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

The First Circuit vacated the order of the district court dismissing Plaintiffs' action seeking damages for medical malpractice, holding that the district court abused its discretion by failing to apply the requisite exceptional-circumstances test.Plaintiffs commenced this civil action in federal court alleging negligence under Puerto Rico law leading to the death of their mother. Approximately one month earlier, a larger group of plaintiffs brought a similar medical malpractice suit in the superior court of Puerto Rico also arising from the decedent's death. A defendant in both cases filed a motion in federal court to stay or dismiss the federal court proceeding. The district court granted the motion, finding the "prior pending action" doctrine applicable. The First Circuit vacated the order below, holding that the district court erred in applying the "prior pending action" doctrine in lieu of the test set forth in Colorado River Water Conservation District v. United States, 424 U.S. 800 (1976) and its progeny. View "Maldonado-Cabrera v. Anglero-Alfaro" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment ruling in favor of Defendant, a marketing company, holding that district court correctly concluded that Plaintiffs, who worked as "brand representatives" for Defendant, qualified as outside salespeople under governing law.Plaintiffs sued Defendant on behalf of themselves and other brand representatives, seeking to recover unpaid overtime wages under the Fair Labor Standards Act (FLSA) and analogous state wage laws, alleging that they failed to receiver overtime wages for working over forty hours per week. The district court granted summary judgment in favor of Defendant, concluding that Plaintiffs fell within the FLSA's outside sales exemption and thus were not entitled to overtime compensation. The First Circuit affirmed, holding that Plaintiffs fell within the outside sales exemption, 29 U.S.C. 213(a)(1). View "Modeski v. Summit Retail Solutions, Inc." on Justia Law

The First Circuit granted in part one of Petitioner's petitions for review of the decision of the Board of Immigration Appeals (BIA) ordering Petitioner removed, holding that remand was required.The same day the denial of Petitioner's I-751 petition to remove the conditions of his residency was issued, the Department of Homeland Security (DHS) initiated removal proceedings against Petitioner. Petitioner subsequently divorced his former wife and married anew. Petitioner's new wife filed an application for adjustment of Petitioner's status on the basis of their marriage and an I-751 waiver petition. Petitioner was subsequently indicted for kidnapping and two counts of sexual assault. The IJ granted Petitioner's application for adjustment of status. The BIA sustained the DHS's appeal and ordered Petitioner removed without acknowledging that Petitioner had a pending I-751 waiver. The First Circuit held (1) the BIA abused its discretion in denying Petitioner's motion to reconsider based on two clear-error-standard violations; and (2) remand was required for consideration of the effect, if any, of the final denial of the I-751 waiver on Petitioner's motions. View "Adeyanju v. Garland" on Justia Law

In this medical malpractice action the First Circuit affirmed the judgment of the district court entering judgment in accordance with the jury's verdict finding Doctors' Center Hospital (Manati), Inc. (Doctors' Center) liable for eight percent of a more than $14 million total award, holding that there was no error.This lawsuit stemmed from obstetric care provided to Plaintiff, Jeanette Rodriguez-Valentin in connection with the birth of her son, DALR. The jury found Doctors' Center liability and awarded damages. The jury apportioned ninety-two percent of that liability to two treating physicians with whom Plaintiff settled prior to trial and apportioned to Doctors' Center the remaining amount of $1,143,680. The First Circuit affirmed, holding that the district court (1) did not err or abuse its discretion in deferring to the jury's evaluation of the evidence; and (2) did not err in denying Doctors' Center's motions for judgment as a matter of law, for a new trial, or for remittitur. View "Rodriguez-Valentin v. Doctors' Center Hospital (Manati), Inc." on Justia Law

The First Circuit affirmed the ruling of the Board of Immigration Appeals (BIA) denying Petitioner's application for asylum, withholding of removal, protection under the Convention Against Torture (CAT), and voluntary departure, holding that the BIA's determination was supported by substantial evidence.Petitioner, a native and citizen of Guatemala, was charged with removability. Petitioner conceded removability and applied for asylum, withholding of removal, protection under the CAT, and post-conclusion voluntary departure. The immigration judge (IJ) found that Petitioner's asylum claim failed on the merits and that Petitioner was not entitled to relief on his remaining arguments for relief. The BIA affirmed. The First Circuit affirmed, holding that substantial evidence supported the decisions of the IJ and the BIA. View "Lopez-Perez v. Garland" on Justia Law

