U.S. Court of Appeals for the First Circuit - Justia Case Law Summaries

US v. Gonzalez

2026-09-04T10:00:03-08:00

The appellant participated in a drug smuggling operation, originating from Venezuela and intending to transfer cocaine to another vessel at a prearranged location off the coast of Puerto Rico. When the rendezvous failed, the vessel, carrying three individuals and over 600 kilograms of cocaine, headed toward Puerto Rico, where it was intercepted by local and federal authorities. The appellant, who admitted to being the vessel's captain, was arrested along with the others. A federal grand jury in the District of Puerto Rico indicted the appellant on four drug trafficking counts. He pleaded guilty to all charges without a plea agreement. The United States Probation Office prepared a presentence report, applying a sentencing enhancement for his role as captain and recommending other adjustments. The government and the appellant filed sentencing memoranda, with the government supporting a sentence of 135 months and the appellant requesting 84 months and raising objections to the captain enhancement and the lack of a minor participant reduction. The United States District Court for the District of Puerto Rico imposed a 135-month sentence and five years of supervised release, accepting the government’s recommendations. The appellant appealed. The United States Court of Appeals for the First Circuit reviewed the procedural and substantive reasonableness of the sentence. It upheld the application of the captain enhancement, finding no error in the district court’s interpretation of the relevant guidelines. However, the government conceded, and the court agreed, that the district court should reconsider the denial of a minor participant role adjustment in light of recent First Circuit decisions. The court also rejected the appellant’s claims regarding sentencing disparities and failure to consider mitigating factors. The First Circuit affirmed the sentence in part, vacated in part, and remanded for further proceedings on the minor participant issue. View "US v. Gonzalez" on Justia Law

Instituto Medico del Norte, Inc. v. Greengift Capital, LLC

2026-09-02T13:00:03-08:00

A medical institution in Puerto Rico borrowed over $10 million from a bank in 1984 to build a hospital, but soon disputes arose regarding the loan. The bank claimed the institution defaulted, while the institution asserted the bank failed to disburse funds as required. Litigation and bankruptcy proceedings followed. In 1991, the parties settled, but the terms of that settlement—whether the debt was split into interest-bearing and non-interest-bearing portions—remained contested. Over the next decades, the loan changed hands, and in 2013 the institution filed for Chapter 11 bankruptcy again. The current loan-holder claimed a significantly higher outstanding balance than the institution believed was owed, due in part to differing interpretations of the 1991 agreement and subsequent bankruptcy plan. The United States Bankruptcy Court for the District of Puerto Rico previously addressed these disputes. It issued orders requiring the institution to demonstrate, with evidence, that the 1991 agreement created a non-interest-bearing note and that it had made payments in accordance with the bankruptcy plan. The court denied discovery, required summary judgment briefing, and ultimately issued an order with minimal analysis, granting the loan-holder’s motion to dismiss and denying the institution’s motion for summary judgment. The court’s reasoning was ambiguous, referencing both summary judgment and pleading standards, and did not clearly identify the basis for its decision. On appeal, the United States District Court for the District of Puerto Rico affirmed, concluding the bankruptcy plan did not incorporate the 1991 bifurcated note arrangement. The United States Court of Appeals for the First Circuit, reviewing the case, found the bankruptcy court’s order insufficiently reasoned to permit meaningful appellate review. The First Circuit vacated the lower courts’ decisions and remanded for further proceedings, instructing the bankruptcy court to clarify its reasoning, identify the applicable legal standards, and consider whether summary judgment or further fact-finding is appropriate. View "Instituto Medico del Norte, Inc. v. Greengift Capital, LLC" on Justia Law

Espinoza Benitez v. Blanche

2026-09-01T14:00:04-08:00

The petitioner, a native and citizen of El Salvador, entered the United States in 2000 on a visa and overstayed its expiration in 2001. In 2018, the Department of Homeland Security commenced removal proceedings against him. He conceded removability and sought cancellation of removal, arguing that his deportation would result in “exceptional and extremely unusual hardship” to his two U.S. citizen children. His main argument was that, if removed, he would not be able to provide his son with necessary asthma medication. He provided evidence of his son's medical history, his own role as the primary financial provider, and concerns about affordability and availability of medical care in El Salvador. An Immigration Judge conducted an evidentiary hearing and denied the application for cancellation of removal. The judge found that the petitioner had not demonstrated that his son's asthma constituted a serious medical condition or that, even if it did, treatment and medication would be unavailable or unaffordable in El Salvador. The judge also found insufficient evidence regarding the cost and availability of asthma medications, as well as the family's ability to afford them if relocated. The Board of Immigration Appeals affirmed the Immigration Judge’s decision without issuing a separate opinion. The United States Court of Appeals for the First Circuit reviewed the case, treating the Immigration Judge’s opinion as the final agency action. Applying a deferential standard of review, the court examined whether the agency correctly applied the “exceptional and extremely unusual hardship” standard to the facts. The court held that the Immigration Judge properly applied agency precedent and weighed all relevant factors in the aggregate. The court concluded that the petitioner failed to meet his burden and that the evidence did not rise to the statutory hardship level. Accordingly, the First Circuit denied the petition for review. View "Espinoza Benitez v. Blanche" on Justia Law

de la Fuente Diaz v. Gonzalez Colon

2026-09-01T14:00:03-08:00

Six nonbinary individuals born in Puerto Rico sought to amend their birth certificates to reflect a nonbinary gender marker ("X"), arguing that the existing Application for Gender Change, which only allowed selection of "male" or "female," discriminated against them. Their request followed an earlier federal court decision (Arroyo González v. Rossello Nevares) that required Puerto Rico to allow transgender binary individuals to amend their birth certificates, but did not address nonbinary persons. After their request was denied by the Director of the Demographic Registry, the plaintiffs filed suit, alleging violations of their constitutional rights under the Equal Protection and Due Process Clauses of the Fourteenth Amendment and the First Amendment. The United States District Court for the District of Puerto Rico reviewed cross-motions for summary judgment. The district court granted summary judgment to the plaintiffs on their Equal Protection claim, finding that Puerto Rico’s Birth Certificate Policy created a facial classification between binary and nonbinary individuals. The court applied rational basis review and concluded that Puerto Rico’s stated interests—including separation of powers and maintaining the integrity of public records—did not justify the exclusion of a nonbinary option. It found no rational basis for the policy and inferred animosity towards nonbinary persons, ordering Puerto Rico to amend its Application for Gender Change to include an "X" gender marker. The United States Court of Appeals for the First Circuit reviewed the district court’s summary judgment order de novo. The appellate court concluded that Puerto Rico's Birth Certificate Policy is supported by a rational basis, specifically Puerto Rico’s legitimate interest in protecting privacy rights. Because the plaintiffs did not demonstrate that the policy infringes on their privacy rights or that privacy rights are not furthered by the policy, the court found a rational relationship between the challenged classification and the government’s legitimate goals. The First Circuit vacated the district court’s order and remanded for further proceedings. View "de la Fuente Diaz v. Gonzalez Colon" on Justia Law

Citation Insurance Company v. Broan-NuTone LLC

2026-08-28T11:30:04-08:00

A homeowner in Massachusetts experienced a fire in his residence, which originated in the ceiling above a bathroom exhaust fan. Both the homeowner and a Verizon technician were present at the time; the technician had earlier tripped a fuse while working in the basement. The local fire department determined the fire started with the bathroom vent fan and found no connection to the technician’s work. The homeowner’s insurer, having paid out the claim for the fire damage, brought a subrogation action against the manufacturers of the fan and its motor, alleging that a defect in the fan or its components caused the fire. The United States District Court for the District of Massachusetts reviewed the case after the insurer presented claims for negligence and breach of implied warranty of merchantability against the fan and motor manufacturers. The insurer designated two experts, one of whom opined that the fire originated within the fan but could not specify the precise failure mode. During discovery, the expert could not identify which of several known defects in a thermal cutoff device caused the failure, nor could he provide details on the cost or feasibility of proposed alternative designs. The District Court granted summary judgment to the defendants, finding that the insurer had not provided sufficient admissible expert evidence to show a specific manufacturing or design defect, and excluded some of the expert’s deposition testimony as a sanction for violating expert disclosure rules. On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s decision. The Court held that, even considering the malfunction theory, the insurer failed to provide sufficient evidence from which a jury could infer a manufacturing defect or a feasible alternative design. The appellate court concluded that summary judgment for the defendants was appropriate, as the insurer did not meet its burden under Massachusetts law to establish liability for breach of implied warranty or negligence. View "Citation Insurance Company v. Broan-NuTone LLC" on Justia Law

US v. Velez-Ramirez

2026-08-28T11:30:04-08:00

A police officer in Puerto Rico was convicted after accepting a bribe from a woman he had arrested for marijuana possession. The officer promised to help the woman avoid a criminal conviction in exchange for sex. The woman, a young assistant nurse studying to become a full-time nurse, feared that a conviction would jeopardize her career. After her arrest, she met with the officer, who suggested that he could get her case dismissed if she provided sexual favors. She agreed, and they had sex, but the officer did not deliver on his promise. The woman subsequently faced multiple court appearances, hired a private attorney, and ultimately pleaded guilty, incurring various costs and emotional distress. The United States District Court for the District of Puerto Rico presided over the trial, during which the jury convicted the officer of violating 18 U.S.C. § 666(a)(1)(B), which prohibits government officials from accepting bribes in connection with business or transactions involving $5,000 or more. The defendant moved for acquittal, arguing that the government failed to prove the value of the "business" or "transaction" exceeded $5,000. The district court denied the motion. On appeal, the defendant challenged both the sufficiency of the evidence regarding the $5,000 threshold and an alleged violation of his Fifth Amendment right against self-incrimination due to statements by the prosecution during closing argument. The United States Court of Appeals for the First Circuit reviewed the conviction. The court held that the evidence was sufficient for a reasonable jury to find that the value of avoiding a criminal conviction—considering the woman’s career prospects, legal expenses, fines, and her own testimony—exceeded $5,000. The court also found no clear or obvious error in the prosecution’s closing argument regarding the defendant’s decision not to testify. The conviction was affirmed. View "US v. Velez-Ramirez" on Justia Law

McDonald v. US

2026-08-28T11:30:03-08:00

The appellant was convicted in the 1990s for bank and armored car robberies committed with a group that included Anthony Shea. These crimes involved frequent use of firearms, and in one particularly violent incident, two armored car guards were killed execution-style. The convictions included armed bank robbery, carjacking, Hobbs Act robbery and conspiracy, gun possession by a felon or drug user, and aiding and abetting the use of a firearm during a crime of violence under 18 U.S.C. § 924(c). The trial judge instructed the jury that several offenses were “crimes of violence” for the gun-use charge, but the verdict form did not specify which predicate offense the jury relied upon. Following his conviction, the United States District Court for the District of New Hampshire sentenced him to life imprisonment, applying enhancements under the Armed Career Criminal Act (ACCA) based on prior convictions. After the Supreme Court in Johnson v. United States struck down ACCA’s residual clause, a panel of the United States Court of Appeals for the First Circuit allowed the appellant to file a successive habeas petition. The district court subsequently vacated the ACCA-enhanced sentence and imposed a lower term, but declined to grant a full resentencing or to vacate the § 924(c) conviction, reasoning that the jury instruction error was harmless because valid predicate offenses remained. Upon appeal, the United States Court of Appeals for the First Circuit reviewed the denial of § 2255 relief de novo and for harmless error. It held that the district court's reliance on the harmless-error standard was correct and that the error in instructing on an invalid predicate offense did not have a substantial and injurious effect on the jury’s verdict, given the interrelated and coextensive nature of the valid and invalid predicates. The court further held that the appellant was not entitled to a certificate of appealability or to a full resentencing, as no substantial constitutional claim was raised regarding the district court’s choice of remedy. The judgment was affirmed and the request for a certificate of appealability denied. View "McDonald v. US" on Justia Law

Fellers v. Kelley

2026-08-26T13:30:02-08:00

Several parents and a grandparent of two female high school athletes challenged actions taken by officials of a New Hampshire public school district. The dispute arose after the parents wore pink "XX" wristbands during a girls' soccer game as a passive protest against the participation of a transgender athlete, in light of recent litigation about transgender students’ eligibility for girls’ sports. School administrators, concerned about possible harassment and disruption, instructed the protestors to remove the wristbands and later issued sanctions, including no-trespass orders preventing them from attending future school events. The United States District Court for the District of New Hampshire reviewed the plaintiffs’ request for a preliminary injunction. It analyzed the school’s actions under First Amendment principles applicable to limited public fora and determined that the administrators’ interpretation and enforcement of school policy did not constitute impermissible viewpoint discrimination. The district court denied the request for injunctive relief, concluding that the school’s interests justified its response to the protest. The United States Court of Appeals for the First Circuit examined whether the school district’s actions amounted to viewpoint discrimination against the plaintiffs’ passive speech. The court found that the protest did not materially disrupt the event or amount to harassment, and that the sanctions appeared motivated by disagreement with the protest’s message. The First Circuit held that the plaintiffs demonstrated a likelihood of success on their viewpoint discrimination claim, specifically regarding the sanctions imposed at the soccer game’s sidelines and adjacent parking lot. The court remanded the case to the district court for further proceedings to determine whether any interim relief, such as a declaratory judgment, is warranted. No costs were awarded. View "Fellers v. Kelley" on Justia Law

Bromfield v. Blanche

2026-08-25T13:00:03-08:00

A Jamaican national entered the United States on a tourist visa in 2004 and remained beyond his authorized stay. He was arrested by U.S. authorities in 2009 and charged as removable. Following his marriages to two U.S. citizens—both ending in divorce—he sought various forms of immigration relief, including adjustment of status and asylum. His immigration history was complicated by criminal convictions for making false statements and misrepresenting a Social Security number when applying for a U.S. passport, as well as allegations of marriage fraud. After several procedural delays and changes in representation, he eventually filed applications for asylum, withholding of removal, and protection under the Convention Against Torture, claiming fear of gang violence in Jamaica due to his brother’s work as a police officer. The Immigration Judge in Boston, Massachusetts, denied all applications. The judge found the petitioner ineligible for adjustment of status due to his criminal convictions and lack of a valid waiver, and further determined that even if eligible, the relief would be denied as a matter of discretion. The judge also found the asylum application untimely, not excused by changed or extraordinary circumstances, and lacking merit. The judge made an adverse credibility finding against the petitioner and concluded that his proposed social group was not legally cognizable. The judge denied withholding of removal and CAT protection on similar grounds. The Board of Immigration Appeals affirmed the judge’s decision. The United States Court of Appeals for the First Circuit reviewed the case. It held that it lacked jurisdiction to review the discretionary denial of adjustment of status and the agency’s determination that the asylum application was untimely without excusing circumstances. The court dismissed the petition as to those claims. On the remaining claims, the court denied the petition, upholding the adverse credibility finding and the ruling that the proposed social group was not cognizable. View "Bromfield v. Blanche" on Justia Law

Russo v. New Hampshire Neurospine Institute, P.A.

2026-08-25T13:00:03-08:00

A physician assistant worked for a medical practice in New Hampshire for over a decade. During her employment, she had a series of contentious interactions with one of the practice’s orthopedic surgeons, who was also a partner and vice-president of the organization. The surgeon accused her of being disrespectful and ultimately insisted that he could not remain at the practice if she continued to work there. This ultimatum led the practice’s partners to vote unanimously to terminate her employment. However, the practice allowed her to continue working during a transition period while the parties negotiated a severance agreement and a possible independent contractor arrangement. After the employee raised concerns that her termination was driven by sex discrimination, the practice ended negotiations and immediately terminated her employment. She subsequently filed suit in the United States District Court for the District of New Hampshire against both the medical practice and the surgeon, alleging sex discrimination and retaliation under federal and state law. The district court granted summary judgment in favor of both defendants, concluding that there was insufficient evidence to support her claims. On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s grant of summary judgment on the sex discrimination claim, finding there was no genuine issue of material fact that her termination was motivated by gender bias rather than personal conflict. However, the court reversed summary judgment on the retaliation claim against the practice. The court held there was sufficient evidence for a reasonable jury to find that the practice accelerated her termination and withdrew an independent contractor opportunity in retaliation for her complaint of sex discrimination. The case was remanded for further proceedings on the retaliation claim. View "Russo v. New Hampshire Neurospine Institute, P.A." on Justia Law

US v. Reynoso

2026-08-24T13:30:04-08:00

Federal prosecutors obtained a seizure warrant from a magistrate judge in the District of Puerto Rico authorizing the seizure of approximately 119.65 Bitcoin from a wallet associated with Juan Carlos Reynoso. The warrant required that the assets be transferred to a government-controlled wallet within 24 hours and prohibited Reynoso from obstructing or interfering with the seizure. Reynoso’s attorney, Walter Reynoso, agreed to accept service of the warrant on his client’s behalf, but due to family commitments, did not promptly relay the warrant to Reynoso. By the time Walter opened the warrant email, the deadline had passed, and multiple transfers had already occurred from the wallet. Additional transfers took place in the days following, resulting in the complete dissipation of the assets. The government filed a motion in the United States District Court for the District of Puerto Rico to hold Reynoso in civil contempt for failing to comply with the warrant. The court issued an order to show cause, and Reynoso responded by seeking to quash service and requesting an evidentiary hearing, arguing that material facts were in dispute. The government opposed, asserting there were no significant factual disputes. The District Court denied the motion to quash, granted the contempt motion, and held Reynoso in civil contempt, stating that a hearing was unnecessary because the facts were not in dispute. On appeal to the United States Court of Appeals for the First Circuit, Reynoso argued that the District Court abused its discretion by denying an evidentiary hearing. The First Circuit affirmed the contempt order, holding that an evidentiary hearing is not required when the record reveals no genuine dispute of material fact, and that Reynoso failed to identify any evidence that would have created such a dispute regarding any element necessary for a civil contempt finding. View "US v. Reynoso" on Justia Law

Pereira Alves v. Blanche

2026-08-24T13:30:04-08:00

A family of four, natives and citizens of Brazil, entered the United States without authorization in October 2021 and were subsequently charged with removability. Through counsel, they conceded removability and sought asylum, withholding of removal, and protection under the Convention Against Torture, claiming persecution by Brazilian military police due to their association with Cristiana’s brother, who was a gang leader and imprisoned. The alleged harm included threats, intimidation, and witnessing violence against family members at Cristiana’s mother’s house, but neither Cristiana nor her husband suffered direct physical harm or arrest. After the mother’s death, Cristiana feared she would be targeted as her brother’s only remaining family in Brazil. An Immigration Judge from the U.S. Department of Justice’s Executive Office for Immigration Review denied their applications in December 2023, finding their testimony credible but insufficient to establish past persecution or a well-founded fear of future persecution. The IJ concluded that the harm experienced was indirect and limited, primarily occurring at the mother’s house, and could have been avoided by not visiting there. The IJ also found the applicants failed to show objective evidence of ongoing threats or that internal relocation within Brazil would be unreasonable. The IJ’s denial of relief was affirmed by the Board of Immigration Appeals (BIA), which also dismissed arguments based on the asylum grant to Cristiana’s sister, Poliana, distinguishing her circumstances as involving direct physical harm. The United States Court of Appeals for the First Circuit reviewed both the IJ’s and BIA’s decisions under the substantial evidence standard. The court held that the applicants did not demonstrate past persecution or a well-founded fear of future persecution, nor did they show they were similarly situated to Poliana. The petitions for review were denied, and the disposition affirmed the decisions of the BIA and IJ. View "Pereira Alves v. Blanche" on Justia Law

