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

The First Circuit affirmed the order of the district court granting summary judgment in favor of Defendant, his former employer, and dismissing Plaintiff's complaint alleging that Defendant terminated his employment because of his age and because he received a liver transplant, holding that the district court did not err.Plaintiff filed a complaint alleging disability discrimination under the Americans With Disabilities Act (ADA) and age discrimination under the Age Discrimination in Employment Act (ADEA). The district court granted summary judgment for Defendant and dismissed the complaint. The First Circuit affirmed, holding that the evidence on the record did not support either Plaintiff's ADA claim or his ADEA claim. View "Lahens v. AT&T Mobility Puerto Rico, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court granting the separate post-verdict motions for judgment of acquittal filed by the two defendants in this case, Eddie Guerrero-Narvaez and Kayvan Cartagena-Suarez, holding that there was no error.After a jury trial, Defendants were convicted of aiding and abetting each other in the commission of a carjacking. Defendants subsequently filed separate post-verdict motions for judgment of acquittal. The district court granted Guerrero-Narvaez's motion, ruling that no reasonable trier of fact could find from the evidence presented at trial that Guerrero-Narvaez possessed the requisite specific intent to violate the federal carjacking statute. The court then granted Cartagena-Suarez's motion as well. The government appealed. The First Circuit affirmed, holding that the evidence did not support the jury's conclusion that Cartagena-Suarez possessed the necessary intent. View "United States v. Guerrero-Narvaez" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Plaintiff's defamation complaint, holding that the district court properly dismissed the complaint.Plaintiff brought this action against Defendant, a moderator of of a neighborhood online forum who had copied the forum's discussion threats and reposted them to a new online platform. Plaintiff sued for defamation under Massachusetts law and copyright infringement. The district court granted Defendant's motion to dismiss for failure to state a claim. The First Circuit affirmed, holding that the district court properly ruled that Defendant established two affirmative defenses to Plaintiff's claims: (1) as to the defamation claim, immunity from liability under section 230 of the Communications Decency Act; and (2) as to the copyright claim, fair use. View "Monsarrat v. Newman" on Justia Law

The First Circuit affirmed the order of the district court entering summary judgment in favor of Defendant and dismissing Plaintiff's claims for fraud, civil conspiracy, breach of fiduciary duty, and unjust enrichment, holding that Plaintiff failed to make a sufficient showing on essential elements of her case.In 2014, Plaintiff sold her special limited partnership interests in an affordable housing property for $1.5 million. In 2016, the property sold for $11.7 million. Plaintiff brought this lawsuit alleging claims for civil conspiracy, fraud, unjust enrichment, and breach of fiduciary duty, alleging that she was fraudulently led to believe that Defendant had power over the property and would block any attempt to sell or refinance it. The district court entered summary judgment for Defendant. The First Circuit affirmed, holding (1) Plaintiff failed to establish that Defendant intentionally misrepresented the value of the property and Plaintiff's special interest; and (2) Plaintiff's remaining causes of action were unsuccessful in the absence of wrongdoing or foreseeable damages. View "Katz v. Belveron Real Estate Partners, LLC" on Justia Law

The First Circuit affirmed Appellant's plea of guilty to one count of investment adviser fraud, four counts of wire fraud, and one count of aggravated identity theft, holding that there was no prejudicial error in the proceedings below.On appeal, Appellant argued that her plea was not knowing and voluntary, that the evidence was insufficient to convict her of wire fraud and aggravated identity theft, that several sentencing enhancements were improperly applied, and that her counsel was ineffective. The First Circuit affirmed, holding (1) there was no error in the district court's acceptance of Appellant's guilty plea; (2) Appellant's conduct clearly satisfied the statutory requirements for wire fraud and aggravated identity theft; and (3) Appellant's challenges to several aspects of her sentence were unavailing. View "United States v. Kitts" on Justia Law

