William G. Young

In this case, Michael Murray petitioned for a writ of coram nobis to challenge the length of his 1994 federal sentence for marijuana conspiracy and distribution, arguing that his prior 1984 conviction for similar conduct was invalid due to alleged FBI misconduct and false testimony tied to the Whitey Bulger scandal, which he claimed improperly influenced the sentence. The 1984 conviction had been affirmed on appeal after remand from the Supreme Court on Fourth Amendment and Speedy Trial Act issues, and Murray's sentence was later reduced by agreement. The court denied the petition without an evidentiary hearing, holding that Murray failed to show any fundamental error in the 1984 proceedings because any potential factual inaccuracies were immaterial to the conviction and his claims amounted to unsupported speculation. The decision rested on the high bar for coram nobis relief and the lack of evidence that the 1984 conviction would have been overturned.

criminal lawprocedure

In Carrasquillo v. United States, the petitioner filed a habeas petition under 28 U.S.C. § 2255 claiming that his counsel was ineffective for failing to shield him from government pressure during a post-plea proffer, which led to an admission of gun possession, and that the pre-sentence report inaccurately described his drinking. The district court had summarily dismissed the petition, noting that Carrasquillo failed to show prejudice, and on limited remand from the First Circuit, the court clarified its reasoning. The court decided that the petition was properly dismissed because Carrasquillo suffered no constitutional prejudice, as neither the gun possession admission nor his drinking history influenced the imposed sentence. The core reasoning was that the sentence was determined primarily by the need for proportionality among co-defendants' culpability levels under 18 U.S.C. § 3553(a) factors, rather than by the challenged elements, and no sentencing enhancement for the gun was ultimately applied.

criminal lawprocedure

In Rivera v. Astrue, the plaintiff sought judicial review under 42 U.S.C. § 405(g) of the Social Security Commissioner's denial of his applications for SSDI and SSI benefits, arguing that the hearing officer improperly weighed medical opinions by favoring state-agency psychologists over his treating clinician and failed to apply the proper standards for evaluating pain and credibility under Avery v. Secretary of Health & Human Servs. The court denied Rivera's motion to reverse and granted the Commissioner's motion to affirm the denial of benefits. The decision rested on the conclusion that substantial evidence supported the hearing officer's findings, including appropriate weighting of opinions where inconsistencies existed and credibility determinations based on Rivera's reported daily activities, work history, and functional assessments that indicated greater capabilities than claimed.

healthcarefederal power

The Dixons sued Wells Fargo seeking to enjoin foreclosure on their home, specific performance of an alleged oral agreement to modify their mortgage loan, and damages, claiming they relied on the bank's instructions to stop payments in anticipation of a modification. Wells Fargo moved to dismiss, arguing that the promissory estoppel allegations were insufficiently definite and that any state-law claim was preempted by the Home Owners’ Loan Act and its regulations. Having already dismissed the contract claim for inadequate pleading and denied remand, the court took under advisement whether the complaint plausibly alleged a binding promise and reasonable detrimental reliance under promissory estoppel, as well as the scope of HOLA preemption for claims directly affecting federal savings banks' lending practices.

propertybusiness & regulatoryfederal power

The case involved doctors Christof Westenfelder and Axel Zander suing AlloCure Inc. and related parties after their termination, asserting that AlloCure breached a Stock Restriction Agreement governing repurchase of their company shares. The plaintiffs moved for a preliminary injunction to bar arbitration of that claim, while AlloCure moved to compel arbitration under a clause in separate Consulting Agreements the parties had signed earlier. The court allowed the injunction, denied the motion to compel, and held that the claim was not subject to arbitration. It reasoned that the broad arbitration clause covered only disputes arising out of or relating to the Consulting Agreements, that the stock-repurchase claim did not implicate obligations under those agreements, and that parties cannot be forced to arbitrate absent consent even when multiple contracts are connected by the same transaction.

business & regulatoryprocedure

The case involves plaintiff Michael Mahon suing the United States and others for severe injuries from falling off a portico at the Commandant's House in the Boston National Historic Park, which he attributes to defective guardrails. The United States moved to dismiss under the discretionary function exception to the Federal Tort Claims Act's waiver of sovereign immunity. The court initially granted the motion but, on reconsideration after reviewing a concession contract between the National Park Service and a management company, vacated the dismissal and denied the motion. The core reasoning is that Service management policies impose a specific, non-discretionary duty to review and approve the concessioner's risk management plan, and the alleged failure to do so could support liability even if decisions about the guardrails themselves remain discretionary.

torts & liabilityfederal power

In this case, the plaintiff sued the City of Boston and its police commissioner on behalf of herself and her deceased husband, alleging that Boston police officers shot and killed her husband while he was experiencing a mental health crisis and behaving erratically with a pellet gun; she claimed the shooting resulted from the city's unconstitutional policies or customs regarding officer training and discipline, asserting a federal claim under 42 U.S.C. § 1983 for a Fourth Amendment violation along with related state-law claims for wrongful death, negligence, and gross negligence. The court granted the city's motion to dismiss the federal claim, holding that the complaint failed to plausibly allege facts supporting municipal liability under Monell v. Department of Social Services, as there were insufficient allegations of a policy of inadequate training on handling mentally ill individuals or of a custom of failing to discipline officers for excessive force that caused the incident. The court then declined to exercise supplemental jurisdiction over the state-law claims and dismissed them without prejudice. The decision rested on the absence of concrete, non-conclusory facts linking any city policy to the officers' actions.

