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

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

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

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

United States v. Rosa-Borges

2026-05-01T14:00:03-08:00

In this case, the defendant completed a federal prison sentence for a prior firearm conviction and then began supervised release. During this supervised period, he was found in possession of a firearm and ammunition, which led to the initiation of revocation proceedings for violating the terms of his supervised release. Shortly thereafter, a search of his residence yielded additional ammunition. These events resulted in new criminal charges for possession of a firearm by a prohibited person under 18 U.S.C. § 922(g)(1). The defendant pleaded guilty to the new charge pursuant to a plea agreement and also faced sentencing for the supervised release violations. Previously, the United States District Court for the District of Puerto Rico sentenced the defendant both for the new § 922(g)(1) offense and for the supervised release violations. The defendant appealed, and the United States Court of Appeals for the First Circuit (in United States v. Rosa-Borges, 101 F.4th 66 (1st Cir. 2024)) vacated both sentences, finding that the district court had improperly relied on unreliable hearsay from the presentence report. On remand, the district court refused to strike the problematic information from the presentence report but stated it would not rely on it, then reimposed an upwardly variant sentence for the new firearm offense, in part based on the amount and nature of the ammunition. For the supervised release violation, the court imposed a consecutive sentence, finding a Grade A violation. Upon the second appeal, the United States Court of Appeals for the First Circuit affirmed the revocation sentence, concluding that the defendant had waived his challenges to that sentence. However, the appellate court vacated the sentence for the § 922(g)(1) conviction, holding that the district court relied on a legally invalid rationale—namely, treating 31 rounds of ammunition as an aggravating factor and referencing unsupported facts about the ammunition’s nature. The case was remanded for resentencing before a different judge. View "United States v. Rosa-Borges" on Justia Law

New England Fishermen's Stewardship Association v. Lutnick

2026-04-30T10:30:04-08:00

A dispute arose between a regional fishermen’s association and the federal government concerning changes to catch limits for several fish species in the Northeast Multispecies Fishery Management Plan. The association, representing commercial fishermen allegedly harmed by reduced catch limits, challenged the legality of the Framework Adjustment 65 Final Rule and its implementing regulations. At the core of the association’s argument was the claim that the involvement of the New England Fishery Management Council in the development of these rules violated the U.S. Constitution’s Appointments Clause. The association argued that the Council exercised significant authority in the regulatory process but its members were not properly appointed as federal officers. The United States District Court for the District of Maine reviewed the case. It concluded that the association had standing due to the economic injury suffered by its members. The district court rejected the primary constitutional claim, holding that the Council’s role was advisory and final binding authority rested solely with the Secretary of Commerce, who promulgated the regulations. The court did, however, agree with the association in part, finding certain unrelated statutory provisions unconstitutional, but determined that this did not entitle the association to its requested relief. The district court severed those statutory provisions. The United States Court of Appeals for the First Circuit heard the appeal. After reviewing the statutory framework and the specific facts, the court held that the Council’s role was advisory and did not amount to the exercise of significant federal authority under the Appointments Clause. The harm to the association’s members derived from the Secretary’s independent decision to promulgate the binding regulations, not from the Council’s recommendations. The First Circuit affirmed the denial of injunctive and declaratory relief and reversed the district court’s severance of the unrelated statutory provisions. View "New England Fishermen's Stewardship Association v. Lutnick" on Justia Law

Friedman v. Central Maine Power Company

2026-04-29T21:00:04-08:00

A Maine resident who suffers from a rare and incurable form of blood cancer was a long-time customer of an electric utility that uses smart meters emitting radiofrequency signals to track electricity usage. After the utility received regulatory approval, it allowed customers to keep analog meters for an additional fee, citing health and safety concerns that had been raised but not resolved by the state public utilities commission. The resident, concerned that radiofrequency radiation might worsen his cancer symptoms, requested a waiver of the opt-out fee, supported by a letter from his oncologist. The utility denied the waiver, and after the resident refused to pay the fee, his electric service was disconnected. The resident sued in the United States District Court for the District of Maine, alleging disability discrimination under the Americans with Disabilities Act, the Rehabilitation Act, and the Fair Housing Act. He also claimed the fee constituted an unlawful surcharge under the ADA. The district court denied the utility’s initial motion to dismiss but, after discovery, granted summary judgment in favor of the utility. The district court limited the resident’s expert witnesses to general, not specific, causation testimony, and excluded the opinions of his treating physicians as untimely disclosed expert testimony. The court found a lack of admissible evidence connecting smart meter radiation to the resident’s health, and held the opt-out fee was not an unlawful surcharge. The United States Court of Appeals for the First Circuit affirmed. It held that, without timely, admissible expert evidence of specific causation linking the smart meter’s radiation to a non-speculative risk of harm to the resident’s health, the resident’s claims could not survive summary judgment. The court also held that the opt-out fee was not a discriminatory surcharge because waiver of the fee was not required under the ADA. View "Friedman v. Central Maine Power Company" on Justia Law

St. John v. Campbell

2026-04-29T21:00:04-08:00

In 2010, the petitioner was convicted in a Massachusetts Superior Court of several offenses, including burglary and mayhem, after being identified as the assailant in an attack involving hot cooking oil. The trial was conducted without a jury, and the court sentenced her to ten to eleven years in prison. Her conviction was affirmed by the Massachusetts Appeals Court, and the Supreme Judicial Court denied further review. While serving her sentence, federal immigration authorities revoked her permanent resident status and ordered her removal from the United States. After her release from state custody in December 2021, she was detained by federal authorities and deported to Trinidad and Tobago in January 2024. Following her deportation, the petitioner exhausted her state remedies, including a motion for a new trial based on alleged ineffective assistance of counsel, which was denied by the Superior Court and affirmed by the Massachusetts Appeals Court. In March 2024, she filed a habeas corpus petition in the United States District Court for the District of Massachusetts, naming the Massachusetts Attorney General as the respondent. She claimed her convictions resulted from ineffective assistance of counsel and challenged the state court’s handling of new evidence. The district court dismissed the petition for lack of jurisdiction, reasoning that she was not in custody, as required by federal habeas law, at the time of filing. The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court’s dismissal. The First Circuit held that because the petitioner was not in the custody of any Massachusetts official when she filed her habeas petition—and did not name as respondent any official with actual custody—the federal courts lacked jurisdiction to hear her petition under 28 U.S.C. § 2254. The court did not reach other arguments and concluded that dismissal was required. View "St. John v. Campbell" on Justia Law

US v. Mao

2026-04-29T21:00:03-08:00

From December 2019 through May 2021, an individual incarcerated at the Buckingham Correctional Center in Virginia conspired with others, including two Massachusetts-based drug traffickers and a correctional officer, to distribute controlled substances—specifically MDMA and buprenorphine—inside the facility. The proceeds from these transactions were then collected and managed by the group. A federal grand jury in the District of Massachusetts indicted the defendant on charges of conspiracy to distribute and possess with intent to distribute controlled substances, and conspiracy to commit money laundering. The defendant pled guilty to both charges. The United States District Court for the District of Massachusetts received a presentence investigation report that classified the defendant as a “career offender” under the United States Sentencing Guidelines, based on two prior Virginia felony convictions: use of a firearm in the commission of a robbery and attempted murder. The report also found that the instant conviction for conspiracy to distribute controlled substances qualified as a “controlled substance offense.” The defendant objected, arguing that the firearm conviction was not a “crime of violence” under the Guidelines and that conspiracy to distribute drugs was not a “controlled substance offense.” The district court rejected both arguments and imposed a 121-month sentence. On appeal, the United States Court of Appeals for the First Circuit reviewed the classification of the prior Virginia firearm conviction and the instant drug conspiracy conviction. The court held that the Virginia conviction for use of a firearm in the commission of a robbery qualified as a “crime of violence” under both the enumerated offenses clause and the force clause of the Guidelines. It also held that conspiracy to distribute controlled substances is a “controlled substance offense” under binding First Circuit precedent, finding no basis to depart from this view despite arguments regarding inter-circuit disagreement and recent Supreme Court decisions. The First Circuit affirmed the sentence. View "US v. Mao" on Justia Law

Putnam v. EPR Properties

2026-04-28T09:00:03-08:00

Elizabeth and Cale Putnam, residents of Massachusetts, traveled to the Hotel Valcartier in Québec, Canada, with their five-year-old son, Anthony. While staying at the hotel, an unsecured Murphy bed fell on Anthony, causing fatal injuries. The Putnams had booked their stay at the hotel and its associated Ice Hotel through the hotel’s website, received receipts and marketing communications at their Massachusetts address, and noticed other Massachusetts vehicles at the hotel during their visit. Following Anthony’s death, the Putnams filed a wrongful death lawsuit in the United States District Court for the District of Massachusetts against Premier Parks, LLC, which they believed operated the hotel, and EPR Properties, which they believed owned it. Both Premier and EPR moved to dismiss for lack of personal jurisdiction, submitting affidavits asserting they neither owned nor operated the hotel, nor marketed or contracted with Massachusetts residents regarding the hotel. The Putnams submitted documentary evidence suggesting connections between Premier, EPR, and the hotel, but the district court dismissed the case with prejudice and denied their request for jurisdictional discovery. On appeal, the United States Court of Appeals for the First Circuit reviewed the dismissal de novo. The court found that, as to Premier Parks, the Putnams presented enough documentary evidence to create a genuine dispute regarding Premier’s involvement in the hotel’s operations, marketing, and staffing. The court held that the district court abused its discretion by denying jurisdictional discovery with respect to Premier and reversed the dismissal as to Premier, remanding for discovery. Regarding EPR, the court concluded that the Putnams failed to contradict EPR’s affidavit that it did not own or operate the hotel or market it to Massachusetts residents. The court affirmed the dismissal as to EPR but modified the judgment to be without prejudice. View "Putnam v. EPR Properties" on Justia Law

