Deference to government powerSkepticism of government power
Permits §1983 suit against mayor for pet seizures under Fourth/Fourteenth Amendments in [5], indicating skepticism of official action. Maldonado v. Fontanes ↗
In Carreras v. Sajo, Garcia & Partners, the plaintiff sued his former employer for discrimination and retaliation under the Americans with Disabilities Act, claiming his termination was due to his type II diabetes and a request for accommodation regarding work hours. The district court granted summary judgment to the defendant after deeming many of the defendant's facts admitted because the plaintiff's response failed to comply with Puerto Rico's anti-ferret rule under Local Rule 56. On appeal, the First Circuit affirmed, holding that the procedural default properly led to the admission of facts showing no genuine dispute that the plaintiff was not disabled under the ADA and that the termination was based on unsatisfactory work performance rather than retaliation.
This case involved Katharine Richardson's claims against her former employer, Friendly Ice Cream Corporation, alleging violations of the Americans with Disabilities Act and the Maine Human Rights Act through failure to accommodate her shoulder impingement syndrome and termination of her employment due to the disability. The district court granted summary judgment to Friendly's on the grounds that Richardson was not a qualified individual under the statutes because she could not perform the essential functions of her assistant manager position with or without reasonable accommodation. The First Circuit affirmed, reasoning that Richardson had not shown a genuine issue of material fact as to her ability to carry out manual tasks central to assisting with restaurant operations, even accounting for modifications to her work methods or delegation of duties to other employees. The court noted that the proposed accommodations were either inadequate to enable performance of essential functions or unreasonable as a matter of law because they would require reallocating core responsibilities. The court also rejected the interactive process claim for the same reasons.
In United States v. Larios, three defendants were charged with drug trafficking offenses after being recorded on audio and video participating in a controlled cocaine transaction in a motel room rented by undercover agents. Two defendants pleaded guilty to conspiracy and related charges and received 120-month sentences, while the third proceeded to trial, was convicted, and received a 168-month sentence. The defendants appealed, arguing that admission of the unauthorized audio recording at sentencing and trial violated the federal wiretap statute (Title III) because they had a reasonable expectation of privacy in the room. The First Circuit held that any error in admitting the recording at sentencing was harmless as to the two pleading defendants and that the defendant convicted at trial had no reasonable expectation of privacy given his brief engagement with the room, and therefore affirmed the judgments.
The case involved Ismael Alfonzo-Reyes, a Farm Service Agency loan manager, and his wife Vanessa Morales-Hernández, who were convicted after an 82-day jury trial of fraud, bribery, and related charges for submitting false FSA emergency loan applications on behalf of dairy farmers following Hurricane Georges in Puerto Rico. The defendants inflated claimed damages, directed the procurement of falsified supporting documents, and paid kickbacks to an FSA official to approve over $10 million in loans. On appeal to the First Circuit, the defendants challenged the sufficiency of the evidence, certain jury instructions, sentencing calculations, and other procedural rulings. The court affirmed the convictions and sentences, holding that the evidence was sufficient when viewed in the light most favorable to the verdict, that the district court properly applied the advisory guidelines and considered the relevant statutory factors, and that no reversible errors occurred in the trial or sentencing proceedings.
The case involved a civil rights lawsuit by Adam Jennings against state police officer Kenneth Jones, alleging excessive force during an arrest at a tribal smoke shop that resulted in a broken ankle. A jury initially awarded damages on excessive force and battery claims against Jones, but the district court granted a new trial after finding the verdict against the weight of credible evidence and potentially incompatible with qualified immunity. The First Circuit affirmed, holding that the district court did not abuse its discretion in reassessing witness credibility and the strength of the evidence on whether force was increased after resistance ended.
The case was a medical malpractice action brought by Zoraida Montalvo, individually and as administratrix of her mother's estate, against multiple Puerto Rico healthcare providers for alleged failures to diagnose her mother's lung cancer, seeking damages for the mother's pain and suffering as well as the daughter's own emotional distress from the wrongful death. The district court granted summary judgment dismissing the suit as time-barred under Puerto Rico's one-year statute of limitations, concluding that the claims accrued by March 5, 2003, when the mother was discharged from a New York hospital with a terminal cancer diagnosis. The First Circuit vacated the judgment and remanded, holding that the complaint filed on April 20, 2004, was timely under the applicable Puerto Rico limitations rules, including considerations of accrual tied to the date of death and the plaintiff's ability to pursue both inherited and personal claims.