Hurley v. Curtis

2026-08-21T13:30:03-08:00

Several former residents and the owner of a certified sober home in Falmouth, Massachusetts, brought claims against local police officers after officers entered the home on three occasions between October 2019 and January 2020. The police responded to reports of overdoses or to serve arrest warrants, and the plaintiffs alleged that the officers conducted unlawful searches and seizures, detained and interrogated residents, and made threats. The plaintiffs argued that police actions stemmed from animus related to the owner’s prior complaints about police corruption. The plaintiffs initially filed suit in Massachusetts state court, alleging violations of the Fourth Amendment and the Massachusetts Declaration of Rights, as well as several state torts such as false arrest, invasion of privacy, and conspiracy. The case was removed to the United States District Court for the District of Massachusetts. After discovery, the district court granted summary judgment for the defendant officers on all claims except those related to a January 2020 entry. The court then revisited its prior order, addressing qualified immunity and granting summary judgment on the remaining federal claims, ultimately dismissing all claims against the Falmouth police officers. The United States Court of Appeals for the First Circuit reviewed the case de novo. The court concluded that many of the plaintiffs’ claims lacked sufficient factual support to survive summary judgment or were unsupported by specific evidence tying the alleged conduct to the defendant officers. Some claims were also deemed waived due to inadequate argument. The court held that the officers’ entries and searches were justified by consent or exigent circumstances, and that even if there were constitutional violations, the officers were protected by qualified immunity. The court also found that without an underlying tort, the conspiracy claim could not succeed. The First Circuit affirmed the district court’s grant of summary judgment in favor of the defendants. View "Hurley v. Curtis" on Justia Law

Air-Con, Inc. v. Daikin Applied Latin America, LLC

2026-08-21T13:30:03-08:00

A Puerto Rican distributor of HVAC products brought suit against a Miami-based manufacturer after their commercial relationship deteriorated. The distributor alleged that the manufacturer’s actions impaired its distribution rights under Puerto Rico’s Dealer’s Act (Law 75). After the distributor dismissed claims against certain non-diverse defendants, the manufacturer removed the case to federal court and asserted a counterclaim alleging the distributor owed over $235,000, as well as seeking a declaratory judgment that it had just cause to terminate the relationship. The United States District Court for the District of Puerto Rico granted summary judgment to the manufacturer on the Law 75 claim, finding in its favor, and dismissed the manufacturer’s declaratory judgment counterclaim as unripe. The court denied summary judgment on the remaining damages counterclaim, finding material factual disputes and setting it for trial. The distributor sought entry of final judgment under Rule 54(b), which the court denied due to overlap between the claims. The distributor’s attempt to obtain appellate review via a petition under Rule 5 was also denied by the United States Court of Appeals for the First Circuit. Subsequently, the manufacturer moved to voluntarily dismiss its remaining counterclaim without prejudice. The district court granted that motion, dismissing the counterclaim without prejudice and denying the distributor’s requests for dismissal with prejudice or for attorney fees and costs. The court then entered judgment dismissing the distributor’s claims with prejudice and the manufacturer’s counterclaim without prejudice. On appeal, the United States Court of Appeals for the First Circuit determined that it lacked appellate jurisdiction. The court held that a voluntary dismissal without prejudice does not produce a final decision under 28 U.S.C. § 1291 when the dismissed claim could be revived in the same district court. Consequently, there was no final, appealable judgment, and the appeal was dismissed. View "Air-Con, Inc. v. Daikin Applied Latin America, LLC" on Justia Law

US v. Bourget

2026-08-21T13:30:02-08:00

A correctional officer participated in a "forced cell move" at a federal medical facility, where a mentally ill and physically frail inmate, KT, was handcuffed behind his back. During the incident, the officer, equipped with a shield, entered the cell at high speed and struck KT in the chin and face, causing him to fall backward and suffer serious head and facial injuries. The event was captured on video. Prior to this, KT had spat on staff, including the officer, but was not threatening or aggressive at the time the force was used. The officer was indicted in the United States District Court for the District of Massachusetts on two counts of deprivation of rights under color of law. At the first jury trial, he was acquitted on one count, while the jury hung on the count concerning the shield strike, leading to a retrial. In the second trial, the district court excluded a training video the defense sought to introduce, finding it irrelevant and more prejudicial than probative, particularly since the circumstances in the video were materially different from those at issue. The jury convicted the officer on the remaining count. The district court denied post-trial motions and imposed a sentence of imprisonment and supervised release. On appeal to the United States Court of Appeals for the First Circuit, the officer challenged the sufficiency of the evidence, jury instructions, exclusion of the training video, and certain testimonial evidence, also alleging cumulative error. The First Circuit held that sufficient evidence supported the jury's finding that the officer acted maliciously and sadistically, violating the inmate's Eighth Amendment rights and meeting the willfulness standard under 18 U.S.C. § 242. The court found no error in the exclusion of the video, the jury instructions, or the evidentiary rulings, and determined that no cumulative error occurred. The conviction was affirmed. View "US v. Bourget" on Justia Law

In Re: Apellis Pharm., Inc. Securities Litigation

2026-08-19T12:30:04-08:00

Plaintiffs, who were investors in a pharmaceutical company, brought a putative class action alleging securities fraud. The company had developed a drug to treat geographic atrophy, a form of age-related macular degeneration, and conducted two large clinical trials (OAKS and DERBY) before the drug's approval by the FDA. During the class period, company representatives publicly stated that there were no observed cases of retinal vasculitis, a serious eye condition, among trial participants. After the drug's commercialization, new reports emerged of retinal vasculitis in patients treated with the drug, leading to a decline in the company’s stock price and the addition of a warning to the drug’s label. The action was initially filed in the U.S. District Court for the District of Delaware and later transferred to the U.S. District Court for the District of Massachusetts. The plaintiffs argued that the company's statements were misleading half-truths because the clinical trials were not specifically designed to detect retinal vasculitis, and this limitation was not disclosed to investors. The defendants moved to dismiss, contending that the statements were not materially misleading and that there was no sufficient allegation of scienter (intent to defraud). The U.S. District Court for the District of Massachusetts granted the motion, holding that the omissions were not actionable because the relevant trial protocols and methodologies had been publicly disclosed and disagreements over scientific methodology do not support securities fraud claims. On appeal, the United States Court of Appeals for the First Circuit affirmed the dismissal. The court held that the company’s statements were not materially misleading because the information regarding the trial protocols, including when and how retinal vasculitis could be detected, was publicly available. The court concluded that no material misrepresentation or actionable omission had occurred, and thus affirmed the district court’s judgment. View "In Re: Apellis Pharm., Inc. Securities Litigation" on Justia Law

SEC v. Gastauer

2026-08-19T12:30:04-08:00

A German national was named as a relief defendant in a civil enforcement action brought by the Securities and Exchange Commission. The SEC alleged that he received approximately $3.3 million in funds, transferred from U.S.-based companies controlled by his son, who was a primary defendant in a securities fraud scheme. The SEC sought to recover those funds through disgorgement, claiming the money represented proceeds of illegal activity. The relief defendant maintained that he lived in Germany, had limited visits to the United States, and challenged the court's personal jurisdiction over him. The United States District Court for the District of Massachusetts initially denied the relief defendant’s motion to dismiss for lack of personal jurisdiction and later imposed sanctions against him for discovery violations. The court entered summary judgment for the SEC, ordering disgorgement. On appeal, the United States Court of Appeals for the First Circuit concluded in a prior decision that the district court could not establish personal jurisdiction over him by imputing the contacts of his son, and remanded for further proceedings. On remand, the district court permitted the SEC to seek jurisdictional discovery regarding the relief defendant’s own contacts with the United States. The relief defendant did not oppose discovery, refused to participate further, and failed to communicate directly with the court. The district court sanctioned him by deeming facts establishing personal jurisdiction as admitted, and reinstated summary judgment for the full disgorgement amount. The United States Court of Appeals for the First Circuit held that the relief defendant forfeited or waived any challenge to the jurisdictional discovery process, the district court’s orders, and related arguments by failing to raise them in the district court after remand. The court affirmed the district court’s judgment. View "SEC v. Gastauer" on Justia Law

5-Star General Store v. American Express Company

2026-08-19T12:30:03-08:00

A group of small merchants, including a store in Rhode Island, entered into arbitration agreements with a credit card company, which required arbitration of disputes before the American Arbitration Association (AAA). In August 2023, these merchants initiated thousands of arbitration proceedings against the company, challenging certain “swipe-fee” policies that they argued harmed small businesses. A dispute arose over the filing fees that the credit card company owed to the AAA. The AAA administrator determined the applicable fees and repeatedly warned both parties that the arbitrations would be administratively closed if the fees were not paid. The merchants paid their share of the fees, but the credit card company refused to pay, contesting the fee amount. As a result, in late February 2024, the AAA administratively closed the arbitrations. Subsequently, the merchants filed a class action in the United States District Court for the District of Rhode Island, arguing that the company’s refusal to pay arbitration fees constituted a default and waiver of its right to compel arbitration under the Federal Arbitration Act (FAA). The credit card company moved to stay the litigation and compel arbitration. The District Court denied the motion, finding that the company had defaulted and waived its arbitration rights by failing to pay the required fees, and rejected the company’s argument that the merchants had acted with unclean hands. The United States Court of Appeals for the First Circuit reviewed the case. The court held that the district court had the authority to decide whether the company’s conduct amounted to waiver or default under the FAA, and that the company’s deliberate refusal to pay arbitration fees, despite repeated warnings, constituted waiver and default. The First Circuit also found no error in the district court’s rejection of the unclean hands defense. The appellate court affirmed the district court’s denial of the motion to stay and compel arbitration. View "5-Star General Store v. American Express Company" on Justia Law

Nicholls v. Veolia Water Contract Operations USA, Inc.

2026-08-19T12:30:03-08:00

Several employees of Veolia Water Contract Operations USA, Inc. sued their employer, seeking prevailing wages under the Massachusetts Prevailing Wage Act (PWA) for certain repair and replacement work they performed pursuant to a contract between Veolia and the Springfield Water and Sewer Commission. That contract was authorized by a 1997 Massachusetts Special Act, which provided that work falling within "the construction and design of improvements" remained governed by the PWA. The disputed work occurred during the contract’s second stage, which involved ongoing operation, maintenance, repair, and replacement of wastewater facilities. After both sides moved for summary judgment, the United States District Court for the District of Massachusetts ruled for Veolia. The court concluded that the employees’ work did not fall under "construction and design of improvements" as used in the Special Act and, relying on the Supreme Judicial Court of Massachusetts’s (SJC) decision in Metcalf v. BSC Group, Inc., determined that the structure of the procurement scheme made the PWA inapplicable to the service contract as a whole. The employees appealed. The United States Court of Appeals for the First Circuit, reviewing the case, certified two questions regarding Massachusetts law to the SJC. The SJC clarified that "construction and design of improvements" in the Special Act is broader than the PWA’s definition of “construction” but does not include ordinary repairs or maintenance. The SJC also held that the Special Act was not incompatible with the PWA and that Metcalf was not controlling. Based on the SJC’s answers, the First Circuit held that the district court’s summary judgment for Veolia could not stand, reversed the order, vacated the judgment, and remanded the case for further proceedings to determine which, if any, of the employees’ tasks fell within the statutory phrase. View "Nicholls v. Veolia Water Contract Operations USA, Inc." on Justia Law

Giguere v. Tardif

2026-08-17T13:30:03-08:00

A Canadian couple moved to Massachusetts with their two young children after both were granted E-2 non-immigrant visas to work at a family business expanding into the United States. Their move was described as a trial, intended to assess whether they liked living in the U.S. and to help launch the business. They left most possessions in Canada and maintained financial and familial ties there. After selling their Canadian home, they bought a condominium in Massachusetts. Over time, the spouses developed differing intentions about making the United States their permanent home. The father struggled to adapt to life in Massachusetts and expressed his desire to return to Canada, while the mother wished to stay. In August 2024, after the father traveled to Canada, the mother withdrew funds from joint accounts, changed the locks on the home, and refused to let the children visit their father in Canada. Subsequently, the mother filed for divorce in Massachusetts, and the father counterclaimed for custody and removal of the children to Canada. Temporary custody arrangements were made. The father then filed applications under the Hague Convention in both Canada and the United States, alleging wrongful retention of the children. The United States District Court for the District of Massachusetts held a hearing and concluded that the mother’s actions amounted to wrongful retention under the Hague Convention, finding that the children’s “habitual residence” remained Canada. The court ordered the children returned to Canada. The United States Court of Appeals for the First Circuit reviewed the district court’s decision, applying clear error review to the findings of fact. The court affirmed, holding that the district court correctly identified Canada as the children’s habitual residence as of the date of wrongful retention. The court also rejected the mother’s defenses of “now-settled,” consent, and acquiescence, finding no clear error in the district court’s determinations. The judgment ordering the return of the children to Canada was affirmed. View "Giguere v. Tardif" on Justia Law

Kyick Holdings, LLC v. Bessent

2026-08-17T13:30:03-08:00

The Internal Revenue Service (IRS) sent a notice of transferee liability for unpaid taxes to a limited liability company (the appellant) at the address listed on its most recent tax return. The appellant did not receive the notice because it was returned by the postal service as undeliverable. The company only learned of the notice months later and subsequently filed a petition in the United States Tax Court to contest the liability, but did so 143 days after the IRS had mailed the notice. The statutory deadline for such petitions is 90 days. After the petition was filed, the IRS moved to dismiss it on the grounds that the Tax Court lacked jurisdiction because the filing was untimely. The appellant argued that the notice was not properly delivered and that the statute of limitations should bar the IRS’s assertion of liability. The Tax Court found that the IRS had exercised reasonable diligence in determining the company's address, as it used the address provided on the most recent tax return. Because the petition was not filed within the 90-day period specified by 26 U.S.C. § 6213(a), the Tax Court dismissed the case for lack of jurisdiction. On appeal, the United States Court of Appeals for the First Circuit reviewed the decision. The Court held that the IRS had complied with statutory requirements in mailing the notice to the correct address and exercised reasonable diligence. The Court further determined that the 90-day filing deadline in § 6213(a) is nonjurisdictional, meaning it does not limit the Tax Court’s power to hear late petitions. However, the Court also held that the deadline, though nonjurisdictional, is mandatory and not subject to equitable tolling. The dismissal of the petition was thus affirmed, though on different grounds than those relied upon by the Tax Court. View "Kyick Holdings, LLC v. Bessent" on Justia Law

Guerrero Orellana v. Moniz

2026-08-13T17:30:03-08:00

A Salvadoran national entered the United States without inspection in 2013 and lived in Massachusetts. In September 2025, he was arrested by immigration authorities during a vehicle stop and placed in removal proceedings, charged as inadmissible for being present without admission or valid documentation. Under longstanding practice, individuals in his situation could seek release from detention on bond while their removal cases were pending. However, in July 2025, the Department of Homeland Security issued guidance, later adopted by the Board of Immigration Appeals in Matter of Yajure Hurtado, that mandatory detention without bond applied to all noncitizens present in the U.S. without admission, shifting the legal framework and increasing the detained population. After his arrest, the individual challenged his detention without a bond hearing by filing a habeas petition in the United States District Court for the District of Massachusetts. The district court issued a preliminary injunction, requiring his release or a bond hearing, and later certified a class action for similarly situated noncitizens. The district court ultimately held that the new DHS policy violated the Immigration and Nationality Act (INA), finding that those present in the United States without admission were entitled to bond hearings under 8 U.S.C. § 1226(a), not subject to mandatory detention under § 1225(b)(2)(A). On appeal, the United States Court of Appeals for the First Circuit reviewed whether the INA requires mandatory detention without bond for noncitizens present in the country without admission, or if they are eligible for bond hearings. The First Circuit held that § 1225(b)(2)(A) applies only to noncitizens "seeking admission"—that is, those seeking lawful entry at the border—not those already present after unlawful entry. Accordingly, detention and bond eligibility for class members are governed by § 1226(a), not § 1225(b)(2)(A), and the district court’s order was affirmed. View "Guerrero Orellana v. Moniz" on Justia Law

LUMA Energy LLC v. Puerto Rico Dep't of Consumer Affairs

2026-08-13T08:30:04-08:00

LUMA Energy, LLC and LUMA Energy ServCo, LLC entered into a long-term contract to operate and maintain Puerto Rico’s electric power transmission and distribution system, previously managed by the Puerto Rico Electric Power Authority (PREPA), a Title III debtor under PROMESA. The agreement included a liability waiver provision, which was subsequently approved with modifications by the Puerto Rico Energy Bureau (PREB). After LUMA invoked the waiver to deny numerous consumer claims, the Puerto Rico Department of Consumer Affairs (DACO) brought suit in Puerto Rico’s courts against LUMA, PREPA, and PREB, challenging the constitutionality of the waiver. The Supreme Court of Puerto Rico accepted the case for review. While the DACO action was pending, LUMA, without participation from PREPA or the Financial Oversight and Management Board (the Board), sought an order from the United States District Court for the District of Puerto Rico (acting as the Title III court) to enforce the automatic bankruptcy stay and halt the DACO litigation. The Title III court denied LUMA’s motion, finding the police and regulatory power exception to the automatic stay applicable because DACO’s action was an exercise of governmental authority to protect consumers. LUMA appealed this order. The United States Court of Appeals for the First Circuit reviewed the case. The main holding was that LUMA lacked statutory standing to appeal the Title III court’s denial of its motion to enforce the automatic stay. The First Circuit clarified that LUMA was not a “person aggrieved” for purposes of appellate standing under the Bankruptcy Code as incorporated by PROMESA, because LUMA did not show it suffered a direct and adverse pecuniary injury of the type the automatic stay is meant to prevent. Accordingly, the First Circuit dismissed the appeal for lack of appellate jurisdiction. View "LUMA Energy LLC v. Puerto Rico Dep't of Consumer Affairs" on Justia Law

Urena v. Travelers Casualty and Surety Co. of America

2026-08-11T13:30:03-08:00

The case concerns the estate administrators of a former employee, Juliana Rodriguez Morel, who alleged she was discriminated and retaliated against by her employer, Mammoth Tech, Inc., during her pregnancy. After initially filing an administrative complaint with the New Hampshire Commission for Human Rights and the EEOC in 2019, Rodriguez Morel obtained a right-to-sue letter from the EEOC. She then filed a lawsuit in the United States District Court for the District of New Hampshire. That court entered a default judgment against Mammoth in 2023, awarding damages and fees. Subsequently, in 2025, the estate administrators initiated a separate action in the same district court against Travelers Casualty and Surety Company of America, Mammoth’s insurer. They sought a declaratory judgment that Travelers was required to pay the losses Mammoth incurred as a result of the default judgment, arguing that the insurer’s policy provided coverage for the claims in question. Travelers moved for judgment on the pleadings, contending that the policy did not provide coverage because Mammoth had received notice of the claims prior to the policy period, thus excluding coverage under the policy’s terms. The District Court agreed with Travelers and granted judgment on the pleadings. The United States Court of Appeals for the First Circuit reviewed the case de novo. The court held that the insurance policy’s “Related Claims” provision applied, which meant that all related claims were considered made at the time the first such claim was made. Because the first notice of the employment discrimination claims was before the policy period, the policy did not cover the judgment. The First Circuit affirmed the District Court’s decision, holding that the administrators failed to show any conflict or ambiguity in the policy that would override the Related Claims provision. View "Urena v. Travelers Casualty and Surety Co. of America" on Justia Law

Bangs v. Blanche

2026-08-11T13:30:03-08:00

The petitioner, a native of Sierra Leone and citizen of Liberia, entered the United States as a refugee in 2004 and later became a lawful permanent resident. After a troubled period as a youth, he was convicted in New Hampshire of witness tampering for retaliating against a friend whom he believed had reported him for shoplifting. His actions included physical assault and other forms of abuse. Based on this state conviction, the government initiated removal proceedings, alleging that his offense constituted an aggravated felony “relating to obstruction of justice” under federal immigration law. An Immigration Judge found the petitioner removable due to his conviction but granted deferral of removal under the Convention Against Torture (CAT), finding it more likely than not that he would face torture if returned to Sierra Leone. The Board of Immigration Appeals (BIA) affirmed the finding of removability based on the aggravated felony determination but reversed the deferral of removal under CAT. The petitioner then sought review of the BIA’s decision, challenging both the aggravated felony classification and the denial of CAT protection. The United States Court of Appeals for the First Circuit reviewed whether a conviction under New Hampshire’s witness tampering statute qualifies as an aggravated felony “relating to obstruction of justice” under 8 U.S.C. § 1101(a)(43)(S). The court held that the New Hampshire statute does not require a specific intent to interfere with legal process, a necessary element for the federal generic offense of obstruction of justice. Therefore, the statute criminalizes a broader range of conduct than the federal definition. The First Circuit vacated the BIA’s decision and remanded the case, concluding that the petitioner’s conviction does not render him removable under the aggravated felony provision. View "Bangs v. Blanche" on Justia Law