Miles v. Bowers

2026-04-27T21:00:03-08:00

Arthur Miles was sentenced to a total of 300 months’ imprisonment following two separate federal convictions. After his first sentencing in October 2022, Miles was housed at the Marion County Jail in Indiana for fifteen months—some of this time was before and some after his second federal sentencing. During his time at the county jail, Miles worked as an orderly. He later argued that under the First Step Act of 2018 (“FSA”), he was entitled to earn time credits for this work, which could reduce his sentence, because his federal sentence had commenced and the work was equivalent to an evidence-based recidivism reduction (“EBRR”) program. The United States District Court for the District of Massachusetts reviewed Miles’s habeas petition after a magistrate judge recommended denying the Bureau of Prisons’ (BOP) motion to dismiss. The magistrate judge found that BOP regulations preventing prisoners from earning FSA credits until they arrived at a federal facility conflicted with the FSA’s language. The district court, however, rejected this recommendation and dismissed Miles’s petition, holding that the BOP’s rules did not violate the FSA. The United States Court of Appeals for the First Circuit held that the BOP’s regulation, which delayed the accrual of FSA time credits until a prisoner’s arrival at a federal facility, was invalid because it conflicted with the statutory definition of when a sentence commences. The court further held that a risk and needs assessment is not a prerequisite for earning FSA credits, and that prisoners may earn credits for qualifying programming—such as work as an orderly—performed after sentencing even while housed in non-federal facilities. The court vacated the dismissal of Miles’s habeas petition and remanded for further proceedings to determine his entitlement to credits for his time at the county jail. View "Miles v. Bowers" on Justia Law

US v. Shafa

2026-04-24T10:30:02-08:00

The case involves a Massachusetts psychiatrist who owned and operated a clinic providing treatment for addiction with imported drugs. The drugs included naltrexone and disulfiram in forms not approved by the FDA for use in the United States. The shipments were brought in from Hong Kong and falsely described on import documents as “plastic beads in plastic tubes,” with their value understated. The government charged the defendant with several crimes, including international money laundering, unlawful importation of merchandise, and receipt and delivery of misbranded drugs. The jury found the defendant guilty on some counts but acquitted him on others, including all counts against his wife. The United States District Court for the District of Massachusetts conducted the trial. After the jury’s verdict, the court sentenced the defendant to 36 months’ imprisonment on each count, to be served concurrently, and calculated the sentence using the fraud guideline in the United States Sentencing Guidelines. The defendant appealed, arguing that the district court erred in its evidentiary rulings, in admitting or excluding certain testimony, and in its application of the Sentencing Guidelines. The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the defendant’s convictions, finding no reversible error in the district court’s evidentiary decisions or in its exclusion of expert testimony. The appellate court vacated the sentence for the misdemeanor misbranding conviction because it exceeded the statutory maximum. The court retained jurisdiction over the appeal and remanded to the district court for clarification regarding the application of the fraud guideline, specifically instructing the lower court to explain the basis for its use of that guideline and to address the impact of recent amendments related to acquitted conduct. View "US v. Shafa" on Justia Law

Lopez Martinez v. Blanche

2026-04-23T21:00:03-08:00

A Honduran citizen and his minor son entered the United States in 2017 without valid documentation and were detained. The father applied for asylum and withholding of removal, basing his claims on his evangelical Christian faith, family relationship, and his opposition to gangs, particularly due to his efforts to encourage gang members to leave their organizations and his resistance to the recruitment of his son by local gangs. He presented evidence of threats and violence against himself and his family by gang members, as well as country conditions reports describing severe gang control in Honduras and the dangers faced by those opposing gangs or spreading religious messages. An immigration judge (IJ) denied his claims, finding him not credible and concluding that, even if credible, he failed to show past persecution or a well-founded fear of future persecution based on membership in a cognizable social group. The IJ did not address the political opinion or religion-based claims. On appeal, the Board of Immigration Appeals (BIA) assumed his credibility but determined he had not shown a nexus between the feared harm and a protected ground under the Immigration and Nationality Act. The BIA rejected his political opinion claim, holding that resisting gang recruitment does not constitute an actual or imputed political opinion, and did not substantively address his religion-based arguments. The United States Court of Appeals for the First Circuit reviewed the BIA’s decision. The court held that there is no categorical bar to asylum or withholding claims based on resistance to gang recruitment or opposition to gangs as a political opinion; such claims require a fact-specific inquiry into whether an actual or imputed political opinion motivated the persecution. The court also concluded that the BIA failed to address the religion-based claim. The First Circuit granted the petition, vacated the BIA’s decision, and remanded for further proceedings. View "Lopez Martinez v. Blanche" on Justia Law

Perez v. FEMA

2026-04-22T21:00:03-08:00

After Puerto Rico was struck by Hurricane Maria, a nonprofit organization based in Oklahoma, known as "The Facilitators: Iron Horse, Inc." (TFCI), received federal funds from the Federal Emergency Management Agency (FEMA) to provide post-disaster services. The plaintiffs in this case were hired by TFCI to perform this work. When TFCI’s federal funding was exhausted, it sought additional funds from FEMA, but that request was denied. Despite this, the plaintiffs continued working without full pay for several weeks before being terminated by TFCI. The plaintiffs filed suit in the United States District Court for the District of Puerto Rico seeking backpay from FEMA and TFCI, claiming they were entitled to wages as employees under the Fair Labor Standards Act (FLSA). FEMA removed the case to federal court. The plaintiffs amended their complaint multiple times to clarify their FLSA claims and add additional plaintiffs. Both sides moved for summary judgment. The district court granted summary judgment for FEMA, finding the plaintiffs were not FEMA employees under the FLSA, and entered summary judgment for TFCI as well. The court declined to exercise supplemental jurisdiction over the Commonwealth-law claims. On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s decision de novo. The court found that the uncontroverted facts established that TFCI, not FEMA, had the authority to hire, fire, supervise work, set pay, and maintain employment records for the plaintiffs. Arguments by the plaintiffs that FEMA exercised sufficient control were unsupported by the record. The First Circuit held that FEMA was not the plaintiffs’ employer under the FLSA and affirmed the district court’s grant of summary judgment in favor of FEMA. View "Perez v. FEMA" on Justia Law

US v. Giang

2026-04-22T21:00:03-08:00

The defendant, who immigrated to the United States from Vietnam, operated a staffing agency that provided temporary laborers to various clients in Massachusetts. She managed most of the agency’s operations, including payroll, and worked closely with her daughter, who had accounting training. Between 2015 and 2019, the defendant withdrew over $3.7 million in cash from business accounts, frequently in increments just below the $10,000 federal reporting threshold, and used this cash to pay workers. Evidence at trial showed that the agency paid employees additional cash wages not reported to tax authorities, resulting in unpaid employment taxes and underreported payroll to the company’s workers’ compensation insurer, which led to lower insurance premiums. A federal grand jury in the District of Massachusetts indicted the defendant on four counts of failing to collect or pay employment taxes and one count of mail fraud. After a jury trial, she was convicted on all counts and sentenced to eighteen months’ imprisonment and two years of supervised release. She appealed, challenging the admission of evidence regarding the structuring of cash withdrawals, the district court’s refusal to give a jury instruction on implicit bias, the instructions related to tax obligations and good faith, and the sufficiency of the evidence supporting the mail fraud conviction. The United States Court of Appeals for the First Circuit reviewed the case and affirmed the convictions. The court held that evidence about the structuring of cash withdrawals was properly admitted as intrinsic to the charged offenses and relevant to intent. The refusal to instruct on implicit bias was not an error because the district court’s voir dire and instructions substantially covered the issue. The court found no reversible error in the jury instructions regarding tax law and good faith, and concluded that any error was harmless. Finally, the evidence of mail fraud was found sufficient, as it was reasonably foreseeable that the mail would be used in the insurance audit process. View "US v. Giang" on Justia Law

