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

Employees of Veolia Water Contract Operations USA, Inc. filed a lawsuit in Massachusetts state court, claiming they were entitled to prevailing wages under the Massachusetts Prevailing Wage Act (PWA) for work performed. They argued that their work fell within the scope of the PWA. Veolia removed the case to federal court based on diversity jurisdiction.The United States District Court for the District of Massachusetts granted summary judgment in favor of Veolia. The court concluded that the Special Act of 1997, which pertains to the Springfield Water and Sewer Commission, exempted Veolia from the obligation to pay prevailing wages under the PWA. The employees appealed this decision.The United States Court of Appeals for the First Circuit reviewed the case. The central issue was whether the Special Act required Veolia to pay prevailing wages. The court noted that the outcome depended on unresolved questions of Massachusetts law and significant policy concerns. Consequently, the First Circuit decided to certify the dispositive state law questions to the Massachusetts Supreme Judicial Court for clarification.The First Circuit certified two questions: the meaning of "construction and design of improvements" in the Special Act and whether the Special Act is incompatible with the PWA under the Massachusetts Supreme Judicial Court's decision in Metcalf v. BSC Group, Inc. The First Circuit retained jurisdiction over the appeal pending the resolution of these certified questions. View "Nicholls v. Veolia Water Contract Operations USA, Inc." on Justia Law

In this case, the plaintiffs, David Boniface, Nissandère Martyr, and Juders Ysemé, brought claims against Jean Morose Viliena under the Torture Victim Protection Act (TVPA) for events that occurred in Haiti in 2007-08. The claims included the extrajudicial killing of Boniface's brother, Eclesiaste Boniface, the attempted extrajudicial killings of Martyr and Ysemé, and the torture of Martyr and Ysemé. The jury in the U.S. District Court for the District of Massachusetts found Viliena liable and awarded compensatory and punitive damages.Viliena appealed, challenging the findings of liability and the damages awards. He argued that federal courts lacked subject-matter jurisdiction and that Congress did not have the power to authorize causes of action under the TVPA for conduct occurring abroad between foreign nationals. He also contended that the TVPA does not provide for attempted extrajudicial killing and raised various specific challenges to the trial and damages awards.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed that it had subject-matter jurisdiction over the TVPA claims. However, it vacated the denial of the motion for reconsideration and remanded for the district court to address whether Congress had the power to provide any cause of action under the TVPA for conduct occurring outside the United States between foreign citizens. The court also agreed with Viliena that the TVPA does not provide a cause of action for attempted extrajudicial killing.The court found sufficient evidence to support the jury's findings of liability for the extrajudicial killing and torture claims. However, it determined that a new trial on damages was necessary due to the erroneous inclusion of the attempted extrajudicial killing claims. The case was remanded for further proceedings consistent with the opinion. View "Boniface v. Viliena" on Justia Law

The case involves a dispute between the former owner-operator of a professional baseball franchise in Puerto Rico and the league, its president, and other franchise owners. The plaintiffs allege that the defendants conspired to force the former owner to relinquish control of the franchise, violating the Sherman Act, a federal civil rights statute, and various Puerto Rico laws. The plaintiffs claim that the defendants' actions were in retaliation for the former owner's public criticism of the conditions at the team's stadium and his proposal to move the team to another municipality.The United States District Court for the District of Puerto Rico dismissed the plaintiffs' Sherman Act claims, citing the "business of baseball" exemption. The court also ruled that the plaintiffs' claims under Puerto Rico's antitrust and fair competition laws were preempted by federal law. Additionally, the court dismissed the plaintiffs' federal civil rights claim on res judicata grounds, based on a prior judgment from the Superior Court of San Juan. The court then declined to exercise supplemental jurisdiction over the remaining Puerto Rico law claim.The United States Court of Appeals for the First Circuit affirmed the dismissal of the Sherman Act claims, agreeing that the "business of baseball" exemption applied to the Puerto Rico professional baseball league. However, the court vacated the District Court's dismissal of the Puerto Rico antitrust and fair competition claims, finding that the District Court had incorrectly applied the Supremacy Clause. The court also reversed the dismissal of the federal civil rights claim, concluding that the District Court had misapplied the doctrine of res judicata. Consequently, the court reversed the dismissal of the remaining Puerto Rico law claim, as a federal claim remained in the case. View "Cangrejeros de Santurce Baseball Club, LLC v. Liga de Beisbol Profesional de Puerto Rico, Inc." on Justia Law