Cosel v. Wendt

2026-08-11T13:30:03-08:00

A woman and her husband, after marrying, received a parcel of real estate from her parents, which they held as tenants by the entirety in Massachusetts. They planned and undertook substantial renovations, initially funded by gifts from the husband’s parents. When those funds ran out, the husband’s parents provided over $1.5 million more, which was later documented as a loan in a promissory note signed only by the husband, not the wife. The couple’s marriage deteriorated, leading to divorce proceedings. During the divorce, the husband’s parents obtained a default judgment against the husband (but not the wife) for the loan and secured a writ of execution against his interest in the property, which was recorded. After the divorce, the family court awarded the property solely to the wife, free from any claim by the husband, and clarified that it could not adjudicate the parents’ rights under the promissory note. Subsequently, the husband’s parents transferred their judgment to a family trust, which noticed a sheriff’s sale of the husband’s purported interest in the property. The wife sued in state court to stop the sale, the case was removed to federal court, and both sides sought summary judgment. The United States District Court for the District of Massachusetts granted summary judgment to the wife, holding that the divorce and property distribution extinguished the creditor’s interest and that, even if the loan were valid, the wife was not jointly liable because the funds were not spent on “necessaries” under Massachusetts law. On appeal, the United States Court of Appeals for the First Circuit vacated the district court’s prediction of state law concerning the effect of divorce on a creditor’s interest and remanded for factual findings on the validity of the loan as to the wife. The court also found that neither preclusion nor the state’s domestic relations exception barred the wife’s challenge, and that factual disputes remained as to whether the loan was spent on necessaries. The court affirmed, reversed, and vacated in part, remanding for further proceedings. View "Cosel v. Wendt" on Justia Law

Woonasquatucket River Watershed Council v. USDA

2026-08-07T12:30:04-08:00

Several nonprofit organizations filed suit after President Trump issued an executive order and subsequent memorandum directing federal agencies to pause the disbursement of funds appropriated under the Infrastructure Investment and Jobs Act (IIJA) and the Inflation Reduction Act (IRA). The nonprofits, which had been awarded grants under these statutes, alleged that the “freeze” on funding had resulted in denial of financial assistance and disruption of their operations. The complaint named several federal agencies and officials, alleging violations of the Administrative Procedure Act (APA) and seeking declaratory and injunctive relief. The United States District Court for the District of Rhode Island found that the plaintiffs had Article III standing and rejected the government’s arguments regarding prior pending actions in other courts and the nature of the claims as contract disputes. The District Court determined that the challenged agency actions were not committed to agency discretion, likely constituted final agency actions, and were likely arbitrary and capricious under the APA. The court granted a preliminary injunction, ordering agencies to resume processing and payment of already-awarded funds and prohibiting further implementation of the funding freeze directives. The United States Court of Appeals for the First Circuit reviewed the case and affirmed much of the District Court’s order, finding that the nonprofits demonstrated standing and were likely to succeed on the merits of their APA claims. The Court held that the categorical funding freezes constituted final agency actions and that agencies failed to consider reliance interests, rendering their actions likely arbitrary and capricious. However, the Court vacated the portion of the order that directly compelled agencies to make monetary payments under contractual grants, finding it exceeded the District Court’s authority under the APA. The remainder of the injunctive relief was affirmed. View "Woonasquatucket River Watershed Council v. USDA" on Justia Law

Guzman v. Blanche

2026-08-07T12:30:03-08:00

A Salvadoran citizen entered the United States in May 2015 and was later apprehended by immigration authorities in July 2017. Removal proceedings were initiated, and she applied for asylum, withholding of removal, and protection under the Convention Against Torture. Her application described fear of harm from her sister’s former partner, who was associated with MS-13, and detailed prior robberies by gangs in El Salvador. She claimed threats and harm related to her urging her sister to report sexual assault perpetrated by the partner, who subsequently threatened her and her family. An Immigration Judge denied her claims for asylum and withholding of removal, finding the asylum application time-barred and determining there was no nexus between the violence she experienced and any statutorily protected ground, such as gender, familial ties, or political opinion. The judge found the robberies were motivated by financial gain and the threats by personal revenge, not by protected grounds. The judge also denied Convention Against Torture protection. The applicant appealed to the Board of Immigration Appeals, arguing the judge failed to properly consider mixed motives and humanitarian asylum. The Board dismissed the appeal, holding that she failed to show a protected ground was a central reason for the alleged harm and also denied humanitarian asylum for the same reason. The United States Court of Appeals for the First Circuit reviewed the agency’s decisions as a unit, applying substantial evidence review to factual findings and de novo review to legal conclusions. The court held that substantial evidence supported the agency’s determination that there was no nexus between the alleged persecution and a statutorily protected ground. Because this finding was dispositive, the petition for review was denied. The court also concluded that the lack of nexus foreclosed claims for humanitarian asylum and withholding of removal, and rejected ancillary due process claims. View "Guzman v. Blanche" on Justia Law

US v. Cooper

2026-08-06T13:30:05-08:00

In this case, a man working as a security guard in Massachusetts developed a relationship with a minor, J.C., initially meeting her when she was 15 and beginning a sexual relationship after she turned 16. Over time, their relationship became abusive and exploitative. The man coerced J.C. into prostitution in Massachusetts, using force and threats, and later took her to New York, where he continued to exert control over her, ultimately compelling her to work as a stripper using a false ID. The events spanned multiple states and involved both physical violence and psychological coercion. A grand jury in the District of Massachusetts indicted the defendant on three counts: sex trafficking of a minor, transportation of a minor for illegal sexual activity, and forced labor. The defendant raised several pretrial challenges, including claims that the indictment was duplicitous, that the evidence was insufficient, and that Massachusetts was not the proper venue for the forced labor charge. The United States District Court for the District of Massachusetts denied his motions to dismiss, and the case proceeded to trial. After the jury convicted the defendant on all counts, the district court denied post-trial motions and sentenced him to 216 months in prison. On appeal, the United States Court of Appeals for the First Circuit reviewed several issues. The court held that the sex trafficking statute listed alternative means of committing a single crime, not separate offenses, and found sufficient evidence to support the sex trafficking and transportation convictions. However, the court concluded that, because there was a factual dispute about whether Massachusetts was the proper venue for the forced labor charge, the issue of venue should have been submitted to the jury. The court thus vacated the forced labor conviction and remanded for further proceedings, while affirming the convictions on the other two counts. View "US v. Cooper" on Justia Law

US v. Andino-Arroyo

2026-08-04T12:30:04-08:00

The defendant was originally convicted in 2011 for conspiring to possess cocaine with intent to distribute and was sentenced to five years in prison and eight years of supervised release. Over the following years, he repeatedly violated conditions of his supervised release, resulting in three earlier revocations and terms of imprisonment. His violations included possessing ammunition as a felon, drug use, absconding from supervision, and failing to comply with location monitoring and curfew requirements. Each time, after serving additional prison terms and being given further chances under supervision, he committed new violations. On the fourth occasion, after again failing to comply with curfew and location monitoring, and absconding, the probation office reported his conduct to the court. The United States District Court for the District of Puerto Rico held a fourth revocation hearing. The defendant did not contest the alleged violations and, through counsel, acknowledged his record and expressed remorse. Both parties jointly recommended a fifteen-month prison term with no further supervised release. The district court, however, imposed the statutory maximum of thirty-six months’ imprisonment with no supervised release, citing the defendant’s repeated disregard for the law and failure to benefit from prior interventions. The United States Court of Appeals for the First Circuit reviewed the case. The defendant argued the sentence was procedurally and substantively unreasonable, and that the district court improperly considered impermissible punitive factors. The appellate court applied plain error review and concluded that the district court had adequately explained its reasons, emphasizing the defendant’s history and the need for deterrence, not retribution. The court held that the district court’s upward variance was justified by the defendant’s repeated noncompliance and affirmed the judgment. View "US v. Andino-Arroyo" on Justia Law

Rodriguez-Cotto v. Gonzalez-Colon

2026-08-04T12:30:04-08:00

After Puerto Rico experienced several states of emergency, including the COVID-19 pandemic, the government amended its public safety law, Law 20, specifically Article 5.14(a), to criminalize knowingly or recklessly disseminating false information about imminent catastrophes. The law applies during a governor-declared state of emergency or disaster and covers statements made through any medium, including social networks and mass media. Violation of the law can result in misdemeanor or felony charges, depending on the harm caused. Two independent journalists, who had published critical coverage of the government’s handling of emergencies, challenged the constitutionality of Article 5.14(a), arguing it violated their First Amendment rights. The United States District Court for the District of Puerto Rico reviewed the journalists’ claims. The court found Article 5.14(a) to be a content-based regulation, as it distinguished between true and false speech, and applied strict scrutiny. While the government’s interest in public safety was recognized as compelling, the court determined that the statute’s broad restrictions were not narrowly tailored, lacking meaningful limiting features and being both overinclusive and underinclusive. As a result, the district court issued a permanent injunction preventing enforcement of Article 5.14(a). The government’s motion for reconsideration was unsuccessful, leading to a timely appeal. The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court’s decision, holding that Article 5.14(a) is a content-based regulation subject to strict scrutiny, and does not fall within any traditional exceptions to First Amendment protection. The First Circuit found that the statute was not narrowly tailored to serve the government’s compelling interest in public safety and failed to demonstrate necessity or a direct causal link between the restriction and the harm prevented. The injunction against enforcement of Article 5.14(a) was affirmed. View "Rodriguez-Cotto v. Gonzalez-Colon" on Justia Law

North End Chamber of Commerce, Inc. v. City of Boston

2026-07-30T14:00:04-08:00

During the COVID-19 pandemic, the City of Boston implemented a temporary outdoor dining program that allowed restaurants across the city to use outdoor spaces for dining under relaxed licensing rules. In 2022, the City adopted a special plan for the North End neighborhood, which included higher fees, a shorter outdoor dining season, and additional restrictions compared to other neighborhoods. The City cited quality-of-life concerns, such as congestion and sanitation, and ongoing complaints from residents as reasons for the North End-specific rules. In 2023 and 2024, the City went further and banned on-street dining in the North End, while permitting it elsewhere. These actions prompted a group of North End restaurants and the local Chamber of Commerce to sue the City, alleging constitutional and state law violations. The United States District Court for the District of Massachusetts dismissed the plaintiffs’ lengthy complaint, finding that it violated Rule 8 of the Federal Rules of Civil Procedure by being excessively long and repetitive, and also determined that the complaint failed on the merits. The court denied the plaintiffs leave to amend, citing their multiple prior complaints and the substantive deficiencies in their claims. On appeal, the United States Court of Appeals for the First Circuit affirmed the dismissal of the federal constitutional claims (counts I–V) with prejudice, agreeing that the complaint was overly burdensome and failed to plausibly allege violations of equal protection, due process, or arbitrary action by the City. The Court held that disparate impact or political controversy alone does not suggest unconstitutional discrimination or retaliation, and the City’s actions had a rational basis. The First Circuit vacated the dismissal of the state law tax claim (count VI) and remanded with instructions to dismiss that claim without prejudice, as the federal court declined to reach its merits after disposing of the federal claims. View "North End Chamber of Commerce, Inc. v. City of Boston" on Justia Law

US v. Gonzalez

2026-07-30T14:00:03-08:00

An individual, born in 1937, assumed the identity of his younger brother, who died in infancy, to fraudulently obtain a second Social Security number and collect retirement benefits under both his own and his brother’s identities. Over the course of nearly two decades, he received Social Security payments in both names and also procured and used U.S. passports issued under his deceased brother’s identity. His scheme unraveled after a state motor vehicle official noticed similarities between two identification cards with different names but similar photos and addresses. Subsequent investigation revealed the use of both identities for benefits and travel, as well as submission of multiple passport applications with false information. A grand jury in the United States District Court for the District of Maine indicted the defendant on six counts, including identity theft, passport fraud, Social Security fraud, and mail fraud. At trial, the defendant contested the propriety of venue in Maine for two passport fraud counts and challenged the calculation of restitution. The district court submitted the venue question to the jury, which found venue proper for both passport counts and convicted him on all charges. He was sentenced to probation and ordered to pay $175,757 in restitution. Upon appeal, the United States Court of Appeals for the First Circuit reviewed the jury’s venue determinations and the restitution order. The court held that sufficient circumstantial evidence supported venue in Maine for both the false statement in the passport application and the use of a fraudulently obtained passport, applying the appropriate legal standards for each count. The court also found no abuse of discretion in the district court’s method for calculating restitution, concluding that the government met its burden of proof regarding the loss amount. The First Circuit affirmed both the convictions and the restitution order. View "US v. Gonzalez" on Justia Law

Kim v. Blanche

2026-07-30T14:00:03-08:00

A noncitizen who arrived in the United States from Cambodia as a child and later became a lawful permanent resident was convicted in Rhode Island state court in 1996 of a controlled substance offense. This conviction led to deportation proceedings, and an immigration judge found him deportable in 1998. The Board of Immigration Appeals (BIA) dismissed his appeal in 1999. Over twenty years later, the Rhode Island prosecutor dismissed his conviction in 2020, citing equitable reasons. The noncitizen then unsuccessfully filed his first motion to reopen his removal proceedings with the BIA, which denied it as untimely and found no substantive or procedural defect in the original conviction. Following this, the noncitizen obtained a consent order from the Rhode Island Superior Court in 2023, vacating his prior plea and sentence based on a violation of Rule 11 of the Rhode Island Rules of Criminal Procedure, which relates to due process in plea colloquies. In April 2024, he filed a second motion to reopen his removal proceedings with the BIA, this time invoking the BIA’s sua sponte authority. The BIA again denied reopening, treating the motion as statutory, finding it time and number barred, and concluding he failed to demonstrate due diligence or a defect in the conviction. On review, the United States Court of Appeals for the First Circuit found that the BIA committed legal error by mischaracterizing the second motion as statutory rather than sua sponte. The appellate court held that sua sponte motions are not subject to the same time and number limitations or equitable tolling standards as statutory motions. The court also found that the BIA erred by overlooking the Superior Court's order, which clearly indicated the conviction was vacated due to a procedural defect. The First Circuit granted the petition for review and remanded for further proceedings. View "Kim v. Blanche" on Justia Law

Grant v. Trial Court of the Commonwealth of Massachusetts

2026-07-24T13:30:04-08:00

A group of individuals who wished to protest outside a high-profile murder trial in Massachusetts were prohibited from doing so by a Superior Court judge’s order establishing a 200-foot buffer zone around the courthouse, including nearby sidewalks and streets. After the buffer zone was imposed, the plaintiffs—demonstrators—filed suit in federal court against various public officials and entities, alleging violations of their First Amendment and due process rights. The United States District Court for the District of Massachusetts initially denied a preliminary injunction against the buffer zone, but the United States Court of Appeals for the First Circuit vacated that denial and remanded, suggesting that a restriction more closely tailored to demonstrations intended to interfere with justice might be permissible. In response, the Superior Court judge amended the order to include a requirement of intent to interfere with the administration of justice or influence trial participants. The district court then partially granted and partially denied a renewed motion for a preliminary injunction: it found the revised order survived a facial First Amendment challenge but agreed with plaintiffs that there had been unconstitutional as-applied enforcement, granting limited relief. After the murder trial concluded and the buffer zone order expired by its own terms, the plaintiffs continued to appeal the denial of broader injunctive relief. The United States Court of Appeals for the First Circuit held that the case was moot because the order was no longer in effect and there was no reasonable expectation the same plaintiffs would again face a similar restriction. The court determined that neither injunctive nor declaratory relief was available and that the “capable of repetition, yet evading review” exception did not apply. As a result, the First Circuit vacated the district court’s partial denial of the preliminary injunction and ordered dismissal of that portion of the case, leaving the remainder to the district court. View "Grant v. Trial Court of the Commonwealth of Massachusetts" on Justia Law

US v. Irizarry-Irizarry

2026-07-24T13:30:04-08:00

A lawyer who served as a legal advisor to a Puerto Rican municipality and its mayor became involved in a scheme related to funds awarded to the municipality for trauma center renovations. The municipal legislature had created a for-profit corporation to promote economic development. Following the deposit of $9 million—traceable to the trauma center renovation funds—financial consultants persuaded the mayor to invest the money, promising it would benefit the municipality and be returned after generating interest. However, the consultants and associates, including the defendant, orchestrated a fraudulent transfer of the funds through multiple accounts and corporate entities. The defendant’s company received significant payments from these transactions, for which he fabricated invoices and provided no actual services. He used some of the money for personal expenses. When auditors later questioned the $9 million transfer, the defendant and others falsely asserted that the transaction was lawful and the funds were appropriately invested. A federal grand jury in Puerto Rico indicted the defendant and several others on charges including wire fraud conspiracy, substantive wire fraud, and money laundering. At trial in the United States District Court for the District of Puerto Rico, the defendant moved for judgment of acquittal based on insufficient evidence, but the court denied the motions. The jury found him guilty on all counts. The district court sentenced him to thirty-seven months’ imprisonment and denied his subsequent pro se motion for a sentence reduction. The United States Court of Appeals for the First Circuit reviewed the case. The court held that sufficient evidence supported the defendant’s convictions, as a reasonable jury could find he knowingly participated in a single overarching conspiracy to defraud the municipality. The court also held it lacked jurisdiction to review the denial of his sentence reduction motion because no notice of appeal was filed for that order. The court affirmed the convictions and dismissed the sentencing challenge. View "US v. Irizarry-Irizarry" on Justia Law

Recchia v. Campbell

2026-07-21T13:30:03-08:00

In this case, the owner of a Massachusetts gun store and the store itself challenged recent amendments to state law that prohibit the sale, transfer, or possession of certain "assault-style firearms" and related magazines. The plaintiffs argued that these provisions, enacted in 2024, violated their rights under the Second Amendment, the dormant Commerce Clause, and the Equal Protection Clause of the Fourteenth Amendment. They asserted that the law infringed on their ability to keep and bear arms, imposed unconstitutional burdens on interstate commerce by affecting out-of-state manufacturers and their own business, and discriminated against them compared to individuals and businesses in other states. The United States District Court for the District of Massachusetts granted the state defendants’ motion to dismiss for failure to state a claim. The district court concluded that the plaintiffs’ Second Amendment claim was foreclosed by the First Circuit’s earlier decision in Capen v. Campbell, which upheld a similar Massachusetts firearms ban. The court also found the plaintiffs’ dormant Commerce Clause and Equal Protection Clause claims inadequately pleaded, noting that the complaint did not plausibly allege discrimination against interstate commerce or that similarly situated persons were treated differently. The United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The First Circuit held that its prior decision in Capen v. Campbell controlled and that the challenged restrictions on assault-style firearms were consistent with the Nation’s historical tradition of firearm regulation and thus did not violate the Second Amendment. The court further held that the law did not discriminate against or impose an undue burden on interstate commerce, nor did it violate equal protection, as the right to make a living is not a fundamental right and the law had a rational basis. The district court’s judgment was affirmed. View "Recchia v. Campbell" on Justia Law

Rhode Island Truck Ctr., LLC v. Daimler Trucks North America, LLC

2026-07-17T08:30:02-08:00

A truck dealership and a manufacturer entered into a contract permitting the dealership to sell and service the manufacturer’s trucks in specified regions, with the manufacturer holding the right to appoint additional dealers in those regions at its sole discretion when it determined such appointments were warranted. The manufacturer appointed a new dealer within the dealership’s area, citing customer support needs and concerns about the dealership’s performance. Internal documents revealed the manufacturer had a plan to consolidate its dealer network for efficiency and improved sales, and had previously denied the dealership’s request to expand its franchise. Despite the appointment of the new dealer, the original dealership retained its nonexclusive right to sell trucks in its area. Prior to the current suit, the dealership protested before the Rhode Island Dealer Board, alleging statutory notice failures and bad faith denial of expansion, but the Board dismissed the protest as extraterritorial application of Rhode Island law. The dealership sought reversal in Rhode Island Superior Court, and the case was removed to the United States District Court for the District of Rhode Island, which granted summary judgment to the manufacturer. The United States Court of Appeals for the First Circuit affirmed summary judgment on certain claims and certified a question to the Rhode Island Supreme Court, which clarified statutory interpretation. Based on that, the First Circuit affirmed the district court’s summary judgment on the statutory-notice claim. Upon de novo review, the United States Court of Appeals for the First Circuit held that the manufacturer acted within its contractual discretion in appointing a new dealer, as the contract only required the manufacturer to have a reason related to its business objectives, not to market conditions. The court also held there was no breach of the implied covenant of good faith and fair dealing, as the manufacturer’s actions were consistent with the contract’s objectives. The court affirmed the district court’s grant of summary judgment in favor of the manufacturer. View "Rhode Island Truck Ctr., LLC v. Daimler Trucks North America, LLC" on Justia Law

Wilson v. Iguana Sport Services, Corp.