Martinez v. Blanche

2026-04-19T21:00:02-08:00

A Venezuelan national entered the United States lawfully on a B1 visa, later overstayed, and remained in the country. He married a U.S. citizen, with whom he shares a child. After overstaying his visa, he purchased a false Social Security card and birth certificate under another person’s name, using these documents to obtain employment and a driver's license. He was charged under this alias with assault and battery but was acquitted by a jury. Subsequently, he was discovered using false identification during a traffic stop, leading to several criminal charges, which were later dropped. Following these events, the Department of Homeland Security initiated removal proceedings against him, citing his overstay. He applied for adjustment of status based on his marriage to a U.S. citizen. The Immigration Judge (IJ) found his testimony credible, acknowledged his use of false documents for employment, and weighed positive discretionary factors, including his marriage, child, and employment, ultimately granting his application for adjustment of status. The Department of Homeland Security appealed, and the Board of Immigration Appeals (BIA) reversed the IJ’s grant. The BIA gave weight to what it characterized as "criminal behavior," including the use of false identification to "avoid criminal prosecution," and concluded that the negative factors outweighed the positives, denying adjustment of status and ordering removal. The United States Court of Appeals for the First Circuit considered whether the BIA had engaged in impermissible factfinding. The court held that the BIA exceeded its authority by making a specific finding about the petitioner’s intent in using the false ID—a fact not found by the IJ and not supported in the record. The First Circuit reversed the BIA’s decision and remanded for proceedings consistent with its opinion. View "Martinez v. Blanche" on Justia Law

US v. Cartagena

2026-04-15T10:00:04-08:00

In this case, four police officers in Puerto Rico pursued two young men suspected of engaging in a drug deal. One officer shot 17-year-old Calep Carvajal in the back as he fled on a bicycle. Defendant José Cartagena apprehended and handcuffed Carvajal, and was accused of pistol-whipping him while he was on the ground. Additional assaults allegedly occurred during and after transport to the police station. Cartagena later filed a false report about the incident and lied to a juvenile prosecutor about Carvajal’s injuries. Federal charges were brought under various statutes, including civil rights violations and obstruction of justice. After a grand jury indictment, three officers pleaded guilty. Cartagena initially entered a plea but withdrew it and went to trial in the United States District Court for the District of Puerto Rico. He was convicted by a jury on all counts and sentenced to concurrent prison terms. On appeal, he challenged the sufficiency of the evidence and asserted that his Sixth Amendment Confrontation Clause rights were violated when the prosecution introduced a hearsay statement from the victim, who was not available for cross-examination. The United States Court of Appeals for the First Circuit reviewed the case. It found the evidence sufficient to support convictions on most counts but determined that the admission of the victim’s testimonial hearsay statement, offered through a government medical expert, violated Cartagena’s Confrontation Clause rights as to the count involving the alleged pistol-whipping during the arrest. The court vacated the conviction on that count, affirmed the convictions on the other counts, and remanded the case for further proceedings consistent with its opinion. View "US v. Cartagena" on Justia Law

US v. Nieves-Diaz

2026-04-14T13:00:04-08:00

After police executed a search warrant at an apartment in San Juan, Puerto Rico, where Heclouis Joel Nieves-Díaz was residing, they found drugs, ammunition, and a machine gun conversion device. Nieves, who was on supervised release for a previous federal drug conviction, pleaded guilty to federal charges including being a felon in possession of ammunition, illegal possession of a machine gun conversion device, and possession with intent to distribute cocaine. The United States District Court for the District of Puerto Rico initially sentenced Nieves to eighty-four months' imprisonment, applying a four-level enhancement for using or possessing ammunition in connection with another felony. On appeal, the United States Court of Appeals for the First Circuit vacated that sentence, finding the enhancement inapplicable. On remand, the district court recalculated the guidelines range and resentenced Nieves to sixty-six months—twenty-five months above the top of the new Guidelines range—based on an upward variance. The court justified the variance by citing Nieves’s criminal history, the quantity of ammunition, and the prevalence of gun violence in Puerto Rico. Nieves appealed again, arguing that the district court failed to adequately explain the upward variance, particularly regarding the significance of the ammunition in the absence of a firearm. The United States Court of Appeals for the First Circuit held that the district court’s explanation for the variance was insufficient, especially in not addressing Nieves’s argument about the lack of a firearm. The court vacated the sentence and remanded for resentencing, clarifying that while the district court could consider Nieves’s criminal history and community factors, it must provide a more specific explanation if it imposes an upward variance based on the quantity of ammunition. The appellate court declined to limit the sentence on remand or order reassignment to a different judge. View "US v. Nieves-Diaz" on Justia Law

Garcia-Navarro v. Universal Insurance Company

2026-04-10T13:00:04-08:00

The plaintiff brought a suit under Puerto Rico law after her mother died while residing in an assisted living facility. The plaintiff alleged that the facility's staff, including a licensed practical nurse, incorrectly informed treating physicians that her mother was a Jehovah's Witness. As a result, necessary blood transfusions were not administered, and the mother died from heart failure. The facility’s insurer had denied coverage for the incident under its general liability policy, claiming that the alleged wrongful acts were excluded as “professional services.” The United States District Court for the District of Puerto Rico first granted partial summary judgment for the insurer, finding that certain actions—such as failing to call 911—were excluded as “professional services,” but allowed the case to proceed on claims related to record-keeping and miscommunication, concluding those were not “professional services” under existing precedent. After the case was reassigned, the new district judge reaffirmed that ruling, and a damages trial resulted in a verdict against the facility. Subsequent to a decision by the Puerto Rico Supreme Court in Rivera-Matos v. Commonwealth, which clarified the scope of “professional services” exclusions, the district judge permitted the insurer to relitigate the coverage issue, ultimately finding that the exclusion did apply to the acts in question and entering judgment for the insurer. On appeal, the United States Court of Appeals for the First Circuit held that the plaintiff had forfeited her argument that the Puerto Rico Supreme Court’s decision should not be applied retroactively, as she had not raised it below. The court further found no plain error in the application of the new precedent. The judgment of the district court in favor of the insurer was affirmed. View "Garcia-Navarro v. Universal Insurance Company" on Justia Law

Beckwith v. Frey

2026-04-03T12:30:05-08:00

After a mass shooting in Lewiston, Maine in October 2023, which resulted in significant loss of life, the state enacted a law requiring a seventy-two-hour waiting period before a firearm seller may deliver a purchased firearm to the buyer. The law’s purpose was to reduce suicides and homicides associated with impulsive gun purchases. The statute contains exceptions for law enforcement officers, certain security personnel, family transactions, collectors, antiques, and cases where background checks are not required. Several individuals and firearms businesses challenged the law in federal court, alleging it violated their Second Amendment rights, both facially and as applied. The United States District Court for the District of Maine granted a preliminary injunction, concluding that the plaintiffs were likely to succeed on the merits of their facial Second Amendment claim. The court applied the two-step framework from New York State Rifle & Pistol Ass’n, Inc. v. Bruen, first finding that the law implicated conduct covered by the plain text of the Second Amendment, and then determining that the state had not shown that the law was consistent with the nation’s historical tradition of firearms regulation. The district court also found that the other factors for granting a preliminary injunction were present. On appeal, the United States Court of Appeals for the First Circuit reviewed the matter de novo. The appellate court concluded that the seventy-two-hour waiting period regulates conduct antecedent to “keeping” or “bearing” arms, and thus does not directly implicate the plain text of the Second Amendment. The court found that the law imposes, at most, a presumptively lawful condition on the commercial sale of firearms, akin to “shall-issue” licensing regimes, and is constitutional unless shown to be abusive. The court determined that the plaintiffs had not shown the law was abusive toward Second Amendment rights. Accordingly, the First Circuit vacated the preliminary injunction and remanded the case for further proceedings. View "Beckwith v. Frey" on Justia Law

US v. Calderin-Pascual

2026-04-03T12:30:05-08:00

A man sought to contest the forfeiture of a boat, claiming he was its rightful owner. The boat had been seized and made subject to forfeiture following his brother’s guilty plea to a federal drug conspiracy that began in May 2019. The man submitted a pro se petition in federal district court, asserting under penalty of perjury that he was the sole and rightful owner of the boat at the time it was seized. He attached several documents, all in Spanish, which he described as evidence of ownership and title. Later, with counsel, he provided additional documents purporting to show that he acquired the boat in 2017. The United States District Court for the District of Puerto Rico had issued a preliminary order of forfeiture following the brother’s plea. After the man’s petition, the government moved to dismiss, arguing that the petition failed to allege when and how the man acquired his interest in the boat, as required by statute. The district court granted the government’s motion to dismiss without a hearing and entered a final order of forfeiture. The man appealed, arguing that his submissions sufficed or, alternatively, that he should have been allowed to amend his petition. The United States Court of Appeals for the First Circuit reviewed the case de novo. It held that the man’s petition did not satisfy the statutory requirement to state the time and circumstances of his acquisition of the boat, and that untranslated documents could not be considered. However, the appellate court found that the district court did not address the alternative request for leave to amend, and the reasons for denial were not apparent from the record. The First Circuit vacated the denial of the petition and remanded for further proceedings, directing the district court to consider the request to amend in light of the liberal construction required by statute. View "US v. Calderin-Pascual" on Justia Law