In this case, the defendant was convicted of kidnapping resulting in death under 18 U.S.C. § 1201(a)(1). The incident occurred in February 2019, when the defendant encountered the victim in downtown Boston, Massachusetts. They walked to his car together, and he later drove to his apartment in Providence, Rhode Island. Surveillance footage showed him carrying the victim's limp body into his apartment. Four days later, police found the victim's dead body in the defendant's car trunk in Delaware. The defendant was arrested and charged with kidnapping resulting in death.The United States District Court for the District of Massachusetts conducted the trial, where the jury found the defendant guilty. The court sentenced him to life in prison without the possibility of parole. The defendant appealed, alleging various errors in the district court proceedings, including issues with the indictment, denial of a bill of particulars, and the admission and exclusion of certain evidence.The United States Court of Appeals for the First Circuit reviewed the case. The court found no error in the district court's proceedings. It held that the indictment was sufficient, the denial of a bill of particulars was not an abuse of discretion, and the evidence admitted and excluded was handled appropriately. The court also found that the jury instructions were proper and that there was sufficient evidence to support the conviction. The court affirmed the defendant's conviction and sentence. View "United States v. Coleman" on Justia Law

In early 2025, the National Institutes of Health (NIH) and the Department of Health and Human Services (HHS) implemented a new policy prohibiting NIH from funding certain categories of scientific research grants. Two groups of plaintiffs, including private research organizations, individual researchers, and several states, sued, alleging that the new policy and the resulting grant terminations violated the Administrative Procedure Act (APA) and the U.S. Constitution. They argued that the policy was arbitrary and capricious, as the prohibited research categories were undefined and the rationale for discontinuing the research was circular.The United States District Court for the District of Massachusetts held a trial on the merits and ruled in favor of the plaintiffs, finding the agencies' actions to be "breathtakingly arbitrary and capricious." The court set aside the new policy and related grant terminations as illegal under the APA. The court found that the decisions were based on circular reasoning, lacked a rational connection to the facts, and ignored significant reliance interests. The government then moved for a stay of the district court's order pending appeal, which the district court denied.The United States Court of Appeals for the First Circuit reviewed the case. The court concluded that the district court had jurisdiction to review the agency action under the APA and to grant declaratory relief. The court found that the district court's orders did not enforce a contractual obligation to pay money but rather provided declaratory relief that set aside agency actions as arbitrary and capricious. The court also determined that the grant terminations were reviewable under the APA and that the Department had failed to show a likelihood of success on the merits. The court denied the Department's motion for a stay, concluding that the balance of equities and the public interest favored the plaintiffs. View "American Public Health Assn v. National Institutes of Health" on Justia Law

Marcos Da Silva Borges, his wife Eliane Maria Silva Teixeira Borges, and their two children entered the United States in October 2021 and were charged with inadmissibility under the Immigration and Nationality Act (INA). The family argued that the government needed to prove their noncitizen status by "clear, unequivocal, and convincing" evidence, a higher standard than "clear and convincing" evidence. They also contended that the government failed to meet this burden with the evidence presented. The Immigration Judge (IJ) and the Board of Immigration Appeals (BIA) both ruled against the family, applying the "clear and convincing" standard.The IJ initially denied the family's motion to terminate the removal proceedings, finding that the government met its burden of proof. The BIA remanded the case for a full decision, which the IJ provided, again using the "clear and convincing" standard. The BIA upheld this decision, rejecting the family's arguments about the standard of proof and the reliability of the evidence.The United States Court of Appeals for the First Circuit reviewed the case. The court referenced its recent decision in Rosa v. Bondi, which held that the "clear, unequivocal, and convincing" standard applies in removal proceedings for individuals charged with inadmissibility and that this standard is more demanding than "clear and convincing" evidence. The court found that the agency applied the incorrect legal standard in evaluating the Borges family's removability. Consequently, the First Circuit granted the petition for review, vacated the BIA's order, and remanded the case for further proceedings consistent with the correct standard of proof. View "Da Silva Borges v. Bondi" on Justia Law

A Puerto Rico-based poultry importer, Northwestern Selecta, Inc. (NWS), challenged a regulation by the Puerto Rico Department of Agriculture (PRDA) requiring a PRDA inspector to be present when shipping containers of poultry meat are opened and unloaded. NWS argued that this requirement is preempted by the federal Poultry Products Inspection Act (PPIA), which regulates the inspection and distribution of poultry products. The PPIA includes a preemption clause that prohibits states from imposing additional or different requirements on official establishments beyond those established by the PPIA.The United States District Court for the District of Puerto Rico agreed with NWS, finding that the PRDA's inspector requirement falls within the scope of the PPIA's preemption clause and is not exempted by the PPIA's savings clause. The district court granted declaratory relief to NWS and permanently enjoined the enforcement of the PRDA's regulation against NWS. The PRDA appealed the decision, arguing that the district court misinterpreted the scope of the PPIA's preemption clause and the application of the savings clause.The United States Court of Appeals for the First Circuit reviewed the case de novo. The court held that the PPIA's preemption clause broadly covers state regulations related to the operations of official establishments, which includes the opening and unloading of shipping containers at NWS's facility. The court found that the PRDA's inspector requirement directly impacts NWS's operations and is therefore preempted by the PPIA. Additionally, the court determined that the savings clause does not exempt the PRDA's regulation from preemption because it does not apply to poultry products outside of NWS's facility. Consequently, the First Circuit affirmed the district court's judgment, upholding the permanent injunction against the enforcement of the PRDA's regulation. View "Northwestern Selecta, Inc. v. Gonzalez-Beiro" on Justia Law

