Justia Civil Rights Opinion Summaries

After a jury trial, Appellant was convicted of conspiracy to possess with intent to distribute and distribution of cocaine and cocaine base and possession of cocaine base. The district court sentenced Appellant to 262 months' imprisonment in 2002. In 2007, the United States Sentencing Guidelines were amended to reduce crack-cocaine base offense levels. Appellant subsequently moved for and was granted a sentence reduction under 18 U.S.C. 3582(c)(2). In 2011, the guidelines were again amended, retroactively lowering the base offenses even further for crack-cocaine offenses. Appellant moved a second time for a reduction of his sentence. The district court denied the motion, concluding that Appellant was ineligible to receive that reduction because the amended guidelines range exceeded Appellant's modified sentence. The First Circuit Court of Appeals affirmed, holding that the district court did not err in determining Appellant was ineligible for a sentence reduction under 18 U.S.C. 3582(c)(2). View "United States v. Hogan" on Justia Law

Defendant pleaded guilty to conspiracy to possess with intent to distribute cocaine. Defendant appealed, asserting that he did not understand the criminal intent required as an element of the crime and that the district court accepted his guilty plea without an adequate factual basis for the mens rea element of the conspiracy charge. The First Circuit Court of Appeals affirmed the conviction, holding (1) the district court did not plainly err in finding Defendant's plea was knowing, intelligent, and voluntary, as the record contained sufficient evidence of Appellant's appreciation of the elements of the charged crime; and (2) there was a suitable factual basis for Appellant's guilty plea. View "United States v. Ramos-Mejia" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to life imprisonment. Appellant subsequently applied for postconviction relief, alleging that the prosecution failed to turn over exculpatory evidence during his trial. The state superior court denied the application, finding that the withheld information was not material under the Brady test for materiality. The Rhode Island Supreme Court affirmed. Appellant then filed a petition for writ of habeas corpus, challenging the state courts' rulings with regard to his postconviction application. The federal district court denied relief. The First Circuit Court of Appeals affirmed, holding (1) the Rhode Island Supreme Court did not use a materiality standard that was contrary to clearly established U.S. Supreme Court law; and (2) the Rhode Island Supreme Court's application of the materiality standard was not an unreasonable application of clearly established U.S. Supreme Court law. View "DeCiantis v. Wall" on Justia Law

Defendants in this case were a Puerto Rico legislator and a Commonwealth businessman who were charged with unlawfully exchanging favorable action on legislation for a trip to Las Vegas to attend a prize fight. After a jury trial, Defendants were convicted of, inter alia, federal program bribery in violation of 18 U.S.C. 666. Defendants appealed, contending, among other issues, that the district court erred in instructing the jury to find guilt on the section 666 counts based on a gratuity theory rather than a bribery theory. The First Circuit Court of appeals (1) vacated Defendants' section 666 convictions, holding that because section 666 does not criminalize gratuities in addition to bribes, the district court erred in its instructions; and (2) directed the district court to enter a judgment of acquittal on Defendants' conspiracy charges, holding that the Double Jeopardy Clause entitled both men to acquittal on their respective conspiracy charges. View "United States v. Bravo-Fernandez" on Justia Law

From 1999 to at least 2007, Defendant illegally downloaded and distributed copyrighted music without authorization. In 2007, a group of recording companies (collectively, "Sony") filed this action against Defendant under the Copyright Act, seeking damages and injunctive relief. Sony pursued claims for thirty copyrighted works, although Defendant allegedly distributed far more than that amount. After a trial, the jury awarded $675,000 in damages, which represented $22,500 for each of thirty songs whose copyright Defendant violated. Defendant appealed, arguing that the award was so large that it violated his constitutional due process rights. The First Circuit Court of Appeals affirmed, holding that the jury's award did not violate Defendant's right to due process. View "Sony BMG Music Entm't v. Tenenbaum" on Justia Law

