Justia Civil Rights Opinion Summaries

Puerto Rico law operated to cause hundreds of thousands of motor vehicle owners to pay twice for liability insurance. Commonwealth law declared motor vehicle owners to be entitled to a refund of the excess premiums paid, but large amounts of unclaimed refunds accumulated. The Commonwealth subsequently placed the unclaimed refunds with its Treasury Secretary with the condition that, if not claimed within five years, the funds escheated to the Commonwealth without notice to the vehicle owners. In Garcia-Rubiera II, the First Circuit Court of Appeals held that the Commonwealth's failure to notify vehicle owners of their reimbursement rights violated their procedural due process rights. On remand, the district court ordered the Commonwealth to notify vehicle owners of their reimbursement rights, to publish notices in two newspapers alerting the owners of their rights, and to give owners a 120-day grace period for them to claim reimbursement. The First Circuit again remanded for the district court to craft with "the benefit of further guidance" an injunction that more fittingly remedied the Commonwealth's constitutional violations and ordered no duplicate premiums to escheat to the Commonwealth until it established and complied with a reimbursement procedure meeting the requirements of due process. View "Garcia-Rubiera v. Fortuno" on Justia Law

Defendant pleaded guilty to conspiring to possess with intent to distribute heroin, possessing with the intent to distribute heroin, conspiring to import heroin, and importing heroin into the United States. Defendant was sentenced to twenty-four months' imprisonment and two years of supervised release. Defendant appealed, arguing that her sentence was procedurally and substantively flawed. The First Circuit Court of Appeals affirmed, holding that the district court (1) did not err in denying Defendant's request for a continuance of the sentencing hearing; (2) did not abuse its discretion in choosing to impose a term of imprisonment; and (3) afforded Defendant an adequate opportunity to allocute. View "United States v. Pacheco" on Justia Law

A New Hampshire court issued a warrant to search Defendant's home after a state trooper submitted a supporting affidavit detailing the trooper's suspicion that Defendant's home contained a marijuana grow operation. Based on the items seized from Defendant's home, Defendant was charged with manufacturing marijuana, possessing marijuana with the intent to distribute, and possessing a firearm in furtherance of a drug trafficking crime. Defendant moved to suppress the evidence, arguing that the search warrant lacked probable cause. The district court suppressed the evidence, finding that the trooper recklessly omitted from his affidavit information material to a probable cause determination. The First Circuit Court of Appeals affirmed, holding that the search warrant at issue contained reckless material omissions, and the omitted information, when included back into the affidavit, failed to establish probable cause. View "United States v. Gifford" on Justia Law

After a jury trial, Defendants - Santos-Rivera, Diaz-Correa, and Carrasquillo-Ocasio - were convicted of conspiracy to possess with the intent to distribute drugs and drug possession for their rule in a criminal organization operating a "drug point" in a public housing project in Puerto Rico. Diaz-Correa was also convicted of conspiracy to possess firearms in furtherance of drug trafficking crimes. Diaz-Correa and Carrasquillo-Ocasio challenged their convictions on appeal, and Carrasquillo-Ocasio and Santos-Rivera challenged their sentences. The First Circuit Court of Appeals affirmed the judgments of the district court, holding (1) the evidence was sufficient for a reasonable factfinder to conclude beyond a reasonable doubt that Diaz-Correa and Carrasquillo-Ocasio were involved in the drug trafficking conspiracy and drug distribution activities at the housing project; (2) there was sufficient evidence to conclude that Diaz-Correa had agreed to use firearms to promote the drug-trafficking operation; (3) the case involved an instance of prosecutorial misconduct during closing argument, but the error was harmless; and (4) the district court did not err in the sentences imposed on Carrasquillo-Ocasio and Santos-Rivera. View "United States v. Santos-Rivera" on Justia Law

Defendant, a native of Russia, assumed the name, identifying information, and life history of Fionghal MacEoghan for more than twenty years. After law enforcement officials discovered Defendant's appropriation of MacEoghan's identity, Defendant was charged with, inter alia, aggravated identity theft, wire fraud, and providing false information to obtain federal financial aid in a nine count indictment. During trial, Defendant testified that he believed he had been lawfully adopted by MacEoghan's biological father, and thus that he had taken on MacEoghan's identity through legitimate means. The jury rejected Defendant's defense and found him guilty of eight counts of the indictment. The First Circuit Court of Appeals affirmed, holding that the district court did not err (1) in excluding a proposed expert witness in Soviet adoption practices and cultural difference between the former Soviet Union and the United States; and (2) in admitting evidence pertaining to Defendant's prior larceny conviction. View "United States v. Tetioukhine" on Justia Law