Derek Muñoz-Gonzalez was indicted on multiple charges related to child pornography, including production, possession, and distribution. He agreed to plead guilty to two counts of producing child pornography. The plea agreement included a waiver-of-appeal clause, which stated that Muñoz waived his right to appeal if sentenced to 327 months or less. The district court sentenced him to 327 months. Muñoz appealed, claiming the prosecutor breached the plea agreement by advocating for two enhancements not included in the agreement's sentencing guidelines calculation and argued that the waiver-of-appeal clause did not preclude him from raising this breach claim.The United States District Court for the District of Puerto Rico initially reviewed the case. Muñoz was charged by a federal grand jury and subsequently pleaded guilty to two counts of producing child pornography. The plea agreement stipulated an advisory guideline range of 262 to 327 months' imprisonment, and the government agreed to dismiss the other counts. At sentencing, the district court considered the stipulated facts and sentenced Muñoz to 327 months, within the waiver-of-appeal limit.The United States Court of Appeals for the First Circuit reviewed the case. Muñoz argued that the prosecutor breached the plea agreement by highlighting facts not included in the guidelines calculation. The court held that the prosecutor did not breach the plea agreement, as the comments made were consistent with the stipulated facts and were in response to the defense's arguments for a lesser sentence. The court also noted that Muñoz failed to address the plain-error standard in his opening brief, resulting in a waiver of his breach-of-plea-agreement claim. Consequently, the court affirmed the district court's decision. View "United States v. Munoz-Gonzalez" on Justia Law

In 2013, the U.S. Department of Homeland Security initiated removal proceedings against Lesbia Asucena Alay, a native and citizen of Guatemala. Alay conceded her removability but sought cancellation of removal, arguing that her removal would result in "exceptional and extremely unusual hardship" to her two U.S. citizen children. Alay also applied for asylum and withholding of removal but later withdrew those applications.The Immigration Judge (IJ) denied Alay's application for cancellation of removal in December 2019, concluding that she had not demonstrated that her removal would result in "exceptional and extremely unusual hardship" to her children. The IJ found that Alay's children, A.L. and F.L., would remain in the U.S. with their father, who could care for and support them. The IJ acknowledged the potential hardships, including loss of income and separation from their mother, but determined these were not substantially beyond what is normally expected from removal.The Board of Immigration Appeals (BIA) affirmed the IJ's decision, recognizing the hardships Alay's children would face but agreeing that these did not meet the threshold of "exceptional and extremely unusual hardship." The BIA noted that A.L. and F.L. were healthy and doing well in school, and concluded that the hardships they would experience were consistent with those ordinarily resulting from the removal of a close family member.The United States Court of Appeals for the First Circuit reviewed the case and denied Alay's petition for review. The court held that the agency had properly considered the evidence and made an individualized assessment of the hardships. The court found no legal error in the agency's determination that the hardships faced by Alay's children did not meet the statutory standard for cancellation of removal. View "Alay v. Bondi" on Justia Law

Petitioner, a native and citizen of Brazil, entered the United States without inspection in 2004 to be with his son, Gustavo, a U.S. citizen. Petitioner sought cancellation of removal, claiming his removal would cause exceptional and extremely unusual hardship to Gustavo. The immigration judge (IJ) found Petitioner credible but determined he failed to meet the high burden of proving such hardship. The IJ noted Gustavo's behavioral issues but found no evidence of medical or learning disabilities and concluded that Gustavo's mother, who was his primary caretaker, would continue to support him.The Board of Immigration Appeals (BIA) affirmed the IJ's decision on two grounds: first, Gustavo had turned 21 while the appeal was pending, disqualifying him as a qualifying relative; second, the BIA agreed with the IJ's hardship determination. Petitioner then sought review from the United States Court of Appeals for the First Circuit.The First Circuit reviewed the BIA's decision, which had adopted the IJ's reasoning. The court noted that it could only review legal questions and not factual determinations. Petitioner argued that the BIA failed to state the standard of review, applied the wrong standard, ignored relevant factors, cherry-picked evidence, and improperly required expert reports. The court found no merit in these arguments, noting that the BIA's decision was consistent with its precedent and that the BIA had appropriately reviewed the IJ's findings for clear error and the hardship determination de novo.Ultimately, the First Circuit held that the agency did not err in its hardship determination, finding that Petitioner failed to prove that Gustavo's hardship would be substantially beyond the ordinary hardship expected when a close family member is removed. The petition for review was denied. View "Goncalves Leao v. Bondi" on Justia Law