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.

Mar 20 2026
20-1275 Panel Decision

United States v. Rosario-Orangel

The First Circuit affirms federal RICO and drug conspiracy convictions for three defendants, rejecting challenges to the admission of hearsay statements made by coconspirators. The court holds that the District Court properly found the statements were made during and in furtherance of the conspiracy, or that any error in their admission was harmless given the overwhelming evidence of guilt.

Criminal Drug Trafficking
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Mar 19 2026
24-1500 Panel Decision

ZipBy USA LLC v. Parzych

The First Circuit affirmed the district court's judgment, upholding a jury verdict against a former executive for breaching fiduciary duties and contracts while attempting to acquire his former company. The court also agreed with the district court's decision to set aside the jury's verdict on trade secret claims, finding the information at issue did not meet the legal definition of a trade secret.

Civil Intellectual Property
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Mar 19 2026
24-1204 Panel Decision

Hodzic v. Bondi

The First Circuit Court of Appeals denied the Hodzics' petitions for review of the Board of Immigration Appeals' orders denying their motions to reopen and reconsider. The court held that the BIA acted within its discretion and that the petitioners failed to demonstrate the legal or constitutional errors required to trigger judicial review of a sua sponte motion.

Civil Immigration (Civil)
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Mar 19 2026
24-1696 Panel Decision

Hodzic v. Bondi

The First Circuit denied petitions for review challenging the Board of Immigration Appeals' refusal to reopen removal proceedings sua sponte. The court found that the Hodzics failed to demonstrate any colorable legal or constitutional error in the agency's discretionary decision.

Civil Immigration (Civil)
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Mar 19 2026
24-1494 Panel Decision

ZipBy USA LLC v. Parzych

The First Circuit affirmed a district court judgment holding a former company president liable for breach of fiduciary duty and contract after he attempted to acquire his former employer's target company for himself. The court upheld the jury's damages award and the permanent injunction while agreeing that the evidence did not support a finding of trade secret misappropriation.

Civil Intellectual Property
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Mar 19 2026
24-1586 Panel Decision

ZipBy USA LLC v. Parzych

The First Circuit affirmed a district court judgment holding a former corporate president liable for breaching fiduciary duties and contract terms by attempting to acquire a target company for himself. While the appellate court upheld the jury's findings on breach of contract and fiduciary duty, it agreed that the evidence was insufficient to support a verdict on trade secret misappropriation.

Civil Intellectual Property
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Mar 18 2026
25-1395 Panel Decision

THOMAS R. NARRIGAN, individually and on behalf of all others similarly situated v. DEBORAH B. GOLDBERG, in her official capacity as Treasurer and Receiver General of the Commonw...

The First Circuit affirmed the dismissal of a class action challenging Massachusetts's Unclaimed Property Act under the Fifth Amendment's Takings Clause. The court held that the plaintiff's claims were either unripe or barred by a lack of standing to seek prospective relief.

Civil Civil Rights - Section 1983 Standing
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Mar 18 2026
24-1715 Panel Decision

RODOLFO CARR v. KENNETH LIZOTTE

The First Circuit affirmed the denial of a habeas petition challenging a first-degree murder conviction, ruling that the Sixth Amendment speedy-trial clock did not begin until Carr's 1997 indictment. The court further held that Carr's claims of ineffective assistance of counsel failed because his attorneys' strategic choices were not objectively unreasonable and the additional evidence would not have changed the outcome under state law.

Constitutional Habeas Corpus - State Prisoner (28 USC 2254)
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Mar 17 2026
25-1254 Panel Decision

ABDULKADIR ABDISALAM individually and for all others similarly situated v. STRATEGIC DELIVERY SOLUTIONS, LLC

The First Circuit affirmed the denial of a motion to compel arbitration, holding that an individual courier could not be bound by a vendor agreement he signed only as the owner of a corporation. The court ruled that equitable estoppel theories failed because the benefits flowed to the corporate entity, not the individual, and the claims were not sufficiently intertwined with the agreement.

Civil Insurance
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Mar 17 2026
24-1311 Unpublished

UNITED STATES OF AMERICA v. MARK ANTHONY FIGUEROA

The First Circuit affirmed Mark Anthony Figueroa's money laundering conspiracy conviction, ruling that the district court's admission of a cooperating witness's kidnapping testimony and law enforcement overview testimony did not constitute reversible error. The court held that any evidentiary mistakes were harmless given the overwhelming independent evidence linking the defendant to drug trafficking proceeds.

Criminal Money Laundering
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