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

The First Circuit affirmed the order of the Title III court confirming a plan of adjustments for the debts of the Commonwealth and two of its instrumentalities in this action brought under the Title III of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA), holding that otherwise valid Fifth Amendment takings claims arising pre-petition cannot be discharged in Title III bankruptcy proceedings without payment of just compensation.After the court charged with overseeing Title III proceedings confirmed the plan of adjustment at issue several stakeholders brought appeals challenging aspects of the court's confirmation order. At issue was the appeal of the Financial Oversight and Management Board of Puerto Rico challenging the Title III court's conclusion that claimants owed just compensation for the taking of real property by debtors were entitled to receive satisfaction in full for on their claims. The First Circuit affirmed the Title III court's order confirming the plan, holding that discharging valid, pre-petition takings claims for less than just compensation would violate the Fifth Amendment and render a plan providing for such discharge unconfirmable under PROMESA. View "Financial Oversight & Management Board v. Cooperativa de Ahorro y Credito" on Justia Law

The First Circuit affirmed the judgment of the district court resentencing Defendant while applying two sentencing enhancements under the United States Sentencing Guidelines, holding that both enhancements applied.Defendant, a former supervising pharmacist at the New England Compounding Center (NECC), was convicted for his conduct in connection with a criminal investigation into a 2012 deadly nationwide outbreak of fungal meningitis that was traced to the NECC's shipments of contaminated drugs. The district court sentenced Defendant to a term of imprisonment of ninety-six months. On appeal, the First Circuit vacated and remanded Defendant's sentence. On remand, the district court held that two enhancements applied to Defendant and resentenced him to a 126-month term of imprisonment. The First Circuit affirmed, holding that the district court did not err in applying the two enhancements. View "United States v. Chin" on Justia Law

The First Circuit affirmed the judgment of the district court finding Defendants liable for failing to pay all of the wages owed to Plaintiff, their former employee, holding that there was no error in the district court's evidentiary decisions.On appeal, Defendants argued that the district court erred in excluding evidence that Plaintiff was accused of rape just months before he began to pursue the wage claims at issue and that the district court erred in admitting testimony, along with documentary evidence, from one of Plaintiff's former colleagues. The First Circuit affirmed, holding that the challenged evidentiary decisions at issue - one to exclude evidence and the other to admit evidence - were proper and did not require remand for a new trial. View "Gonpo v. Sonam's Stonewalls & Art, LLC" on Justia Law

The First Circuit reversed the order of the district court denying Defendant's motion for summary judgment as to Plaintiff's whistleblower retaliation claim brought under section 1514A of the Sarbanes-Oxley Act, holding that Plaintiff could not satisfy his burden of bringing a claim for whistleblower retaliation under section 18 U.S.C. 1514A.Plaintiff, a former employee of Defendant, sued Defendant for whistleblower retaliation under section 1514A, but his particular whistleblower claim was based on an alleged violation of 15 U.S.C. 78m(b)(2), (5). Defendant moved for summary judgment following the completion of discovery, arguing that Plaintiff's action did not fall within any of the definitions of protected activity under section 1514A. The district court denied the motion as to the whistleblower retaliation claim. The First Circuit reversed and remanded with instructions to enter summary judgment in favor of Defendant, holding that Plaintiff's conduct was not "protected activity" under section 1514A. View "Baker v. Smith & Wesson, Inc." on Justia Law

The First Circuit affirmed Defendant's convictions for unlawfully possessing firearms and ammunition as a convicted felon and for unlawfully possessing a firearm with an obliterated serial number, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that the district court abused its discretion when it qualified Special Agent Israel Valle with the Bureau of Alcohol, Tobacco, Firearms and Explosives as an expert under Fed. R. Evid. 702 on whether the ammunition and firearms charged in the indictment had traveled in interstate commerce. The First Circuit disagreed and affirmed, holding (1) the district court did not abuse its discretion in ruling that Special Agent Valle was qualified to testify as an expert; and (2) Defendant's additional pro se arguments were without merit. View "United States v. Cortez-Oropeza" on Justia Law