Wescott v. Stanfill

2026-04-02T13:00:05-08:00

A law firm and one of its clients challenged Maine’s Interest on Lawyers’ Trust Accounts (IOLTA) program, which requires attorneys to deposit certain client funds into pooled, interest-bearing accounts. The interest generated is collected by a nonprofit, the Maine Justice Foundation, and distributed to organizations supporting access to justice in Maine. The plaintiffs argued that being compelled to participate in the program forced them to subsidize advocacy with which they disagreed, violating their First and Fourteenth Amendment rights. The United States District Court for the District of Maine dismissed the claims against the Chief Justice of the Maine Supreme Judicial Court and the State Court Administrator on the merits, concluding that the plaintiffs failed to state a claim. Specifically, the District Court found that, under Maine’s rules, only client funds that could not generate net interest for the client (due to the amount or duration) are required to be deposited in IOLTA accounts, and the plaintiffs did not plausibly allege otherwise. The claim against the Maine Justice Foundation was dismissed for lack of jurisdiction, as the Foundation neither promulgates nor enforces the challenged rule. On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s rulings. The appellate court held that the plaintiffs failed to plausibly allege they were compelled to deposit funds that would have generated net interest for the client, as required to make out a compelled-speech claim under controlling precedent. The court also found that any appeal of the dismissal against the Maine Justice Foundation was moot, since the complaint was fatally deficient regardless of the defendant. Thus, the First Circuit affirmed the judgment of the District Court. View "Wescott v. Stanfill" on Justia Law

US v. Ross

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

The case concerns a defendant who, after previously being convicted of possessing child pornography and serving a prison sentence followed by supervised release, was found during his supervision with additional devices containing child sexual abuse material (CSAM). The defendant, Kevin Lee Ross, was subject to conditions including restrictions on his internet use, device monitoring, and random searches. During his term of supervised release, a tip from his brother led probation officers to search his residence and vehicle, where they discovered a cell phone, laptop, and external hard drive, all containing a large quantity of CSAM. Ross denied knowledge of the devices and their contents. A grand jury in the United States District Court for the District of Maine indicted Ross for possessing child pornography across three devices. At trial, Ross stipulated that certain exhibits contained child pornography as legally defined. Despite this, the government introduced and published nine representative exhibits to the jury and had a special agent describe their contents. Ross objected, arguing that, due to the stipulation, displaying the images and providing descriptions was unfairly prejudicial under Federal Rule of Evidence 403. The district court overruled his objections, relying on precedent that allows the government to present its evidence even where a defendant is willing to stipulate to certain elements. The jury convicted Ross. On appeal to the United States Court of Appeals for the First Circuit, Ross argued that the district court abused its discretion by allowing the publication and description of the CSAM exhibits in light of the stipulation. The First Circuit held that the district court did not abuse its discretion, finding that the evidence remained probative to issues of possession and knowledge, especially since Ross denied knowing the contents of the devices. The court affirmed Ross’s conviction. View "US v. Ross" on Justia Law

Villalobos-Santana v. PR Police Department

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

Two former police officers sued their employer, the Puerto Rico Police Department, alleging illegal retaliation after one reported age discrimination to the Equal Employment Opportunity Commission and the other testified in support. The plaintiffs claimed that, as a result, they suffered adverse employment actions such as dangerous shift changes, loss of duties, and fabricated complaints. The challenged conduct primarily occurred after Puerto Rico filed for financial reorganization under PROMESA, a federal statute enacted in response to the Commonwealth’s fiscal crisis. The United States District Court for the District of Puerto Rico presided over the case while Puerto Rico’s reorganization plan was pending in the Title III court. After the reorganization plan’s "Effective Date" passed, and while the plaintiffs’ suit was ongoing, the Department asserted that the claims had been discharged under the plan because the plaintiffs had not timely filed proofs of claim. The District Court agreed, permanently stayed the case, and enjoined the plaintiffs from pursuing their claims, finding that the claims must have arisen at least in part before the plan’s Effective Date since the suit was filed prior to that date. The District Court did not address the plaintiffs' judicial estoppel argument or their contention that post-petition claims were not dischargeable. On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s judgment, but on different grounds. The appellate court held that the plaintiffs’ retaliation claims qualified as administrative expense claims under PROMESA (via incorporation of the Bankruptcy Code), and because the plaintiffs did not timely file such claims before the administrative claims bar date, they were discharged by the plan. The court also rejected the plaintiffs' judicial estoppel argument, finding no inconsistency in the Department’s litigation positions. The First Circuit’s judgment affirmed the permanent stay and injunction. View "Villalobos-Santana v. PR Police Department" on Justia Law

United States v. Ponzo

2026-04-01T12:30:05-08:00

Two brothers operated an energy-conservation contracting business and, beginning in 2013, engaged in a bribery scheme involving the Mass Save program, a state-mandated initiative to promote energy efficiency. One brother owned CAP Electric, Inc., and recruited the other to establish Air Tight Solutions, LLC as a Mass Save contractor with the assistance of a CLEAResult employee, who was responsible for selecting and overseeing contractors. The brothers paid this employee, and later another, regular bribes in cash and gifts to secure contracts, favorable treatment, and advance warning of audits. Air Tight performed little or no work directly, subcontracted projects, and disguised employees and payments to conceal the scheme. Over several years, their companies received multi-million dollar payments from the program. The United States District Court for the District of Massachusetts accepted their guilty pleas to conspiracy, honest-services wire fraud, making false statements, and (for one brother) aiding and assisting false tax returns. The district judge sentenced both to 27 months in prison (above-guidelines for one), and ordered forfeiture of $13.2 million and $3.6 million respectively. The brothers challenged the sentences and forfeitures on several grounds, including alleged errors in calculating tax loss, application of sentencing enhancements, and the process and proportionality of the forfeiture orders. The United States Court of Appeals for the First Circuit reviewed the case. It held that the district court did not err in calculating tax loss or applying sentencing enhancements for sophisticated means, obstruction of justice, and aggravating role. The appellate court also held that the district court correctly found a sufficient connection between the criminal conduct and the forfeited proceeds, and that any procedural errors in the forfeiture process were harmless. Finally, the court determined that the forfeiture orders were not unconstitutionally excessive. The First Circuit affirmed the sentences and forfeiture orders. View "United States v. Ponzo" on Justia Law

Ocasio v. Comision Estatal de Elecciones

2026-04-01T12:30:04-08:00

Two individuals challenged the Puerto Rican electoral commission and its acting president, arguing that restrictions on early and absentee voting during the 2020 general election unlawfully burdened the right to vote for citizens over sixty, especially considering the COVID-19 pandemic. In August 2020, they brought suit under 42 U.S.C. § 1983, seeking relief on constitutional grounds. The district court promptly issued a preliminary injunction, then a permanent injunction, allowing voters over sixty to vote early by mail. After judgment, the plaintiffs were awarded nearly $65,000 in attorneys’ fees under 42 U.S.C. § 1988. While the fee motion was pending, Puerto Rico’s government was in the process of debt restructuring under Title III of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA). The restructuring plan, confirmed in January 2022, discharged claims against Puerto Rico arising before the plan’s effective date unless creditors filed proof of claim by a set deadline. Defendants argued in the U.S. District Court for the District of Puerto Rico that the attorneys’ fees award was subject to the plan’s discharge and enjoined from collection, because the plaintiffs had not filed a timely administrative expense claim. The district court rejected this, finding the fee award unrelated to the bankruptcy case. On appeal, the United States Court of Appeals for the First Circuit concluded that the claim for attorneys’ fees, though arising from post-petition litigation, related to events before the plan’s effective date. The court held that because the plaintiffs had actual knowledge of the restructuring proceedings but did not file a timely proof of claim, their fee claim was discharged under the confirmed plan and enjoined from collection. The First Circuit reversed the district court’s order, holding that the discharge injunction applied to the attorneys’ fee award. View "Ocasio v. Comision Estatal de Elecciones" on Justia Law

National Alliance to End Homelessness v. Department of Housing and Urban Development

2026-04-01T09:30:05-08:00

The case concerns significant changes made by the U.S. Department of Housing and Urban Development (HUD) to the Continuum of Care (CoC) program, which provides federal funding for homeless assistance projects. In November 2025, HUD issued a new Notice of Funding Opportunity (NOFO) that rescinded a previously issued two-year NOFO and introduced new requirements, including a drastic reduction in renewal funding for core permanent housing projects and new eligibility conditions. These changes threatened to eliminate funding for many projects, risking increased homelessness in the affected communities. Two groups of plaintiffs, including states, cities, and advocacy organizations, challenged HUD’s actions, alleging violations of the Administrative Procedure Act (APA) and constitutional provisions. The United States District Court for the District of Rhode Island issued preliminary injunctions prohibiting HUD from rescinding the prior NOFO and from implementing the challenged conditions in the new NOFOs. The court found that HUD’s actions likely violated the APA, were arbitrary and capricious, and would cause irreparable harm by creating funding gaps and service disruptions for vulnerable populations. After Congress passed new appropriations legislation in early 2026—setting a structure for grant renewals to avoid funding gaps—HUD moved to dissolve the injunctions, arguing that the legislative changes eliminated any ongoing harm and affected the merits of the legal claims. The district court denied the motion, concluding that the risk of harm persisted and that the plaintiffs remained likely to succeed on their claims. On appeal, the United States Court of Appeals for the First Circuit reviewed only the district court’s denial of HUD’s motion to dissolve the preliminary injunctions. The court held that HUD failed to make a strong showing that the intervening appropriations law eliminated the plaintiffs’ risk of harm or undermined the basis for the injunctions. The First Circuit therefore denied HUD’s request for a stay pending appeal. View "National Alliance to End Homelessness v. Department of Housing and Urban Development" on Justia Law