2026-07-15T12:30:04-08:00

Two hotel guests drowned while swimming in the ocean in front of a beachfront hotel in Carolina, Puerto Rico. Their family members, the plaintiffs, alleged that neither the hotel nor its contractor, Iguana Sport Services, Corp. (“Iguana”), provided warnings or safety measures regarding dangerous ocean conditions, despite rip current warnings being in effect at the time. Iguana had been contracted to provide towel and beach attendants for the hotel and held certain government permits to operate in the hotel’s beach area. The family members filed suit in the United States District Court for the District of Puerto Rico, naming the hotel, Iguana, and other related entities as defendants. After settling with all other defendants, the plaintiffs proceeded against Iguana. Iguana moved for summary judgment, arguing it had no duty—by contract, permit, or law—to warn or protect guests from ocean dangers. The district court granted summary judgment in favor of Iguana, finding it did not owe a duty of care to the deceased guests under any contractual, regulatory, or statutory basis, including the heightened duty of care sometimes imposed on innkeepers by Puerto Rico law. On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s decision. The plaintiffs argued Iguana owed a duty under its agreements, its government permit, and Puerto Rico’s heightened standard for innkeepers or similar entities. The First Circuit held that unresolved and outcome-determinative questions of Puerto Rico law existed regarding the scope and applicability of any heightened duty of care for entities like Iguana. The court therefore certified two dispositive legal questions to the Puerto Rico Supreme Court and retained jurisdiction pending that court’s response, rather than issuing a ruling on the merits at this time. View "Wilson v. Iguana Sport Services, Corp." on Justia Law

US v. Omoruyi

2026-07-15T12:30:03-08:00

Two brothers residing in Massachusetts used fake passports to open numerous bank accounts between 2019 and 2020, including accounts in their own names, names of fabricated individuals, and a fictitious company. These accounts were used to deposit funds acquired from romance scams targeting vulnerable victims and unemployment scams involving stolen identities. The brothers exchanged account information with each other and with overseas collaborators, and withdrew funds using debit cards linked to the fraudulent accounts. The FBI investigated after being alerted by victims, ultimately searching the brothers’ residences and storage facilities, where they found fake identification documents and related materials. A grand jury indicted the brothers in 2021 on charges of bank fraud, conspiracy to commit bank fraud, and conspiracy to commit money laundering. After an eight-day jury trial in the United States District Court for the District of Massachusetts, both were convicted on all counts. The district court sentenced Henry to seventy-eight months and Osaretin to seventy-two months of imprisonment, both with two years of supervised release. Restitution was deferred pending a hearing, after which the district court ordered both defendants to pay $615,805.65 in restitution, jointly and severally. The brothers appealed both their convictions and the restitution order. The United States Court of Appeals for the First Circuit reviewed the consolidated appeals, addressing challenges to the sufficiency of the evidence, jury instructions, sentencing enhancements, and restitution orders. The court held that the evidence was sufficient to support the convictions for bank fraud and conspiracy, that the jury instructions were not plainly erroneous or misleading, and that the sentencing enhancement for possession or use of authentication features was appropriate. The court also concluded that the district court had jurisdiction to issue the restitution order and did not err in making the defendants jointly and severally liable. Accordingly, the First Circuit affirmed the convictions and restitution orders. View "US v. Omoruyi" on Justia Law

Czerno v. General Electric Company

2026-07-14T13:30:03-08:00

A mother brought suit on behalf of herself and her minor son, alleging that the son developed leukemia after attending school near and residing close to a manufacturing plant operated by General Electric Company. The plant, located in Pittsfield, Massachusetts, produced electrical transformers and capacitors containing polychlorinated biphenyls (PCBs) for decades. The plaintiff claimed that GE’s use, disposal, and storage of PCBs caused the son’s illness, and sought recovery under various legal theories, including strict liability, negligence, fraudulent misrepresentation, nuisance, improper transportation of hazardous material, and loss of consortium. The complaint included claims related to the defective design and use of PCB materials, as well as their disposal and remediation. The plaintiff originally filed suit in Massachusetts state superior court. GE removed the case to the United States District Court for the District of Massachusetts, asserting federal officer removal jurisdiction under 28 U.S.C. § 1442(a)(1), based on its wartime production of PCB-containing devices for the federal government and its later remediation efforts pursuant to a consent decree with the EPA. The plaintiff moved to remand the case to state court, arguing that GE failed to meet the requirements for federal officer removal. The district court agreed, ordered remand, and stayed that order pending appeal. The United States Court of Appeals for the First Circuit reviewed the district court’s jurisdictional determination de novo. It held that GE satisfied both the “acting under” and “for or relating to” elements of the federal officer removal statute, due to its extensive work producing PCB-containing devices for the federal government. The court reversed the district court’s remand order and remanded the case for the district court to determine whether GE has a colorable federal defense. View "Czerno v. General Electric Company" on Justia Law

Adames-Garcia v. Divris

2026-07-14T13:30:03-08:00

A state prisoner challenged the denial of his federal habeas corpus petition after being convicted of several charges, including aggravated rape, in Massachusetts. The prosecution’s case was based on the victim’s testimony, physical evidence, and expert and witness accounts, while the defendant claimed the sexual encounter was consensual. During jury deliberations, seven not-guilty verdicts were returned on some charges, but deliberations continued on the remaining counts. After the weekend recess, a Facebook post by a former police officer urged community members to attend the next court session to support the victim, and a small demonstration took place at the courthouse with attendees wearing teal ribbons. The defense raised concerns about potential juror exposure to these influences, but the judge declined an individual juror inquiry, instead asking general questions about their ability to continue serving. Following conviction, the defense contacted jurors, and one juror reported seeing the Facebook post, being aware of the demonstration, and claimed that these factors led to greater weight being given to the victim’s testimony on the last day of deliberations. The trial court held an evidentiary hearing, found that some jurors were aware of the post and demonstration, but concluded that exposure was brief, not discussed during deliberations, and not prejudicial. The trial court specifically discredited the juror’s account of actual prejudice. The Massachusetts Appeals Court affirmed, and the Supreme Judicial Court declined review. In federal habeas proceedings, the U.S. District Court for the District of Massachusetts denied relief, holding that the state court’s examination of extraneous influence claims met federal constitutional standards and that its factual findings were owed deference. The United States Court of Appeals for the First Circuit affirmed, holding that the state court’s decision was neither contrary to nor an unreasonable application of clearly established Supreme Court precedent, and that its factual determinations were reasonable. The denial of habeas relief was affirmed. View "Adames-Garcia v. Divris" on Justia Law

Bruno Project Rescue, Inc. v. Centers for Disease Control and Prevention

2026-07-13T13:30:04-08:00

Several nonprofit organizations that rescue stray puppies from Caribbean islands and arrange for their adoption in the United States challenged a 2024 regulation issued by the Centers for Disease Control and Prevention (CDC). This regulation requires all dogs imported into the United States to be at least six months old, denying entry to younger dogs regardless of their country of origin. The CDC implemented this rule to prevent the reintroduction of rabies, citing both the difficulty of accurately assessing rabies risk and age in younger puppies and concerns about fraudulent documentation regarding the dogs’ origins and vaccination status. After the regulation was enacted, the plaintiffs argued that it exceeded the CDC’s statutory authority under 42 U.S.C. § 264(a) and was arbitrary and capricious under the Administrative Procedure Act. The United States District Court for the District of Massachusetts granted summary judgment to the CDC, finding the age requirement within the agency’s statutory authority as an inspection measure directly related to preventing the introduction of communicable diseases. The district court also concluded that the CDC had reasonably explained its rationale for the rule and had not acted arbitrarily. On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s judgment de novo, applying the standards articulated in recent Supreme Court decisions. The First Circuit held that the CDC’s age requirement is a permissible inspection measure under its statutory authority and is rationally connected to the goal of preventing rabies reintroduction. The court further held that the CDC’s decision was not arbitrary or capricious, as it considered relevant concerns and provided an adequate explanation, including addressing the plaintiffs’ reliance interests. Accordingly, the First Circuit affirmed the district court’s judgment. View "Bruno Project Rescue, Inc. v. Centers for Disease Control and Prevention" on Justia Law

Farid v. Trustees of Dartmouth College

2026-07-13T13:30:04-08:00

A professor at Dartmouth College’s Thayer School of Engineering, who is Muslim and of Arab-Egyptian descent, applied for tenure after six years of employment, consistent with his offer letter. He alleged that he was discouraged from advising a Muslim student group, removed from a research project, and denied access to campus data, which he believed impeded his work. His tenure application was reviewed by faculty who cited concerns about inflated accomplishments, high self-citation rates, less competitive grant funding, and poor teaching evaluations. The faculty voted overwhelmingly to deny tenure. An internal review committee found procedural errors in how the consequences of tenure denial were explained, allowing him to reapply, but found no discrimination. Separately, a student accused the professor of research misconduct for not crediting him as an author on a collaborative paper. An investigation committee ultimately found no research misconduct but concluded the professor’s conduct was unethical and recommended he not be allowed to collaborate with Dartmouth in the future. The United States District Court for the District of New Hampshire granted summary judgment to Dartmouth on all claims of discrimination and retaliation, finding no genuine issue of material fact. The professor appealed, challenging both the discrimination and retaliation rulings, as well as a discovery order. The United States Court of Appeals for the First Circuit reviewed the case de novo. It held that the plaintiff failed to provide sufficient evidence of pretext or discriminatory animus under both Title VII and New Hampshire’s employment discrimination statute. The court determined that differences in qualifications and procedural issues did not support an inference of discrimination or retaliation. The summary judgment was affirmed, and the challenge to the discovery order was deemed moot due to the affirmed judgment. View "Farid v. Trustees of Dartmouth College" on Justia Law

Buccieri v. Brewster Ambulance Service, Inc.

2026-07-13T13:30:03-08:00

John Buccieri, who is deaf and communicates primarily through American Sign Language, applied for a Chair Car Driver position with Brewster Ambulance Service, Inc., a medical transportation provider in Massachusetts. The job required frequent communications with dispatch, patients, and facility staff, as well as monitoring patients for emergencies. Buccieri requested to use Video Relay Services (VRS) and a phone holder as accommodations to facilitate communication with dispatch. Brewster considered his application and allowed him a ride-along in a Chair Car, but concerns arose about his ability to communicate and respond to emergencies, especially with patients and staff. Brewster ultimately declined to hire Buccieri, citing safety and operational concerns, and explored but rejected alternative positions for him. Buccieri sued Brewster in the United States District Court for the District of Massachusetts under the Americans with Disabilities Act (ADA), alleging failure to hire and failure to engage in the interactive process required by the ADA. The case proceeded to a jury trial, which found for Brewster on the failure-to-hire claim, concluding that accommodating Buccieri would have imposed an undue hardship or posed a direct threat. However, the jury found for Buccieri on the interactive process claim, indicating Brewster had not sufficiently engaged in dialogue to identify reasonable accommodations. Following the verdict, Brewster filed a Rule 50(b) motion for judgment as a matter of law. The district court granted the motion, setting aside the jury's finding on the interactive process claim, and entered judgment for Brewster on all counts. The United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the district court’s order. The court held that, based on the evidence, no reasonable jury could conclude that a reasonable accommodation existed that would have allowed Buccieri to perform the essential communications functions of the driver positions without undue hardship to Brewster. View "Buccieri v. Brewster Ambulance Service, Inc." on Justia Law

US v. Gonzalez-Arocho

2026-07-09T13:00:03-08:00

Federal agents in Puerto Rico were investigating the illegal exchange of child pornography in an online chatroom in 2021. Their investigation identified a phone number linked to Miguel González-Arocho and, through T-Mobile, they learned that this number was registered to a gray Apple iPhone 6s with a specific IMEI number. A Homeland Security Investigations agent applied for a search warrant based on probable cause, and a magistrate judge issued a warrant authorizing the search and seizure of the identified iPhone 6s. When executing the warrant, agents instead seized and searched an iPhone 13 belonging to González, which bore the same phone number but was a different device from the one specified in the warrant. The search uncovered over 100 files of child pornography on the iPhone 13. A grand jury indicted González for possession and receipt of child exploitation material. González moved to suppress the evidence found on the iPhone 13, arguing the warrant did not authorize a search of that device. The United States District Court for the District of Puerto Rico held an evidentiary hearing and found that the agents knowingly searched a device not covered by the warrant and that González had not validly consented to the search. The magistrate judge recommended denying the suppression motion under the good faith exception, but the district court disagreed, concluding the exception did not apply because the agents knew they were searching a different device and failed to obtain a new warrant. On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s decision to suppress the evidence. The court held that the good faith exception to the exclusionary rule did not apply because the agents, aware they had seized a different device than specified in the warrant, failed to take reasonable steps to resolve the discrepancy or seek a new warrant before searching the iPhone 13. View "US v. Gonzalez-Arocho" on Justia Law

Flaherty v. Amigos Del Mar LTD.

2026-07-08T11:00:03-08:00

In May 2019, a woman was severely injured during a scuba diving trip in Belize after an employee of a Belizean dive shop, who was not a certified dive master, pushed her off a boat owned by the company. As she entered the water, she was caught by the boat’s engaged propellers, causing significant injuries to her foot, ankle, and knee. She, along with her husband and son, filed a lawsuit in the United States District Court for the District of Massachusetts in August 2020, alleging maritime claims and asserting federal jurisdiction. The Belizean company was served under international procedures, and its founder acknowledged receipt. The company did not participate in the proceedings, leading the court to enter a default judgment against it in June 2021, and, after an evidentiary hearing, award over six million dollars in damages in February 2022. After the judgment, the plaintiff sought to enforce it in Belize, resulting in further default proceedings and an order to pay over seven million dollars, with enforcement actions against the company’s assets. The company eventually contested the judgment in Belize, and the Belizean court later set aside its own default judgment. In February 2024, about two years after the original U.S. judgment and nineteen months after the enforcement effort in Belize began, the company first appeared in the Massachusetts case, seeking to vacate the default judgment under Federal Rule of Civil Procedure 60(b)(4), arguing lack of jurisdiction. The United States Court of Appeals for the First Circuit reviewed whether the company’s motion to vacate was timely under Rule 60(c)(1), which requires such motions to be made “within a reasonable time.” Citing recent Supreme Court precedent, the First Circuit held that this timing requirement applies even to claims that a judgment is void for lack of jurisdiction. The court concluded the company’s nearly two-year delay was unreasonable and affirmed the district court’s denial of the motion. View "Flaherty v. Amigos Del Mar LTD." on Justia Law

Taylor v. Cao

2026-07-07T13:30:03-08:00

The appellant, a former Marine, sought to upgrade his 1986 discharge from “Other Than Honorable” to “Honorable.” He argued that his misconduct while in the service was the result of undiagnosed post-traumatic stress disorder (PTSD) and major depressive disorder, which he claimed were caused by racial harassment and traumatic experiences during his time in the Marine Corps. He supported his application with a psychologist’s assessment diagnosing him with PTSD and major depressive disorder linked to his service. The Board for Correction of Naval Records (BCNR) also considered an advisory opinion from a Navy psychologist, who concluded that while some of the appellant’s misconduct might be attributable to PTSD or depression, not all incidents were clearly connected. After the BCNR denied his request for a discharge upgrade, the appellant brought suit in the United States District Court for the District of Massachusetts. He argued that the BCNR did not apply Department of Defense guidance requiring liberal consideration for discharge-upgrade applications involving PTSD and that the Board failed to adequately explain its reasoning. The district court, applying an “unusually deferential” standard of review to the BCNR’s decision, found that the Board’s denial was supported by substantial evidence and not arbitrary or capricious. The court granted summary judgment for the Secretary of the Navy and denied the appellant’s motion for summary judgment. On appeal, the United States Court of Appeals for the First Circuit reviewed the administrative record de novo but accorded the BCNR “unusual deference” under governing law. The court held that the BCNR properly considered all relevant Department of Defense memoranda and the evidence linking the appellant’s mental health conditions to his misconduct. The court affirmed the district court’s judgment, concluding that the BCNR’s decision was neither arbitrary nor capricious and adequately explained. View "Taylor v. Cao" on Justia Law

Hernandez v. Blanche

2026-07-07T13:30:03-08:00

The plaintiff worked for over twenty years in various administrative roles for the Drug Enforcement Agency (DEA) in Puerto Rico, eventually becoming Secretary to the Assistant Special Agent in Charge. In 2016, after suffering a foot injury, she requested workplace accommodations, some of which were denied. She filed an Equal Employment Opportunity (EEO) complaint alleging discrimination based on disability and national origin. Subsequently, other DEA agents filed an EEO complaint against her, and she filed a retaliation complaint with the Department of Justice’s Office of the Inspector General. A series of workplace conflicts followed, including a verbal altercation, revocation of outside work permission, and eventual suspension. After further absence and issues with communication with supervisors, she was reassigned to another office. An internal investigation led to her termination for insubordination and alleged lack of candor. She appealed her termination to the Merit Systems Protection Board (MSPB), arguing it was retaliatory and unsupported by evidence. The MSPB found no lack of candor, but upheld the insubordination charge and her termination. She then sought judicial review in the United States District Court for the District of Puerto Rico, which denied her discovery motions and granted summary judgment to the government, finding no prima facie case of retaliation and holding that the MSPB’s decision was supported by substantial evidence. The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court’s rulings. The court held that the denial of the plaintiff’s Rule 56(d) motion for additional discovery was not an abuse of discretion, as she did not show good cause for her delay. On the merits, the court concluded that the MSPB’s finding of insubordination was supported by substantial evidence and that the plaintiff failed to show the employer’s stated reasons for termination were pretext for retaliation under Title VII. View "Hernandez v. Blanche" on Justia Law

US v. Johnson

2026-07-07T13:30:02-08:00

The defendant was investigated after law enforcement used a specialized tool called Freenet Roundup, which is a modified version of a peer-to-peer software called Freenet. Freenet allows users to share files anonymously, but its Opennet mode warns users that their identity could be discovered and their IP address is visible to strangers. Freenet Roundup, available only to law enforcement, logs requests for known child sexual abuse material (CSAM) and uses a formula to help identify whether a request came from an original source or was simply relayed. After Freenet Roundup flagged requests associated with the defendant’s IP address for CSAM, the FBI obtained a search warrant for his residence, finding devices containing child pornography. The defendant was charged in the United States District Court for the District of Massachusetts with possession of child pornography. Before trial, he moved to suppress the evidence, arguing that law enforcement’s use of Freenet Roundup constituted an unlawful Fourth Amendment search, as he claimed a reasonable expectation of privacy in his Freenet transmissions. The district court denied the motion, reasoning that because the defendant voluntarily used Freenet’s Opennet mode, which warns of identity risks and connections with strangers, he lacked a reasonable expectation of privacy in the relevant activity. The court distinguished this case from Carpenter v. United States, finding that law enforcement’s actions did not amount to wholesale surveillance or use of technology not in general public use. The defendant then entered a conditional guilty plea, preserving his right to appeal the suppression ruling. On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s findings for clear error and its legal conclusions de novo. The First Circuit held that a defendant lacks a reasonable expectation of privacy in activity voluntarily shared on publicly-available peer-to-peer networks like Freenet’s Opennet mode. The court affirmed the district court’s denial of the suppression motion. View "US v. Johnson" on Justia Law

