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

The First Circuit dismissed Appellant's appeal from his mandatory minimum sixty-month sentence, holding that Appellant knowingly and voluntarily agreed to an appeal waiver, barring this appeal.Pursuant to a written agreement, Appellant pleaded guilty to one count of conspiracy to possess with intent to distribute cocaine. The sentencing court sentenced Defendant to sixty months' imprisonment and eight years of supervised release. Appellant appealed, stating that enforcing his appeal waive would work a miscarriage of justice. The First Circuit dismissed the appeal, holding that even if Appellant hadn't waived his argument on appeal, there was no miscarriage of justice. View "United States v. Candelario-Ramos" on Justia Law

In this dispute between Boston Executive Helicopters (BEH) and the Town of Norwood, the First Circuit affirmed in part and reversed in part the judgment of the district court denying BEH's motions to enforce the parties' settlement agreement as construed by BEH and to rescind the settlement agreement, holding that Norwood breached one provision of the settlement agreement.The settlement agreement at issue temporarily resolved the parties' dispute, but BEH later moved the district court to enforce the agreement as construed by BEH. On appeal from the district court's denial of the motion, BEH filed a motion to rescind the settlement agreement or, in the alternative, to reconsider its denial of the motion to enforce. The district court denied the requests. The First Circuit largely affirmed, holding (1) remand was required for consideration of BEH's motion for enforce the agreement as it pertained to one issue; and (2) otherwise, the district court's judgment was without error. View "Boston Executive Helicopters, LLC v. Maguire" on Justia Law

The First Circuit affirmed in part and vacated in part the judgment of the district court granting Edge Pharma, LLC's motion to dismiss for failure to state a claim the allegations brought by Azurity Pharmaceuticals, Inc. under both the Lanham Act and Mass. Gen. Laws ch. 93A based on statements that Edge made on its website, holding that Azurity's claims cannot survive.Azurity's suit alleged that the statements at issue falsely represented that Edge was not in violation of the Food, Drug, and Cosmetic Act (FDCA) and that the statements falsely held out Edge's vancomycin drug as being superior to Azurity's. The district court concluded that the FDCA precluded Azurity's Lanham Act claim, which meant that the Chapter 93A likewise failed "as it is premised on the same allegations" as the Lanham Act claim. The First Circuit held (1) the district court properly dismissed the Lanham Act claim on the alternative ground that Azurity did not plausibly allege that some of the statements made a misleading representation of fact and that other statements at issue were in violation of the Lanham Act; and (2) insofar as no variant of Azurity's Lanham Act claim could survive, for the same reasons this Court vacates and affirms in part the dismissal of Azurity's Chapter 93A claim. View "Azurity Pharmaceuticals, Inc. v. Edge Pharma, LLC" on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment in favor of the Town of Brookline and its Selectmen and dismissing Plaintiffs' claims of unconstitutional mistreatment by the Town's "deliberate indifference" to complaints of racial discrimination by Brookline police, holding that Plaintiffs' claims on appeal were unavailing.The five named plaintiffs here claimed that Brookline police officers violated their rights under the Equal Protection Clause by treating them differently because they are Hispanic. The district court granted summary judgment for Defendants. The First Circuit affirmed, holding that the record evidence did not support a finding of deliberate indifference. View "Baez v. Town of Brookline, Mass." on Justia Law

In this dispute over an award of attorneys' fees under 42 U.S.C. 1988, the First Circuit identified only one defect in the award, thus vacating the existing fee award in the amount of $20,243 and remanding to the district court to enter a modified fee award in the amount of $18,218, holding that the district court abused its discretion in part.The underlying case revolved around a parcel of real property in Puerto Rico formerly owned by Plaintiff. Defendants, including the Puerto Rico Highway and Transportation Authority, moved for summary judgment for Plaintiff's failure to seek just compensation in the Puerto Rico courts before raising a federal takings claim. The district court granted the motion. As to attorney's fees, the district court found that the federal takings claim was frivolous and awarded payment of fees in the amount of $20,243. The First Circuit vacated the award, holding that the time expended in connection with a non-frivolous supplemental tort claim should have been deducted from the fee award. View "Efron v. Mora Development Corp." on Justia Law

