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

The defendant pleaded guilty in 2013 to possessing child pornography, after sharing videos of minors being sexually abused and attempting to arrange sex with a minor. He was sentenced to ten years in prison and 25 years of supervised release, with conditions restricting his access to internet-capable devices. After completing his prison term, he began supervised release in December 2019. His release was revoked three times for violations, including unauthorized internet access and failure to comply with monitoring requirements. The conditions at issue required him to use only devices with court-approved monitoring software and to contribute to the cost of monitoring based on his ability to pay.Following the first revocation, the United States District Court for the District of Puerto Rico imposed new, stricter internet monitoring conditions. After further violations, including possessing unauthorized devices and failing to report employment changes, the court again revoked his supervised release (the “Second Revocation”), sentencing him to time served and a renewed term of supervised release with the same conditions. The defendant objected, arguing that the court improperly relied on ex parte communications from his probation officer and that the internet monitoring conditions were unconstitutional and unlawfully delegated judicial authority to the Probation Office.The United States Court of Appeals for the First Circuit reviewed the appeal. The court held that, although the district court erred by relying on new, significant facts from ex parte communications regarding the defendant’s employment, the error was harmless because other uncontested violations supported the revocation and sentence. The court also held that the challenged internet monitoring conditions were not facially unconstitutional or an unlawful delegation of judicial authority. The court found the defendant’s as-applied constitutional challenges unripe, as they depended on future enforcement. The judgment and sentence from the Second Revocation were affirmed. View "United States v. Negron-Cruz" on Justia Law

A Guatemalan national who had lived in the United States since 2000 applied for cancellation of removal, withholding of removal, and protection under the Convention Against Torture (CAT). She testified that, before leaving Guatemala, she received frequent death threats from individuals seeking to extort her father's meat shop and experienced a separate violent incident unrelated to her family. She feared returning to Guatemala due to potential targeting by gangs, particularly as a deportee perceived to have money. In the United States, she had three U.S. citizen children, one of whom suffered from anxiety and was receiving therapy.An Immigration Judge (IJ) denied all three forms of relief. The IJ found that the petitioner was not statutorily eligible for cancellation of removal due to insufficient continuous presence in the United States and, alternatively, that she failed to show her children would suffer exceptional and extremely unusual hardship if she were removed. The IJ also determined that the threats and harm she experienced in Guatemala did not amount to persecution on account of a protected ground, but rather were motivated by general criminal activity. The IJ further found no evidence that she would be tortured with the acquiescence of the Guatemalan government, denying her CAT claim.The Board of Immigration Appeals (BIA) affirmed the IJ’s decision on all grounds. The BIA agreed that the hardship to her children did not meet the statutory threshold, that there was no nexus between the harm feared and a protected ground for withholding of removal, and that the CAT claim was waived due to lack of meaningful challenge.The United States Court of Appeals for the First Circuit reviewed the case and denied the petition for review. The court held that the BIA did not err in its determinations regarding hardship, nexus to a protected ground, or waiver of the CAT claim. View "Lopez Cano v. Bondi" on Justia Law

The appellant, a former Senior Vice President of Corporate Development at a pharmaceutical company, had a longstanding history of back and hip problems, leading him to stop working in 2014. He received long-term disability benefits under an insurance plan administered by USAble Life for several years. In 2019, USAble terminated his benefits, citing evidence of significant improvements in his physical condition, including weight loss, increased exercise, travel, and other activities inconsistent with total disability. The termination was based on updated medical records, surveillance, and reviews by independent physicians, despite continued support for disability from some of the appellant’s treating doctors.After the termination, the appellant pursued multiple rounds of internal appeals with USAble, submitting additional medical and vocational evidence. USAble obtained further independent medical reviews, which consistently concluded that the appellant was no longer disabled under the plan’s definition. The appellant then filed suit in the United States District Court for the District of Massachusetts, which granted summary judgment in favor of USAble, finding that the insurer’s decision was reasonable and supported by substantial evidence.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s summary judgment ruling de novo but applied a deferential “arbitrary and capricious” standard to USAble’s benefits determination, as required under ERISA. The First Circuit held that USAble’s decision to terminate benefits was reasoned and supported by substantial evidence, that USAble properly applied the plan’s definition of disability, and that it adequately explained its disagreement with the appellant’s treating physicians. The court also found that any structural conflict of interest was sufficiently mitigated. Accordingly, the First Circuit affirmed the district court’s judgment in favor of USAble. View "Bernitz v. USAble Life" on Justia Law