United States v. Roache

2026-03-30T13:30:04-08:00

Federal agents began investigating after tracing firearms used in crimes in Massachusetts to purchases made by a South Carolina resident, Brunson. During interviews in 2021, Brunson told agents he had purchased twenty-four firearms for someone known as “Boston,” later identifying Roache as that individual. Brunson described a process in which Roache would select, pay for, and then receive firearms from him. Additional investigation revealed more firearms linked to Brunson’s purchases had been recovered in Massachusetts, and records showed similar transactions between Brunson and Roache continued into early 2023. In total, agents traced at least forty-six firearms purchased by Brunson, with evidence directly connecting Roache to six purchases in 2023. Roache and Brunson were indicted and pled guilty in the United States District Court for the District of Massachusetts to conspiring to traffic firearms. The Presentence Investigation Report (PSR) recommended a six-level sentencing enhancement based on the number of firearms Brunson stated he had purchased for Roache, as well as those confirmed in 2023. Roache objected, arguing that Brunson’s statements about the earlier purchases were uncorroborated and unreliable. The district court overruled Roache’s objection, finding that Brunson’s statements were sufficiently reliable, given corroborative evidence and the consistency of the described transactions with later confirmed acts. Roache was sentenced to fifty-seven months’ imprisonment, with three years of supervised release. The United States Court of Appeals for the First Circuit reviewed the district court’s application of the six-level enhancement for procedural error. The appellate court held that the district court did not abuse its discretion in crediting Brunson’s statements about the number of firearms trafficked, as those statements were supported by adequate indicia of reliability, and affirmed the sentence. View "United States v. Roache" on Justia Law

Kendell Seafood Imports, Inc. v. Mark Foods, LLC

2026-03-27T13:00:07-08:00

Kendell Seafood Imports, Inc. and Mark Foods, LLC are both fish importers. Kendell alleged that Mark Foods tortiously interfered with its agreement with Chilean Sea Bass, Inc. (CSB), a fish distributor. According to Kendell, it had arranged with CSB to purchase the distributor’s entire catch for several years, including 2021, and that CSB agreed to roll over an outstanding 2020 balance into the 2021 price. Kendell further claimed that Mark Foods was aware of this agreement and attempted to solicit business from CSB during the same period, thereby interfering with Kendell’s relationship and causing it harm. After Kendell initially sued Mark Foods for tortious interference in the United States District Court for the District of Rhode Island, Mark Foods moved to dismiss the complaint. In response, Kendell filed an amended complaint with similar facts but with additional details about the agreement with CSB. The district court treated the amended complaint as operative and, after considering substantive arguments from both parties, granted Mark Foods’ motion to dismiss with prejudice. The district court found that Kendell’s allegations did not plausibly support three essential elements of tortious interference: the defendant’s knowledge of the contract, intentional interference, and resulting damages. The United States Court of Appeals for the First Circuit reviewed the case on appeal. It held that the district court properly applied the pending motion to dismiss to the amended complaint, as the amendments did not affect the relevant arguments. Applying Rhode Island law, the First Circuit concluded that Kendell had not sufficiently pleaded that Mark Foods knew about the specific agreement with CSB. Because this element was not plausibly alleged, the court affirmed the district court’s order dismissing the case with prejudice. View "Kendell Seafood Imports, Inc. v. Mark Foods, LLC" on Justia Law

Holland v. Elevance Health, Inc.

2026-03-27T13:00:07-08:00

An employee of the Falmouth Public Schools in Maine, enrolled in a health insurance plan administered by Anthem Health Plans of Maine, Inc., challenged the plan’s exclusion of coverage for weight-loss medications. After being diagnosed with obesity and prescribed FDA-approved weight-loss drugs, the employee’s requests for coverage were repeatedly denied. Her medical providers appealed to Anthem, supporting the necessity of the medication, but Anthem maintained its denial, citing the plan’s explicit exclusion of weight-loss medications regardless of obesity diagnosis. The employee, on behalf of herself and a proposed class, sued Anthem’s parent company, Elevance Health, Inc., in the United States District Court for the District of Maine. She alleged that the exclusion constituted disability discrimination under Section 1557 of the Patient Protection and Affordable Care Act, which incorporates the nondiscrimination requirements of Section 504 of the Rehabilitation Act. Elevance moved to dismiss, arguing the complaint failed to plausibly allege disability discrimination. The district court granted the motion, reasoning that the exclusion applied to all enrollees, regardless of disability status, and did not target disabled individuals for discriminatory treatment. The court found the allegations of discrimination to be conclusory and insufficient to support claims of intentional, proxy, or disparate impact discrimination. On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The appellate court held that the plaintiff failed to plausibly allege that the exclusion of weight-loss medication coverage constituted discrimination under Section 1557. The court concluded that the exclusion was facially neutral, did not serve as a proxy for disability discrimination, and did not result in a lack of meaningful access to plan benefits for disabled individuals. Accordingly, the dismissal of the complaint was affirmed. View "Holland v. Elevance Health, Inc." on Justia Law

Urizar-Mota v. US

2026-03-27T13:00:06-08:00

A mother of four regularly sought care at a federally funded health center in Rhode Island from 2006 onward. Over a period of several years, she repeatedly reported persistent, weeks-long headaches with changing characteristics to her primary-care providers, also disclosing experiences of domestic abuse. Despite these reports, she was diagnosed with migraines and prescribed medication, but was never referred to a neurologist or for neuroimaging. In 2019, her symptoms worsened, and she lost consciousness, leading to hospitalization and the discovery of a slow-growing brain tumor, which had caused a buildup of cerebral fluid. Surgery to remove the tumor resulted in cerebellar strokes and permanent neurological damage, severely limiting her mobility and ability to care for her family. After the Department of Health and Human Services denied her administrative claim, she and her family filed suit under the Federal Tort Claims Act (FTCA) in the United States District Court for the District of Rhode Island. The district court found negligence by the primary-care providers, awarded her damages for medical expenses, pain and suffering, and homemaker loss, and awarded her children damages for loss of consortium. The government appealed, arguing that the children’s consortium claims were not properly presented administratively, that the homemaker damages were excessive, and that the findings on standard of care, causation, and medical expenses were erroneous. The United States Court of Appeals for the First Circuit held that the children’s loss-of-consortium claims were barred for failure to exhaust administrative remedies and reversed those damages. The court vacated the homemaker damages award as excessive and unsupported by the evidence, remanding for further proceedings. The court affirmed the district court’s findings on negligence and causation and upheld the pain and suffering awards, but reduced the medical expense award by the cost of an unrelated spinal MRI. The judgment was thus affirmed in part, reversed in part, modified in part, and remanded. View "Urizar-Mota v. US" on Justia Law

Ramos-Ramos v. Jordan-Conde

2026-03-25T13:00:04-08:00

Four employees of the University of Puerto Rico sought to stop the deduction of union dues from their paychecks after the Supreme Court’s decision in Janus v. American Federation of State, County, & Municipal Employees, Council 31, which held that public sector employees could not be compelled to pay union dues without consent. Despite their requests, the University and the union continued to deduct dues for nearly three years. The employees then brought suit against the University’s president and the union, alleging violations of their First Amendment rights and seeking declaratory and injunctive relief, as well as damages. The United States District Court for the District of Puerto Rico largely granted summary judgment to the University president and the union, finding no constitutional violation. However, the court ordered the union to reimburse the employees for dues deducted after their resignations but denied interest and did not grant declaratory or injunctive relief. The court also declined to exercise supplemental jurisdiction over the employees’ Puerto Rico law claims. On appeal, the United States Court of Appeals for the First Circuit was asked only to direct the district court to issue declaratory judgments stating that the past and potential future deductions were unconstitutional. The First Circuit dismissed the appeal as moot. It held that a declaration regarding past conduct would be merely advisory because the deductions had already ceased and a judgment ordering reimbursement was in place. The court also found the request for prospective relief moot, as the University and union had admitted their error, stopped the deductions, and adopted new policies to comply with Janus. The court concluded there was no substantial controversy remaining and that the voluntary cessation doctrine did not apply under these facts. The appeal was therefore dismissed as moot. View "Ramos-Ramos v. Jordan-Conde" on Justia Law

Harris v. National Grid USA Service Company, Inc.

