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

The First Circuit reversed the decision of the district court that the prosecutor in the underlying Rhode Island case transgressed the Batson rule in the course of jury selection but that Petitioner was not entitled to habeas corpus relief, holding that the decision of the Rhode Island Supreme Court could not withstand habeas review.Petitioner, a Rhode Island state prisoner and an African-American man who was convicted of murder and other crimes, claimed in his petition for writ of habeas corpus that the prosecutor violated Batson during jury selection. The federal district court concluded that Petitioner's rights under Batson were violated but that the Rhode Island Supreme Court did not abuse its discretion in finding sufficient race-neutral reasons for a peremptory challenge against the juror in question. The First Circuit reversed, holding (1) the prosecutor's explanation for his peremptory strike was not race-neutral on its face and thus violated Batson; and (2) the Rhode Island Supreme Court's decision rested on either an unreasonable application of clearly established federal law, an unreasonable determination of the facts, or both. View "Porter v. Coyne-Fague" on Justia Law

The First Circuit affirmed the judgment of the district court entering summary judgment in favor of Dr. Peter Millett and dismissing Joseph Shea's alleged breach of oral contract action, holding that the statute of frauds barred this Court from enforcing any agreement against Millett so as to require him to pay Shea from July 1, 2016 onward.In 2010, Millett spoke with Shea at a medical conference seeking Shea's help in negotiating a certain deal. Shea understood this conversation to create a binding contract. In 2017, Shea brought this lawsuit asserting that he was owed payments beyond a final payment made on June 30, 2016. The district court entered summary judgment in favor of Millett, concluding that any agreement between the parties was unenforceable under the Massachusetts statute of frauds, Mass. Gen. Laws ch. 259, 1, 7. The First Circuit affirmed, holding that there was no enforceable contract between the parties requiring Millett to pay Shea after June 30, 2016. View "Shea v. Millett" on Justia Law

The First Circuit affirmed the judgment of the district court revoking Defendant's supervised release and adding to the terms of his supervised release a monitoring condition as to Defendant's computer activities to provide him with incentives to comply with the law, holding that the condition was not unwarranted.Defendant pleaded guilty to a twenty-four-count indictment charging him with money laundering, mail and wire fraud, and tax evasion and was sentenced to fifteen-years in prison. After he was released, Defendant stipulated to violating the terms of his supervised release. The district court revoked Defendant's supervised release and imposed several new conditions of supervision, including the condition at issue on appeal. The First Circuit affirmed, holding that the imposition of the computer monitoring condition was not an abuse of discretion. View "United States v. Windle" on Justia Law

The First Circuit affirmed the judgment of the district court sentencing Defendant to a 150-month term of immurement in connection with his plea of guilty to conspiracy to distribute and to possess with intent to distribute controlled substances, holding that there was no breach of the plea agreement in this case.On appeal, Defendant argued that the government breached the parties' agreement to recommend a sentence at the low end of the applicable guideline range and that the alleged breach defeated a waiver-of-appeal provision in the plea agreement. The First Circuit affirmed the judgment below, holding that, under the plain error standard, Defendant failed to show that the prosecutor's overall conduct was other than "reasonably consistent with making [the promised] recommendation." View "United States v. Lessard" on Justia Law

In this climate-change case, the First Circuit once more affirmed the order of the federal district court allowing Rhode Island's motion to return to state court its state court complaint against oil and gas companies for damages caused by fossil fuels, holding that Rhode Island's complaint did not give rise to federal removal jurisdiction.Rhode Island originally brought this complaint in state court, alleging state-law causes of action for, inter alia, public nuisance. After the energy companies removed the case to federal district court Rhode Island moved for the case to be remanded to state court. The district court granted the motion and ordered the case remanded to state court. The First Circuit affirmed the remand order. On certiorari, the Supreme Court instructed that the First Circuit give further consideration in light of recent caselaw. The First Circuit received supplemental briefs and then affirmed once more the judge's remand order, holding that removal based on federal-question jurisdiction and on other jurisdictional and removal statutes was not proper. View "State of Rhode Island v. Shell Oil Products Co., LLC" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing all claims in this dispute between brokerage customers of Defendant, who purchased special Puerto Rico securities during a recession but before the bond market crash, holding that there was no error in the proceedings below.Plaintiffs brought a securities class action against Defendant, asserting claims under federal securities laws and Puerto Rico law. The district court entered judgment dismissing the federal law claims with prejudice and the state law claims without prejudice. The First Circuit affirmed, holding that Plaintiffs' claims that there were allegedly material omissions on the part of Defendant were not actionable. View "Ponsa-Rabell v. Santander Securities, LLC" on Justia Law

