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The First Circuit held that Massachusetts General Laws chapter 272, section 16, prohibiting open and gross lewdness, is not categorically a crime involving moral turpitude under federal immigration law. The court reversed the Board of Immigration Appeals' removal order, ruling that the state statute does not require proof of lewd intent.
The First Circuit affirmed the dismissal of a federal employee's retaliation claim under the False Claims Act against the Secretary of Veterans Affairs. The court held that Congress did not expressly waive federal sovereign immunity for such claims, barring the suit against the United States.
The First Circuit affirmed the dismissal of residents' constitutional and statutory challenges to a new zoning district because they failed to allege specific, concrete injuries required for Article III standing. The court held that vague assertions about potential property value changes and generalized grievances were insufficient to establish a personal stake in the outcome.
The First Circuit affirmed a district court order enforcing a global settlement resolving Fair Labor Standards Act and state wage claims against a luxury hotel. The court held that a single attorney could simultaneously represent individual plaintiffs and a certified class in negotiating the deal without creating a disqualifying conflict of interest.
The First Circuit affirmed the convictions of a Massachusetts pizzeria owner for forced labor, ruling that a pattern of physical abuse and threats of deportation against undocumented workers satisfied the statutory elements of coercion. The court also upheld the defendant's 102-month sentence, rejecting challenges to evidentiary rulings and sentencing enhancements.
The Eleventh Circuit affirmed Stefan Zappey's conviction for sexually abusing children at a Department of Defense school in Germany, ruling that the district court properly limited expert testimony on memory reliability. The court held that while general science on memory is admissible, experts cannot opine on witness credibility or present cumulative testimony that duplicates other evidence.
The Supreme Court held that Delaware's affidavit-of-merit requirement cannot be enforced in federal court because it conflicts with Federal Rule of Civil Procedure 8. The Court reversed the Third Circuit's dismissal, ruling that federal pleading standards govern the sufficiency of a complaint in diversity cases.
The Supreme Court held that Federal Rule of Civil Procedure 60(c)(1) imposes a reasonable-time limit on motions seeking relief from judgments alleged to be void. The Court rejected the argument that void judgments are legal nullities exempt from temporal filing deadlines.
The Supreme Court held that restitution ordered under the Mandatory Victims Restitution Act constitutes criminal punishment for purposes of the Ex Post Facto Clause. Consequently, applying the MVRA to a defendant who committed their crime before the Act's enactment violates the Constitution.
The D.C. Circuit affirmed the district court's grant of summary judgment, holding that the Secretary of Health and Human Services lacked the authority to unilaterally direct contractors to reopen final Medicare cost determinations outside the specific regulatory framework. The court ruled that the agency's attempt to apply a new reimbursement formula to settled reports was barred by explicit time limits and a prohibition on reopening based on changes in legal interpretation.