The First Circuit affirmed Defendant's sentence for being a felon in possession of a firearm, holding that the district court did not err in its application of the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e)(1) and in its imposition of a mandatory fifteen-year sentence.Defendant pled guilty to a felon in possession charge. The district court concluded that, due to his four prior Maine burglary convictions, Defendant qualified for the ACCA's enhanced mandatory minimum penalty, and sentenced Defendant to fifteen years' imprisonment. The First Circuit affirmed, holding (1) the district court did not err in applying the ACCA to Defendant based on his prior burglary convictions in Maine; and (2) this Court declines to overturn its prior decision in United States v. Duquette, 778 F.3d 314 (1st Cir. 2015), and its application of the categorical approach to the statute at issue here. View "United States v. Bowers" on Justia Law

The First Circuit affirmed in part and reversed in part the district court's grant of summary judgment in favor of Defendant on Plaintiff's federal and Massachusetts state law employment discrimination claims, holding that that court erred in granting summary judgment as to several of Plaintiff's claims.Plaintiff, a former employee of Defendant, an online home furnishings company with a principal place of business in Massachusetts, sued Defendant bringing claims under both Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq., and Mass. Gen. Laws ch. 151B, 4.1, 4.4, and 4.4A. The district court granted summary judgment for Defendant on all claims. The First Circuit reversed in part, holding that the district court (1) correctly granted summary judgment to Defendant on Plaintiff's state and federal claims for failing to remedy sexual harassment; and (2) erred in granting summary judgment to Defendant on Plaintiff's remaining claims. View "Forsythe v. Wayfair, LLC" on Justia Law

The First Circuit reversed the order of the district court ordering the release of sealed archival records of certain grand jury proceedings and its judgment in favor of historian and Petitioner Jill Lepore, holding that the federal court did not have the authority to order the release of the grand jury records.As research on a book she was writing, Petitioner filed a Freedom of Information Act request seeking the release of sealed archival records of grand jury proceedings from 1971 that were held to consider possible criminal charges arising out of the publication of excerpts from the "Pentagon Papers," a government study of the Vietnam War. The district court ultimately ordered the records released. The First Circuit reversed, holding that the court erred in holding that it had the authority to order the release of grand jury records based upon its finding that historical interest in the records outweighed any countervailing considerations. View "Lepore v. United States" on Justia Law

The First Circuit dismissed Defendants' appeals from the trial court's refusal to dismiss their indictments, holding that this Court lacked jurisdiction to review before final judgment the district court's order denying Defendants' motions to dismiss.A United States Attorney for the District of Massachusetts charged Massachusetts state district court judge Shelley Joseph and Wesley MacGregor, her courtroom deputy, for allegedly interfering with the enforcement of federal immigration law. Defendants filed motions to dismiss their indictments based on Judge Joseph's claim of absolute judicial immunity and on their contention that their prosecution was unconstitutional. The district court denied the motions to dismiss, and Defendants appealed. The First Circuit dismissed the appeals as premature, holding that, at this stage in the proceedings, this Court had no jurisdiction to review the merits of the district court's rulings. View "United States v. Joseph" on Justia Law

The First Circuit denied Petitioner's petition for review of a final order of removal issued by the Board of Immigration Appeals (BIA), holding that the immigration judge (IJ) and BIA properly concluded that Petitioner's Massachusetts conviction for accessory after the fact rendered him removable as an aggravated felon.The U.S. Department of Homeland Security initiated removal proceedings against Petitioner. An IJ held that Petitioner was removable under the Immigration and Nationality Act, 8 U.S.C. 1227(a)(2)(A)(iii) for having committed an aggravated felony, as defined under 8 U.S.C. 1101(a)(43). As relevant to this appeal, the IJ held that Petitioner's Massachusetts accessory-after-the-fact conviction was categorically an offense relating to obstruction of justice and so was a proper ground for removal as an aggravated felony. The BIA denied Petitioner's appeal. The First Circuit denied Petitioner's petition for review, holding that the BIA did not err in determining that Petitioner's Massachusetts conviction rendered him ineligible for withholding of removal. View "Silva v. Garland" on Justia Law