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.

Apr 30 2026
26-1209 Panel Decision

GORDON-DARBY HOLDINGS, INC v. ROBERT L. QUINN, in the official capacity as Commissioner of the New Hampshire Department of Safety, et al

The First Circuit granted the Commissioners' motion to stay a preliminary injunction that had blocked New Hampshire from repealing its motor vehicle emissions inspection program. The court held that the state likely succeeded on the merits because the Clean Air Act does not authorize citizen suits based on purely prospective violations of State Implementation Plans.

Civil Environmental (Civil)
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Apr 29 2026
25-1354 Panel Decision

SANDRA NATASHA ST. JOHN v. ANDREA JOY CAMPBELL

The First Circuit affirmed the dismissal of a habeas corpus petition filed by a deported individual, holding that federal jurisdiction under 28 U.S.C. § 2254 requires the petitioner to be in custody of state authorities at the time of filing. Because the petitioner had been deported to Trinidad and Tobago before filing her claim, she failed to satisfy the statutory custody requirement.

Constitutional Habeas Corpus - General (28 USC 2241) Habeas Corpus - State Prisoner (28 USC 2254)
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Apr 28 2026
25-1857 Panel Decision

ELIZABETH PUTNAM; CALE PUTNAM v. EPR PROPERTIES; PREMIER PARKS, LLC

The First Circuit reversed the dismissal of a wrongful death claim against Premier Parks, LLC, finding that public statements and operational intermingling created a genuine dispute regarding personal jurisdiction. Conversely, the court affirmed the dismissal against EPR Properties, ruling that the plaintiffs failed to provide evidence linking the real estate trust to the hotel's marketing or booking activities in Massachusetts.

Civil Tort / Personal Injury
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Apr 27 2026
25-1291 Panel Decision

ARTHUR MILES v. WARDEN FREDDIE BOWERS

The First Circuit vacated the dismissal of Arthur Miles' habeas petition, ruling that the Bureau of Prisons cannot deny First Step Act time credits for work performed in a county jail prior to transfer to a federal facility. The court held that the BOP's regulations contradicting the statutory definition of when a sentence commences are invalid and that a risk assessment is not a prerequisite for earning credits.

Constitutional Habeas Corpus - General (28 USC 2241)
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Apr 24 2026
25-1146 Panel Decision

UNITED STATES v. RAHIM SHAFA

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.

Criminal Money Laundering Sentencing Guidelines
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Apr 23 2026
25-1225 Panel Decision

Lopez Martinez v. Blanche

The First Circuit granted a petition for review challenging a Board of Immigration Appeals denial of asylum and withholding of removal. The court held that the agency erred by applying a categorical bar to political opinion claims based on opposition to gangs and failed to address religion-based claims.

Civil Immigration (Civil)
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