US v. Rosado Maldonado

2026-07-06T13:00:04-08:00

Police officers in Worcester, Massachusetts, observed Joan Rosado Maldonado raise his arm before hearing a gunshot. Approaching the scene, they found Maldonado outside an apartment building and, upon searching him, discovered a loaded firearm in his satchel. Maldonado was indicted for being a prohibited person in possession of a firearm and ammunition under federal law. He pleaded guilty in March 2024. At sentencing, his prior convictions for trafficking in cocaine (2010) and possession with intent to distribute a Class B substance (2019), both under Massachusetts law, were considered in calculating his sentence. The United States District Court for the District of Massachusetts adopted the United States Probation Office's recommendation, assigning Maldonado a base offense level of twenty-four under the United States Sentencing Guidelines § 2K2.1(a)(2). This was based on the determination that his two prior convictions qualified as “controlled substance offenses.” The resulting guideline range was seventy to eighty-seven months’ imprisonment, and Maldonado was sentenced to sixty months in prison with three years of supervised release. The court also imposed various supervised release conditions, some of which Maldonado objected to, including restrictions on associating with persons possessing firearms. He timely appealed his sentence, arguing that his prior Massachusetts convictions did not categorically qualify as controlled substance offenses under federal law. The United States Court of Appeals for the First Circuit held that the term “controlled substance” in the relevant sentencing guideline refers only to substances regulated by the federal Controlled Substances Act, not by state law. Because Massachusetts included ioflupane as “cocaine” in its controlled substances list while federal law did not, Maldonado’s convictions were not a categorical match. The First Circuit vacated Maldonado’s sentence and remanded the case for resentencing. View "US v. Rosado Maldonado" on Justia Law

US v. Fulcar

2026-07-06T13:00:04-08:00

The defendant was indicted by a federal grand jury in Massachusetts on three counts: being a prohibited person in possession of a firearm and ammunition, and two counts of possession with intent to distribute controlled substances. The first drug count was based on drugs found during his arrest, and the second on drugs found at his residence during a search. He moved to suppress evidence seized from his home, arguing the search violated the Fourth Amendment, but the district court denied the motion, finding the search was conducted under a valid warrant and in good faith. He also sought dismissal of the firearm charge, claiming the statute was unconstitutional under the Second Amendment, but that motion was denied. He then pleaded guilty to all counts. The United States District Court for the District of Massachusetts grouped the convictions for sentencing under the United States Sentencing Guidelines. The presentence report applied several enhancements, including one for being a career offender based on prior convictions. The defendant objected, arguing he had only one qualifying conviction and that a 2008 Massachusetts conviction for possession with intent to distribute cocaine should not count, because the definition of “controlled substance” had changed under federal law. The district court rejected his objections, but stated it would have imposed the same sentence even if it had accepted his arguments. The court ultimately imposed a below-Guidelines sentence of 96 months. The United States Court of Appeals for the First Circuit held that the district court erred in applying the career offender enhancement because the relevant Massachusetts conviction did not qualify as a “controlled substance offense” under the Guidelines at the time of federal sentencing, since the substance at issue was no longer federally controlled. Nevertheless, the error was harmless because the district court made clear it would have imposed the same sentence regardless. The court affirmed the convictions and sentences. View "US v. Fulcar" on Justia Law

St. Dominic Academy v. Makin

2026-07-02T13:30:04-08:00

A Maine Catholic school, the Roman Catholic Diocese that operates it, and parents seeking to send their children there challenged several antidiscrimination provisions in Maine’s Human Rights Act (MHRA). The MHRA applies to schools receiving public tuition assistance and prohibits discrimination based on religion, sexual orientation, and gender identity. St. Dominic Academy, not currently receiving tuition assistance but eligible to do so, argued that these rules would require them to change admissions and employment policies central to their religious mission, including prioritizing Catholic students and requiring conformity with Catholic teachings. The school also objected to policies on gender identity that would compel the school to use students’ preferred pronouns and permit dress consistent with gender identity, potentially over parental objections. The United States District Court for the District of Maine denied St. Dominic’s request for a preliminary injunction, finding the school’s employment practices protected by MHRA carveouts and determining St. Dominic had not shown a likelihood of success on its other claims. The court also denied similar relief in a companion case brought by another religious school, and entered final judgment for the state officials. Reviewing the appeal, the United States Court of Appeals for the First Circuit affirmed in part and reversed in part. The court affirmed that St. Dominic lacked standing to challenge the employment rule, and that the challenges to the religious nondiscrimination and sexual orientation/gender identity rules were unlikely to succeed: these rules are neutral, generally applicable, and rationally related to legitimate state interests. However, the court reversed as to the “Religious Expression Rule,” finding it facially nonneutral and likely unconstitutional under the Free Exercise Clause. The First Circuit ordered entry of a preliminary injunction against enforcement of this rule as applied to St. Dominic. The parental-rights claim was deemed moot and remanded for dismissal. View "St. Dominic Academy v. Makin" on Justia Law

Crosspoint Church v. Makin

2026-07-02T13:30:03-08:00

A Christian church in Maine operates a private K–12 school that adheres closely to its religious beliefs, including requiring students and staff to conform to a statement of faith and specific codes of conduct and dress. The school is willing to admit students of any background if their families support its religious philosophy, but it maintains policies that exclude students who are openly gay or transgender and requires employees to be co-religionists. The school sought to participate in Maine’s tuition-assistance program, which allows public funds for private education in certain circumstances, but did not apply because of state nondiscrimination laws it believed would conflict with its religious practices. The United States District Court for the District of Maine denied the school’s motion for a permanent injunction against several provisions of the Maine Human Rights Act (MHRA), finding either no case or controversy or no constitutional violation. The case reached the United States Court of Appeals for the First Circuit after the parties stipulated to final judgment based on the preliminary injunction record, reserving all appellate rights. The United States Court of Appeals for the First Circuit reviewed whether the MHRA’s rules on employment, religious expression, religious nondiscrimination, and sexual orientation/gender identity nondiscrimination violate the First Amendment as applied to the school. The court held there was no case or controversy regarding the employment rule due to existing carveouts. It affirmed the district court’s rejection of the school’s challenges to the religious nondiscrimination and sexual orientation/gender identity rules, finding no constitutional violation. However, the court determined that the religious expression rule violates the school’s free-exercise rights and must be enjoined as applied to the school. The judgment was affirmed in part and reversed in part, and the case was remanded for entry of a permanent injunction against enforcement of the religious expression rule. View "Crosspoint Church v. Makin" on Justia Law

Calvary Chapel Belfast v. University of Maine System

2026-07-01T15:00:03-08:00

A religious nonprofit organization sought to purchase a former university campus property after being selected as the winning bidder in a competitive process conducted by a state university system. Following the public announcement of the award, there was significant public opposition to the sale, particularly due to the religious nature of the winning bidder. Two unsuccessful bidders filed administrative protests, raising both procedural and substantive objections, including criticism of the university's decision to sell to a religious organization. The university's designated official initially denied these protests, but upon further internal review, a higher-level administrator determined that a flaw in the bid evaluation process—specifically, the failure to consider cost-saving proposals for existing infrastructure—warranted rescinding the award and restarting the process. In the new round, the property was awarded to a different bidder who scored higher under revised criteria. The original winning bidder, the religious organization, challenged the university's decision in the United States District Court for the District of Maine, alleging violations of the Equal Protection and Free Exercise Clauses of the U.S. Constitution. The district court denied the plaintiff’s motions for a temporary restraining order and a preliminary injunction, finding that the plaintiff failed to show a likelihood of success on the merits of either claim. The court credited testimony that the university’s decision was motivated by cost-saving considerations rather than religious bias, and found no clear evidence of procedural irregularity or pretext. On appeal, the United States Court of Appeals for the First Circuit reviewed the denial of the preliminary injunction for abuse of discretion. The Court affirmed the district court’s decision, holding that the lower court applied the correct legal standards and did not clearly err in its factual findings. The Court concluded that the plaintiff failed to demonstrate a likelihood of success on the merits of its constitutional claims. View "Calvary Chapel Belfast v. University of Maine System" on Justia Law

Hernandez-Castrodad v. Steidel-Figueroa

2026-07-01T13:00:03-08:00

Plaintiffs had their property taken by the Commonwealth of Puerto Rico through eminent domain. They received over two million dollars in compensation, including interest accrued up to the time of payment. However, they alleged a second violation occurred when the court-administered disbursement process failed to notify them of further accrued interest and deducted a 15% administrative fee from that interest. They challenged these practices as unconstitutional takings and violations of due process, seeking declaratory and equitable relief against the Administrator of the Administration of Tribunals. The United States District Court for the District of Puerto Rico initially dismissed most claims, finding plaintiffs lacked standing because they had not alleged an attempt to withdraw the accrued interest, making their injury speculative. After reconsideration, the court revived the claim challenging the deduction of administrative fees, but limited relief to prospective injunctive relief due to Eleventh Amendment constraints. The court ultimately granted summary judgment to the defendant, finding the administrative fee reasonable and not an unconstitutional taking, as plaintiffs provided no evidence to the contrary. The United States Court of Appeals for the First Circuit reviewed the case and confronted jurisdictional issues arising from Puerto Rico’s Title III bankruptcy under PROMESA. The court held that the administrative fee claim was void for violating the automatic stay provisions, as it amounted to a demand for property of the debtor (the Commonwealth), and dismissed that portion of the appeal. Regarding the interest claim, the court affirmed the district court’s dismissal, ruling plaintiffs lacked standing because they failed to allege they sought disbursement or challenged existing procedures. The First Circuit thus dismissed the appeal from summary judgment and affirmed the district court's dismissal. View "Hernandez-Castrodad v. Steidel-Figueroa" on Justia Law

Lopez Collazo v. Ruiz-Feliciano

2026-06-30T12:00:03-08:00

After the 2020 mayoral election in Maricao, Puerto Rico, the Popular Democratic Party candidate, Wilfredo Ruiz-Feliciano, assumed office, replacing the New Progressive Party incumbent. Odette López Collazo, a longstanding NPP member who had served as Internal Auditor since 1994, was not reappointed by the new mayor. López Collazo alleged that her non-reappointment was due solely to her political affiliation and constituted political discrimination in violation of her First and Fourteenth Amendment rights. She also asserted related claims against other municipal officials regarding the failure to pay out her accrued leave, but only the claim against Ruiz-Feliciano for political discrimination remained at issue in this appeal. The United States District Court for the District of Puerto Rico granted summary judgment in favor of Ruiz-Feliciano. The court concluded that First Amendment protections against political discrimination did not apply to a decision not to hire or reappoint, and further reasoned that because the Internal Auditor position was a “trust” position under Puerto Rico law, the mayor could hire and fire at will, including for political reasons. López Collazo moved for reconsideration, which was denied, and then sought partial final judgment under Rule 54(b) to appeal. After resolving procedural questions regarding finality, all claims but the political discrimination claim against Ruiz-Feliciano were dismissed with prejudice, and the appeal proceeded. The United States Court of Appeals for the First Circuit reviewed the district court’s grant of summary judgment de novo. The Court of Appeals held that First Amendment protections do apply to a failure to hire or reappoint a public employee, and that legislative classification of a position as a “trust” position is not dispositive in determining whether political affiliation is an appropriate requirement. The appellate court vacated the district court’s summary judgment and remanded for further proceedings. View "Lopez Collazo v. Ruiz-Feliciano" on Justia Law

US v. Colon-Vazquez

2026-06-26T12:00:02-08:00

The case concerns a man who was found sleeping in a stolen vehicle by Puerto Rican police. Upon investigation, officers discovered that he possessed three firearms, two of which had been modified to function as machineguns, as well as a large quantity of ammunition, high-capacity magazines, ski masks, gloves, and other items often associated with criminal activity. He was charged with one count of possession of a machinegun under federal law and pled guilty pursuant to a plea agreement. The plea agreement anticipated a lower offense level and allowed the defendant to argue for an eighteen-month sentence, while the government agreed not to recommend more than twenty-four months. However, the United States Probation Office prepared a presentence report calculating a higher offense level, resulting in a Guidelines sentencing range of thirty to thirty-seven months. The defendant did not object to this calculation. At sentencing in the United States District Court for the District of Puerto Rico, both parties presented arguments, and the defendant personally expressed remorse. The district court, after reviewing the facts, the presentence report, and the parties' arguments, imposed a forty-eight-month sentence, representing an eleven-month upward variance from the Guidelines range. The court cited the quantity and type of firearms and ammunition, the presence of items commonly used in violent crime, and the high rate of violent crime in Puerto Rico as justifications for the variance. The United States Court of Appeals for the First Circuit reviewed the case. The court held that the district court did not commit procedural or substantive error. It found that the upward variance was adequately explained and justified, particularly by the significant quantity of ammunition and high-capacity magazines, and was consistent with precedent. The First Circuit affirmed the forty-eight-month sentence. View "US v. Colon-Vazquez" on Justia Law

Taker v. Blanche

2026-06-22T13:30:03-08:00

The case centers on Tyler Jon Taker, a resident of Maine, who became subject to a state court order for protection from abuse, which he agreed to. This order prohibited him from possessing firearms and certain other weapons until March 22, 2026. While the protective order was in effect, Taker applied for a concealed handgun permit, but his application was denied by the local police chief due to the existence of the order. Taker then filed a federal lawsuit against various federal, state, and local officials, seeking declaratory and injunctive relief from federal and state statutes that prohibit individuals with certain convictions or protective orders from possessing firearms. He also sought damages against the police chief under 42 U.S.C. § 1983 for the denial of his concealed carry permit. The United States District Court for the District of Maine dismissed Taker’s claims. The court found that Taker was not a law-abiding citizen due to his prior felony drug conviction and that the statutes prohibiting his possession of firearms were consistent with historical tradition and thus constitutional. The District Court did not specify whether it dismissed for failure to state a claim or lack of subject matter jurisdiction but appeared to rule on the merits. Taker appealed this dismissal. The United States Court of Appeals for the First Circuit reviewed the case. The court held that Taker lacked Article III standing to pursue declaratory and injunctive relief because the protective order itself independently barred him from possessing firearms, so the relief sought would not redress his alleged injury. As for the damages claim against the police chief, the court found that the chief was entitled to qualified immunity because Taker’s constitutional rights were not clearly established in this context. The First Circuit affirmed the dismissal of the damages claim, vacated the dismissal of the declaratory and injunctive claims, and remanded with instructions to dismiss those claims for lack of jurisdiction. View "Taker v. Blanche" on Justia Law

Alves-Pains v. Blanche

2026-06-18T09:30:03-08:00

A family from Brazil, consisting of a mother, her three children, and her husband, entered the United States without inspection in 2021. The mother applied for asylum, claiming past persecution and a well-founded fear of future persecution based on alleged abuse by the father of her eldest child during their relationship in Brazil. She proposed two particular social groups (PSGs) in support of her claim: “Brazilian women who are unable to leave relationships with the fathers of their children” and “perceived immediate family member of Gomes as mother in a nuclear family where the persecutor is the father and the child is I.F.G.P.” Her husband and children sought derivative asylum status and also filed their own applications for withholding of removal and protection under the Convention Against Torture, relying on her account. In removal proceedings before an Immigration Judge, the petitioners conceded inadmissibility. After a merits hearing, the Immigration Judge found the mother not credible regarding her abuse claims and denied all requested relief, ordering the family removed to Brazil. The Board of Immigration Appeals (BIA) dismissed their appeal, assuming the mother’s credibility but determining she was not a member of the first proposed PSG and that the second PSG lacked particularity. The petitioners did not seek review of the BIA’s initial decision. Instead, they filed a timely motion for reconsideration with the BIA, arguing errors in the BIA’s PSG analysis. The BIA denied reconsideration, finding no factual or legal error in its earlier decision. The petitioners then sought review in the United States Court of Appeals for the First Circuit. The First Circuit held that the BIA did not abuse its discretion in denying reconsideration. The court found substantial evidence supporting the BIA’s conclusions that the mother had not established membership in the PSGs and that the proposed groups were not cognizable. The petition for review was denied. View "Alves-Pains v. Blanche" on Justia Law

US v. Baxter

2026-06-16T13:30:03-08:00

Federal authorities investigated an individual in Massachusetts after monitoring his activity on Freenet, an internet-based peer-to-peer network known for anonymous file sharing. Law enforcement noted that a user at his IP address requested child pornography files. They obtained a search warrant and, upon execution, seized several electronic devices from the individual’s home. One device contained substantial evidence of child pornography, including images and videos of an identified minor in various states of undress, as well as internet activity linking the device to the individual. Following investigation, the United States filed criminal charges for possession, receipt, and production of child pornography. A grand jury returned indictments on all three counts. The individual moved to suppress evidence from the search, arguing the warrant lacked probable cause. The United States District Court for the District of Massachusetts denied this motion. At trial, a jury convicted the defendant on all charges. The district court then imposed sentencing enhancements for, among other things, a pattern of activity, use of a computer, vulnerable victim status, and obstruction of justice, resulting in a total sentence of 20 years for the production count and 14 years each for the receipt and possession counts, to be served concurrently. On appeal to the United States Court of Appeals for the First Circuit, the defendant challenged the denial of his suppression motion, the sufficiency and constitutionality of the production charge, certain evidentiary rulings, and the sentencing enhancements. The First Circuit reviewed each claim and rejected them, finding the search warrant was supported by probable cause, the evidence sufficient for conviction, § 2251(a) constitutional as applied, and no reversible error in evidentiary or sentencing rulings. The First Circuit affirmed both the conviction and sentence. View "US v. Baxter" on Justia Law

US v. Acevedo-Rodriguez

2026-06-16T13:30:03-08:00

Over the course of three weeks in late 2018, the defendant, along with accomplices, committed a series of violent crimes in Puerto Rico, including eleven Hobbs Act robberies (one attempted) and six carjackings (one attempted). The group’s crime spree ended after a failed gas station robbery in San Juan, during which an accomplice was shot by a security guard. The police investigation connected the defendant to the broader pattern of robberies and carjackings. He was indicted on multiple charges, including firearm offenses under 18 U.S.C. § 924(c). Pursuant to a plea agreement, he pleaded guilty to the robbery and carjacking counts, and one firearm count, in exchange for the government dismissing the remaining firearm charges and recommending a total sentence of 207 months. The United States District Court for the District of Puerto Rico initially sentenced the defendant to 207 months, consistent with the plea agreement. Following the Supreme Court’s decision in United States v. Taylor, which held that attempted Hobbs Act robbery is not a “crime of violence” under § 924(c), the defendant’s firearm conviction was vacated on collateral review. At resentencing, the district court again imposed a 207-month sentence for the remaining counts, despite a lower advisory Sentencing Guidelines range. The defendant appealed, challenging the substantive and procedural reasonableness of the sentence. The United States Court of Appeals for the First Circuit reviewed the case and affirmed the sentence. The court held that the district court did not commit procedural error, adequately explained its reasons for the upward variance, and properly considered both aggravating and mitigating factors. The appellate court further concluded that the sentence was substantively reasonable, given the seriousness and scope of the defendant’s conduct, and was not an abuse of discretion. View "US v. Acevedo-Rodriguez" on Justia Law