The First Circuit affirmed the decision of the district court granting judgment to Defendants and denying a declaration requested by Plaintiffs that the Massachusetts Bureau of Special Education Appeals (BSEA) erred in determining that Swampscott Public Schools had provided their daughter, G.D., with a free appropriate public school education as required under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. §§ 1400 et seq., holding that there was no error.Plaintiffs sought a determination from the BSEA that G.D.'s Individualized Education Program (IEP) was not reasonably calculated to provide her with a free appropriate public education (FAPE) and further sought reimbursement from Swampscott Public Schools associated with Plaintiffs' unilateral placement of G.D. at a nearby private school. After the BSEA denied the claims Plaintiffs filed suit against the school district and the BSEA. The district court determined that G.D.'s IEP was reasonably calculated to provide her with a FAPE and entered judgment for Defendants. The First Circuit affirmed, holding that Plaintiffs were not entitled to relief as to any of their allegations of error. View "G.D. v. Swampscott Public Schools" on Justia Law

The First Circuit affirmed the judgment of the district court rejecting the jury's advisory verdict in this case, holding that Plaintiff was not entitled to relief on his claims of error.Plaintiff, a former intelligence specialist, sued his former employer, the United States Attorney's Office for the District of Puerto Rico pursuant to Title VII of the Civil Rights Act, alleging discriminatory retaliation and constructive discharge resulting from a hostile work environment. After a jury returned a verdict on liability for retaliation and awarding the statutory maximum in damages, the district court charged the jury to return an advisory verdict on the issue of damages for constructive discharge. The jury returned a verdict in favor of Plaintiff as to that issue, and thereafter, Plaintiff sought a judgment of front and back pay. The district court rejected the jury's advisory verdict, concluding that the verdict was not supported by the evidence, that Plaintiff was not constructively discharged, and that Plaintiff was not entitled to front or back pay. The First Circuit affirmed, holding (1) Plaintiff waived his objection to the district court's decision to submit the constructive discharge issue to an advisory jury; and (2) the district court's factual findings were not clearly erroneous. View "Reyes-Caparros v. Garland" on Justia Law

The First Circuit vacated Defendant's sentence of ninety months of imprisonment and three years of supervised release for his conviction for one count of possession of a firearm by a prohibited person in violation of 18 U.S.C. 922(g)(1), holding that the evidence did not support the application of a sentencing enhancement.On appeal, Defendant argued that his sentence could not stand because it was predicated on the application of a four-level enhancement pursuant to U.S.S.G. 2K2.1(b)(6)(B) that the record did not support. Defendant argued that the district court erred in applying the enhancement, which was based on Defendant's possession of firearms "in connection with drug trafficking, a felony offense," because it improperly relied on a conclusory allegation that Defendant was working as an armed enforcer for a drug trade organization. The First Circuit vacated the sentence and remanded for resentencing, holding that the evidence did not support the sentencing enhancement's application. View "United States v. Carrion-Melendez" on Justia Law

The First Circuit dismissed as moot Gary Lee Sampson's appeal from his death sentence for murder and declined to exercise its equitable discretion to vacate the death sentence, holding that Sampson's convictions, life sentence, and death sentence remain intact.Following a retrial, a unanimous jury sentenced Sampson to death for committing a murder. Sampson appealed. While his appeal was pending, Sampson died in prison. The First Circuit held (1) the parties correctly agree that Sampson's underlying convictions and life sentence cannot, as a matter of law, be vacated; and (2) as to the death sentence, the appeal was moot. View "United States v. Sampson" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment in favor of the Town of Brookline, Massachusetts on Plaintiff's claim brought pursuant to 42 U.S.C. 1983 alleging discrimination on the basis of race in violation of the Fourteenth Amendment's Equal Protection Clause, holding that the district court did not err in granting summary judgment.Plaintiff brought this action alleging that Brookline violated his equal protection rights in terminating his employment. The district court granted summary judgment in favor of the Town. The First Circuit affirmed, holding that Plaintiff's evidence failed to establish that the Town's proffered reasons for failing to accommodate and then dismissing Plaintiff were a pretext for race discrimination. View "Fincher v. Town of Brookline" on Justia Law