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

The First Circuit affirmed the judgment of the district court ruling for the government on its complaint seeing to obtain a judgment against Monica Toth for failing to pay an ordered penalty holding that there was no error.In 2013, the IRS assessed a civil penalty against Toth in consequence of her failure to comply with the reporting requirements of the Bank Secrecy Act in connection with her Swiss bank account. Toth refused to pay the penalty of the maximum allowable set forth in the Act, and the government filed suit. The district court granting summary judgment in favor of Toth. The First Circuit affirmed, holding that Toth was not entitled to relief on any of her proffered grounds for overturning the summary judgment against her. View "United States v. Toth" on Justia Law

The First Circuit reversed the order of the district court granting summary judgment against Plaintiffs in this medical malpractice suit brought under the Federal Tort Claims Act (FTCA), see 28 U.S.C. 1346(b), 2671-2680, holding that summary judgment was inappropriate.Noel Martinez-Marrero died while being treated at the United States Department of Veterans Affairs Medical Center. His four children brought suit against the United States in the District of Puerto Rico pursuant to the FTCA, alleging medical negligence. The district court granted summary judgment in favor of Defendants after excluding the expert testimony of Dr. Ortiz Feliciano. The First Circuit reversed and remanded the case for further proceedings, holding that the district court erred in excluding Dr. Feliciano's expert testimony pursuant to Fed. R. Evid. 702 and Fed. R. Civ. P. 26. View "Martinez v. United States" on Justia Law

The First Circuit affirmed the grant of summary judgment against Eulalia Lopez-Ramirez (Lopez) in the medical malpractice suit that she and her daughter brought under Puerto Rico law, holding that Plaintiffs' allegations of error were unavailing.Plaintiffs brought this suit seeking damages in connection with the brain surgery that was performed on Lopez to alleviate her facial spasms. After the surgery, Lopez developed full right facial paralysis. Plaintiffs claimed that Defendants' negligence in providing medical care to Lopez made them liable under Puerto Rico Laws title 31, Section 5141 and 5142. The district court granted summary judgment for Defendants. The First Circuit affirmed, holding that Plaintiffs' allegations of error were unavailing. View "Lopez-Ramirez v. Centro Medico del Turabo, Inc." on Justia Law

The First Circuit affirmed in part and reversed in part the grant of summary judgment against Blackstone Headwaters Coalition in this citizen suit brought against various defendants involved in the development of a construction site, holding that North and South Rivers Watershed Ass'n v. Town of Scituate, 949 F.2d 552 (1st Cir. 1991), construed the scope of 33 U.S.C. 1319(g)(6)(A)'s limitation on citizen suits too broadly.In Scituate, a First Circuit panel held that the limitation on citizen suits established by 33 U.S.C. 1319(g)(6)(A) precludes a citizen suit that seeks to obtain declaratory or prospective injunctive relief from a violation of the Clean Water Act (CWA), 33 U.S.C. 1251 et seq. In the instant case, a panel of the Court relied on Scituate to affirm the district court's grant of summary judgment against Blackstone. The Court then reconsidered its decision in Scituate, vacated the panel opinion in this case, and reversed the grant of summary judgment in part, holding that, contrary to Scituate, the limitation set forth in section 1319(g)(6)(A) bars only a citizen suit that seeks to apply a civil penalty for an ongoing violation of the CWA and does not bar a citizen suit for declaratory and prospective injunction relief to redress an ongoing violation of the CWA. View "Blackstone Headwaters Coalition v. Gallo Builders, Inc." on Justia Law

The First Circuit affirmed the decision of the district court denying motion for a preliminary injunction sought by Appellants, then-employees of Mass General Brigham, Inc. (MGB), to stop their employer's application of its mandatory COVID-19 vaccination policy to them, holding that the district court did not err.In November 2021, Appellants bought this action. The district court denied a preliminary injunction. Appellants then noticed an appeal and also sought emergency injunctive relief from the First Circuit. The First Circuit held that they had not met the requirements for an injunction pending appeal. Now that the merits of Appellants' appeal were before the Court, the First Circuit affirmed the denial of a preliminary injunction, holding that the district court correctly denied relief. View "Together Employees v. Mass General Brigham Inc." on Justia Law