civil rightsproceduretorts & liability

Pamela Whitzell sued under 42 U.S.C. § 405(g) seeking review of the Social Security Commissioner's denial of her applications for Supplemental Security Income and Disability Insurance Benefits, claiming disability from mental conditions including PTSD, depression, and panic disorder as well as physical back pain diagnosed as myofascial pain disorder. The court affirmed the Commissioner's decision, holding that the administrative law judge's residual functional capacity findings were supported by substantial evidence from treating and reviewing physicians. It further ruled that the ALJ properly considered the back pain by noting inconsistent treatment, lack of objective support for severe limitations, and the specialist's conclusion that no interventional treatment was needed. The appeal covered only the period from November 2003 to August 2006 after earlier procedural rulings.

healthcarefederal power

Marcus Miller pleaded guilty to federal drug conspiracy and distribution charges involving crack cocaine and was sentenced as a career offender based on two prior Massachusetts convictions for assault and battery on a police officer and assault and battery with a dangerous weapon. He filed a habeas corpus petition under 28 U.S.C. § 2255 arguing that the assault-on-a-police-officer conviction does not qualify as a "crime of violence" under the career-offender guidelines and therefore his sentence should be reduced. The court denied the petition without a hearing, holding that the conviction categorically qualifies as a crime of violence under the residual clause of U.S.S.G. § 4B1.2(a) because it presents a serious potential risk of physical injury to another. The decision follows binding First Circuit precedent in United States v. Dancy and United States v. Fernandez, which applied the categorical approach and concluded that the offense nearly always involves conduct creating such risk, even when committed recklessly, consistent with the Supreme Court's analysis in Sykes v. United States.

criminal lawprocedure

In this case, franchisees of Coverall North America, Inc. sued under the Massachusetts Independent Contractor Statute, alleging they were misclassified as independent contractors rather than employees. After the court ruled they were employees as a matter of law and certain claims went to arbitration, plaintiffs Awuah and DaSilva prevailed on misclassification and received damages awards. They then moved for attorneys' fees covering summary judgment briefing on classification, arbitration clause challenges, and the arbitration hearing itself. The court granted the motion, awarding $34,119 in fees and $3,362.12 in costs, holding that the plaintiffs were prevailing parties entitled to recovery under Mass. Gen. L. ch. 149, § 150, with fee amounts calculated using prior-approved hourly rates and reasonable hours adjusted for the arbitration's limited scope.

labor & employment

This case involved Maureen Lappen's challenge to the denial of her application for Social Security Disability Insurance Benefits under the Social Security Act. Lappen argued that the Administrative Law Judge misstated medical expert findings and lacked substantial evidence to deem her subjective complaints not credible. The court reviewed the Commissioner's final decision under 42 U.S.C. § 405(g) and found that the ALJ's determination—that Lappen was not disabled—was supported by substantial evidence from medical records, expert testimony noting limitations in functioning without marked impairments, and inconsistencies in Lappen's reports including her undisclosed alcohol use. The court therefore denied Lappen's motion to reverse or remand and affirmed the Commissioner's decision.

federal powerhealthcareprocedure

Armanda C. Sousa sued the Commissioner of Social Security under 42 U.S.C. § 405(g) for review of the denial of her application for Social Security Disability Insurance Benefits, claiming that the residual functional capacity determination omitted limitations on her right arm use due to shoulder issues and that the hypothetical to the vocational expert was incomplete. The court denied Sousa's motion to reverse and granted the Commissioner's motion to affirm the denial. The hearing officer's assessment was supported by substantial evidence in the medical records showing full range of motion after surgeries and no ongoing need for extra limitations like unscheduled breaks or psychological interruptions beyond those already incorporated into unskilled work with occasional changes.

federal powerprocedure

The case involved the United States suing the Commonwealth of Massachusetts over its use of the Caritas Physical Abilities Test (PAT) for hiring entry-level correctional officers and correctional program officers, claiming the test created an unlawful disparate impact on women under Title VII. The opinion sets out the three-prong statutory framework for disparate impact claims, requiring the plaintiff first to prove disparate impact, then the employer to show the practice is job-related and consistent with business necessity, and finally allowing the plaintiff to identify a less discriminatory alternative. After contentious discovery and cross-motions for summary judgment, with the United States seeking judgment on all prongs and the Commonwealth cross-moving only on the first prong, the court stressed that genuine disputes required live judicial fact-finding rather than resolution by affidavit and declined to continue the scheduled trial. The opinion notes that the litigation had narrowed to a single issue after the United States abandoned part of its case.