A dispute arose when an insurance company denied coverage to an entity listed as an "Additional Insured" under a claims-made insurance policy. The insurer had issued the policy to a company operating an elder care facility. The plaintiff, a commercial real estate lender, had provided a loan secured by a mortgage on the property and later sought the appointment of a receiver after the operator defaulted. In January 2022, several residents were removed from the facility, leading to lawsuits alleging wrongful eviction and other claims against entities involved in financing and controlling the facility, including the plaintiff.The United States District Court for the District of Massachusetts reviewed the plaintiff’s suit seeking a declaration that the insurer had a duty to defend it in two underlying lawsuits. The district court granted summary judgment in part to each party, holding that the insurer had a duty to defend the plaintiff in one action (the Frost action) based on a claim related to the collection of an administrative fee, but not in the other (the Salie action), due to the plaintiff’s failure to provide timely notice as required by the policy. The court also granted summary judgment to the insurer on the plaintiff’s state-law claims for unfair and deceptive practices, finding insufficient evidence of bad faith.On appeal, the United States Court of Appeals for the First Circuit reversed the district court’s decision regarding the Frost action, holding that the insurer did not have a duty to defend because the claims did not allege liability solely attributable to the original insured, as required by the policy’s endorsement. The court affirmed the district court’s decision as to the Salie action and the state-law claims, concluding that the plaintiff’s failure to comply with the policy’s notice requirements and the insurer’s reasonable denial of coverage precluded recovery. The case was remanded for further proceedings. View "BI 40 LLC v. Ironshore Specialty Insurance Company" on Justia Law

Two individuals, along with other plaintiffs, filed suit under Section 7 of the Clayton Act to block a proposed merger between two airlines. After their case was filed, the U.S. Department of Justice, joined by several states and the District of Columbia, brought a separate action challenging the same merger. Both cases were assigned to the same judge in the U.S. District Court for the District of Massachusetts, but were not consolidated. The district court found that only two of the original plaintiffs had standing, dismissing the others. The plaintiffs’ request to consolidate their case with the DOJ’s was denied.The DOJ case proceeded to trial first, resulting in a bench trial judgment that the merger violated the Clayton Act, and the court permanently enjoined the merger. The airlines appealed but later abandoned the merger and dismissed their appeal. As a result, the district court dismissed the remaining plaintiffs’ case as moot, since the relief they sought had already been granted in the DOJ case. The dismissed plaintiffs then moved for attorneys’ fees and costs, arguing they were prevailing parties under Section 16 of the Clayton Act because their efforts contributed to the outcome.The United States Court of Appeals for the First Circuit reviewed whether the plaintiffs qualified as prevailing parties eligible for attorneys’ fees. The court held that, under the standard set by Buckhannon Board & Care Home, Inc. v. West Virginia Department of Health & Human Resources, a party must obtain a judicially sanctioned change in the legal relationship of the parties, such as a judgment on the merits or a consent decree. Because the plaintiffs’ case was dismissed as moot without a judgment on the merits, and they were not beneficiaries of the injunction in the DOJ case, the court concluded they were not prevailing parties. The First Circuit affirmed the district court’s denial of attorneys’ fees and costs. View "Garavanian v. JetBlue Airways Corp." on Justia Law