US v. da Conceicao-Level

2026-06-16T13:30:03-08:00

A Brazilian pilot, facing financial difficulties at his flight school, was recruited to transport mining equipment from Venezuela. Upon arrival, he discovered the job actually involved smuggling cocaine. Initially reluctant, he was persuaded by the recruiter’s promise of payment and the assertion that completing the flight was necessary to return home. The pilot and another individual stayed at a jungle encampment monitored by armed FARC soldiers, eventually agreeing to fly cocaine to Puerto Rico. After landing, law enforcement, who had coordinated a months-long sting operation, arrested both men and seized the drugs and a large military-style hunting knife from the plane. The United States District Court for the District of Puerto Rico indicted both individuals on six counts related to drug trafficking and importation. The pilot entered a straight guilty plea and was sentenced to 135 months in prison, after the court applied a sentencing enhancement for possession of a dangerous weapon, denied a reduction for a mitigating role, and declined a downward departure for duress. The co-defendant pled to a lesser charge and received a lighter sentence. On appeal, the United States Court of Appeals for the First Circuit reviewed three sentencing issues: the dangerous weapon enhancement, the denial of the mitigating role adjustment, and the denial of a duress departure. The court affirmed the application of the dangerous weapon enhancement and the denial of the duress departure, finding no clear error. However, it determined that the district court erred in its analysis of the mitigating role by failing to consider the broader universe of participants in the drug conspiracy, as required under recent precedent. The First Circuit vacated the pilot’s sentence and remanded for resentencing consistent with its opinion. View "US v. da Conceicao-Level" on Justia Law

Hernandez Zorilla v. FOMB

2026-06-12T12:30:04-08:00

Two individuals attended a demonstration in San Juan, Puerto Rico, on May 1, 2018, where they allege that officers of the Puerto Rico Police Bureau used excessive force against them, including the use of tear gas and rubber bullets. In April 2019, they filed lawsuits in the United States District Court for the District of Puerto Rico, asserting violations of their constitutional rights and seeking both injunctive and monetary relief. The suits named the then-Governor and other officials and employees of the Commonwealth, including police officers, as defendants, with claims brought against some defendants in their personal capacities. During this time, the Commonwealth of Puerto Rico was undergoing bankruptcy-like restructuring under Title III of PROMESA, and, in 2022, the Title III court confirmed a Plan of Adjustment, which discharged certain claims against the Commonwealth and enjoined pursuit of those claims. The district court stayed the plaintiffs’ lawsuit pending a determination of whether the Plan discharged their claims. On September 30, 2025, the Title III court held that the Plan did not discharge personal-capacity claims against Commonwealth officials or employees, thus allowing the plaintiffs to proceed. The Financial Oversight and Management Board appealed this decision. The United States Court of Appeals for the First Circuit reviewed the Title III court’s factual findings for clear error and its legal conclusions de novo. The appellate court held that the discharge and related injunction in the confirmed Plan of Adjustment do not apply to claims against Commonwealth officers or employees sued in their personal capacities. The court reasoned that discharging such claims would amount to a non-consensual third-party release, which the Plan expressly does not provide. Accordingly, the First Circuit affirmed the Title III court’s decision in full. View "Hernandez Zorilla v. FOMB" on Justia Law

US v. McKenzie

2026-06-12T12:30:04-08:00

Federal law enforcement agents in the Boston area conducted an undercover operation targeting individuals seeking commercial sex with minors. An agent posted an online advertisement that led Dimitri McKenzie to initiate contact, during which the agent represented that two girls, aged fourteen and twelve, were available. Although McKenzie initially expressed disinterest in underage individuals, he later agreed to meet with “Bri,” the purported fourteen-year-old, negotiated a price, and went to a hotel with cash, where he was arrested. “Bri” did not exist; the entire operation was a sting. At trial, the government relied on communications between McKenzie and the agent, and McKenzie testified in his own defense, claiming he intended only to help, not to purchase sex. A federal grand jury indicted McKenzie in the United States District Court for the District of Massachusetts for attempted sex trafficking of a child under 18 U.S.C. §§ 1591 and 1594. The jury found him guilty after deliberation. The district court entered judgment and sentenced him to 126 months’ imprisonment. McKenzie appealed, challenging the sufficiency of the evidence, the jury instructions regarding mens rea, the refusal to give an entrapment instruction, various evidentiary rulings, and the language of the judgment affecting his eligibility for time credits. The United States Court of Appeals for the First Circuit reviewed the case and affirmed the conviction. The court held that for attempted sex trafficking of a minor, the government need only prove the defendant either believed or recklessly disregarded a substantial and unjustifiable risk that the person solicited was under eighteen, even if no actual minor existed. The court also found no error in the district court’s refusal to give an entrapment instruction or in the challenged evidentiary rulings. Finally, the court clarified that McKenzie’s conviction was under 18 U.S.C. § 1594, making him eligible for First Step Act time credits. View "US v. McKenzie" on Justia Law

Cortes-Ramos v. Martin-Morales

2026-06-12T12:30:03-08:00

After participating in a songwriting contest co-sponsored by Sony and a well-known Puerto Rican singer, the plaintiff submitted an original song and accompanying music video for consideration. Upon advancing as a finalist, the plaintiff was asked to sign documents related to contest participation. Another entrant was ultimately selected as the contest winner. Later, the defendant released a song and video that the plaintiff claimed were substantially similar to his contest submission, leading the plaintiff to file suit for copyright infringement and allege fraudulent inducement into the contest. Following extensive procedural history, including several prior appeals and a Supreme Court decision clarifying when copyright owners may sue, the United States District Court for the District of Puerto Rico dismissed the plaintiff’s earlier complaint without prejudice due to the timing of his copyright registration. The plaintiff then filed a new action, again asserting copyright infringement. The defendant responded with counterclaims challenging the validity of the plaintiff’s copyright registration and moved for summary judgment, arguing that the plaintiff had assigned his copyright to Sony by agreeing to the contest’s rules. The district court adopted a magistrate judge’s recommendation granting summary judgment to the defendant, dismissed the plaintiff’s remaining claims, and invalidated the plaintiff’s copyright registration, all without permitting discovery. On appeal, the United States Court of Appeals for the First Circuit held that the district court abused its discretion by granting summary judgment and invalidating the copyright registration without affording the plaintiff a fair opportunity to conduct discovery, particularly since the relevant evidence was largely under the defendant’s and Sony’s control. The First Circuit vacated the district court’s summary judgment order and the invalidation of the copyright registration, remanding the case for further proceedings to allow discovery. View "Cortes-Ramos v. Martin-Morales" on Justia Law

Santos-Pagan v. Bayamon Medical Center

2026-06-11T13:30:03-08:00

A former patient of a hospital in Bayamón, Puerto Rico, alleged that her personally identifiable and health information was compromised in a ransomware attack that affected over half a million patients. She received a notice letter from the hospital confirming the breach but stating that, although files were accessed and encrypted, there was no indication that patient information had been used by unauthorized persons. Subsequently, she filed a putative class action in federal court, claiming that the breach resulted from the hospital’s failure to properly safeguard patient data. She asserted that this failure exposed her and others to risks such as identity theft, required them to spend time and incur expenses mitigating potential harm, and diminished the value of their information. The United States District Court for the District of Puerto Rico, after several rounds of amended complaints and motions, dismissed the claims for lack of Article III standing. The district court found that the plaintiff’s complaint did not plausibly allege that her alleged injury—such as the discovery of a fraudulent cellphone account opened in her name—was traceable to the hospital’s data breach. Attempts to add further allegations or conduct jurisdictional discovery were denied as futile. On appeal, the United States Court of Appeals for the First Circuit reviewed whether the plaintiff had adequately pleaded both an injury in fact and traceability for standing. The court held that, while the complaint sufficiently alleged an injury in fact by describing actual misuse of her information, it failed to plausibly connect that harm to the hospital’s data breach. The court found no specific facts to support a temporal or factual link between the breach and the fraudulent activity. As a result, the First Circuit affirmed the dismissal of all claims for lack of standing. View "Santos-Pagan v. Bayamon Medical Center" on Justia Law

Crawford v. Salve Regina University

2026-06-11T13:30:02-08:00

A tenured professor at a university was terminated in 2022 following a classroom incident where students objected to terminology used in an assigned reading and a subsequent discussion of LGBTQ+ rights in Latin America. The professor alleged that her Department Chair encouraged students to submit complaints against her, and that there was a coordinated effort to undermine her reputation. After complaints were submitted, the university held a student meeting about the professor’s conduct, restricted some of her duties, and ultimately terminated her employment "for cause," citing continued misconduct and failure to fulfill faculty responsibilities. The professor appealed her termination to the Faculty Hearing Board, which upheld the decision by a narrow margin, citing procedural issues but attributing them to outdated dismissal procedures rather than prejudice. The Board found her teaching was not culturally responsive and noted longstanding concerns about her interaction with students. The minority opinion of the Board disagreed, finding the process unfair. The university’s Board of Trustees unanimously affirmed the termination. The professor then filed a verified complaint in Rhode Island Superior Court against the university, its Board of Trustees, and several colleagues. She alleged violations of federal and state anti-discrimination laws, as well as state tort and contract claims related to her termination. The university removed the case to the United States District Court for the District of Rhode Island and moved to dismiss. The district court dismissed the federal and state anti-discrimination claims for failure to state a claim, finding insufficient factual allegations connecting protected characteristics to the termination. The court declined to exercise supplemental jurisdiction over the state claims and remanded them to state court. On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s judgment. The First Circuit held that the professor failed to plead sufficient facts to make her discrimination, hostile work environment, and retaliation claims plausible, and found no error in the district court’s consideration of certain documents. View "Crawford v. Salve Regina University" on Justia Law

US v. Daigle

2026-06-10T14:00:03-08:00

Law enforcement conducted a lengthy investigation into Freenet, a peer-to-peer network used for sharing files, including child pornography. Using a modified version of Freenet, officers identified that a computer with an IP address linked to a Waltham, Massachusetts residence requested blocks for three files known to contain child pornography within a ten-minute period. The software required users to obtain specific keys and take multiple steps to access such files. Nine months after these requests, officers applied for and executed a search warrant at the residence, which belonged to Robert Daigle, and found files containing child pornography. A grand jury indicted Daigle for receipt of child pornography in violation of federal law. Daigle moved to suppress evidence obtained during the search, arguing that the warrant affidavit lacked probable cause and that the information was stale due to the nine-month gap between the file requests and the search. The United States District Court for the District of Massachusetts denied the motion, finding probable cause and rejecting the staleness argument, while also holding that the good-faith exception to the exclusionary rule would apply. Daigle entered a conditional guilty plea, preserving his right to appeal the suppression ruling. The United States Court of Appeals for the First Circuit reviewed the district court's legal conclusions de novo. The appellate court held that the totality of the circumstances, including the multi-step process required to request files on Freenet and the fact that three requests for known child pornography files were made in quick succession, established a fair probability that evidence of child pornography would be found at Daigle’s residence. The court also determined that the information was not stale, as it was reasonable to infer that evidence would remain on Daigle’s computer nine months later. The court affirmed the district court’s denial of Daigle’s motion to suppress. View "US v. Daigle" on Justia Law

US v. Rodriguez-Reyes

2026-06-10T14:00:02-08:00

In this case, the defendant participated in a violent drug trafficking conspiracy centered in a San Juan public housing project. After the prior leader’s arrest, the defendant expanded his marijuana sales, carried firearms, and used violence to protect and grow his operation. This included involvement in a drive-by shooting that killed three people and the murder of a rival drug dealer. Following his arrest, a jury convicted him of conspiracy to possess with intent to distribute marijuana and over 50 grams of crack cocaine, as well as conspiracy to possess and use firearms in furtherance of those crimes. The United States District Court for the District of Puerto Rico sentenced him to life imprisonment on the drug conspiracy count, applying the Sentencing Guidelines’ murder cross-reference due to the killings, and ten years for the firearms offense, to be served consecutively. The United States Court of Appeals for the First Circuit previously affirmed both the conviction and the sentence. Many years later, the defendant moved for a sentence reduction under the First Step Act, arguing that changes made by the Fair Sentencing Act (incorporated by the First Step Act) retroactively reduced the statutory penalties for his offense. The district court denied the motion, concluding he was not eligible because the Fair Sentencing Act was already in effect at his sentencing, and, in the alternative, declined to reduce the sentence considering the seriousness of his crimes. Upon review, the United States Court of Appeals for the First Circuit affirmed the district court’s decision. The court held that even assuming eligibility for relief under the First Step Act, the district court did not abuse its discretion in denying a sentence reduction after weighing the statutory sentencing factors, the defendant’s rehabilitative efforts, and the grave nature of his criminal conduct. The appellate court found the lower court’s reasoning was adequately discernible from the record. View "US v. Rodriguez-Reyes" on Justia Law

US v. Maldonado-Maldonado

2026-06-08T13:30:02-08:00

In August 2020, while incarcerated at the Metropolitan Detention Center in Guaynabo, an individual assaulted a senior corrections officer with the assistance of his cellmate. The officer sustained injuries to his head and neck and experienced persistent headaches. The assailant was charged with assaulting, resisting, or impeding a federal officer. He eventually entered a guilty plea, and as part of a plea agreement, both he and the government proposed a sentencing range of 18 to 24 months, based on the guideline for obstructing or impeding officers. However, a presentence investigation report recommended a significantly higher range, relying on evidence from his cellmate’s trial and applying the aggravated assault guideline. The United States District Court for the District of Puerto Rico initially imposed a 78-month sentence, adopting the higher guideline calculation and enhancements from the presentence report, despite the plea agreement. On appeal, the United States Court of Appeals for the First Circuit found that the government had breached the plea agreement by advocating for the higher guideline at sentencing. The appellate court vacated the sentence and remanded the case for resentencing before a different judge, but declined to instruct the court to impose a sentence of time served. At resentencing, the government honored the plea agreement and advocated for a sentence of time served, consistent with the original agreement. The district court, however, relied on information about recent disciplinary violations not disclosed in the presentence report or to the defense, referencing them as evidence of poor rehabilitation prospects and a high risk of recidivism. The court imposed a 71-month sentence. On appeal, the United States Court of Appeals for the First Circuit held that the district court erred by relying on undisclosed, extra-record information in sentencing, vacated the sentence, and remanded for resentencing before a different district court judge. View "US v. Maldonado-Maldonado" on Justia Law

Premca Extra Income Fund LP v. Angle

2026-06-05T13:30:03-08:00

A robotics company, whose primary product is a well-known robot vacuum, agreed in August 2022 to be acquired by a major online retailer. Over the next eighteen months, the companies sought approval for the merger from regulatory authorities in the United States and Europe. In January 2024, facing significant regulatory obstacles, the parties abandoned the merger. Following this, shareholders of the robotics company, led by an investment fund, brought a securities fraud class action against the company’s CEO and CFO. They alleged that during the merger’s review period, company statements misrepresented or omitted material information regarding the likelihood of regulatory approval, particularly concerning the company’s expectation of approval and the acquirer’s cooperation with regulators. The United States District Court for the District of Massachusetts dismissed the amended complaint with prejudice. The court found that the plaintiffs failed to identify any actionable material misrepresentation or omission and did not adequately allege scienter (the intent or knowledge of wrongdoing). During the appeal, the robotics company entered Chapter 11 bankruptcy, resulting in its dismissal from the appeal, which continued as to the individual defendants. The United States Court of Appeals for the First Circuit reviewed the case. It agreed with the district court that the complaint failed to state a claim for most of the statements challenged by the plaintiffs, affirming dismissal as to those. However, the court found that the amended complaint plausibly alleged that an August 24, 2023, proxy statement expressed an opinion about expected regulatory approval while omitting important contrary information regarding European regulatory concerns and the acquirer’s refusal to cooperate. This omission, in the circumstances, was sufficient to state a claim as to that statement. The dismissal was reversed in part and affirmed in part, and the case was remanded for further proceedings. View "Premca Extra Income Fund LP v. Angle" on Justia Law

Jordan v. Lizotte

2026-06-05T13:30:03-08:00

In September 2002, Dennis Jordan and seven others attempted to enter an after-hours party in Brockton, Massachusetts. After being removed from the entry line by a bouncer, a violent altercation occurred during which gunshots were fired, injuring three bouncers and paralyzing one. Jordan was seen by the bus driver, Jerial Wilson, shortly after the shooting, wielding a handgun and instructing the driver to leave the scene. Jordan was arrested less than a month later and, during booking, made several statements to police suggesting knowledge of the crime and the weapon involved. Jordan was indicted in Massachusetts on multiple counts, including armed assault with intent to murder and firearms offenses. He was first convicted in 2005, but a new trial was ordered due to missing transcripts. At his retrial in 2013, Jordan was again convicted on all counts. The Massachusetts Appeals Court affirmed his conviction and the Massachusetts Supreme Judicial Court denied further review. Jordan then filed a habeas corpus petition in the U.S. District Court for the District of Massachusetts, which denied relief. Jordan appealed to the United States Court of Appeals for the First Circuit. The First Circuit reviewed Jordan’s claims that his counsel was ineffective for failing to request an eyewitness identification instruction, that the trial court improperly limited his cross-examination of the bus driver, and that the prosecution withheld exculpatory evidence. The court found that the Massachusetts Appeals Court’s determinations were not unreasonable applications of clearly established federal law under the Antiterrorism and Effective Death Penalty Act. The First Circuit held that no fairminded jurist would be compelled to find a reasonable probability of a different outcome absent the alleged errors. The court affirmed the denial of Jordan’s habeas petition. View "Jordan v. Lizotte" on Justia Law

Muchiri v. Blanche

2026-06-03T13:00:04-08:00

A Kenyan national was served with a notice to appear for removal proceedings in Massachusetts, charged with overstaying his visa. During removal proceedings before an Immigration Judge (IJ), he applied for asylum, humanitarian asylum, withholding of removal, and relief under the Convention Against Torture, claiming abuse by his father, a member of the Mungiki group in Kenya. The IJ found him credible and determined he suffered past persecution due to his family, but concluded that the presumption of future persecution was rebutted because he was now an adult, no longer under his father's control, and because country conditions in Kenya had changed. The IJ also denied humanitarian asylum and withholding of removal, citing insufficient severity of past harm or likelihood of future harm, and noted that, even if eligible, relief would be denied on discretionary grounds due to the petitioner’s criminal history in the United States. The petitioner appealed to the Board of Immigration Appeals (BIA), which dismissed his appeal. He then moved for reconsideration, asserting that the BIA overlooked his claims that he reasonably feared persecution by Kenyan officials on account of family status or ethnicity. The BIA granted the motion to reconsider but again dismissed the appeal, finding the past harm occurred only during childhood and upholding that changed country conditions rebutted any presumption of future persecution. It also reaffirmed denial of humanitarian asylum and CAT protection. The United States Court of Appeals for the First Circuit reviewed both BIA decisions. The court held that the BIA’s decisions did not adequately explain whether it addressed the petitioner’s arguments regarding a reasonable fear of future persecution by Kenyan police due to his family or ethnic status. The court vacated the BIA’s orders and remanded for further proceedings consistent with its opinion. View "Muchiri v. Blanche" on Justia Law

US v. Maldonado

2026-06-02T10:30:03-08:00

A 55-year-old registered sex offender initiated contact with someone he believed was a 13-year-old girl on a social networking site, but who was actually a law enforcement officer conducting an online sting operation. Over two days, he exchanged hundreds of text messages with the purported minor, quickly engaging in sexually explicit conversations, sending obscene images and videos of himself, and soliciting nude photos. He discussed meeting in person for sexual activity. The investigation revealed that he used an unauthorized phone while under probation. He was arrested, and federal authorities recovered evidence from his devices. Initially indicted on three charges in April 2019 in the United States District Court for the District of Rhode Island, he was later charged in a four-count superseding indictment in May 2023. Pursuant to a plea agreement, he pled guilty to three counts—attempting to entice a minor, attempting to transfer obscene material to a minor, and committing these offenses while a registered sex offender—with the government dismissing the newly added charge. The presentence report recommended a Guidelines Sentencing Range (GSR) of 382 to 447 months. The defendant requested a downward variance to the statutory minimum, citing personal hardships and a clinical evaluation indicating moderate risk of reoffending. The government recommended the maximum within the GSR. The district court sentenced him to 447 months, emphasizing public protection and his history of sexual offenses. The United States Court of Appeals for the First Circuit reviewed the case. The court held that the defendant’s unconditional guilty plea waived his right to challenge alleged prosecutorial misconduct in the grand jury proceedings. His ineffective assistance of counsel claim was dismissed without prejudice, as such claims typically require collateral review. Procedural objections to sentencing were found unpreserved and thus waived. The court found the sentence substantively reasonable given the facts, and affirmed the judgment of the district court. View "US v. Maldonado" on Justia Law