Defendant was convicted of two counts of carjacking resulting in death. After a penalty phase hearing, the jury recommended that Defendant be sentenced to death on both counts. The district court imposed a sentence of death. The First Circuit Court of Appeals affirmed. Defendant subsequently filed a writ of habeas corpus, claiming that juror dishonesty during the voir dire process prior to the penalty phase hearing deprived him of an impartial jury. After an evidentiary hearing, the district court vacated the death sentence and ordered a new penalty phase hearing. The First Circuit affirmed, holding that the death sentence must be vacated and a new penalty phase hearing undertaken because the juror's dishonesty deprived Defendant of the right to an impartial jury. View "Sampson v. United States" on Justia Law

The City of Springfield passed an ordinance creating a single-parcel historic district encompassing a church owned by the Roman Catholic Bishop of Springfield (RCB). Under the ordinance, RCB could not make any changes affecting the exterior of the church without the permission of the Springfield Historical Commission (SHC). RCB challenged the ordinance, claiming it violated RCB's rights under the First Amendment, the Religious Land Use and Institutionalized Persons Act, and the Massachusetts Constitution. The district court granted summary judgment for the City, concluding that some of RCB's claims were not ripe for review and that its remaining claims failed as a matter of law. The First Circuit Court of Appeals dismissed RCB's unripe claims without prejudice and rejected the remaining ripe claim, holding (1) the claims that the district court found were unripe should have been dismissed without prejudice, not resolved on summary judgment; (2) those of RCB's claims which depended on the potential consequences of compliance with the ordinance were not ripe for adjudication; and (3) RCB's claim based on the enactment of the ordinance was ripe for review but failed on the merits. View "Roman Catholic Bishop of Springfield v. City of Springfield" on Justia Law

Plaintiff served as the human resources director of two Puerto Rico governmental agencies. Plaintiff resigned one position and was terminated from the other. Plaintiff sued her former supervisors under 42 U.S.C. 1983 and Puerto Rico law, alleging that she was retaliated against due to her allegiance with a certain political faction disfavored by Defendants and because she refused to follow personnel-related orders that she considered illegal and politically motivated. The district court dismissed some of Plaintiff's claims and granted summary judgment on the remainder. The First Circuit Court of Appeals affirmed in all respects, holding that the district court did not err (1) in dismissing Plaintiff's First Amendment free speech claim, as Plaintiff's "speech" exclusively revolved around her professional duties as human resource director; (2) in dismissing a claim Plaintiff made under the Puerto Rico Whistleblowers Protection Act, as Plaintiff failed to raise her meritorious arguments regarding this claim in district court; and (3) in granting summary judgment on Plaintiff's freedom of association claim, as the First Amendment was inapplicable to Plaintiff's position as human resources director. View "O'Connell v. Marrero-Recio" on Justia Law

Appellant was charged with being a possession of a firearm and moved to suppress the firearm seized from him during a traffic stop. The district court denied the motion without a hearing, concluding that the seizure was justified under the plain view doctrine. Defendant subsequently filed a motion to reconsider and a second motion to suppress the firearm, requesting evidentiary hearings on both motions. After a non-evidentiary hearing, the district court denied both motions. The First Circuit Court of Appeals affirmed, holding that the district court did not abuse its discretion in denying an evidentiary hearing on Appellant's motion to reconsider and second motion to suppress. View "United States v. Cintron" on Justia Law

Defendant was convicted of willfully damaging federal property, creating a hazard on federal property, and creating a nuisance on federal property after he badly soiled a federal courtroom. Defendant appealed, arguing that because the regulations he was charged with violating were posted inside rather than outside the courthouse entrance, his conviction must be reversed pursuant to 40 U.S.C. 1315(c)(1) and a General Services Administration (GSA) regulation. The First Circuit Court of Appeals affirmed, holding (1) the regulations were posted in compliance with the statute, which requires posting of the regulations Defendant violated in a conspicuous place on the property; (2) while the GSA regulation specifies that the notice about the rules governing the building should be posted at the public entrance, the regulation does not provide that imperfect compliance with the exterior posting requirement nullifies a conviction for violating the prohibition; and (3) sufficient evidence established that Defendant had the mental state required for his conviction. View "United States v. Strong" on Justia Law