A graphic designer was commissioned in 2016 to create a room-sized artwork for a brewery’s exhibition at an annual fair produced by the defendant. The agreement specified that the designer would retain copyright ownership and that the installation could only be shown in person to paying patrons at the 2016 event. During the fair, the defendant created and widely disseminated marketing videos online featuring the designer’s work without attribution, despite the designer’s requests for credit. The designer applied for copyright registration in April 2017, and the work was eventually registered, though the exact date of registration is not in the record.The designer first filed a pro se copyright infringement suit in the United States District Court for the District of Massachusetts in early 2018, but the court dismissed it without prejudice for failure to allege copyright registration. Instead of amending, the designer filed a second action in state court, which was removed to federal court. After amending her complaint, the district court again dismissed the copyright claims, this time with prejudice, for failure to state a plausible claim and failure to allege registration. The designer did not respond to the motion to dismiss. In December 2020, now represented by counsel, she filed the present suit in federal court, which was dismissed with prejudice on claim preclusion grounds. On appeal, the United States Court of Appeals for the First Circuit reversed and remanded for further consideration.On remand, the district court again dismissed the case, this time on both claim preclusion and statute of limitations grounds. The United States Court of Appeals for the First Circuit affirmed the dismissal, holding that the copyright infringement claims were untimely under the three-year statute of limitations, as the plaintiff knew or should have known of the alleged infringement by early 2017. The court also found no basis for equitable tolling. View "Foss v. Eastern States Exposition" on Justia Law

Two hospitals incorporated and operating in Mexico provided emergency medical care to individuals insured under Medicare Advantage plans issued by a Maine-based health insurance company. The patients, while in Mexico, signed contracts with the hospitals agreeing to pay for all services rendered and provided their insurance information. The hospitals, through a third-party administrator, contacted the insurer and received representations that the patients had “full medical insurance benefits” for the proposed out-of-country emergency services. Relying on these representations, the hospitals provided extensive treatment. After the patients were discharged, the insurer refused to reimburse the hospitals beyond a $25,000 cap, citing the terms of the Medicare Advantage plans.The hospitals filed separate lawsuits in the United States District Court for the District of Maine, asserting Maine common-law claims for promissory estoppel and negligent misrepresentation. They argued that the insurer’s representations induced them to provide care for which they were not fully reimbursed. The insurer moved to dismiss, contending that the claims were, in substance, claims for Medicare benefits and thus subject to the Medicare Act’s administrative exhaustion requirements. The district court agreed, finding that the claims arose under the Medicare Act and that the hospitals had not exhausted administrative remedies. The court dismissed both actions for lack of subject-matter jurisdiction and later denied the hospitals’ motions to alter the judgments, rejecting the argument that foreign hospitals are exempt from the exhaustion requirement.On appeal, the United States Court of Appeals for the First Circuit affirmed. The court held that the hospitals’ claims, though styled as common-law torts, were “inextricably intertwined” with determinations of Medicare benefits and thus arose under the Medicare Act. Because the hospitals had not exhausted administrative remedies, the district court properly dismissed the actions for lack of subject-matter jurisdiction. The court also found no basis to excuse exhaustion for foreign hospitals. View "Hospital Amerimed Cancun S A DE C V v. Martin's Point Health Care, Inc." on Justia Law