2026-03-24T12:30:05-08:00

The plaintiff was employed as a Change Analyst by a utility company, with responsibilities requiring travel throughout a multi-state service territory. Amid the COVID-19 pandemic in July 2020, the plaintiff took a vacation to Ohio and California and, upon its conclusion, sought to work remotely from outside his designated territory. Although company policy permitted temporary remote work from outside the service area, it required supervisory approval, which the plaintiff had not obtained. When notified by the company’s Human Resources Director that he would be deemed to have resigned unless he immediately returned to his territory, the plaintiff, for the first time, disclosed a preexisting condition and requested a reasonable accommodation to work remotely, citing COVID-19 risks. He provided a brief doctor’s note but did not supply further documentation or assert any reason he could not work remotely from within his service territory. After failing to return or provide sufficient medical documentation, his employment was terminated. The United States District Court for the District of Massachusetts granted summary judgment in favor of the employer on the plaintiff’s claims of retaliation under Massachusetts law and the Family and Medical Leave Act, finding no causal connection between the plaintiff’s protected activity and his termination. The district court determined that the employer had already decided to terminate the plaintiff before he engaged in any protected conduct. Reviewing the case de novo, the United States Court of Appeals for the First Circuit affirmed. The court held that the clear chronological order of events precluded any finding that the plaintiff’s request for accommodation or invocation of FMLA rights caused his termination. The court found that the adverse employment action was determined before the protected activity occurred and that the employer’s actions showed consideration for, rather than retaliation against, the plaintiff’s rights. The grant of summary judgment was affirmed in full. View "Harris v. National Grid USA Service Company, Inc." on Justia Law

Manzo v. Wohlstadter

2026-03-24T12:30:04-08:00

The plaintiffs, who were long-time friends of the defendants, invested significant sums in a biopharmaceutical company controlled by the defendants. The defendants did not disclose that the company was in serious financial distress, under a substantial obligation to a lender, and prohibited from incurring additional debt. The investment was structured through promissory notes, which included false warranties regarding the company’s financial status and claimed the formation of a new entity that never materialized. Instead of funding a new venture, the defendants used the investment to pay off existing company debt. Less than two years later, the company declared bankruptcy, making the notes essentially worthless. The plaintiffs brought claims under federal and Massachusetts securities laws, the Massachusetts consumer protection statute, and for common law fraud and negligent misrepresentation in the United States District Court for the District of Massachusetts. The defendants moved to dismiss the action, relying on a forum selection clause in the promissory notes requiring litigation in Delaware courts. The district court granted the motion and dismissed the case without prejudice, concluding that the clause applied to the plaintiffs’ claims. On appeal, the United States Court of Appeals for the First Circuit reviewed the dismissal de novo. The plaintiffs argued that their claims did not “arise out of” the notes and that the forum selection clause was unenforceable as contrary to Massachusetts public policy. The First Circuit rejected both arguments, holding that the claims arose from the notes and that the plaintiffs did not meet the heavy burden required to invalidate the clause on public policy grounds. The First Circuit affirmed the district court’s dismissal without prejudice, leaving the plaintiffs free to pursue their claims in the contractually designated Delaware courts. View "Manzo v. Wohlstadter" on Justia Law

Hellman v. Department of Elementary and Secondary Education

2026-03-20T13:30:05-08:00

The case involves parents of two children with disabilities, both of whom attend private religious schools in Massachusetts. State law entitles all students with disabilities, including those in private schools, to publicly funded special education services. However, a state regulation requires that while public school students can receive these services at their school of enrollment, private school students may only receive them at a public school or another public or neutral location. The parents, who observe Jewish law and prefer their children’s education be informed by Judaism, found it burdensome and disruptive to transport their children to and from different locations for services and chose to forgo the publicly funded services. The parents sued the Massachusetts Department of Elementary and Secondary Education, individual board members, and the commissioner in the United States District Court for the District of Massachusetts. They alleged that the regulation violated the Due Process, Equal Protection, and Privileges or Immunities Clauses of the Fourteenth Amendment by interfering with their fundamental right to direct the upbringing and education of their children. The district court dismissed the complaint for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6). On appeal, the United States Court of Appeals for the First Circuit affirmed the dismissal. The Court held that while parents have a fundamental right to choose private schooling, the regulation does not restrict that right but merely defines the terms under which the state provides public benefits. The regulation does not ban or penalize private schooling or deprive meaningful access to it. Instead, it survives rational basis review because it is rationally related to the legitimate state interest of providing special education services while complying with the Massachusetts Constitution’s prohibition on aiding private schools. The court also rejected the Equal Protection and Privileges or Immunities claims. View "Hellman v. Department of Elementary and Secondary Education" on Justia Law

ZipBy USA LLC v. Parzych

2026-03-20T13:30:04-08:00

Gregory Parzych served as president of ZipBy USA, LLC, a parking technology company, after previously founding and selling a similar company, TCS. While employed by ZipBy, Parzych entered into several agreements restricting conflicts of interest and disclosure of confidential information. In 2020, Parzych learned that TCS might be for sale. He advised ZipBy’s owner against pursuing the acquisition, then secretly attempted to purchase TCS for himself via a shell company, using financial information he had obtained as a ZipBy executive. ZipBy discovered his actions, terminated his employment, and, along with affiliates, sued Parzych for breach of fiduciary duty, breach of contract, misappropriation of trade secrets, trademark infringement, and false designation. After a jury trial in the United States District Court for the District of Massachusetts, the jury found for ZipBy on all claims, awarding compensatory and exemplary damages. The district court later granted judgment as a matter of law for Parzych on the trade secret claims, striking the exemplary damages but upholding the other verdicts and damages. The court also entered a permanent injunction barring Parzych from acquiring TCS and awarded ZipBy a portion of its attorneys’ fees. Parzych appealed, contesting evidentiary rulings, denial of a trial continuance, and the fee award, while ZipBy cross-appealed the judgment on the trade secret claims. The United States Court of Appeals for the First Circuit affirmed the district court’s judgment. It held that the district court did not abuse its discretion in admitting ZipBy’s expert lost-profits testimony, excluding late-disclosed evidence, or denying a trial continuance due to counsel’s COVID-19 infection. The appellate court agreed with the district court’s judgment as a matter of law against ZipBy’s trade secret claims, finding insufficient evidence that Parzych’s actions constituted trade secret misappropriation. Finally, the fee award was affirmed as a reasonable enforcement of the IP Agreement’s fee-shifting provision. View "ZipBy USA LLC v. Parzych" on Justia Law

United States v. Rosario-Orangel

2026-03-20T13:30:04-08:00

Three defendants were charged following a federal investigation into La Asociación Ñeta, an organization originally founded to advocate for prisoners’ rights in Puerto Rico, but later alleged to have evolved into a criminal enterprise engaged in drug trafficking and violence. The defendants were accused of conspiring to violate the Racketeer Influenced and Corrupt Organizations (RICO) Act, and of conspiring to possess with intent to distribute heroin, cocaine, and marijuana. The indictment described La Ñeta as an enterprise whose members facilitated drug transactions and other criminal conduct. The defendants were tried jointly before a jury and convicted on both counts. After conviction in the United States District Court for the District of Puerto Rico, the defendants appealed to the United States Court of Appeals for the First Circuit. Their appeals were consolidated with those of several codefendants. In an earlier opinion, the First Circuit rejected most challenges but found that it could not resolve whether certain hearsay statements used at trial were admissible under United States v. Petrozziello because the District Court had not made the required findings. The First Circuit remanded for the District Court to make explicit findings about whether the statements were made by coconspirators during and in furtherance of the conspiracy, and retained jurisdiction over the appeals. After the District Court made its findings, the First Circuit reviewed the record and supplemental briefs. The court held that the challenged statements were properly admitted under Petrozziello or, where any error occurred, it was harmless given the overwhelming evidence of guilt. The court also rejected a cumulative error argument, finding no basis to overturn the convictions. The United States Court of Appeals for the First Circuit affirmed the convictions of all three defendants. View "United States v. Rosario-Orangel" on Justia Law

Hodzic v. Bondi

2026-03-19T12:30:04-08:00

A married couple, both Bosnian Muslims from the Sandzak region of Serbia and North Macedonia, entered the United States in 2000 using forged Slovenian passports. They feared for their safety due to regional conflicts and the increased presence of Serbian military forces. Upon arrival, they expressed fear of returning to their home countries and were found to have a credible fear of persecution. The couple was placed in removal proceedings, and sought asylum, withholding of removal, and relief under the Convention Against Torture, citing religious and group-based persecution. An Immigration Judge found them removable and denied their applications for relief in 2002. The Board of Immigration Appeals (BIA) dismissed their appeal in 2004. Subsequent motions to reopen and reconsider removal proceedings, including those based on a pending employment-based visa and later based on changes in law, were denied by the BIA as untimely or lacking in exceptional circumstances. The couple’s applications for adjustment of status were also denied by USCIS, finding they were inadmissible for fraud or willful misrepresentation. Later, their removal was ordered, and all further appeals to the BIA were dismissed. The United States Court of Appeals for the First Circuit reviewed the BIA’s denial of the couple’s motions to reopen sua sponte and to reconsider. The court held that it lacked jurisdiction to review the BIA’s denial of sua sponte reopening except for colorable legal or constitutional claims. The court found no legal error in the BIA’s application of the “exceptional situations” standard, no requirement for detailed explanation in denying sua sponte reopening, and that recent Supreme Court precedent did not require reopening. The court also found no violation of procedural or substantive due process. The petitions for review were denied. View "Hodzic v. Bondi" on Justia Law

