Feliciano-Hernandez v. Pereira-Castillo, 663 F.3d 527

Feliciano-Hernández was convicted in Puerto Rico in 1981 and sentenced to perpetual imprisonment with a 12-year minimum under habitual-offender provisions.
The minimum term ended in 1993, but Parole Board annual reviews denied parole until Feliciano-Hernández was released in 2008.
In 2009 Feliciano-Hernández filed a federal §1983 complaint alleging his confinement beyond the sentence violated the Eighth, Fifth, and Fourteenth Amendments.
The district court dismissed the federal claims under Rule 12(b)(6); Puerto Rico law claims were dismissed without prejudice.
Feliciano-Hernández moved for reconsideration and to amend the complaint; the court denied both, and final judgment followed in August 2010.
On appeal, the First Circuit affirmed, holding the complaint failed to state a §1983 claim under Iqbal/Twombly and that reconsideration and belated amendment were properly denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the complaint states a §1983 claim against high-level officials for supervisory liability	Feliciano-Hernández alleges deliberate indifference by supervisors to his continued confinement.	Defendants lacked personal involvement and notice; no affirmative link shown.	No; Iqbal/Twombly require more than bare conclusions; no notice/link shown.
Whether the complaint plausibly alleged notice to the named defendants of a constitutional violation	Notice existed via 1998 habeas and 2005 mandamus proceedings and related filings.	No individual defendant was put on notice; proceedings involved others or improper channels.	No; no specific, fact-based notice to each defendant; Iqbal compliance required.
Whether the district court abused its discretion in denying the motion to reconsider and to file an amended complaint	The reconsideration argued errors and sought leave to amend.	District court acted within broad discretion; arguments either duplicative or untimely.	No; court did not abuse discretion; amendments were untimely and futile.
Whether the district court properly denied leave to file a belated amended complaint after judgment	Amendment would cure deficiencies	Post-judgment amendment requires vacating judgment; amendment would be futile.	No; post-judgment amendment not permitted absent vacatur; denial affirmed.

Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (pleading must state plausible claim, not mere conclusory allegations)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (claims require more than bare assertions of legal conclusions)
Maldonado v. Fontanes, 568 F.3d 263 (1st Cir. 2009) (establishes that a right must be clearly established for qualified immunity)
Soto-Torres v. Fraticelli, 654 F.3d 153 (1st Cir. 2011) (supervisor liability requires an affirmatively linked conduct)
Sanchez v. Pereira-Castillo, 590 F.3d 31 (1st Cir. 2009) (broad, conclusory supervisory allegations insufficient under Iqbal)
Peñalbert-Rosa v. Fortuño-Burset, 631 F.3d 592 (1st Cir. 2011) (allegations against governor insufficient under Iqbal)
Leavitt v. Corr. Med. Servs., 645 F.3d 484 (1st Cir. 2011) (regional medical director not vicariously liable for subordinates' conduct)
Ramos-Falcón v. A.E.D., 301 F.3d 1 (1st Cir. 2002) (after entry of default, court can assess sufficiency of complaint)