1st Circuit Case Commentaries

Hodzic v. Bondi — Statutory “Exceptional Circumstances” Do Not Govern BIA Sua Sponte Reopening, and Niz-Chavez Does Not Compel Reopening

Date: Mar 24, 2026

Hodzic v. Bondi — Statutory “Exceptional Circumstances” Do Not Govern BIA Sua Sponte Reopening, and Niz-Chavez Does Not Compel Reopening 1. Introduction In Hodzic v. Bondi (1st Cir. Mar. 19, 2026),...

Police “Wanted Posters” Do Not Trigger the Federal Sixth Amendment Speedy-Trial Clock; In Massachusetts, the Clock Starts at Arrest/Indictment, Not at Complaint

Date: Mar 20, 2026

Police “Wanted Posters” Do Not Trigger the Federal Sixth Amendment Speedy-Trial Clock; In Massachusetts, the Clock Starts at Arrest/Indictment, Not at Complaint 1. Introduction Carr v. Lizotte (1st...

Narrigan v. Goldberg — Ripeness and Standing Limits for Takings Challenges to Unclaimed-Property Interest Regimes

Date: Mar 20, 2026

Narrigan v. Goldberg: Takings Challenges to Unclaimed-Property Interest Are (i) Unripe Before a Claim-and-Refusal and (ii) Cannot Support Prospective Relief Once the Alleged Taking Is Complete...

Delegation Clauses and Equitable Estoppel Do Not Let a Signatory Force a Nonsignatory Courier Into Arbitration When the Contract Is Only With the Courier’s LLC

Date: Mar 19, 2026

Delegation Clauses and Equitable Estoppel Do Not Let a Signatory Force a Nonsignatory Courier Into Arbitration When the Contract Is Only With the Courier’s LLC I. Introduction Abdisalam v. Strategic...

Overwhelming Evidence Renders Alleged “Overview” and Prejudicial-Background Testimony Harmless in Money-Laundering Conspiracy Trials

Date: Mar 19, 2026

Overwhelming Evidence Renders Alleged “Overview” and Prejudicial-Background Testimony Harmless in Money-Laundering Conspiracy Trials Case: United States v. Figueroa (1st Cir. Mar. 17, 2026) (Not for...

Categorical Funding Freezes Are Reviewable and Likely Arbitrary, but APA Courts Cannot Order Grant/Contract Payments (Tucker Act Limit)

Date: Mar 18, 2026

Categorical Funding Freezes Are Reviewable and Likely Arbitrary, but APA Courts Cannot Order Grant/Contract Payments (Tucker Act Limit) Introduction In State of New York v. Trump (1st Cir. Mar. 16,...

Rescission-in-Name-Only Does Not Moot a De Facto Federal Funding Freeze; APA Injunctions May Bar Categorical Freezes but Generally May Not Compel Grant/Contract Disbursements

Date: Mar 18, 2026

Rescission-in-Name-Only Does Not Moot a De Facto Federal Funding Freeze; APA Injunctions May Bar Categorical Freezes but Generally May Not Compel Grant/Contract Disbursements 1. Introduction In State...

Pro Se Extension Motions as Functional Notices of Appeal; Post-Muldrow “Worse Off” Standard Applied to ADEA Without Converting PIPs into Per Se Adverse Actions

Date: Mar 14, 2026

Pro Se Extension Motions as Functional Notices of Appeal; Post-Muldrow “Worse Off” Standard Applied to ADEA Without Converting PIPs into Per Se Adverse Actions Case: Walsh v. HNTB Corporation (No....

United States v. Parlin: Sufficiency Review Uses All Admitted Evidence; Harmless-Error Affirmance Without Deciding Lay vs. Expert Drug-Quantity Testimony

Date: Mar 14, 2026

United States v. Parlin: Sufficiency Review Uses All Admitted Evidence; Harmless-Error Affirmance Without Deciding Lay vs. Expert Drug-Quantity Testimony Introduction In United States v. Parlin (1st...

Maldonado-Ruiz v. Bondi: Unfulfilled, Unreported Threats and Subjective Belief Are Insufficient to Prove Nexus or Government Inability in LGBTI Asylum Claims

Date: Mar 12, 2026

Maldonado-Ruiz v. Bondi: Unfulfilled, Unreported Threats and Subjective Belief Are Insufficient to Prove Nexus or Government Inability in LGBTI Asylum Claims 1. Introduction In Maldonado-Ruiz v....