Narrigan v. Goldberg

2026-03-18T13:30:05-08:00

The plaintiff filed a putative class action against the Treasurer of the Commonwealth of Massachusetts, challenging the Massachusetts Disposition of Unclaimed Property Act under the Takings Clause of the Fifth Amendment. He alleged that the Act’s provisions regarding payment of interest on unclaimed property resulted in an uncompensated taking of his private property for public use. The plaintiff’s complaint included evidence that the state held property in his name, but did not explain his connection to the listed address or further describe the property. He had not filed a claim to recover the property through the statutory process. The United States District Court for the District of Massachusetts dismissed the action, finding that the plaintiff lacked standing to seek injunctive or declaratory relief since he did not demonstrate any future harm, and that the Commonwealth had not waived its Eleventh Amendment immunity. The district court also concluded that the plaintiff failed to state a plausible claim for relief under the Takings Clause, reasoning in part that the statute provides a mechanism for reclaiming the property in full and that any taking resulted from the plaintiff’s own neglect. The district court did not address the ripeness argument raised by the Treasurer. Upon review, the United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The appellate court held that if the plaintiff’s challenge was to the statutory interest rate, his claim was not ripe, as he had not yet made a claim for the property or been denied interest. Alternatively, if the claim was that a taking had already occurred when the state took possession, he lacked standing to seek prospective relief because any injury was in the past and not ongoing. The court thus affirmed the dismissal for lack of Article III jurisdiction. View "Narrigan v. Goldberg" on Justia Law

Carr v. Lizotte

2026-03-18T13:30:04-08:00

In 1974, a fatal shooting occurred in a Boston park, resulting in the death of a fourteen-year-old victim. The suspect, who was twenty years old at the time, was identified by witnesses and a murder complaint was issued against him. Shortly after the incident, the suspect was arrested in Indiana under an alias for an unrelated crime. After being acquitted of that charge, he was mistakenly released, and his whereabouts were unknown to Massachusetts authorities for nearly two decades. During this period, he lived under his own name in Indiana, worked, attended university, and occasionally used aliases when interacting with law enforcement. Following a renewed discovery of his location in 1994, Massachusetts authorities interviewed and indicted him for murder in 1997. He was tried and convicted in 2004. Prior to trial, the defendant filed multiple motions to dismiss the indictment on speedy-trial grounds, all unsuccessful. The Massachusetts Superior Court and then the Supreme Judicial Court (SJC) rejected his arguments, finding that the delay was largely attributable to his own conduct, including the use of aliases. The SJC also denied his ineffective-assistance-of-counsel claims on direct appeal. The United States District Court for the District of Massachusetts denied his habeas petition, which alleged violations of his Sixth Amendment right to a speedy trial and ineffective assistance by counsel. On appeal, the United States Court of Appeals for the First Circuit held that, under binding federal precedent, the speedy-trial right only attached upon indictment, not at the issuance of the complaint, and since the relevant delay was seven years, not thirty, his federal speedy-trial claim failed. The court also found his ineffective-assistance claims unavailing, as the record showed no deficient performance or prejudice. Therefore, the First Circuit affirmed the denial of habeas relief. View "Carr v. Lizotte" on Justia Law

Abdisalam v. Strategic Delivery Solutions, LLC

2026-03-17T13:00:04-08:00

Abdulkadir Abdisalam worked as a courier delivering medical supplies for a company that classified its couriers as independent contractors. To work for the company, Abdisalam was required to form his own corporation, Abdul Courier, LLC, which then entered into a contract with the company. This contract included an arbitration provision requiring disputes to be arbitrated. Abdisalam signed the contract as the owner of his corporation, not in his individual capacity. After several years of providing courier services, Abdisalam alleged that the company misclassified him and others as independent contractors and failed to pay them proper wages, in violation of Massachusetts law. He filed a lawsuit on behalf of himself and a proposed class of couriers seeking remedies under Massachusetts statutes. The company removed the case to the United States District Court for the District of Massachusetts and filed a motion to compel arbitration based on the arbitration provision in its contract with Abdul Courier, LLC. The district court denied the motion, finding that Abdisalam, having signed only as the owner of the LLC and not in his personal capacity, was not bound by the contract’s arbitration clause. The court also rejected the company’s arguments that Abdisalam should be compelled to arbitrate under theories of direct benefits estoppel, intertwined claims estoppel, or as a successor in interest. The United States Court of Appeals for the First Circuit affirmed the district court’s order. The First Circuit held that, under Massachusetts law, it was for the court—not an arbitrator—to decide whether Abdisalam was bound by the arbitration agreement. The court further held that Abdisalam, as a nonsignatory to the agreement in his personal capacity, was not bound by its arbitration provision, and none of the equitable estoppel or successor theories advanced by the defendant provided a basis to compel arbitration. View "Abdisalam v. Strategic Delivery Solutions, LLC" on Justia Law

Walsh v. HNTB Corporation

2026-03-13T13:30:04-08:00

The appellant worked for the appellee as an information technology employee in Boston for over twenty-five years. In August 2019, the company placed her on a three-month performance improvement plan (PIP), which she completed successfully. Approximately ten months after completing the PIP, she resigned from her position. She subsequently brought suit against her former employer, claiming, among other things, that she was subjected to unlawful age discrimination when she was placed on the PIP and then constructively discharged. The United States District Court for the District of Massachusetts granted summary judgment to the employer. The court found that no reasonable factfinder could conclude that the PIP constituted an adverse employment action or that the circumstances of her resignation amounted to a constructive discharge. In the district court’s view, the plaintiff’s successful completion of the PIP, the absence of demotion or pay reduction, and the lack of substantial changes in her responsibilities meant she did not suffer an adverse employment action. The court also concluded that the comments and actions by her supervisors did not create intolerable working conditions that would force a reasonable person to resign. On appeal, the United States Court of Appeals for the First Circuit first addressed the timeliness of the appeal. The court determined that the appellant’s pro se motion for extension of time to file a notice of appeal met the requirements to be treated as a timely notice of appeal, making the appeal timely. On the merits, the First Circuit affirmed the district court’s judgment. It held that, under the Supreme Court’s standard in Muldrow v. City of St. Louis, the PIP did not alter the terms or conditions of employment, and that the record did not support a finding of constructive discharge. The decision of the district court was affirmed. View "Walsh v. HNTB Corporation" on Justia Law

United States v. Parlin

2026-03-11T12:00:04-08:00

Jacob Parlin was arrested after law enforcement, investigating a narcotics operation, intercepted communications implicating him in drug transactions. The Drug Enforcement Administration (DEA) began wiretapping a suspected dealer’s phone, capturing conversations among Parlin, the dealer, and a third party, which discussed drug sales and pricing strategies. Following these intercepts, officers stopped Parlin's vehicle and discovered nearly two pounds of pure methamphetamine, along with drug paraphernalia and a small quantity of drugs indicative of personal use. A federal grand jury indicted Parlin on conspiracy to distribute and possession with intent to distribute fifty grams or more of methamphetamine, as well as substantive distribution and possession charges. At trial in the United States District Court for the District of Massachusetts, Parlin objected to a police officer's testimony about the typical amount of methamphetamine held by users versus distributors, arguing the officer was giving undisclosed expert testimony. The court allowed the testimony, finding it was based on the officer’s personal observations. Parlin was convicted by a jury on both counts. He then moved for acquittal or a mistrial, asserting the testimony was improper; the district court denied these motions, determining the testimony was appropriately limited and other evidence supported the verdict. Parlin appealed to the United States Court of Appeals for the First Circuit, contending the district court erred by admitting the officer’s opinion testimony and that, without it, the evidence was insufficient to prove intent to distribute. The First Circuit held that, even if admitting the testimony was error, it was harmless given the overwhelming evidence of Parlin's intent to distribute, including recorded phone calls and the large quantity of drugs. The court affirmed Parlin’s conviction on both counts. View "United States v. Parlin" on Justia Law

Maldonado-Ruiz v. Bondi

2026-03-10T12:00:04-08:00

A woman from Honduras entered the United States without inspection in 2012 and applied for asylum, withholding of removal, and protection under the Convention Against Torture. She based her claims primarily on her bisexual identity and described various events from her past, including childhood abuse by her father, witnessing violence in her community, receiving derogatory comments and a single unfulfilled threat from an unknown man, and experiencing a burglary. She testified that, although bisexuality is not accepted in Honduras, she lived openly as a bisexual woman for over two years without suffering physical harm due to her sexual orientation. She submitted evidence of discrimination and violence against sexual minorities in Honduras, as well as reports on country conditions. An Immigration Judge (IJ) conducted a merits hearing, found her testimony generally credible, but denied all relief. The IJ concluded that the harm she described did not rise to the level of persecution, that she failed to show her sexual orientation was a central reason for any harm, and that the Honduran government was not shown to be unwilling or unable to protect her from private actors. The IJ also found she did not establish a well-founded fear of future persecution. The Board of Immigration Appeals (BIA) dismissed her appeal, affirming the IJ’s findings and holding that she waived any challenge to the denial of protection under the Convention Against Torture. The United States Court of Appeals for the First Circuit reviewed both the IJ’s and BIA’s decisions, applying the substantial evidence standard. The court held that substantial evidence supported the agency’s conclusions that she failed to demonstrate past persecution, a nexus to a protected ground, or governmental unwillingness or inability to protect her. The court denied her petition for review. View "Maldonado-Ruiz v. Bondi" on Justia Law

United States v. Robles-Lopez

2026-03-04T13:30:04-08:00

The case involves a defendant who was recruited in Puerto Rico to act as a courier, transporting two suitcases containing approximately eleven kilograms of cocaine on a flight to Newark, New Jersey. Airport authorities in San Juan discovered the drugs before the defendant boarded the flight. After her arrest, she admitted to knowingly transporting the suitcases for a promised payment of $1,500, a sum far less than the drugs’ street value. Following her guilty plea to conspiracy and possession with intent to distribute cocaine, the United States District Court for the District of Puerto Rico sentenced her to forty-eight months in prison and forty-eight months of supervised release. The Probation Office recommended a three-level reduction in her Sentencing Guidelines offense level based on her minor or minimal role, highlighting other individuals who recruited her, organized the transport, and prepared the luggage. The government objected, arguing she was indispensable to the offense. The district court agreed with the government and denied the mitigating-role reduction, focusing primarily on her own conduct and the fact she was the one transporting the drugs. On appeal, the United States Court of Appeals for the First Circuit reviewed whether the district court properly conducted the required comparative culpability analysis under the Sentencing Guidelines. The appellate court held that the district court erred by failing to consider the roles of all participants in the criminal activity and by not applying the multi-step analysis clarified in United States v. Guía-Sendeme. The First Circuit vacated the sentence and remanded for resentencing so the district court could properly assess the defendant’s eligibility for a mitigating-role reduction, consistent with current precedent and the proper legal framework. View "United States v. Robles-Lopez" on Justia Law

John B. Cruz Construction Co. v. Beacon Communities Corp.

