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

The First Circuit vacated the district court's grant of summary judgment in this mortgage dispute, holding that the district court abused its discretion in denying Appellants' motion to defer the adjudication of a pending motion for summary judgment and proceeding to grant summary judgment.At is on appeal in this dispute that stretched over more than a decade and implicated several lawsuits was whether the district court abused its discretion in denying Appellants' motion for discovery under Fed. R. Civ. P. 56(d) and then granting summary judgment against them. The First Circuit answered the question in the affirmative, holding that the district court abused its discretion in denying Appellants' Rule 56(d) motion in its totality. The Court remanded this case for further proceedings. View "Emigrant Residential LLC v. Pinti" on Justia Law

The First Circuit upheld the judgment of the district court denying Defendant's motion to dismiss the indictment against him and convicting Defendant of interstate violation of a protection order under 18 U.S.C. 2262(a)(1), holding that no-contact and stay-away provisions in a conditional release order may constitute a "protection order" as defined by the Violence Against Women Act of 1994 (VAWA), 108 Stat. 1796, 1902.Defendant was charged with the felony assault of T.N. A state-court judge issued a conditional release order following a bail hearing that included a no-contact provision with T.N. The assault charge was later dismissed due to T.N.'s death. Three years later, a federal grand jury returned an indictment charging Defendant with two counts of interstate violation of a protection order. Defendant filed a motion to dismiss on the grounds that the conditional release order was not a "protection order" as defined under 18 U.S.C. 2266(5). The district court denied the motion to dismiss. The First Circuit affirmed, holding that the no-contact and stay-away provisions in a conditional release order may, under certain circumstances, satisfy the VAWA's definition of a "protection order" as defined in section 2266(5). View "United States v. Dion" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's petition for habeas corpus, in which he alleged ineffective assistance of counsel, holding that Appellant failed to establish that his counsel's performance was deficient under Strickland v. Washington, 466 U.S. 668 (1984).After a retrial, Appellant was convicted of two counts of attempting to kill a federal witness with intent to prevent testimony and communication with law enforcement. The First Circuit affirmed. Appellant later filed a motion under 28 U.S.C. 2255 to vacate his conviction based on ineffective assistance of counsel. The district court denied relief. The First Circuit affirmed, holding that Appellant's claims of ineffective assistance of counsel were unavailing. View "Watson v. United States" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment in favor of Acadia Insurance Company in this action brought by Railroad Avenue Properties, LLC for breach contract to recover additional insurance proceeds for property damage sustained from a fire at one of Railroad's commercial buildings, holding that there was no error.Although Acadia insured the building at issue and paid Railroad for damages arising out of the fire Railroad claimed that it was entitled to additional payment under the terms the insurance policy in the form of a depreciation holdback and code upgrade coverage. The district court granted summary judgment for Acadia. The First Circuit affirmed, holding that Railroad was not entitled to relief on any of its allegations of error. View "Railroad Avenue Properties, LLC v. Acadia Insurance Co." on Justia Law

The First Circuit granted a petition for review of a ruling by the Board of Immigration Appeals (BIA) that affirmed the final order of removal entered against Petitioner pursuant to 8 U.S.C. 1229-1229a and vacated the BIA's ruling,Petitioner conceded removability but sought relief from removal based on asylum and withholding of removal, as well as the Convention Against Torture (CAT). The immigration judge (IJ) denied the applications, and the BIA affirmed. The First Circuit vacated the BIA's ruling in part, holding (1) Petitioner was not entitled to relief on his assertion of bias; and (2) because the BIA upheld an adverse credibility determination that the IJ reached in part based on an inconsistency in Petitioner's story that simply was not an inconsistency, the BIA's ruling affirming the IJ's denial of that claim must be vacated. View "Pujols v. Garland" on Justia Law

The First Circuit affirmed in part and reversed in part the judgment of the district court dismissing Plaintiff's complaint against Harvard University for breach of contract and other related claims, holding that the district court erred in dismissing Plaintiff's breach of contract claim.The day before Plaintiff was about to graduate from Harvard three female Harvard students accused him of sexual assault. Following a disciplinary hearing, Harvard withheld Plaintiff's undergraduate degree. Plaintiff sued, and the district court dismissed the complaint for failure to state a claim. The First Circuit reversed in part, holding (1) at the pleadings stage, Plaintiff's allegations, taken as true, stated a plausible breach of contract claim; and (2) the district court properly dismissed the remaining counts of Plaintiff's complaint. View "Sonoiki v. Harvard University" on Justia Law

The First Circuit denied a writ of habeas corpus sought by Petitioner under 28 U.S.C. 2254 to vacate her conviction for murder in the first degree, holding that there was no error.Petitioner was convicted of first-degree murder based on deliberate premeditation and extreme atrocity or cruelty and was sentenced to life imprisonment without the possibility of parole. Petitioner later filed a habeas petition claiming ineffective assistance of counsel. The district court denied the petition. The First Circuit affirmed, holding that there was no prejudice on any of the alleged errors claimed by Petitioner. View "Field v. Hallett" on Justia Law

Watkins was convicted of first-degree murder in Massachusetts state court in 2005 for a fatal 2003 shooting. The Supreme Judicial Court affirmed his conviction. His federal habeas petition was denied.The First Circuit affirmed the denial of relief. The state courts made an error of fact in their decisions, rejecting a “Brady” claim that a withheld a police report could have been used for the impeachment of a witness (Rudolph), finding that the report did not show the investigating officers were aware that Rudolph was a witness against Watkins. Under the Antiterrorism and Effective Death Penalty Act's deferential standard of review or applying de novo review, Watkins has not shown prejudice arising from the error or with respect to any of his other claims. There was an extensive examination of bias, and the failure to add onto any such evidence hardly would be prejudicial. Rudolph's motivation for reaching out to the police and the agreement that Rudolph later reached with the Commonwealth were discussed at trial and clearly informed Watkins and the jury that Rudolph sought an incentive in return for his cooperation and testimony. View "Watkins v. Medeiros" on Justia Law

The Court of Appeals of the First Circuit affirmed Defendant's conviction of two counts of committing a hate crime and one count of conspiring to commit a hate crime under the Matthew Shepard and James Byrd Jr, Hate Crimes Prevention Act, 18 U.S.C. 249(a)(1), 371, holding that there was no error or abuse of discretion.Specifically, the First Circuit held (1) section 259(a)(1) does not implicate federalism concerns; (2) certifications made under 249(b) are exempt from judicial review, and therefore, Defendant's challenge to the certification of his prosecution failed; and (3) Defendant's remaining assignment of error was waived. View "United States v. Diggins" on Justia Law

The First Circuit certified to the Massachusetts Supreme Judicial Court (SJC) a question regarding whether Massachusetts recognizes a common-law duty for insurers to cover costs incurred by an insured party to prevent imminent covered loss.Ken's Foods incurred extensive losses from an accidental discharge at one of its processing facilities caused wastewater to enter Georgia waterways. Ken's Foods filed a claim with Steadfast Insurance Company seeking clean-up expenses and business losses resulting from a "pollution event" that cause a "suspension of operations." When Steadfast refused to reimburse Ken's Foods for the cost of its prevention efforts Ken's Foods sued in Massachusetts federal court. At issue was whether Ken's Foods could recover from Steadfast the costs it incurred to avoid suspending its operations after the pollution discharge. The district court granted summary judgment for Steadfast. The First Circuit concluded that certification was necessary and certified to the SJC the issue. View "Ken's Foods, Inc. v. Steadfast Insurance Co." on Justia Law