The First Circuit affirmed the judgment of the district court concluding that Defendant violated the conditions of his supervised release term and the length of his revocation sentence, holding that any error was harmless.Defendant pleaded guilty to participation in a conspiracy to possess with intent to distribute cocaine and was sentenced to a 120-month term of imprisonment to be followed by a sixty-month term of supervised release. The district court subsequently found that Defendant committed a violation of his supervised release, revoked the supervised release, and sentenced Defendant to a sixty-month term of imprisonment to be followed by a thirty-six month term of supervised release. The First Circuit affirmed, holding (1) even if the admission of certain testimony was error, the error was harmless; and (2) the district court did not clearly or obviously err in imposing the revocation sentence that it did. View "United States v. Cintron-Ortiz" on Justia Law

The First Circuit vacated the judgment of the district court granting summary judgment to Defendants and dismissing Plaintiff's claims challenging the termination of his employment on free speech grounds, holding that summary judgment was improper in this case.Plaintiff, a former bus driver for the Worcester Regional Transit Authority (WRTA), brought this action under 42 U.S.C. 1983 claiming that Defendants violated his right to free speech under the First Amendment to the federal constitution and the Massachusetts Civil Rights Act (MCRA) when they terminated his employment following public comments that he made to a television network about proposed budget cuts to the WRTA. The district court granted summary judgment for Defendants. The First Circuit remanded the case, holding (1) the district court erred in concluding that, as a matter of law, Plaintiff was not speaking "as a citizen" during the television interview; and (2) Defendants did not have an adequate justification for treating Plaintiff differently from other members of the general public by terminating him for his protected speech. View "Bruce v. Worcester Regional Transit Authority" on Justia Law

In this interlocutory appeal, the First Circuit affirmed the judgment of the district court denying Defendant's motion to dismiss this suit pursuant to both the Eleventh Amendment and the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA), 48 U.S.C. 2101 et seq., holding that the district court did not err.The plaintiff in this case was the Centro de Periodismo Investigativo (CPI), a non-profit media organization based in Puerto Rico. Plaintiff sued the Financial Oversight and Management Board for Puerto Rico, alleging that the Board improperly ignored their requests for documents or provided less than complete responses in violation of P.R. Const. 4. The Board moved to dismiss the claim for lack of subject-matter jurisdiction and for failure to state a claim. The district court denied the motion. The First Circuit affirmed, holding that Defendants were not entitled to Eleventh Amendment sovereign immunity. View "Centro de Periodismo Investigativo, Inc. v. Financial Oversight & Management Board for Puerto Rico" on Justia Law

The First Circuit affirmed the order of the district court entering summary judgment in favor of RentGrow, Inc. and dismissing Plaintiff's complaint alleging that RentGrow willfully violated the Fair Credit Reporting Act (FCRA), 15 U.S.C. 1681-1681x, holding that summary judgment was properly granted.Plaintiff commenced a civil action in the United States District Court for the District of Massachusetts, sued on her own behalf and as the representative of a putative class of similarly situated persons, alleging that Defendant was liable for both negligent and willful noncompliance with the FCRA. The district court entered summary judgment in Defendant's favor, denied class certification, and dismissed the action. The First Circuit affirmed, holding that Plaintiff did not meet her burden of adducing competent evidence sufficient to prove each and every element of her claim. View "McIntyre v. RentGrow, Inc." on Justia Law