Every decision we've summarized from United States Court of Appeals for the First Circuit.
The First Circuit affirmed Rahim Shafa's convictions for money laundering and drug offenses but vacated his sentence for misdemeanor misbranding due to the District Court's failure to clarify why the fraud guideline applied. The court remanded the case for resentencing on that specific count to resolve ambiguities regarding the acquitted-conduct amendment.
The First Circuit affirmed summary judgment for FEMA, holding that workers hired by a nonprofit contractor were not federal employees under the Fair Labor Standards Act. The court found that FEMA's funding of the contractor did not establish the necessary employment relationship to trigger wage liability against the agency.
The First Circuit reversed the Board of Immigration Appeals' denial of an adjustment of status application because the Board impermissibly relied on a factual finding not contained in the record. The court held that the Board violated due process by determining the petitioner's specific intent to avoid criminal prosecution without evidence in the record before the Immigration Judge.
The First Circuit reversed the dismissal of fraud and contract claims against Debra Monday, holding that the District Court erred by applying a lack of personal jurisdiction standard to a Massachusetts resident properly served within the state. The court affirmed the dismissal of claims against out-of-state defendants, finding the plaintiff failed to adequately develop arguments for personal jurisdiction over them.
The First Circuit vacated a conviction for unlawful force because the government introduced a hearsay statement from an unavailable victim, violating the Sixth Amendment Confrontation Clause. The court affirmed the remaining convictions for obstruction and falsifying records, which were supported by sufficient evidence, and remanded for a new trial limited to the vacated count.
The First Circuit vacated a defendant's sentence because the district court failed to provide a sufficiently reasoned explanation for imposing a twenty-five-month upward variance above the Sentencing Guidelines range. This procedural error prevented the appellate court from reviewing the substantive reasonableness of the sentence, necessitating a remand for resentencing with proper justification.
The First Circuit affirmed summary judgment for Universal Insurance Company, holding that a Puerto Rico Supreme Court decision clarifying the scope of professional services exclusions applied retroactively to pending cases. The court rejected the appellant's argument that the intervening precedent created new law, finding instead that it merely clarified existing statutory interpretation.
The First Circuit affirmed Kevin Lee Ross's conviction for possessing child pornography, ruling that the district court properly admitted graphic exhibits despite a joint stipulation. The court held that the evidence was necessary to prove Ross's knowledge of the illicit material, which he denied, and that its probative value was not substantially outweighed by unfair prejudice.