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

The First Circuit affirmed the judgment of the district court denying Defendant's latest request to withdraw his guilty plea to conspiring to import Cocaine into the United States and money laundering to promote this conspiracy, holding that the district court did not err in denying Defendant's motion to withdraw his guilty plea.Multiple times before he was sentenced Defendant filed motions to withdraw his guilty plea. As to Defendant's most recent withdrawal motion, the magistrate judge recommended that the district court grant the motion. The district court disagreed and denied Defendant's request to withdraw his plea. The First Circuit affirmed, holding (1) the district court's analysis of the plea withdrawal motion was flawed in two respects, but the district court did not abuse its discretion in denying Defendant's motion to withdraw the guilty plea; and (2) the district court did not err in exercising jurisdiction over Defendant. View "United States v. Fonseca" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Amyndas Pharmaceuticals, S.A.'s claims against Zealand Pharma A/S and vacated the dismissal of Amyndas's claims against Zealand Pharma U.S., Inc., holding that the district court erred in dismissing Amyndas's claims against Zealand Pharma U.S.When Amyndas was considering separate joint ventures with Zealand Pharma and Alexion Pharmaceuticals, Inc. it shared trade secrets before understanding that neither of the joint ventures would materialize. Zealand Pharma and Zealand US, its newly established affiliate, subsequently announced a partnership with Alexion Pharmaceuticals, Inc. Amyndas sued for misappropriation of trade secrets and other confidential information. The district court (1) dismissed Amyndas's claims against Zealand Pharma on the ground that Amyndas was required to litigate those claims in Denmark; and (2) dismissed Amyndas's claims against Zealand US for failure to state a claim. The First Circuit vacated in part and remanded the case for further proceedings, holding that the district court (1) correctly dismissed Amyndas's claims against Zealand Pharma; and (2) erred in concluding that Amyndas's claims against Zealand US were futile. View "Amyndas Pharmaceuticals, S.A. v. Zealand Pharma A/S" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant of one count of possession with intent to distribute fentanyl and cocaine base after a traffic stop near Wells, Maine, holding that the district court did not commit plain error in accepting Defendant's guilty plea.On appeal, Defendant argued that the district court impermissibly failed to advise him that he was giving up the right to file pretrial motions at his Rule 11 hearing and that this Court should reverse the denial of his motion to withdraw his guilty plea. The First Circuit affirmed, holding that Defendant's claim on appeal was meritless. View "United States v. Williams" on Justia Law

The First Circuit affirmed the rulings of the district court in this civil action brought under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., holding that none of the parties were entitled to relief on their claims brought on appeal and cross-appeal.Plaintiffs filed an administrative complaint alleging that the Newton Public Schools violated the IDEA by failing to provide their son David with a free appropriate public education, 20 U.S.C. 1412(a)(1). The Massachusetts Bureau of Special Education Appeals rejected the complaint. Thereafter, Plaintiffs brought this complaint. The district court granted judgment for Plaintiffs and ordered Newton to reimburse them for expenses they had incurred in placing their son at a private residential school in Connecticut. Defendants appealed, challenging the court's decision to exclude boarding- and travel-related expenses from the order of reimbursement. The First Circuit affirmed, holding that none of the parties were entitled to relief on their allegations of error. View "Doe v. Newton Public Schools" on Justia Law

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