After a jury trial, Appellant was convicted of seventeen counts of mail fraud, wire fraud, bank fraud, and aggravated identity theft. Appellant appealed, arguing (1) the trial court violated his Sixth Amendment right to confront the witnesses against him by admitting testimony of a forensic examiner about another examiner's prior examination; and (2) the evidence was insufficient to support his aggravated identity theft convictions. The First Circuit Court of Appeals upheld Appellant's convictions on all counts, holding (1) the evidence was sufficient to allow a reasonable jury to conclude beyond a reasonable doubt that Appellant was guilty of aggravated identity theft; and (2) the district court did not plainly err in admitting the testimony of the forensic examiner about the conclusions in another examiner's report, as the statements did not affect Appellant's substantial rights. View "United States v. Soto" on Justia Law

Defendants, Baldwin and Gladys Ihenacho, were the owners and operators of a neighborhood pharmacy. Defendants were convicted of dispensing and shipping drugs to customers pursuant to invalid online prescriptions for Internet pharmacy operations headquartered in the Dominican Republic. Baldwin pled guilty to almost all of the charges. Gladys went to trial, and a jury convicted of her eight counts. The First Circuit Court of Appeals affirmed Baldwin's sentence and Gladys's convictions, holding (1) the district court did not err in applying the fraud sentencing guideline to Baldwin and in calculating the loss caused by Baldwin's offenses for purposes of the fraud guideline; and (2) the evidence was sufficient to support Gladys's convictions for distributing controlled substances, conspiracy, and money laundering. View "United States v. Ihenacho" on Justia Law

While fleeing from the United States Coast Guard, Claimant and his crew tossed more than $8 million into the Caribbean Sea. The Coast Guard subsequently recovered the currency. The government filed this action seeking to have the $8 million, along with additional money found on the crew members' persons, forfeited to the United States. Claimant, who was convicted of knowingly failing to obey a federal law enforcement officer's order to slow down or stop, filed a claim of ownership for the currency. The district court granted summary judgment for the government, holding that Claimant had not shown a colorable interest in the seized currency, and therefore, Claimant failed to establish standing to challenge the forfeiture. The First Circuit Court of Appeals affirmed in part and reversed in part, holding (1) the district court had jurisdiction over a portion of the currency; (2) Claimant did not have constitutional standing the contest the forfeiture of the $8 million; but (3) Claimant did have standing to contest the forfeiture of the $10,000 found on his person. View "United States v. Duyzing" on Justia Law

Plaintiff, a female, brought federal and state claims alleging gender discrimination against the Town of Dennis, Massachusetts, the Town golf course, and several individuals after the golf course refused to let Plaintiff participate in a men's golf tournament. The district court granted summary judgment for Plaintiff and held a trial on damages. The court ruled (1) awarded Plaintiff $34,600 in attorney's fees and costs, (2) rejected Plaintiff's request that the jury be instructed on punitive damages, (3) denied Plaintiff's request for an injunction ordering Defendants to adopt a policy barring gender-based discrimination. Both parties appealed, challenging the nature and extent of Plaintiff's remedy. The First Circuit Court of Appeals (1) affirmed the district court's treatment of punitive damages; (2) vacated the denial of injunctive relief where the district court failed to explain its decision to grant or refuse such relief; and (3) vacated the award of attorney's fees, holding that the district court erred in reducing Plaintiff's requested award based on, inter alia, Plaintiff's rejection of a settlement offer. View "Joyce v. Town of Dennis" on Justia Law

Appellant was convicted of first degree murder. Appellant subsequently commenced this action under the Freedom of Information Act (FOIA) seeking information from the FBI he believed would exonerate him. The government asserted various exemptions to disclosure of the documents' full contents and produced certain heavily redacted documents. After producing these documents, the government moved for summary judgment. The district court granted the government's motion, concluding that the FBI's search was adequate and that it properly claimed the exemptions asserted. The court also awarded Appellant attorneys' fees after significantly reducing the number of compensable hours and the requested hourly rate of Appellant's counsel. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in granting summary judgment to the government, as Appellant failed to raise a triable issue as to the government's treatment of his FOIA request; and (2) the district court did not abuse its discretion in calculating the fee award in this case. View "Moffat v. United States Dep't of Justice" on Justia Law