1st Cir.

United States Court of Appeals for the First Circuit

Every decision we've summarized from United States Court of Appeals for the First Circuit.

Dec 11 2025
Nos. 24-1532, 24-1614, 24-1734 Panel Decision

Orkin v. Albert

The First Circuit vacated and remanded a district court judgment in a family business dispute, finding that the lower court failed to properly apply partnership and implied contract principles to the siblings' decade-long conduct. The appellate court held that the siblings' long-standing practice of treating personal expenses as compensation created an implied agreement, requiring a new determination of Orkin's rightful share of Boost Web funds.

Civil Tax (Civil)
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Dec 11 2025
Nos. 24-1532, 24-1614, 24-1734 Panel Decision

Orkin v. Albert

The First Circuit vacated a district court judgment that had found siblings liable for defamation and conversion in a dispute over a family business operated without formal corporate structure. The appellate court held that the lower court erred by failing to recognize an implied contract for compensation and by issuing an injunction that exceeded its authority to resolve ownership disputes.

Civil Tax (Civil)
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Dec 11 2025
24-1734 Panel Decision

Orkin v. Albert

The First Circuit vacated and remanded a district court judgment that failed to recognize an implied contract entitling a sibling to compensation for his decade-long management of a family business. The court also reversed a finding that the sibling's email accusing him of fraud was not defamatory, holding that the statement unambiguously imputed criminal conduct.

Civil Tax (Civil)
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Dec 3 2025
23-2011 Panel Decision

REYNALDO CRUZ v. UNIÓN INDEPENDIENTE AUTÉNTICA DE LOS EMPLEADOS DE LA AUTORIDAD DE ACUEDUCTOS Y ALCANTARILLADOS; PUERTO RICO AQUEDUCT AND SEWER AUTHORITY; JENNIFFER A. GONZÁLEZ...

The First Circuit reversed a district court dismissal of a § 1983 lawsuit, holding that the case was not moot despite the defendants depositing the disputed union dues. The court remanded the matter to determine whether the plaintiff qualifies as a prevailing party for attorney's fees, a status that could be lost if the case is deemed moot.

Civil Civil Rights - Section 1983
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Dec 1 2025
25-1278 Panel Decision

JONALSON DOR v. PAMELA J. BONDI, Attorney General

The First Circuit held that a noncitizen's deportability for a state drug conviction is determined by the federal Controlled Substances Act as it existed at the time of the conviction, not at the time of removal proceedings. This ruling affirms the Board of Immigration Appeals and joins five other circuits in rejecting the 'time of removal' rule.

Civil Immigration (Civil)
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Dec 1 2025
25-1110 Panel Decision

United States, ex rel. Omni Healthcare Inc. v. MD Spine Solutions LLC

The First Circuit affirmed summary judgment for a clinical laboratory in a False Claims Act case, ruling that labs may generally rely on a physician's order to establish medical necessity. The court held that the relator failed to produce sufficient evidence that the lab knowingly submitted false claims regarding the necessity of PCR urinary tract infection tests.

Criminal Fraud Summary Judgment
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Nov 26 2025
24-2117 Panel Decision

JOHN RESTREPO CASTANO; DIANA LOPEZ VALENCIA; and M.R.L v. PAMELA J. BONDI, Attorney General

The First Circuit denied a petition for review of an asylum and withholding of removal claim, upholding the agency's finding that the Colombian government was able to protect the petitioner from a criminal gang. The court held that the petitioner failed to demonstrate the government's inability to provide protection despite ongoing telephonic threats.

Civil Immigration (Civil)
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Nov 26 2025
25-1251 Panel Decision

UNITED STATES OF AMERICA v. SPINEFRONTIER, INC Interested Party, Appellant ADITYA HUMAD

The First Circuit vacated a district court order finding that a corporate executive's intent to assert an involvement-of-counsel defense impliedly waived the corporation's attorney-client privilege. The appellate court remanded the case for a fresh evaluation of the waiver claim in light of significant procedural changes, including the severance of co-defendants and the withdrawal of one executive from the criminal proceedings.

Criminal Other Criminal
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Nov 14 2025
22-1735 Panel Decision

UNITED STATES OF AMERICA v. CARLOS MALDONADO-VARGAS

The First Circuit affirmed Carlos Maldonado-Vargas's securities fraud conviction and sentence, rejecting claims that bank record summaries were inadmissible and that the evidence was insufficient to prove a Ponzi scheme. The court also upheld the restitution order, ruling that the district court could calculate losses and identify victims based on a broader scheme than those explicitly named in the indictment.

Criminal Fraud Sentencing Guidelines
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