The First Circuit affirmed the judgment of the court charged with overseeing proceedings under Title III of the Puerto Rico Oversight, Management, and Economic Stability Act confirming a plan of adjustment for the debts of the Commonwealth of Puerto Rico and two of its instrumentalities, holding that there was no error or abuse of discretion.In this case arising out of the effort to restructure the Commonwealth's sovereign debt under Title IIII, various organizations that represented some public school teachers and educators participating in the Commonwealth's pension system objected to the manner in which the plan of adjustment handled their claims to current and future pension payments. The Title III court approved the plan of adjustment over Appellants' objections. The First Circuit affirmed, holding that Appellants' arguments on appeal failed. View "Financial Oversight & Management Board for Puerto Rico v. Federacion de Maestros de Puerto Rico, Inc." on Justia Law

The First Circuit affirmed Defendant's sentence for maintaining a drug-involved premises, holding that the sentence was not unreasonable.Defendant pleaded guilty to maintaining a drug-involved premises. The trial court imposed an eighty-six-month term of immurement, reflecting a two-level downward variance for Defendant's agreement to be sentenced remotely and another two-level downward departure requested by the government. On appeal, Defendant challenged the district court's denial of an offense-level reduction for acceptance of responsibility. The First Circuit affirmed, holding (1) it was not clearly erroneous for the district court to find that Defendant's conduct warranted the denial of an acceptance-of-responsibility adjustment; and (2) the district court did not clearly err in balancing the relevant factors when performing the acceptance-of-responsibility analysis. View "United States v. McCarthy" on Justia Law

The First Circuit vacated the judgment of the district court dismissing this complaint alleging a First Amendment claim and seeking a preliminary injunction, holding that Plaintiffs plausibly alleged a First Amendment violation.At issue was the electronic case filing system piloted by the Maine Supreme Judicial Court (SJC) for the state's trial courts, which resulted in delayed access. Plaintiffs, state and federal news agencies, sued Defendants, state court officials, alleging violations of their First Amendment rights. Thereafter, the SJC changed its rules. The district court held that Plaintiffs had failed to state a claim, dismissed the complaint, and denied the motion for a preliminary injunction as moot. The Supreme Court reversed, holding that Plaintiffs plausibly alleged a First Amendment violation. View "Courthouse News Service v. Quinlan, Bangor Publishing Co., Inc." on Justia Law

The First Circuit affirmed Defendant's conviction of possession with intent to distribute forty grams or more of fentanyl, holding that the district court did not err in denying Defendant's motion to suppress evidence seized during a stop and warrantless search of his vehicle.After Defendant was indicted he filed a motion to suppress the evidence obtained a result of the stop and search in this case. The district court denied the motion and found Defendant guilty. On appeal, Defendant argued that the district court abused its discretion in failing to hold an evidentiary hearing on his motion to suppress and that, alternatively, the district court erred in denying his motion to suppress because he was de facto placed under arrest without probable cause. The First Circuit affirmed, holding (1) if there was an arrest it was a lawful one; and (2) no evidentiary hearing was necessary in this case. View "United States v. Batista" on Justia Law

The First Circuit vacated Defendant's sentence and remanded the case for resentencing, holding that the district court incorrectly found that Defendant's prior conviction in a Puerto Rico court for attempted aggravated burglary was a conviction for a crime of violence within the meaning of the United States Sentencing Guidelines sections 2K2.1(a)(4)(A) and 4B1.2(a).Defendant pleaded guilty to being a felon in possession of a firearm. The district court sentenced him to thirty months' imprisonment. Defendant challenged the enhancement of his sentence on appeal. The government conceded that Defendant's Puerto Rico conviction was not one of the enumerated offenses in the Guidelines' definition of "crime of violence" but argued that the error was harmless. The Supreme Court vacated the sentence and remanded for resentencing, holding that Defendant was prejudiced by the trial court's error. View "United States v. Velez-Vargas" on Justia Law