1st Circuit Case Commentaries

United States v. Papantoniadis — Forced Labor Under § 1589 May Be Proven Through a Workplace-Wide Climate of Fear (Including Threatened Deportation) and Contextual Evidence Beyond the Named Victim

Date: Jan 23, 2026

United States v. Papantoniadis — Forced Labor Under § 1589 May Be Proven Through a Workplace-Wide Climate of Fear (Including Threatened Deportation) and Contextual Evidence Beyond the Named Victim...

Mongue v. The Wheatleigh Corporation: Rule 23(e) Allows Approval of a “Global” Settlement Negotiated by Counsel Representing Both a Class and Individual Plaintiffs Absent a Realized Conflict

Date: Jan 23, 2026

Mongue v. The Wheatleigh Corporation: Rule 23(e) Allows Approval of a “Global” Settlement Negotiated by Counsel Representing Both a Class and Individual Plaintiffs Absent a Realized Conflict...

United States v. Maldonado-Velazquez — Upward Variances for Firearms “Firepower” Beyond the Guidelines and No Plea Breach When Government Defends the Sentence on Appeal

Date: Jan 18, 2026

Upward Variances for Firearms “Firepower” Beyond the Guidelines and No Plea Breach When Government Defends the Sentence on Appeal I. Introduction In United States v. Maldonado-Velazquez (1st Cir....

Government-Issued License Plates as “Goods” Under the Lanham Act and the Survival of Personal-Capacity Trademark Claims Against Puerto Rico Officials

Date: Jan 17, 2026

Government-Issued License Plates as “Goods” Under the Lanham Act and the Survival of Personal-Capacity Trademark Claims Against Puerto Rico Officials 1. Introduction Clemente Properties, Inc. v....

U.S.S.G. § 2K2.1 Upward Variances: Large Ammunition Quantities and Multiple (High-Capacity) Magazines as “Heartland” Aggravators, with Sentencing Rationale Inferable from the Record

Date: Jan 16, 2026

U.S.S.G. § 2K2.1 Upward Variances: Large Ammunition Quantities and Multiple (High-Capacity) Magazines as “Heartland” Aggravators, with Sentencing Rationale Inferable from the Record I. Introduction...

U.S. v. Del-Valle-Camacho: Large Ammunition Quantity and Multiple (High-Capacity) Magazines as a Sufficient, Guideline-Independent Basis for an Upward Variance

Date: Jan 16, 2026

Large Ammunition Quantity and Multiple (High-Capacity) Magazines Can Independently Justify an Upward Variance When the Guidelines Do Not Account for That Quantity 1. Introduction In United States v....

Expert-Testimony Gatekeeping for Negligence/IIED Claims Challenging Mandated Child-Abuse Reporting; Evidence of Actual Service Denial Required for Section 504

Date: Jan 15, 2026

Expert-Testimony Gatekeeping for Negligence/IIED Claims Challenging Mandated Child-Abuse Reporting; Evidence of Actual Service Denial Required for Section 504 Case: J.S.H. v. Newton Court: United...

Time-Limited, Health-Furthering Medical Exemptions Do Not Defeat General Applicability of COVID-19 Vaccine Mandates (and Reply-Brief Individualized-Exemption Theories Are Waived)

Date: Jan 10, 2026

Time-Limited, Health-Furthering Medical Exemptions Do Not Defeat General Applicability of COVID-19 Vaccine Mandates (and Reply-Brief Individualized-Exemption Theories Are Waived) Case: Brox v. Woods...

Reliance-Interest Review and the Limits of Post Hoc Declarations in APA Stay Motions: 340B Rebate Pilot Enjoined Pending Appeal

Date: Jan 8, 2026

Reliance-Interest Review and the Limits of Post Hoc Declarations in APA Stay Motions: 340B Rebate Pilot Enjoined Pending Appeal Introduction This First Circuit order arises from a high-stakes...

United States v. Mello — §3146 Failure-to-Appear Grouping Does Not Bar §3C1.1 Obstruction Enhancement (No Double Counting)

Date: Jan 8, 2026

§3146 Failure-to-Appear Counts, When Grouped, Do Not Create “Double Counting” That Bars a §3C1.1 Obstruction Enhancement Case: United States v. Mello (1st Cir. Jan. 7, 2026) | Court: United States...