US v. Pilson

2026-06-01T13:30:03-08:00

Stephen Pilson was convicted in federal court for kidnapping his then-girlfriend, Rilka Stefanov, and for violating an interstate protective order. The events began in October 2019 when Pilson assaulted Stefanov, forced her into a car, and threatened her while driving across state lines. After his conviction and incarceration in Massachusetts for these offenses, and following the imposition of a “No Contact Order,” Pilson was released. Stefanov retrieved him from jail, and a few days later, Pilson again drove her across state lines, threatened her life, physically assaulted her, and attempted to restrain her. Stefanov ultimately escaped and Pilson was apprehended in Maine. A federal grand jury indicted Pilson for kidnapping under 18 U.S.C. § 1201(a)(1) and for violating 18 U.S.C. § 2262(a)(1) concerning the protective order. Pilson moved for acquittal, arguing insufficient evidence of kidnapping across state lines and contesting whether the Massachusetts “No Contact Order” qualified as a federal “protection order,” since Stefanov opposed it. The United States District Court for the District of Maine denied the acquittal motion, instructed the jury that the order was a protection order as a matter of law, and the jury convicted Pilson on both counts. At sentencing, the court applied an enhancement for obstruction of justice based on Pilson’s attempts to influence Stefanov’s testimony. On review, the United States Court of Appeals for the First Circuit affirmed. The court held that sufficient evidence supported the kidnapping conviction, as a reasonable jury could find Stefanov withdrew consent before crossing state lines. The court also held that the “No Contact Order” was a protection order under federal law, regardless of the victim’s later opposition, and found no error in the jury instructions. The sentencing enhancement was upheld as harmless error, since the district court stated it would have imposed the same sentence regardless. View "US v. Pilson" on Justia Law

Buckley v. Blanche

2026-05-29T13:30:04-08:00

A Colombian citizen faced removal proceedings initiated by the Department of Homeland Security for overstaying a visa that expired in 2005. She conceded removability but sought adjustment of status based on an approved family-based visa petition filed by her adult son. At her immigration hearing, she testified about her long-term residence in the United States, her family ties, and two past criminal charges—one dismissed shoplifting charge in Tennessee and another dismissed assault charge in Massachusetts involving her daughter. Despite her credibility and supporting documentation, the immigration judge denied her application for adjustment of status, citing concerns about her past criminal acts, lack of remorse, and insufficient explanation regarding the incidents. Her attorney timely filed a notice of appeal to the Board of Immigration Appeals but failed to submit a promised brief, later seeking to file it late due to an inadvertent calendaring error. The BIA denied the motion to accept the late brief and dismissed her appeal, concluding that she had not meaningfully addressed favorable equities in the discretionary analysis. Subsequently, she moved to reopen her appeal, arguing ineffective assistance of counsel due to her attorney’s failure to file a brief. The BIA denied this motion, citing failure to comply with procedural requirements, lack of prejudice, and not submitting the brief as an attachment. Reviewing these decisions, the United States Court of Appeals for the First Circuit denied the petition challenging the BIA’s dismissal of her appeal, finding it lacked jurisdiction to review discretionary decisions regarding adjustment of status. However, the court granted the petition challenging the denial of the motion to reopen, holding that the BIA abused its discretion by failing to adequately explain its reasoning, overlooking a reasonable probability of prejudice from counsel’s ineffectiveness, and disregarding substantial arguments pertinent to the IJ’s record-building duty. The case was remanded for further proceedings. View "Buckley v. Blanche" on Justia Law

US v. Garcia-Toro

2026-05-29T13:30:03-08:00

Police apprehended the defendant after discovering him in possession of a machine gun while he was on supervised release for a prior federal weapons offense. He entered into a plea agreement with the government, pleading guilty to illegal possession of a machine gun under 18 U.S.C. § 922(o). As part of the plea deal, both the defendant and the government agreed to jointly recommend a sentence within the applicable guidelines range of 27 to 33 months, with the defendant limited to arguing for the low end and the government for the high end. The final sentencing decision was left to the discretion of the judge. The United States District Court for the District of Puerto Rico accepted the plea agreement but ultimately imposed a 48-month sentence, exceeding the guidelines range. The defendant did not challenge the substantive reasonableness of his sentence nor the order revoking his supervised release, but instead appealed, contending that the government breached the plea agreement by providing only superficial support for a guidelines sentence and implicitly encouraging the judge to impose a higher sentence. On appeal, the United States Court of Appeals for the First Circuit reviewed the claim under the plain error standard, as the defendant had not raised the issue before the district court. The appellate court held that even if there were any error, it was not clear or obvious under current law. The court found that the government did not breach the plea agreement, as it expressly recommended a within-guidelines sentence and did not undermine the agreement through its arguments or advocacy. The court distinguished this case from other precedent where prosecutors had clearly breached plea agreements. The First Circuit affirmed the sentence and judgment imposed by the district court. View "US v. Garcia-Toro" on Justia Law

Courtemanche v. Noble

2026-05-28T13:00:04-08:00

Four residents of Worcester County, Massachusetts alleged that the Massachusetts State Police (MSP) secretly recorded their phone conversations with officers and stored the recordings in an online database. They claimed the MSP used these recordings to propose charges in at least 181 criminal cases but did not disclose the existence of the recordings to prosecuting agencies. The plaintiffs, none of whom alleged pending charges or convictions related to these recordings, sought declaratory and injunctive relief, asserting violations of the Massachusetts Wiretap Act (later voluntarily dismissed) and their federal constitutional rights under the Sixth and Fourteenth Amendments via 42 U.S.C. § 1983. The United States District Court for the District of Massachusetts allowed voluntary dismissal of the state law claim but denied the Superintendent’s motion to dismiss the § 1983 claim. The district court found that sovereign immunity did not bar the official-capacity suit under the Ex parte Young exception, as the plaintiffs sought only prospective relief for alleged ongoing violations of federal law. The court further concluded that the plaintiffs had standing, reasoning that the MSP’s counsel had not unequivocally stated that the challenged recording and withholding practices had ceased or that all recordings had been disclosed. On interlocutory appeal, the United States Court of Appeals for the First Circuit reviewed the standing determination. The First Circuit held that the plaintiffs failed to allege an injury in fact with sufficient concreteness or imminence to establish standing for prospective relief. Their allegations were found to be generalized and lacked any indication that they personally faced a substantial risk of future harm. As a result, the First Circuit reversed the district court’s denial of the Superintendent’s motion to dismiss and remanded for further proceedings. View "Courtemanche v. Noble" on Justia Law

USA, ex rel. Solano v. Barton Associates, Inc.

2026-05-28T13:00:03-08:00

Two individuals, Solano and Maxilin, brought a qui tam action under the False Claims Act (FCA), alleging that Barton Associates, Inc., a temporary medical staffing agency, orchestrated a scheme to induce the submission of fraudulent claims to Medicare and other government healthcare programs. Solano, who owns a mobility device business, described being solicited by a Barton employee to participate in a scheme where Barton-recruited clients would create call centers to solicit medical service requests from patients eligible for government programs. Barton would then assign physicians to prescribe services, and charge clients an assessment fee for each prescription, allegedly leading to clients submitting claims to the government. Maxilin, a certified coding associate, alleged that his employer, Medtech, was one of Barton's clients and participated by channeling patients to Barton physicians for “unnecessary” prescriptions. The complaint described large numbers of prescriptions and claims, but Solano did not participate in the scheme and neither plaintiff provided specific details of actual false claims submitted. The United States District Court for the District of Massachusetts dismissed the complaint with prejudice, finding that Solano and Maxilin failed to plead fraud with the particularity required by Federal Rule of Civil Procedure 9(b). The court determined that the complaint only outlined the alleged scheme in general terms and lacked reliable indicia or specific details—such as time periods, locations, amounts, or identification of government programs—to support a strong inference that false claims were actually submitted. The court also denied the plaintiffs’ motion for reconsideration or, alternatively, for leave to amend the complaint. Upon appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s decisions. The appellate court held that the complaint did not meet the Rule 9(b) standard, even under the more flexible approach applicable to inducement-based FCA claims, and found no abuse of discretion in the denial of reconsideration or leave to amend. View "USA, ex rel. Solano v. Barton Associates, Inc." on Justia Law

US v. Johnson

2026-05-28T13:00:03-08:00

Adam Johnson was stopped by New Hampshire State Police in February 2018, where he was found with heroin and confessed to drug activities. He subsequently cooperated with law enforcement as a confidential source for the DEA, entering into two cooperation agreements. Despite initial cooperation and proffers, Johnson was later charged in Maine with conspiracy to distribute and possess with intent to distribute 400 grams or more of fentanyl. Over several years, Johnson changed counsel multiple times, and although plea negotiations and agreements were pursued—including signing a plea and cooperation agreement just before grand jury testimony—he eventually chose to proceed to trial rather than plead guilty. The United States District Court for the District of Maine oversaw the pretrial and trial proceedings. Johnson moved to suppress his plea, cooperation agreements, and grand jury testimony from evidence, arguing he had not knowingly or voluntarily entered the agreements and lacked counsel at critical times. The district court rejected these motions, finding that Johnson had knowingly entered and then breached the agreements by not pleading guilty. The court allowed the government to use Johnson’s statements at trial. After trial, a jury convicted Johnson. At sentencing, the court enhanced Johnson’s offense level for his leadership role in the conspiracy, partly based on PSR statements from a deceased coconspirator, and denied credit for acceptance of responsibility, though the court did grant a downward variance for his initial cooperation. On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s verdict and sentence. The court held Johnson’s arguments regarding the need for an evidentiary hearing and exclusion of his statements were unpreserved or without merit. It found no error in the sentencing enhancements or denial of acceptance-of-responsibility credit, concluding Johnson’s pretrial cooperation did not overcome his later decision to contest factual guilt at trial. The judgment and sentence were affirmed. View "US v. Johnson" on Justia Law

Argueta Castillo v. Blanche

2026-05-27T13:30:03-08:00

A Guatemalan national who had lived in the United States for over twenty years was charged with removability for entering without inspection. He conceded removability but sought cancellation of removal, arguing his removal would cause “exceptional and extremely unusual hardship” to his two U.S. citizen daughters, who lived with him and their mother. The older daughter suffered from anxiety and sleepwalking, while the younger had eye conditions requiring corrective lenses. The family submitted evidence of the daughters’ medical conditions, country conditions in Guatemala, and their financial resources, including significant savings. After a merits hearing, an Immigration Judge found the father credible but denied his application, concluding he had not demonstrated the requisite hardship to his daughters if they accompanied him to Guatemala. The judge found the daughters were doing well in school, their medical conditions were stable and manageable, and there was insufficient evidence that necessary treatment would be unavailable in Guatemala, especially given the family’s assets. The judge also found the hardship factors, considered cumulatively, did not reach the statutory threshold. The Board of Immigration Appeals affirmed, agreeing the hardship was not exceptional, and that the judge had considered all relevant factors and evidence. On review, the United States Court of Appeals for the First Circuit denied the petition. Applying the deferential standard of review required by Wilkinson v. Garland, the court held that the agency’s determination was supported by substantial evidence and was not legally erroneous or clearly erroneous. The court found the agency had properly considered all relevant evidence and factors, and that the petitioner had not established that his daughters would suffer hardship substantially beyond what ordinarily accompanies a parent's removal. The agency’s decision was therefore affirmed. View "Argueta Castillo v. Blanche" on Justia Law

Vasquez-Chavez v. Bondi

2026-05-22T12:30:03-08:00

The petitioner, a native of El Salvador, fled his country after years of physical and verbal abuse by his father. He first entered the United States without inspection in 2016, was granted voluntary departure, and returned to El Salvador. After a brief stay, he again entered the United States without inspection in 2017. He claimed his father attempted to kill him, that the police failed to intervene due to their relationship with his father, and that he was also assaulted by police officers. The petitioner applied for asylum, withholding of removal, and protection under the Convention Against Torture, citing these experiences as the basis for his claims. An Immigration Judge (IJ) found the petitioner's asylum application timely and his testimony credible, but determined that the harm he suffered resulted from a family dispute rather than on account of a protected ground under asylum law. The IJ further found that the petitioner failed to provide sufficient corroborating evidence, such as affidavits from family members, to support his allegations of police involvement. The IJ denied all requested relief, including withholding of removal and CAT protection. The Board of Immigration Appeals (BIA) dismissed his appeal, concluding that the harm stemmed from a personal dispute and that he did not demonstrate government inability or unwillingness to protect him. The BIA also deemed the CAT claim waived and noted that the petitioner did not challenge the finding regarding the government's protection on appeal. The United States Court of Appeals for the First Circuit reviewed the case, applying a substantial evidence standard to factual findings and de novo review to legal conclusions. The court held that substantial evidence supported the BIA’s conclusion that the petitioner failed to show a nexus between the alleged persecution and a protected ground, and that he did not sufficiently challenge the finding regarding government protection. The petition for review was denied. View "Vasquez-Chavez v. Bondi" on Justia Law

Crespo-Morales v. Caro-Delgado

2026-05-22T12:30:03-08:00

In this case, the petitioner was convicted by a jury in Puerto Rico in 1996 for four counts of first-degree murder and related charges, stemming from a shooting known as the "Piñones Massacre." The prosecution’s case relied in part on the testimony of Regino Burgos-Torres, who implicated the petitioner in ordering the killings as revenge for the deaths of his brothers, allegedly at the hands of three of the victims. Many years later, the petitioner discovered that the prosecution had not disclosed affidavits from two eyewitnesses to his brothers’ murders. These affidavits implicated two other individuals and did not mention the three victims, potentially undermining the prosecution’s theory of motive. The petitioner sought a new trial in the Puerto Rico court, arguing that the suppression of the affidavits violated the rule established in Brady v. Maryland. The court denied his motion after holding an evidentiary hearing, finding that the affidavits would not have altered the verdict because what mattered was the petitioner’s belief about who killed his brothers, not who actually did. The intermediate appellate court and the Puerto Rico Supreme Court declined further review. The petitioner then filed a federal habeas corpus petition in the United States District Court for the District of Puerto Rico under 28 U.S.C. § 2254, presenting the same Brady claim. The district court dismissed the petition without reviewing key portions of the state court record, namely the trial testimony of Burgos-Torres. Upon remand from the United States Court of Appeals for the First Circuit to correct this error, the district court again denied relief without obtaining the necessary transcript or a narrative summary of the testimony. The United States Court of Appeals for the First Circuit vacated the district court’s judgment. The court held that the district court could not reasonably evaluate the state court’s adjudication of the Brady claim under § 2254 without the transcript or a narrative summary of Burgos-Torres’s testimony. The case was remanded with instructions to obtain that record and reconsider the petition accordingly. View "Crespo-Morales v. Caro-Delgado" on Justia Law

Arocho-Rodriguez v. Roldan-Concepcion

2026-05-21T13:30:03-08:00

The plaintiff, a member of the New Progressive Party and a former System Technician Coordinator for the Municipality of Aguadilla, Puerto Rico, alleged that after a new mayor from the Popular Democratic Party took office, he was subjected to politically motivated adverse employment actions. Specifically, he claimed his server access was revoked, he received a poor employment evaluation, and his work environment became intolerable, all of which led to his constructive resignation. He asserted that these actions were taken because of his political affiliation. Following discovery, several individual defendants moved for summary judgment on the claims against them in their individual capacities, arguing that the plaintiff had not established a prima facie case of political discrimination under the First Amendment and raising a qualified immunity defense. Importantly, they did not address the claims against them in their official capacities, the municipality, or the equal protection and Puerto Rico law claims. The plaintiff opposed the motion, but the district court, adopting a magistrate judge’s report and recommendation, granted summary judgment for the individual defendants and sua sponte dismissed the entire case with prejudice, citing waiver and a lack of evidence. The United States Court of Appeals for the First Circuit reviewed the case and held that the district court erred in granting summary judgment based on waiver alone and in concluding there was no evidence supporting the plaintiff’s claims. The appellate court found that the plaintiff’s deposition testimony created genuine disputes of material fact regarding the involvement and knowledge of the defendants. The court also held that the district court improperly dismissed claims against parties who had not moved for summary judgment without giving the plaintiff notice. The judgment was reversed and the case remanded for further proceedings. View "Arocho-Rodriguez v. Roldan-Concepcion" on Justia Law

US v. Ortiz-Rodriguez

2026-05-20T13:00:04-08:00

The defendant pleaded guilty in the United States District Court for the District of Puerto Rico to possessing a firearm as a prohibited person and received a sentence of forty-one months’ imprisonment followed by three years of supervised release. Conditions of supervised release included prohibitions on committing new crimes, unlawful drug use, and failing to participate in substance abuse treatment. After beginning supervised release, the defendant tested positive for marijuana and cocaine on multiple occasions, failed to comply with drug treatment programs, and was observed under the influence of controlled substances. The probation officer filed motions with the district court detailing these violations and requested continued supervision or, later, an arrest warrant. A Magistrate Judge advised the defendant of the violations alleged in the probation officer's motion, appointed counsel, and found probable cause. The case was then referred to a district judge of the District of Puerto Rico, who held a revocation hearing. The defendant did not contest the factual allegations and, through counsel, requested a sentence below the guideline range, citing personal hardships and partial compliance with other conditions. The government did not oppose this request. The district court found the violations to constitute a Grade B violation (more serious due to being punishable by over one year’s imprisonment under Puerto Rico law) and imposed a fourteen-month sentence, overruling the defense's objections regarding the grade of violation. On appeal, the United States Court of Appeals for the First Circuit reviewed whether the defendant had adequate notice of the basis for the revocation and sentence, particularly the recharacterization of drug use as felony possession. The court held that although there was a lack of notice regarding the Grade B violation, the defendant failed to show prejudice or that his substantial rights were affected, as required under plain error review. The court affirmed the district court’s judgment. View "US v. Ortiz-Rodriguez" on Justia Law

US v. Pimental

2026-05-20T13:00:04-08:00

A defendant pled guilty to federal bank robbery and faced sentencing in the District of Massachusetts. Prior to sentencing, the U.S. Probation Office calculated a guidelines range based on his criminal history and offense level. The government objected, arguing that the defendant should be classified as a "career offender" under the United States Sentencing Guidelines because he had two prior felony convictions it asserted were "crimes of violence": a federal bank robbery and a Massachusetts carjacking. The defendant conceded the federal conviction qualified, but challenged the classification of the Massachusetts carjacking as a crime of violence. Probation ultimately revised its report to apply the enhancement, doubling his guidelines range. The district court agreed with the government, found the carjacking conviction to be a crime of violence, applied the career offender enhancement, and imposed a 120-month sentence. The defendant appealed. On appeal to the United States Court of Appeals for the First Circuit, the defendant argued that the sentencing enhancement was improper because Massachusetts carjacking is not categorically a crime of violence under U.S.S.G. § 4B1.2(a). The First Circuit reviewed the district court's application of the guidelines de novo and examined whether the state carjacking statute necessarily required the use, attempted use, or threatened use of violent force. The court rejected the government’s reliance on dicta from a Massachusetts Supreme Judicial Court decision, and followed the Supreme Court’s guidance that the meaning of “physical force” in federal law is a federal question. Applying the categorical approach, the First Circuit found that at least one means of committing Massachusetts carjacking—by assault—did not necessarily involve violent force, making the statute broader than the federal definition. The court held that Massachusetts carjacking is not a “crime of violence” for purposes of the career offender guideline. The sentence was vacated and the case remanded for resentencing. View "US v. Pimental" on Justia Law