2026-03-04T12:30:06-08:00

A black-owned construction company was not invited to bid as general contractor on a major Boston public housing redevelopment project after participating in pre-construction work. Years earlier, the developer had called the company’s president to discuss possible involvement, but the parties disputed what promises, if any, were made during that conversation. The construction company performed pre-construction work and was later selected as general contractor for the first phase (Camden), but after performance and communication issues arose during that project, the developer chose a different, white-owned company for the second phase (Lenox). The construction company did not protest at the time but later sued, alleging breach of contract, quasi-contract, violation of Massachusetts consumer protection law, and racial discrimination under 42 U.S.C. § 1981. The matter was first brought in Massachusetts state court, then removed to the United States District Court for the District of Massachusetts based on federal question jurisdiction. After discovery, the developer moved for summary judgment. The District Court granted summary judgment for the developer, finding no enforceable contract or promise had been made regarding the Lenox phase, that the quasi-contract and Chapter 93A claims failed as derivative, and that there was insufficient evidence of racial discrimination. The United States Court of Appeals for the First Circuit affirmed the District Court’s decision. The First Circuit held that the summary judgment record did not contain evidence from which a reasonable jury could find an enforceable implied-in-fact contract or a promise sufficient for promissory estoppel. It further held that the plaintiff failed to create a triable issue of fact regarding pretext or discriminatory intent under § 1981, given the legitimate business reasons cited for the company’s exclusion. Thus, summary judgment on all claims was proper. View "John B. Cruz Construction Co. v. Beacon Communities Corp." on Justia Law

Perruzzi v. The Campbell's Company

2026-03-04T12:30:06-08:00

Two individuals each owned companies that distributed snack foods for a larger food company. Years earlier, they had joined a class action lawsuit claiming that the company misclassified them as independent contractors rather than employees. That class action ended in a settlement, which included an optional provision: class members could agree to arbitrate future disputes in exchange for an additional payment. Both individuals opted into that provision and accepted the payment, thereby agreeing to resolve future disputes through arbitration. Several years later, the two individuals brought a new lawsuit in the United States District Court for the District of Massachusetts, again asserting claims related to alleged misclassification and seeking damages. The defendant company moved to stay the case and compel arbitration under the Federal Arbitration Act (FAA), citing the prior agreement. The plaintiffs opposed, arguing that they were exempt from the FAA as transportation workers under Section 1. The district court rejected that exemption argument, but did not order arbitration. Instead, it stayed and administratively closed the case without entering judgment, stating it was not compelling arbitration but was closing its doors to further proceedings. The United States Court of Appeals for the First Circuit reviewed the district court’s handling. The court held that, although the district court did not expressly deny the motion to compel arbitration, its actions amounted to a denial, and thus appellate jurisdiction existed under 9 U.S.C. § 16(a)(1)(B). The First Circuit vacated the district court’s order and remanded the case for further proceedings, directing the district court to determine whether the motion to compel arbitration should be granted or denied and to explain its reasoning. The court also clarified that, under the parties’ agreement, any compelled arbitration must proceed on an individual, not class, basis. View "Perruzzi v. The Campbell's Company" on Justia Law

Guallini-Indij v. Banco Popular de Puerto Rico

2026-03-04T12:30:04-08:00

Two individuals entered into a loan agreement and mortgage with a bank in Puerto Rico, using their home as collateral. After a decade, they faced financial difficulties and stopped making payments. The bank denied a request to modify the loan but proposed a short sale. The bank then initiated foreclosure proceedings in Puerto Rico’s Court of First Instance, resulting in a judgment against the borrowers. Multiple short sale offers were rejected until one was conditionally accepted, but the sale did not close in time and the home was foreclosed. Subsequently, the bank garnished funds from the borrowers, who then filed for Chapter 13 bankruptcy. The United States Bankruptcy Court for the District of Puerto Rico confirmed the borrowers’ Chapter 13 plan, noting their intent to pursue claims against the bank. The borrowers filed an adversary proceeding seeking damages and other relief. The bank moved to dismiss the adversary complaint, but the bankruptcy court denied this motion, allowing the case to proceed. The borrowers later filed a similar complaint in the United States District Court for the District of Puerto Rico and moved to withdraw the adversary proceeding to the district court. The district court denied the withdrawal as untimely and dismissed the separate federal case. After the borrowers completed their bankruptcy plan and received a discharge, the bankruptcy court dismissed the adversary proceeding for lack of subject matter jurisdiction. On appeal, the United States Court of Appeals for the First Circuit held that the bankruptcy court erred in finding it automatically lost jurisdiction over the adversary proceeding post-discharge. The appellate court vacated and remanded the case for further proceedings, instructing the lower courts to reassess jurisdiction and properly address the borrowers’ motion for withdrawal and their jury trial request. View "Guallini-Indij v. Banco Popular de Puerto Rico" on Justia Law

The City of Boston v. OptumRx, Inc.

2026-03-02T14:00:03-08:00

The City of Boston, along with its Public Health Commission and Housing Authority, brought suit against two pharmacy benefit managers (PBMs), OptumRx and Express Scripts, alleging that the PBMs had worked with opioid manufacturers to misrepresent the risks of opioid drugs. The City claimed that this conduct violated Massachusetts public nuisance law and resulted in harm to the City. The PBMs removed the case to federal court and argued that the suit was untimely because it was brought after the three-year statute of limitations had expired. The City responded by asserting that its complaint sufficiently alleged a continuing nuisance and that the statute of limitations should be tolled due to the PBMs’ fraudulent concealment of their wrongdoing. The United States District Court for the District of Massachusetts granted the PBMs’ motion to dismiss, finding that the City either knew or should have known of its injuries and of the PBMs’ alleged role before 2021, based on public records and prior litigation, and thus failed to file suit within the statutory period. The district court further ruled that the City had not adequately pled a continuing nuisance, as it did not allege any specific, recent unlawful acts within the limitations period, and rejected the City’s claim of fraudulent concealment, determining that the City had the means to discover the facts needed for its claim. The district court also denied a motion by the PBMs to disqualify the City's law firm, Motley Rice. On appeal, the United States Court of Appeals for the First Circuit affirmed both the dismissal of the City’s state law claim and the denial of the motion to disqualify Motley Rice. The court held that the action was time-barred and that the City had not met the requirements for tolling the statute of limitations or for pleading a continuing nuisance under Massachusetts law. View "The City of Boston v. OptumRx, Inc." on Justia Law

Coastal Capital, LLC v. Savage

2026-02-27T14:30:06-08:00

Steven and Virginia Savage were officers and sole shareholders of a company that designed and installed digital planetarium equipment. When their company experienced financial distress, they used personal funds and credit cards to support business operations, but the company eventually defaulted on a large loan personally guaranteed by the Savages. In the year preceding their bankruptcy filing, the Savages received over $700,000 from the company, which they failed to fully disclose in their bankruptcy filings. Their bankruptcy schedules did not mention this income, and significant portions of the transferred funds were not satisfactorily explained, especially regarding rent payments from the company to the Savages and the use of those funds. After the company and the Savages filed for bankruptcy, the creditor, Coastal Capital, objected to the Savages’ discharge in their Chapter 7 proceedings. The United States Bankruptcy Court for the District of New Hampshire held a bench trial and found that, although the Savages explained most of the company funds they received, they failed to account for over $56,000. The court denied the Savages a discharge under 11 U.S.C. § 727(a)(5) for failing to satisfactorily explain the loss or deficiency of assets. The Savages’ post-trial motions were denied, and the United States District Court for the District of New Hampshire affirmed the bankruptcy court’s ruling. On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s judgment. The court held that § 727(a)(5) does not require a “substantial” loss of assets to deny discharge, nor does it require that the unaccounted-for funds be enough to pay all liabilities. It also found no clear error in the bankruptcy court’s factual determinations and rejected the Savages’ arguments regarding destruction of evidence and the sufficiency of their explanations. The denial of discharge was affirmed. View "Coastal Capital, LLC v. Savage" on Justia Law