civil rightslabor & employmentprocedure

This case concerned whether the Massachusetts Department of Transportation (MassDOT) had complied with a prior court injunction addressing its violations of a federal storm water discharge permit under the Clean Water Act at three specific sites, as well as deficiencies in its overall Storm Water Management Plan. After finding earlier violations and issuing an injunction in 2010 that required remedial construction and plan revisions, the court determined that MassDOT had since submitted required reports, implemented the plan changes, and begun construction at the identified sites. The Conservation Law Foundation sought additional injunctive relief and ongoing court supervision, but the court ruled that no further injury had been shown to justify more intervention, that technical implementation disputes were better left to agency expertise, and that federalism concerns counseled against continued judicial oversight of state fiscal and operational decisions. The court therefore granted MassDOT's motion for entry of judgment under Federal Rule of Civil Procedure 58 while denying the request for expanded relief, though it required limited future compliance reports.

environmentprocedure

Nhut Huynh petitioned for federal habeas corpus relief under 28 U.S.C. § 2254 after his Massachusetts state court convictions for two counts of first-degree murder. He argued actual innocence, knowing use of perjured testimony by the prosecutor, and insufficient evidence, relying primarily on security video footage and stills that he claimed showed he did not possess or use a firearm. The district court denied the petition, holding that the Massachusetts Supreme Judicial Court’s affirmance of the convictions was neither contrary to nor an unreasonable application of clearly established federal law. The state court had found the evidence sufficient, citing multiple eyewitness accounts identifying Huynh as the shooter, his motive and confrontational behavior before the shooting, and his flight and other conduct demonstrating consciousness of guilt. Under AEDPA deference, the federal court concluded that the state court’s sufficiency analysis satisfied due process standards.

criminal lawprocedure

The case involved the Conservation Law Foundation suing the Commonwealth of Massachusetts and its agencies for violating the Clean Water Act by discharging polluted storm water from highway systems without full compliance with NPDES permit requirements, including the need for an approved Storm Water Management Plan. After a bench trial, the court ruled in favor of CLF, finding violations at specific sites and ordering the Commonwealth to submit and implement a remedial plan. Because the Commonwealth failed to comply promptly with the court's orders due to bureaucratic delays, CLF moved for interim attorneys' fees as the prevailing party. The court granted the motion, awarding over $386,000 in fees and nearly $60,000 in costs, reasoning that CLF's efforts established the violations and that the Commonwealth's noncompliance justified compensation for work up to that point.

environmentprocedure

The case involves petitioner John Babcock's federal habeas corpus petition under 28 U.S.C. § 2254 challenging a Massachusetts Appeals Court ruling on the timing of his state sentences relative to prior federal sentences for bank robbery/kidnapping and firearm charges. Babcock argued that his concurrent state sentences (totaling nine to ten years) should have begun running during his federal terms rather than after the aggregate federal sentences, which would have led to an earlier release date. The district court adopted the magistrate judge's recommendation and denied the petition, holding that the claim raised only an issue of state law interpretation not cognizable on federal habeas review. Even assuming review on the merits, the court found Babcock failed to show that the state court's factual determination about the sentencing judge's intent was unreasonable.

criminal lawprocedure

The case involved Dathon Wright's federal habeas corpus petition under 28 U.S.C. § 2254 challenging his Massachusetts convictions for voluntary manslaughter and firearm offenses arising from a 2002 nightclub parking lot gunfight in which a bystander was killed by a bullet not fired by Wright. Wright argued that the evidence was insufficient for a rational jury to find he caused the death or was not acting in self-defense. The district court denied the petition without a hearing, ruling that the state appeals court's affirmance was neither contrary to nor an unreasonable application of clearly established federal law under Jackson v. Virginia, because the evidence—viewed in the light most favorable to the prosecution—could support findings that Wright participated in the shootout, intended to cause grievous injury, and was not fleeing in self-defense. The court emphasized that its role was limited to reviewing sufficiency under federal habeas standards, not redefining state criminal law on shootout liability.

criminal lawgunsprocedure

The case involved the conviction of Daquawn Jones for conspiracy to distribute crack cocaine and distribution of .62 grams of crack cocaine within 1000 feet of a school, based on an undercover drug purchase by a state trooper. The court denied the defendant's motion to suppress identification evidence obtained through a suggestive single-photo lineup procedure in which local officers identified the defendant from a video and showed his photo to the undercover officer for confirmation. The core reasoning was that, despite the suggestiveness of the procedure, the identification was reliable due to the officer's heightened awareness from a suspicious vehicle nearby, his concentration on the suspects, good lighting, proximity to the individual, and the short time between the observation and identification. The opinion also discusses the potential role of expert testimony on eyewitness identification reliability and the application of sentencing guidelines to a career offender.

criminal lawprocedure

Maria Teixeira sought judicial review of the Social Security Administration's denial of her claim for disability benefits after a 2007 motor vehicle accident caused a degloving injury to her left hand, ending her work as a shoe inspector. The court examined whether the hearing officer had properly assessed her pain levels and residual functional capacity, and whether transferable skills and available jobs supported a finding of not disabled. The court affirmed the Commissioner's decision, holding that medical reports and vocational expert testimony provided substantial evidence for the hearing officer's conclusions and that any inconsistencies in identifying transferable skills were harmless under the Medical-Vocational Guidelines.

labor & employment