A resident of a memory-care facility in Massachusetts alleged that the facility’s court-appointed receiver, KCP Advisory Group, LLC, conspired with others to unlawfully evict residents, including herself, by falsely claiming that the local fire department had ordered an emergency evacuation. The resident, after being transferred to another facility, filed suit in the United States District Court for the District of Massachusetts, asserting several state-law claims against KCP and other defendants. The complaint alleged that KCP’s actions violated statutory and contractual notice requirements and were carried out in bad faith.KCP moved to dismiss the claims against it, arguing that as a court-appointed receiver, it was entitled to absolute quasi-judicial immunity. The district court granted the motion in part and denied it in part, holding that while quasi-judicial immunity barred claims based on negligent performance of receivership duties, it did not bar claims alleging that KCP acted without jurisdiction, contrary to law and contract, or in bad faith. The court thus denied KCP’s motion to dismiss several counts, including those for violation of the Massachusetts Consumer Protection Act, intentional infliction of emotional distress, civil conspiracy, fraud, and breach of fiduciary duty. KCP appealed the denial of immunity as to these counts.The United States Court of Appeals for the First Circuit reviewed the district court’s denial of absolute quasi-judicial immunity de novo. The appellate court held that KCP’s alleged acts—removing residents from the facility—were judicial in nature and within the scope of its authority as receiver. Because KCP did not act in the absence of all jurisdiction, the court concluded that quasi-judicial immunity barred all of the resident’s claims against KCP. The First Circuit therefore reversed the district court’s denial of KCP’s motion to dismiss the specified counts. View "Suny v. KCP Advisory Group, LLC" on Justia Law

In August 2021, the defendant, along with his brother and another accomplice, committed a series of crimes in Puerto Rico, including two carjackings and an armed robbery. During the first carjacking, a firearm was brandished at the victim, and the group later attempted a second carjacking, which was unsuccessful. That same night, the defendant and another individual robbed a bar, during which the defendant fired a gun both outside and inside the establishment. The defendant was arrested the following day, confessed to the attempted carjacking, and admitted to other criminal conduct that night.A grand jury indicted the defendant on two counts of carjacking and two counts of possession and brandishing a firearm in furtherance of a crime of violence. He entered into a plea agreement, pleading guilty to both carjacking counts and one count of possession of a firearm in furtherance of a crime of violence. The plea agreement contained errors regarding the total offense level for the carjacking counts and the maximum supervised release term for the firearm count. The presentence report corrected these errors, and neither party objected. At sentencing, the United States District Court for the District of Puerto Rico imposed sentences above those recommended by the parties, including an upward variance on the firearm count, citing the seriousness of the offenses and the defendant’s conduct.The United States Court of Appeals for the First Circuit reviewed the case. The court held that, although the defendant was misinformed about the supervised release term for the firearm count at the plea hearing, he was later correctly informed and failed to show a reasonable probability that this error affected his decision to plead guilty. The court also found no Rule 11 error regarding the sentencing range for the carjacking counts and concluded that the upwardly variant sentence for the firearm count was procedurally reasonable. The First Circuit affirmed the conviction and sentence. View "United States v. Morales-Ortiz" on Justia Law

Two brothers with developmental disabilities, Gaven and Jared, live with their parents, who are certified to provide in-home care. Both brothers qualified for Maine’s “Single Member Services,” which would allow each to receive one-on-one care from a designated provider. The family requested that each parent be reimbursed for providing care to one brother. However, the Maine Department of Health and Human Services determined that, because the brothers lived together, they were only eligible for “Two Member Services,” meaning a single provider would be reimbursed to care for both, at half the total rate. The parents continued to provide one-on-one care to both brothers, but were only reimbursed for one provider, resulting in a significant financial shortfall.The family challenged this determination in Maine Superior Court, which ruled in their favor, finding that the Department’s interpretation of its rules was arbitrary and inconsistent with its policies. Following this decision, the Department began reimbursing both parents for providing one-on-one care. The family then filed a federal lawsuit seeking damages for the period before the state court’s ruling, alleging discrimination under Title II of the Americans with Disabilities Act (ADA). The United States District Court for the District of Maine dismissed the case, holding that the Department was protected by Eleventh Amendment sovereign immunity.On appeal, the United States Court of Appeals for the First Circuit reversed the district court’s dismissal. The First Circuit held that the Department was not entitled to sovereign immunity because Congress validly abrogated such immunity under Title II of the ADA in this context. The court found that the Department’s policy violated the brothers’ equal protection rights, as there was no rational basis for providing reduced services solely because the brothers lived together. The case was remanded for further proceedings. View "McKenna v. Maine Department of Health and Human Services" on Justia Law