The case involved defendant José Valdivia, who was convicted after a jury trial in the District of Puerto Rico on charges of conspiracy to possess with intent to distribute and to import one or more kilograms of heroin, based on his role in a drug trafficking operation linked to an Aruba-based organization that used couriers and cruise ship employees to move heroin into Puerto Rico. Valdivia appealed on multiple grounds, including alleged violations of the Speedy Trial Act, improper judicial comments and jury instructions, admission of hearsay and overview testimony, improper expert testimony by a fact witness, denial of motions to suppress foreign wiretap evidence, and errors in applying the sentencing guidelines. The First Circuit Court of Appeals affirmed the convictions and 210-month sentence, holding after review that the district court did not commit reversible error on any of the claims raised. The opinion addressed the factual background of the operation, pretrial delays, evidentiary rulings, and sentencing calculations without finding prejudice or abuse of discretion.
This case involves a qui tam action under the False Claims Act alleging that defendants Brigham and Women's Hospital, Massachusetts General Hospital, and affiliated researchers submitted a grant application to the National Institute on Aging for Alzheimer's disease research that contained statements based on falsified data and misrepresented the use of blinded, reliable methodologies. The relator, Kenneth Jones, also claimed the defendants knowingly failed to investigate and report scientific misconduct as required by NIH regulations. The district court granted summary judgment to the defendants. On appeal, the First Circuit vacated the ruling, holding that the district court abused its discretion by excluding or improperly evaluating expert testimony and erred by not applying the summary judgment standard, which revealed genuine issues of material fact regarding the falsity of statements in the application and the defendants' knowledge.
The case involved the appeal of Cruz Roberto Ramos-González's conviction for possession with intent to distribute over 500 grams of cocaine after police seized blocks of a substance from a truck he allegedly abandoned during a traffic stop. The district court permitted a forensic chemist to testify about the results of a drug analysis performed by a colleague who was unavailable due to illness, despite the testifying chemist having no personal involvement in the testing. The First Circuit vacated the conviction and remanded for a new trial, holding that this violated the defendant's Sixth Amendment confrontation rights because the testimony was not adequately corroborated by other evidence sufficient to prove the substance was cocaine beyond a reasonable doubt.
In this case, debtors Luis Soto-Rios and Brenda Tosado-Arbelo, who had executed three mortgage deeds in favor of Banco Popular de Puerto Rico in 2004 and 2005, filed for Chapter 11 bankruptcy nearly three years later while the deeds remained unrecorded due to a registry backlog. During the bankruptcy proceedings, the debtors initiated an adversary action seeking to avoid the mortgages under the automatic stay, the trustee's strong-arm power, and rules against preferential transfers pursuant to 11 U.S.C. §§ 362(a), 544(a), and 547(b). The bankruptcy court granted summary judgment to the bank, finding that exceptions under §§ 362(b)(3) and 546(b)(1)(A) applied because the bank had presented the deeds pre-petition, and that no preferential transfer occurred as the relevant acts predated the 90-day lookback period; the district court affirmed. On appeal, the First Circuit affirmed, holding that the bank's pre-petition presentment created a sufficient property interest and that the debtors failed to establish the elements of a preferential transfer under § 547(e)(1)(A).
The case involved parents suing the United States under the Federal Tort Claims Act after their three-year-old child was seriously injured by a projectile thrown from a lawnmower operated by a contractor at a childcare center on federal property, where both the childcare provider and lawn maintenance company operated under contracts with the General Services Administration. The district court dismissed the FTCA claim for lack of subject matter jurisdiction based on the independent contractor defense and dismissed the supplemental Puerto Rico law claims. On appeal, the First Circuit affirmed the dismissal but held that the discretionary function exception applied instead, reasoning that the government had discretion to delegate responsibility for safety and coordination of the contractors' activities, immunizing its decision from liability under the FTCA.
The case involved Otto Amilcar Gonzalez-Ruano, a Guatemalan national who entered the United States unlawfully in 1989 and sought special rule cancellation of removal under the Nicaraguan Adjustment and Central American Relief Act (NACARA) after being placed in removal proceedings. An Immigration Judge denied the application, finding that Gonzalez-Ruano's 1997 Massachusetts convictions for assault and battery and willful destruction of property constituted crimes involving moral turpitude, which triggered a stricter eligibility standard that he failed to meet, and that discretionary relief was unwarranted due to his criminal history and violations of protective orders. The Board of Immigration Appeals affirmed. The First Circuit denied the petition in part, holding that there was no legal or constitutional error in the agency's determinations regarding the convictions or the exercise of discretion, and dismissed the remainder for lack of jurisdiction over the discretionary decision.
