under pseudonyms. Plaintiffs filed an appeal from the disclosure order and sought an emergency stay of that order until resolution of their appeal on the merits. The First Circuit denied the stay, holding that the public interest and the media intervenors' interests weighed in favor of denying the stay due to the presumption of public access. View "Does v. Mills" on Justia Law

In this lawsuit challenging both the residency and voter-registration requirements under Maine law the First Circuit affirmed the order issuing a preliminary injunction preventing the residency requirement and voter-registration requirement from being enforced, holding that there was no error.In 2020, Plaintiffs brought this action against the Secretary of State of Maine and the Deputy Secretary of State of Maine for the Bureau of Corporations in their official capacities, alleging that, by restricting who may be a circulator, Maine's residency and voter-registration requirements violate the First Amendment, as incorporated against the states by the Due Process Clause of the Fourteenth Amendment. The district court granted Plaintiffs' request for a preliminary injunction. The First Circuit affirmed, holding that Plaintiffs established that they were likely to succeed on the merits of their claims. View "We The People PAC v. Bellows" on Justia Law

The First Circuit affirmed Defendant's conviction for four offenses relating to Defendant's possession of a handgun with an obliterated serial number and drugs found within the bag that he was carrying, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant challenged the denial of his motion to suppress evidence recovered during his arrest, alleging that his seizure violated his Fourth Amendment rights and that he was coerced into handing over the bag to law enforcement. The First Circuit affirmed, holding (1) the officer lacked reasonable suspicion to justify the initial seizure of Defendant but an intervening voluntary act provided independent probable cause to arrest Defendant; (2) suppression was not warranted under the fruit-of-the-poisonous-tree doctrine; and (3) the district court did not abuse its discretion in imposing limitations on cross-examination during the trial. View "United States v. Sierra-Ayala" on Justia Law

The First Circuit reversed the judgment of the district court denying arbitration requested by two unions - the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union and the United Steelworkers Local 12203 (collectively, Union) - on behalf of former two employees of the Boston Gas Company (Company) as to their claims for pension benefits, holding that this matter called for arbitration.The Union represented the two members in filing grievances regarding their underpaid pensions. The Union submitted the grievances to the Joint Pension Committee, which was unable to resolve the dispute. The Union subsequently sought arbitration over the grievances, but the Company refused to arbitrate. The First Circuit reversed, holding that it was up to an arbitrator, not a court, to determine the matters at issue in this case. View "United Steelworkers v. National Grid" on Justia Law

The First Circuit affirmed the judgment of the district court granting Defendant's motion to dismiss this case brought against him by Plaintiff, his previous employer, for lack of personal jurisdiction, holding that the district court did not err.Plaintiff brought this lawsuit against Defendant in the District of New Hampshire, alleging that he breached his employment contract and violated a non-solicitation of employees clause by encouraging three of Defendant's employees to quit their employment and join him at his new company. The district court dismissed the case for lack of personal jurisdiction. The First Circuit affirmed, holding that the requirements for personal jurisdiction were not met in this case. View "Vapotherm, Inc. v. Santiago" on Justia Law

The First Circuit affirmed the district court's judgment dismissing Plaintiffs' lawsuit asserting race-based discrimination and retaliation in violation of Title VII of the Civil Rights Act, holding that the district court did not err in dismissing the suit for failure to state a claim.Plaintiffs represented a putative class of employees employed by Whole Foods and Amazon who were disciplined for wearing face masks with the message "Black Lives Matter." In their lawsuit, Plaintiffs alleged that the manner in which their employers enforced a previously unenforced dress code policy constituted race-based discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964. The district court dismissed all claims. The First Circuit affirmed, holding that Plaintiffs did not adequately plead claims for racial discrimination and retaliation under Title VII. View "Frith v. Whole Foods Market, Inc." on Justia Law