Scintilla Is Not Enough: Enforcing (or Defeating) Oral/Implied Contract Theories and § 1981 Bid-Exclusion Claims at Summary Judgment

Date: Mar 7, 2026

Scintilla Is Not Enough: Enforcing (or Defeating) Oral/Implied Contract Theories and § 1981 Bid-Exclusion Claims at Summary Judgment I. Introduction John B. Cruz Construction Co., Inc. v. Beacon...

Post-Discharge “Related To” Bankruptcy Jurisdiction Does Not Automatically Terminate; Renewed Withdrawal Motions Must Be Timed to the Current Procedural Posture and Address Jury-Trial Requests

Date: Mar 7, 2026

Post-Discharge “Related To” Bankruptcy Jurisdiction Does Not Automatically Terminate; Renewed Withdrawal Motions Must Be Timed to the Current Procedural Posture and Address Jury-Trial Requests 1....

Administrative Closure Without Compelling Arbitration Is a Denial Appealable Under FAA § 16(a)(1)(B), and FAA § 4 Requires a Clear Order Directing Arbitration “In Accordance with the Terms” (Including Individual Arbitration)

Date: Mar 7, 2026

Administrative Closure Without Compelling Arbitration Is a Denial Appealable Under FAA § 16(a)(1)(B), and FAA § 4 Requires a Clear Order Directing Arbitration “In Accordance with the Terms”...

United States v. Robles-López — Mitigating-Role Reductions Require a Full “Relevant Conduct” Comparator Universe and an On-the-Record Guía-Sendeme Analysis

Date: Mar 7, 2026

Mitigating-Role Reductions Require a Full “Relevant Conduct” Comparator Universe and an On-the-Record Guía-Sendeme Analysis 1. Introduction In United States v. Robles-López (1st Cir. Feb. 3, 2026),...

Boston v. OptumRx: Massachusetts Fraudulent-Concealment Tolling and “Continuing Nuisance” Require More Than Ongoing Harm and Publicly Available Clues Can Impute Actual Knowledge

Date: Mar 3, 2026

Boston v. OptumRx: Massachusetts Fraudulent-Concealment Tolling and “Continuing Nuisance” Require More Than Ongoing Harm and Publicly Available Clues Can Impute Actual Knowledge 1. Introduction In...

Boston v. OptumRx: Public-Nuisance Claims Against PBMs Are Time-Barred When Public Information Makes Wrongdoing Probable and Discoverable (No “Continuing Nuisance” Without New Tortious Acts)

Date: Mar 3, 2026

Boston v. OptumRx: Public-Nuisance Claims Against PBMs Are Time-Barred When Public Information Makes Wrongdoing Probable and Discoverable (No “Continuing Nuisance” Without New Tortious Acts)...

No “Substantial Asset” Threshold Under 11 U.S.C. § 727(a)(5): Any Unexplained Loss of Estate Assets Can Bar a Chapter 7 Discharge

Date: Mar 3, 2026

No “Substantial Asset” Threshold Under 11 U.S.C. § 727(a)(5): Any Unexplained Loss of Estate Assets Can Bar a Chapter 7 Discharge Introduction Case: Coastal Capital, LLC v. Savage, No. 25-1249 (1st...

Da Silva-Queiroga v. Bondi: Isolated Domestic-Violence Harm, No Serious Injury, and Years Without Further Physical Harm Fail to Establish “Persecution” or a Well-Founded Fear

Date: Mar 3, 2026

Da Silva-Queiroga v. Bondi: Isolated Domestic-Violence Harm, No Serious Injury, and Years Without Further Physical Harm Fail to Establish “Persecution” or a Well-Founded Fear 1. Introduction In Da...

Supremacy Clause Limits Puerto Rico Act 66 Payment-Plan Stays of Federal Title VII Judgments

Date: Mar 3, 2026

Supremacy Clause Limits Puerto Rico Act 66 Payment-Plan Stays of Federal Title VII Judgments I. Introduction García Colon v. State Insurance Fund Corporation arises from a Title VII and Puerto Rico...

Supremacy Clause Preempts Puerto Rico Act 66/68 Payment-Plan Stays that Indefinitely Delay Execution of Federal Title VII Judgments

Date: Mar 3, 2026

Supremacy Clause Preempts Puerto Rico Act 66/68 Payment-Plan Stays that Indefinitely Delay Execution of Federal Title VII Judgments Introduction In Garcia Colon v. State Insurance Fund Corporation...

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