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Justia Daily Opinion Summaries

US Court of Appeals for the First Circuit
March 9, 2021

Table of Contents

United States v. Padilla-Galarza

Criminal Law

Wong v. FMR LLC

ERISA

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The Oprah Interview as a Truth Commission

LESLEY WEXLER

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Illinois Law professor Lesley Wexler explains how Oprah’s interview with Prince Harry and Meghan Markle might illuminate how a formal truth commission to deal with legacies of racism and colonialism might function in the British empire. Professor Wexler describes the purpose and function of state-operated truth commissions and notes the similarities and differences between those and the interview.

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US Court of Appeals for the First Circuit Opinions

United States v. Padilla-Galarza

Docket: 18-2078

Opinion Date: March 5, 2021

Judge: Selya

Areas of Law: Criminal Law

The First Circuit affirmed the judgment of the district court convicting Defendant of conspiracy to commit bank robbery, armed bank robbery, conspiracy to commit Hobbs Act robbery, and other offenses, holding that there was no prejudicial error in the proceedings below. Specifically, the First Circuit held (1) the district court did not err in denying Defendant's pretrial motion for severance; (2) the district court did not abuse its discretion in granting a protective order relating to certain discovery materials; (3) the district court did not abuse its discretion by declining to order the government to produce notes taken by law enforcement agents who interviewed a cooperating witness; and (4) Defendant was not entitled to relief on his remaining claims of error.

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Wong v. FMR LLC

Docket: 20-1286

Opinion Date: March 5, 2021

Judge: William Joseph Kayatta, Jr.

Areas of Law: ERISA

The First Circuit affirmed the judgment of the district court dismissing this putative class action complaint brought under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., holding that the district court did not err or abuse its discretion. Plaintiffs claimed that FMR LLC and several related Fidelity entities and affiliates (collectively, Fidelity) violated fiduciary duties it owed to its customer plans and their participants by exacting and retaining certain fees. The fees were exacted from mutual funds for the privilege of being placed on the menu of investment options Fidelity made available to 401(k) plans that contract with it to receive certain investment opportunities and services. The district court granted Fidelity's motion to dismiss for failure to state a claim. The First Circuit affirmed, holding that the district court properly dismissed the complaint.

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