In this dispute between the Maine lobster industry and the National Marine Fisheries Service (the Agency) over a rule barring frequently employed methods of lobstering the First Circuit lifted its issuance of a preliminary injunction and remanded the case for further proceedings, holding that Plaintiffs were unlikely to succeed on the merits of their claim.Plaintiffs, a union of oyster fishers and fishing companies, challenged a regulation issued by the National Marine Fisheries Service in August 2021 that prohibited lobster fishing with vertical buoy lines in certain areas during certain times of year. After the district court granted a preliminary injunction enjoining enforcement of the seasonal disclosure, the government and conservation grounds sought a stay of the order. The First Circuit first stayed the preliminary injunction and then vacated the injunction, holding that Plaintiffs were unlikely to succeed on the merits of their claim. View "District 4 Lodge of the International Ass'n v. Raimondo" on Justia Law

The First Circuit affirmed the district court's judgmentsentencing Defendant to a 188-month term of imprisonment for his conviction of conspiracy to distribute and to possess with intent to distribute on kilogram or more of heroin and 400 grams or more of fentanyl, holding that Defendant's claims did not survive scrutiny.In his complaint, Defendant argued that the district court mistakenly attributed to him the entirety of the drugs found in an apartment used by him and his coconspirators, and (2) the court erred applying the "stash house" enhancement. The First Circuit affirmed, holding (1) the evidence was sufficient to show that Defendant bore responsibility for the drugs in the apartment; and (2) the "stash house" enhancement was appropriately applied in this case. View "United States v. Soto-Villar" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's habeas petition, holding that the Massachusetts state court reasonably applied federal law in deeming the Commonwealth's proof constitutionally adequate.After a jury trial, Defendant was convicted of first-degree murder on a theory of felony murder based on a predicate of armed robbery and sentenced him to a term of life imprisonment on the felony murder charge. The Massachusetts Supreme Judicial Court (SJC) affirmed the conviction. Petitioner sought federal habeas review in the federal district court. The district court denied the petition. The First Circuit affirmed, holding that the district court did not err in denying Appellant's application for habeas relief. View "Webster v. Gray" on Justia Law

The First Circuit denied an emergency stay sought by Plaintiffs of a disclosure order in this challenge to the Maine vaccine mandate for healthcare workers as it stood on October 19, 2021, holding that Plaintiffs were not entitled to the stay.For this first ten months of this case Plaintiffs were allowed to proceed under pseudonyms. Upon a motion by intervenor press/media organizations, the district court ordered Plaintiffs to file an amended complaint identifying by name the individual plaintiffs, finding that Plaintiffs did not meet their burden of rebutting the presumption against parties proceeding under pseudonyms. Plaintiffs filed an appeal from the disclosure order and sought an emergency stay of that order until resolution of their appeal on the merits. The First Circuit denied the stay, holding that the public interest and the media intervenors' interests weighed in favor of denying the stay due to the presumption of public access. View "Does v. Mills" on Justia Law

In this lawsuit challenging both the residency and voter-registration requirements under Maine law the First Circuit affirmed the order issuing a preliminary injunction preventing the residency requirement and voter-registration requirement from being enforced, holding that there was no error.In 2020, Plaintiffs brought this action against the Secretary of State of Maine and the Deputy Secretary of State of Maine for the Bureau of Corporations in their official capacities, alleging that, by restricting who may be a circulator, Maine's residency and voter-registration requirements violate the First Amendment, as incorporated against the states by the Due Process Clause of the Fourteenth Amendment. The district court granted Plaintiffs' request for a preliminary injunction. The First Circuit affirmed, holding that Plaintiffs established that they were likely to succeed on the merits of their claims. View "We The People PAC v. Bellows" on Justia Law