The First Circuit affirmed the order of the federal district court rejecting a challenge to the ruling by a Maine Department of Education hearing officer that the Falmouth School District violated the Individuals with Disabilities Act (IDEA), holding that the district court's challenged rulings were not in error.The hearing officer in this case concluded that Falmouth was required to reimburse the Does for the cost of their son's tuition at a private school because their son had been denied a free appropriate public education during the time periods in question. Falmouth brought this action under the IDEA, challenging the hearing officer's rulings. The Does answered and brought counterclaims against Falmouth under the Rehabilitation Act and Americans With Disabilities Act. The district court granted judgment to the Does and then dismissed the counterclaims. The First Circuit affirmed, holding that the district court did not err or abuse its discretion in the proceedings below. View "Falmouth School Dep't v. Doe" on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment in favor of Defendants and dismissing Plaintiffs' hybrid breach of contract and fair representation claim, their Takings Clause claim, and their claim for declaratory relief, holding that there was no error or abuse of discretion.Plaintiffs, five sergeants in the City of Cranston Police Department, brought this lawsuit against the City of Cranston, the International Brotherhood of Police Officers, Local 301 (the Union), and Matthew Josefson. Plaintiffs were promoted to the rank of sergeant during the time period between Josefson's demotion and reinstatement and then, after Josefson's reinstatement, moved down one position in sergeant rank seniority. Plaintiffs brought suit, alleging several claims. The district court granted summary judgment for Defendants on all claims. The First Circuit affirmed, holding that Plaintiffs' claims failed. View "Barth v. City of Cranston" on Justia Law

The First Circuit vacated Defendant's conviction of attempting to persuade, induce, or entice a minor to engage in criminal sexual activity, holding that the trial was tainted by the erroneous limitation of Defendant's expert testimony.On appeal, Defendant argued that the evidence was constitutionally insufficient to convict him of the charged crimes and that the district court erred in barring his expert witness from testifying about whether Defendant's actions fit the mold of a sexual predator. The First Circuit vacated the judgment below, holding that the district court (1) did not err in denying Defendant's motion for a judgment of acquittal; but (2) erroneously excluded a portion of the testimony of Defendant's proposed expert, and the error was not harmless. View "United States v. Soler-Montalvo" on Justia Law

The First Circuit denied Petitioners' petition for review in this action challenging a final rule promulgated by the Drug Enforcement Administration (DEA) that set the framework through which applicants may register to lawfully manufacture and cultivate cannabis for research purposes, holding that Petitioners were not entitled to relief on their claims.Petitioners - Dr. Lyle Craker, a botany professor, and Scottsdale Research Institute (SRI), a clinical research company - brought this action raising two perceived procedural defects with the DEA's notice of proposed rulemaking that would demand that the final rule be set aside. The First Circuit denied relief, holding (1) Petitioners were not entitled to relief on their claim that the APA required the DEA to include more detail about the legal basis of the proposed rule; (2) the proposed rule did not exceed the DEA's rulemaking authority; (3) Petitioners' challenge to the DEA's definition of "medicinal cannabis" was unavailing; and (4) the DEA's new regulatory framework for registrations was not arbitrary, capricious, or otherwise contrary to law. View "Craker v. U.S. Drug Enforcement Administration" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing this complaint against Karoypharm Therapuetics, Inc. and its corporate officers (collectively, Defendants) alleging securities fraud in violation of sections 10(b) and 20(a) of the Securities Exchange Act, 15 U.S.C. 78j(b) and 78t(a), and Securities and Exchange Commission (SEC) Rule 10-b, 18 C.F.R. 240.10b-5, holding that the district court correctly dismissed the complaint for failure to state a claim.Plaintiff-investors brought this action following a decline in Karyopharm's stock price, alleging that Karyopharm materially misled them as to the safety and efficacy of the company's cancer-fighting drug candidate selinexor. The district court dismissed the complaint for failure to state a claim, concluding that Plaintiffs failed adequately to plead scienter with respect to Defendants' statements about a certain study of the drug as a treatment for pinta-refractory multiple myeloma. The First Circuit affirmed on other grounds, holding that Plaintiffs did not plausibly allege an actionable statement or omission with respect to the trial disclosures, and therefore, dismissal was appropriate. View "Thant v. Karyopharm Therapeutics Inc." on Justia Law