Digital-Evidence Drug-Quantity Extrapolation and No Double Counting Between § 3146 Failure-to-Appear and § 3C1.1 Obstruction

Date: Jan 8, 2026

Digital-Evidence Drug-Quantity Extrapolation and No Double Counting Between § 3146 Failure-to-Appear and § 3C1.1 Obstruction Case: United States v. Mello (1st Cir. Jan. 7, 2026) | Court: United...

Pending Discovery Does Not Block Summary Judgment Absent Rule 56(d), and § 1983 Malicious Prosecution After a Warrant Requires a Franks-Style Falsehood or Omission

Date: Jan 8, 2026

Pending Discovery Does Not Block Summary Judgment Absent Rule 56(d), and § 1983 Malicious Prosecution After a Warrant Requires a Franks-Style Falsehood or Omission 1. Introduction In Besosa-Noceda v....

Radfar v. Covino: Off-Duty Protective-Order Litigation Is Not “Color of Law,” a Stray Ethnic Slur Alone Won’t Prove Discriminatory Purpose, and Malicious Prosecution Requires an Initiated Criminal Proceeding

Date: Jan 8, 2026

Radfar v. Covino: Off-Duty Protective-Order Litigation Is Not “Color of Law,” a Stray Ethnic Slur Alone Won’t Prove Discriminatory Purpose, and Malicious Prosecution Requires an Initiated Criminal...

NIH Cannot Impose an Across-the-Board Indirect-Cost Cap by “Guidance” Where an Appropriations Rider and HHS Regulations Preserve Negotiated Rates

Date: Jan 7, 2026

NIH Cannot Impose an Across-the-Board Indirect-Cost Cap by “Guidance” Where an Appropriations Rider and HHS Regulations Preserve Negotiated Rates 1. Introduction In Association of American...

NIH May Not Impose an Across-the-Board Indirect-Cost Cap by “Guidance” Under the Appropriations Rider and HHS Deviation Regulations

Date: Jan 7, 2026

NIH May Not Impose an Across-the-Board Indirect-Cost Cap by “Guidance” Under the Appropriations Rider and HHS Deviation Regulations Court: U.S. Court of Appeals for the First Circuit (Rikelman,...

NIH Indirect-Cost Caps Are Unlawful: Appropriations Riders and HHS Deviation Rules Bar Across-the-Board Rates, and APA Jurisdiction Lies for Challenges to Agency-Wide Guidance

Date: Jan 7, 2026

NIH Indirect-Cost Caps Are Unlawful: Appropriations Riders and HHS Deviation Rules Bar Across-the-Board Rates, and APA Jurisdiction Lies for Challenges to Agency-Wide Guidance 1. Introduction In...

Citizen Flagpoles, Government Speech, and Viewpoint Discrimination: The First Circuit’s Application of Shurtleff in Scaer v. City of Nashua

Date: Dec 26, 2025

Citizen Flagpoles, Government Speech, and Viewpoint Discrimination: The First Circuit’s Application of Shurtleff in Scaer v. City of Nashua Introduction In Scaer v. City of Nashua, No. 25‑1356 (1st...

Ramos-Hernandez v. Bondi: Limits on Economic-Status and Family-Based Particular Social Groups in Extortion-Based Asylum Claims

Date: Dec 26, 2025

Ramos-Hernandez v. Bondi: Limits on Economic-Status and Family-Based Particular Social Groups in Extortion-Based Asylum Claims I. Introduction A. The Case in Context In Ramos-Hernandez v. Bondi, No....

Life-With-Parole Modifications for Juvenile Offenders as “New Judgments” Under AEDPA: Commentary on Donovan v. Massachusetts Parole Board

Date: Dec 26, 2025

Life-With-Parole Modifications for Juvenile Offenders as “New Judgments” Under AEDPA: Commentary on Donovan v. Massachusetts Parole Board I. Introduction The First Circuit’s decision in Donovan v....

Contextual Extortion: United States v. Díaz-Colón and the Scope of Threats under 18 U.S.C. § 875(d) and the Hobbs Act

Date: Dec 26, 2025

Contextual Extortion: United States v. Díaz-Colón and the Scope of Threats under 18 U.S.C. § 875(d) and the Hobbs Act I. Introduction The First Circuit’s decision in United States v. Díaz-Colón, No....