US v. Deschambault

2026-05-18T13:30:04-08:00

A man was arrested in Maine after a controlled drug purchase arranged by law enforcement. During his arrest, officers found an iPhone under his car seat, along with drug-related items. A state search warrant was obtained to investigate the phone for evidence of drug trafficking. While searching the phone, officers discovered videos depicting the man engaging in sexual acts with a minor. This discovery led to federal charges for sexual exploitation of a minor. At trial in the United States District Court for the District of Maine, the defendant sought to suppress the videos, arguing the state search warrant lacked probable cause and specificity, and that officers exceeded its scope by investigating the videos. The district court denied these motions. The defendant also requested specific voir dire questions about juror bias against interracial relationships and sought to introduce evidence that he believed the minor was of age, but the court rejected these efforts. The jury convicted the defendant on both counts, and he was sentenced to 216 months in prison and ten years of supervised release. On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s rulings. The appellate court held that the state search warrant was supported by probable cause and was sufficiently particular. The court found that officers did not exceed the warrant’s scope by viewing the videos, which were relevant to the drug investigation, nor was there a bar on using evidence lawfully found in the course of one investigation for another crime. The First Circuit also concluded that the voir dire was adequate, the exclusion of mistake-of-age evidence was correct since such a defense is not available under 18 U.S.C. § 2251(a), the jury instructions were not plainly erroneous, and the evidence was sufficient for conviction. The court affirmed the convictions. View "US v. Deschambault" on Justia Law

American Federation of Gov't Employees Local 2305 v. United States Department of Veterans Affairs

2026-05-18T04:00:04-08:00

The case involves a dispute between two unions representing Department of Veterans Affairs (VA) employees and the VA itself, along with the VA Secretary. The core issue centers on the VA’s termination of a collective bargaining agreement (CBA) that was signed in August 2023 and set to last three years. The termination followed a March 2025 executive order by President Trump that excluded the VA from coverage under the Federal Service Labor-Management Relations Statute (FSLMRS), citing national security. The VA Secretary then terminated the CBA, prompting the unions to file suit, alleging violations of the Administrative Procedure Act (APA) and the First Amendment. Prior to this case, unions not party here challenged the executive order in the U.S. District Court for the Northern District of California, which issued a preliminary injunction. That injunction was later stayed and ultimately vacated on appeal by the Ninth Circuit. In the present case, the U.S. District Court for the District of Rhode Island granted a preliminary injunction requiring the VA to reinstate the CBA and later issued an enforcement order when the VA attempted to re-terminate the agreement. The district court found that the termination was likely retaliatory and arbitrary and capricious. On appeal, the United States Court of Appeals for the First Circuit reviewed requests to stay both the preliminary injunction and the enforcement order. The First Circuit denied the VA’s request to stay the preliminary injunction, finding the VA had not made a strong showing of likely success on appeal. However, the court granted a partial stay of the enforcement order, holding that the district court likely lacked jurisdiction to order specific compliance with every term of the CBA under threat of contempt. The court otherwise denied the VA’s requests. View "American Federation of Gov't Employees Local 2305 v. United States Department of Veterans Affairs" on Justia Law

US v. Fernandez-Santos

2026-05-15T13:30:04-08:00

After being released from prison on federal convictions including possession of a firearm by a prohibited person, the defendant was subject to supervised release. While on supervised release, he was arrested when police seized a rifle and ammunition from his residence and a pistol from a discarded bag. There was no direct evidence linking him to the rifle beyond its presence in his home, and the officers did not observe him handling it. The terms of his supervised release barred him from possessing firearms or ammunition. Following his arrest, a probation officer notified the court of alleged violations of supervised release. The defendant waived a preliminary hearing; a magistrate judge found probable cause and referred the matter for final revocation. Meanwhile, the government brought new criminal charges for firearm possession, including possession of a machine gun. At trial on the new charges, expert testimony addressed whether the seized rifle functioned as a machine gun. The court later dismissed these charges due to government discovery violations. The government then relied on selected excerpts from the trial and suppression hearing transcripts as evidence of a “Grade A” supervised release violation—possession of a machine gun—at the revocation hearing. The government expressly limited its evidence to these exhibits. The United States District Court for the District of Puerto Rico found that the defendant knowingly possessed a machine gun, basing its conclusion on the visible features of the firearm and the defendant’s prior conviction. The court revoked supervised release and imposed the statutory maximum sentence. The defendant objected, arguing the government had not proven knowledge or mens rea. On appeal, the United States Court of Appeals for the First Circuit held that the district court committed procedural error by relying on evidence outside the revocation record. The court vacated the sentence and remanded for resentencing limited to the existing record. View "US v. Fernandez-Santos" on Justia Law

US v. Sepetu

2026-05-15T13:30:03-08:00

Over a period of six years, the two defendants participated in a scheme involving the creation of multiple business entities and bank accounts, which were used to facilitate the transfer of large sums of money. One defendant directed friends and family members to register businesses and open accounts on his behalf, while the other registered a business and opened accounts at his request. The operation purported to involve purchasing goods domestically and exporting them overseas, but most of the funds came from a single victim who was deceived in an online romance scam. The defendants withdrew substantial amounts of cash from these accounts and used the funds for personal expenses, while maintaining little to no legitimate business records. After law enforcement began investigating, both defendants were questioned about their activities. They denied knowledge of any illegal source of funds and claimed to believe the business was legitimate. Nonetheless, evidence showed inconsistent statements, continued operation after warnings from banks and law enforcement, and a lack of documentation for the purported business transactions. A grand jury indicted both defendants for conspiracy to commit money laundering. At trial in the United States District Court for the District of New Hampshire, both defendants testified that they were unaware of the illegal origins of the funds, but a jury found them guilty. One defendant also challenged the government’s arguments at trial and the sentencing calculation. On appeal to the United States Court of Appeals for the First Circuit, both defendants argued that the evidence was insufficient to support their convictions, and that the district court erred in its jury instructions regarding willful blindness and good faith. The First Circuit held that the circumstantial evidence was sufficient to sustain the convictions, and that the willful blindness and good faith instructions were proper. The court also found no error in the government’s arguments or in the sentencing calculation, and affirmed both the convictions and the sentence. View "US v. Sepetu" on Justia Law

US v. Perez-Otero

2026-05-15T13:30:03-08:00

The defendant, the former mayor of Guaynabo, Puerto Rico, was indicted on three federal charges: conspiracy to commit federal-program bribery, federal-program bribery and aiding and abetting, and extortion under color of official right. The indictment alleged that while serving as mayor, he used his authority over municipal contracting to steer contracts to a local construction company owned by another individual, in exchange for cash payments. Some of these payments were characterized by the government as bribes, while the defense argued they were campaign contributions intended to pay off campaign debt. The United States District Court for the District of Puerto Rico denied the defendant’s pretrial motion to dismiss the indictment and later denied his motion for judgment of acquittal after the jury found him guilty on all counts. The district court found that the evidence supported the jury’s verdict, sentenced the defendant to concurrent terms of imprisonment and supervised release, and rejected his arguments regarding defects in the indictment, prejudicial variance, improper jury instructions, and jury bias. On appeal, the United States Court of Appeals for the First Circuit reviewed the sufficiency of the evidence de novo, as well as other challenges. The First Circuit held that a rational jury could have found beyond a reasonable doubt that the payments in question were not campaign contributions, and thus the requirements of McCormick v. United States did not apply. The court further held that there was sufficient evidence of a quid pro quo and that the timing and nature of the payments did not convert them into mere gratuities. The court also concluded that there was no prejudicial variance, the jury instructions were not impermissibly biased, and the defendant’s right to an impartial jury was not violated. The First Circuit ultimately affirmed both the convictions and the sentences. View "US v. Perez-Otero" on Justia Law

US v. Fort

2026-05-12T12:30:03-08:00

The defendant, a convicted felon, was living at a multi-unit residence with his girlfriend and her family in New Hampshire. After an altercation involving a damaged car mirror and escalating tensions with a family friend, the defendant brought a loaded pistol outside, intending to confront the friend. During a heated exchange, the defendant fired two shots, killing the family friend and seriously injuring his girlfriend’s uncle. He was arrested later that day and subsequently charged in federal court with possessing a firearm and ammunition as a convicted felon under 18 U.S.C. §§ 922(g)(1) and 924(e). Prior to trial in the United States District Court for the District of New Hampshire, the defendant sought to present affirmative justification defenses, including duress, necessity, and self-defense. He also moved to dismiss the indictment, claiming that the application of § 922(g)(1) violated his Second Amendment rights as applied to his circumstances. The district court held an evidentiary hearing and ultimately ruled that the defendant had failed to make a sufficient threshold showing to present a justification defense to the jury. It also denied his motion to dismiss. The defendant entered a conditional guilty plea, reserving his right to appeal these rulings and later challenged his above-Guidelines sentence as substantively unreasonable. The United States Court of Appeals for the First Circuit reviewed the district court’s rulings and affirmed. The court held that the defendant failed to meet the threshold requirements for a justification defense under established circuit precedent and common law standards. The court further concluded that the defendant’s Second Amendment as-applied challenge lacked merit given the facts, and upheld the district court’s denial of the motion to dismiss. Finally, the First Circuit found the above-Guidelines sentence was justified and not substantively unreasonable. The conviction and sentence were affirmed. View "US v. Fort" on Justia Law

United States v. Middleton

2026-05-08T13:30:05-08:00

During a four-day period in November 2015, Adrienne Rush, a heroin user, was manipulated and coerced into acts of commercial sex by Ricardo Middleton and his associates. Initially seeking drugs, Rush and her friend Julie Deschaine became entangled with Middleton, who, along with others, forced Rush to engage in sex acts with customers in exchange for money, subjected her to physical and sexual violence, and restricted her movements. Eventually, Rush managed to escape and seek help, but Middleton and his co-defendant, Sherry Jones, unsuccessfully attempted to locate her by threatening and assaulting Deschaine. Following these events, Middleton was arrested and indicted in the United States District Court for the District of Maine for sex trafficking by force, fraud, or coercion, in violation of 18 U.S.C. § 1591(a)(1) and (b)(1). While in pretrial detention, Middleton made several phone calls attempting to influence the testimony of a co-defendant, leading to an additional charge for obstruction of a sex trafficking prosecution under 18 U.S.C. § 1591(d). After a trial, a jury found Middleton guilty on both counts, and the district court sentenced him to 360 months in prison, followed by ten years of supervised release. On appeal to the United States Court of Appeals for the First Circuit, Middleton challenged the admission of expert testimony, the sufficiency of the evidence for obstruction, the reasonableness of his sentence, and the effectiveness of his counsel. The First Circuit affirmed the convictions and sentence, holding that the expert testimony was properly admitted, the evidence was sufficient to support the obstruction conviction, and the sentence was substantively reasonable. The ineffective assistance of counsel claim was dismissed as premature, without prejudice to raising it in a collateral proceeding. View "United States v. Middleton" on Justia Law

US v. Ortiz-Colon

2026-05-06T13:00:04-08:00

Federal authorities in Puerto Rico began investigating after a school social worker reported that a 12-year-old student received explicit requests via Instagram. Further investigation revealed that several minors were contacted through multiple Instagram accounts, soliciting initially innocuous photos that escalated to sexually explicit imagery. Authorities traced an IP address linked to these accounts to a San Juan residence, where they found the defendant and seized electronic devices. Forensic analysis of these devices produced evidence of sexually explicit images of multiple minors and communications linking the defendant to the Instagram accounts in question. The United States District Court for the District of Puerto Rico charged the defendant with nine counts of production of child pornography, eight counts of coercion and enticement of a minor, and single counts each of receipt and possession of child pornography. After a six-day trial, a jury convicted the defendant on all nineteen counts. The court sentenced him to 360 months’ imprisonment, a downward variance from the Sentencing Guidelines’ recommendation of life, with concurrent 240-month terms for the possession and receipt charges. On appeal to the United States Court of Appeals for the First Circuit, the defendant challenged various trial procedures, the Double Jeopardy implications of multiple convictions, and the substantive reasonableness of his sentence. The First Circuit held that: (1) the District Court did not plainly err in its jury selection process, handling of juror notes, or admission of witness testimony; (2) the evidence supported all convictions except that possession of child pornography is a lesser included offense of receipt, thus separate convictions for both on the same conduct violate the Double Jeopardy Clause; and (3) the 360-month sentence was substantively reasonable. The First Circuit affirmed the convictions and sentence in part, but remanded for the District Court to vacate either the possession or receipt conviction and the associated penalty. View "US v. Ortiz-Colon" on Justia Law

US v. Padilla-Galarza

2026-05-06T13:00:03-08:00

In this case, the defendant was convicted after a bench trial for his role in a 2010 armed robbery at a Puerto Rico police shooting range, where two officers were held hostage and 125 firearms were stolen. The government alleged that the defendant was the mastermind, coordinating with others who impersonated police officers to execute the plan. The defendant’s trial was delayed for several years due to changes in counsel, continuances, and the reassignment of the trial judge. Shortly before trial, the government filed a superseding indictment to comply with intervening Supreme Court precedent, United States v. Davis, 588 U.S. 445 (2019), which required a change to the predicate offense charged under 18 U.S.C. § 924(c). The United States District Court for the District of Puerto Rico denied the defendant’s motions to dismiss certain counts as time-barred, and also denied his last-minute motions for continuances and for additional funds for expert and investigatory services. The district court also excluded certain evidence and denied access to polygraph results, ultimately acquitting the defendant on one count but convicting him on the remaining counts, including conspiracy, robbery, firearms violations, and being a felon in possession of firearms. On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s rulings. The First Circuit held that the superseding indictment did not materially broaden or amend the original charges and was therefore timely. The court also found no abuse of discretion in the denial of continuances or funds, as the defendant had not shown specific prejudice. The appellate court determined that there was sufficient evidence to support the convictions and that no evidentiary or discovery rulings warranted a new trial. Accordingly, the First Circuit affirmed the convictions. View "US v. Padilla-Galarza" on Justia Law

US v. Rebollar Osorio

2026-05-05T13:00:03-08:00

A grand jury in the District of Maine indicted a noncitizen for knowingly possessing a firearm while being “illegally or unlawfully” in the United States, in violation of 18 U.S.C. § 922(g)(5)(A). The statute prohibits firearm possession by noncitizens who are not lawfully present in the country. The defendant moved to dismiss the indictment, arguing that the statute violated his Second Amendment rights both on its face and as applied to him. The United States District Court for the District of Maine granted the motion to dismiss. It held that the defendant was among “the people” protected by the Second Amendment, relying in part on United States v. Verdugo-Urquidez. The court then found that the government failed to demonstrate, under the test established in New York State Rifle & Pistol Ass’n v. Bruen, that the statute was consistent with the nation’s historical tradition of firearm regulation as applied to the defendant. The court concluded that the government had not met its burden because it did not provide direct historical analogues and relied on secondary sources. As a result, the indictment was dismissed, and the government appealed. The United States Court of Appeals for the First Circuit reviewed the District Court’s application of the Bruen framework de novo. The First Circuit determined that, even assuming the defendant was protected by the Second Amendment, the government had shown that § 922(g)(5)(A) fits within the nation’s historical tradition of firearm regulation. The court relied on English common-law practices, colonial and founding-era laws, and analogues disarming groups considered outside the political community. The Court of Appeals reversed the dismissal and remanded for further proceedings, holding that the statute is constitutional as applied in this case. View "US v. Rebollar Osorio" on Justia Law

US v. Vizcaino-Peguero

2026-05-05T13:00:02-08:00

The appellant was indicted in the United States District Court for the District of Puerto Rico for possessing a firearm while being an alien illegally or unlawfully in the United States, in violation of 18 U.S.C. § 922(g)(5)(A). He moved to dismiss the indictment, arguing that, as applied to him, the statute violated his Second Amendment rights. The District Court denied his motion, finding that, even assuming the Second Amendment protected him, the statute was consistent with the nation’s historical tradition of firearm regulation. The appellant then pleaded guilty, was sentenced, and timely appealed his conviction, preserving his constitutional challenge. The appeal was reviewed by the United States Court of Appeals for the First Circuit. The government argued that the statute did not violate the Second Amendment, both because the appellant was not among “the people” whom the Amendment protects, and because, even if he was, the statute was consistent with historical tradition. The First Circuit, like the District Court, did not resolve whether the Second Amendment’s text covered the appellant, relying instead on the second step of the framework established in New York State Rifle & Pistol Ass’n v. Bruen. Applying the Bruen framework, as clarified by United States v. Rahimi, the First Circuit held that § 922(g)(5)(A) is consistent with the nation’s historical tradition of firearm regulation. The court found that historical analogues, including laws disarming those without allegiance to the sovereign, supported the regulation. The court concluded that the government met its burden to show that the statute is relevantly similar to such historical regulations. Therefore, the First Circuit affirmed the District Court’s judgment and rejected the appellant’s Second Amendment challenge. View "US v. Vizcaino-Peguero" on Justia Law

Lantigua-Nunez v. US Coast Guard

2026-05-01T14:00:04-08:00

A Dominican Republic citizen was operating a high-speed vessel in international waters off Puerto Rico with two others when a United States Coast Guard helicopter and cutter approached. After issuing warning shots that failed to stop the vessel, the Coast Guard fired live rounds at the engine, and two bullets struck the plaintiff’s left arm, causing serious, permanent injury. The plaintiff remained on deck for thirty minutes before receiving medical attention and was later airlifted to a hospital in San Juan. After his administrative claim under the Federal Tort Claims Act (FTCA) was denied, the plaintiff filed suit in the United States District Court for the District of Puerto Rico. He initially brought constitutional claims against individual Coast Guard officers and a tort claim against the federal government under the FTCA’s law enforcement proviso, but later voluntarily dismissed the constitutional claims. The government moved to dismiss the FTCA claim, arguing the claim was subject to admiralty law and thus exclusively governed by the Suits in Admiralty Act (SIAA). The magistrate judge recommended dismissal, concluding the FTCA did not apply because the SIAA provided the exclusive remedy. The judge further recommended denying the plaintiff’s request to amend his complaint to add an SIAA claim because it would be time-barred. The district court adopted these recommendations and dismissed the case with prejudice. On appeal, the United States Court of Appeals for the First Circuit affirmed. The court held that the plaintiff’s claim arose under maritime jurisdiction and was therefore governed exclusively by the SIAA, not the FTCA. Because the FTCA expressly excludes claims for which a remedy is provided by the SIAA, the plaintiff could not proceed under the FTCA, even if his SIAA claim was time-barred. The dismissal with prejudice was affirmed. View "Lantigua-Nunez v. US Coast Guard" on Justia Law

Usma Acosta v. Blanche

2026-05-01T14:00:04-08:00

A man originally from Colombia lived in the United States for nearly thirty years under an assumed identity after fleeing his home country in the 1990s. He married a U.S. citizen, raised a family, and applied for naturalization in 2020. During the application process, a fingerprint check revealed that he had been living under an alias. He was, in fact, a person convicted in absentia in Colombia for the aggravated murder of his first wife and the attempted murder of his daughter, crimes committed before he entered the United States. Following this discovery, U.S. authorities initiated removal proceedings, charging him with procuring immigration status by fraud and willful misrepresentation, including using a false identity and failing to disclose prior marriages. An Immigration Judge found him removable based on clear and convincing evidence, including his admissions and documentary proof. The judge denied all forms of relief from removal, such as asylum, statutory withholding, protection under the Convention Against Torture, waiver of inadmissibility, and cancellation of removal. The judge found that serious reasons existed to believe he had committed a serious nonpolitical crime abroad, precluding several forms of relief. The Board of Immigration Appeals affirmed, also rejecting his claims of judicial bias and his motion to reopen based on new evidence. The United States Court of Appeals for the First Circuit reviewed the case. The court denied the petition as to most claims, holding that the findings of removability were supported by substantial evidence, the adverse credibility determinations were reasonable, and the denial of relief was proper given the serious nonpolitical crime bar. The court dismissed the challenges to discretionary relief for lack of jurisdiction and found no abuse of discretion in denying the motion to reopen. Thus, his removal to Colombia was upheld. View "Usma Acosta v. Blanche" on Justia Law