Justia Civil Rights Opinion Summaries

Plaintiff filed a 42 U.S.C. 1983 action against Defendant, the Secretary of the Commonwealth of Massachusetts, alleging that, in retaliation for Plaintiff's anti-regulatory stance, Defendant used his oversight powers to retaliate unlawfully against Plaintiff. The federal district court dismissed the complaint on immunity grounds. At issue before the First Circuit Court of Appeals was the scope and extent of the immunities offered to state officials, such as Defendant, whose duties encompass both prosecutorial and adjudicatory functions. The First Circuit affirmed the district court, holding that, notwithstanding Defendant's dual roles, Defendant was, with one exception, entitled to absolute immunity from Plaintiff's suit. View "Goldstein v. Galvin" on Justia Law

Defendant was charged with failing to register under the Sex Offender Registration and Notification Act. After a competency hearing, the district court found that Defendant was mentally incompetent and committed him to the custody of the attorney general to be hospitalized. While this interlocutory appeal was pending, the district court issued an order finding it unlikely that Defendant would be able to face the charges against him and ordering that Defendant be further evaluated. The First Circuit Court of Appeals affirmed the district court's order, holding (1) a defendant challenging an order finding him incompetent and committing him to the custody of the attorney general under 18 U.S.C. 4241(d)(1) can seek immediate review of such order; (2) the issue on appeal did not become moot after the district court issued its order finding it unlikely that Defendant would attain competency in the foreseeable future; (3) the district court applied the correct legal standard to determine Defendant's competency; and (4) the district court did not clearly err in finding Defendant incompetent. View "United States v. Mahoney" on Justia Law

Boston College (BC) undertook research into the armed conflict surrounding the independence movement of Northern Ireland during the second half of the Twentieth Century. BC compiled extensive personal interviews and testimonies from formerly active participants in that period. The materials were subject to strict confidentiality agreements entered into between BC and the interviewees. In 2011, a commissioner appointed to represent the United States (Petitioner) issued a subpoena to compel the production by BC of the recordings and/or transcripts of all interviews collected by the project's researchers containing information about an apparent casualty of the interstitial conflict in Northern Ireland. BC filed a motion to quash the subpoena. The district court denied BC's request, ordering that eighty-five interviews in BC's possession be turned over to Petitioner for eventual transfer to UK authorities. The First Circuit Court of Appeals affirmed in part and vacated in part the district court's order, holding that the district court abused its discretion in ordering the production of several of the interviews which did not contain any information relevant to the 2011 subpoena. Remanded. View "United States v. Trs. of Boston College" on Justia Law

Pursuant to a non-binding plea agreement, Defendant pled guilty to a charge of conspiracy with intent to distribute controlled substances. The district court imposed a 210-month incarcerative sentence after applying a sentencing enhancement for possession of a dangerous weapon during and in the course of the crime of conviction and construing the guideline sentencing range accordingly. The First Circuit Court of Appeals affirmed Defendant's sentence, holding (1) the district court's rejection of the sentencing recommendation vitiated Defendant's waiver of appeal in its entirety, and therefore, this appeal was not circumscribed; (2) the dangerous weapons enhancement was adequately grounded in the record; and (3) the sentencing court considered the relevant 18 U.S.C. 3553(a) factors and adequately explained the sentence. View "United States v. Murphy-Cordero" on Justia Law

Plaintiff was a police dispatcher with the Town of Camden Police Department for thirty-one years until his department was eliminated and he was laid off. In the year following Plaintiff's termination, at least two positions opened with the police department for which Plaintiff was qualified. The Town did not recall Plaintiff to either position. Plaintiff subsequently brought a procedural due process against the Town under 42 U.S.C. 1983, alleging that the Town deprived him of a constitutionally protected property interest in his right to be recalled to employment. The district court dismissed Plaintiff's complaint. The First Circuit Court of Appeals vacated the district court's order, holding (1) the district court correctly found that Plaintiff's complaint alleged a protected property interest in his recall right; but (2) the district court erred in concluding that Plaintiff's potential recourse to state law foreclosed his section 1983 claim, as Plaintiff's injury could not be fully redressed by recourse to a state law breach of contract claim or the grievance procedures in a collective bargaining agreement. Remanded. View "Clukey v. Town of Camden" on Justia Law

The police, after seizing a cell phone from Defendant's person as part of his lawful arrest, searched the phone's data without a warrant. Based on information obtained from the cell phone, Defendant was charged with possessing with intent to distribute and distributing cocaine base and with being a felon in possession of a firearm and ammunition. Defendant unsuccessfully filed a motion to suppress the evidence obtained as a result of the warrantless search of his phone, and the district court subsequently convicted Defendant as charged. The First Circuit Court of Appeals reversed the denial of Defendant's motion to suppress and vacated his conviction, holding (1) the search in this case exceeded the boundaries of the Fourth Amendment search-incident-to-arrest exception; and (2) because the government did not argue that the search here was justified by any exception to the warrant requirement, Defendant's motion to suppress must be granted. Remanded. View "United States v. Wurie" on Justia Law

Defendant, a thrice-convicted felon, and his confederates attended a backyard barbecue at which firearms were openly displayed. They subsequently reconvened at the scene of a planned robbery. The robbery was never consummated, but the police arrested Defendant on firearms charges. During the jury trial, the district court admitted evidence of Defendant's statements to the police about events occurring at the cookout. Defendant was convicted as charged. The First Circuit Court of Appeals, holding (1) the government proved beyond a reasonable doubt that Defendant knowingly possessed firearms charged in the indictment, and therefore, the district court correctly denied Defendant's motion for judgment of acquittal; and (2) the district court did not err in admitting Defendant's statements about the robbery scheme and his handling of the revolver at the cookout, as the evidence was relevant and not unfairly prejudicial. View "United States v. Williams" on Justia Law

Defendant was sentenced to eight years' incarceration after she pled guilty to various crimes committed during her sixteen years on the run with wanted fugitive, James "Whitey" Bulger. Defendant challenged her sentence on appeal, claiming that the court erroneously calculated her base offense level on the conspiracy to harbor a fugitive count, incorrectly applied a firearm enhancement, wrongly utilized an obstruction of justice enhancement, and erred in allowing family members of Bulger's alleged victims to speak during sentencing. The First Circuit Court of Appeals affirmed, holding that the district court did not err in (1) finding that Defendant's conduct was not limited to harboring Bulger and refusing to cap her offense level accordingly; (2) applying the firearm enhancement and the obstruction of justice enhancement; and (3) deciding to let the family members speak. View "United States v. Greig" on Justia Law

Plaintiff, an employee of Defendant, filed claims against Defendant for unlawful employment retaliation under Title VII of the Civil Rights Act. Plaintiff alleged that she was subject to several adverse employment actions that were taken in retaliation for occasions on which Plaintiff called attention to Defendant's purportedly discriminatory employment practices. The district court granted summary judgment for Defendant, concluded that, as to the two aspects of her employment at issue, Plaintiff had neither established a prima facie case of retaliation nor shown that Defendants' stated rationales for their purportedly unlawful actions toward her were pretextual. The First Circuit Court of Appeals affirmed, holding that no reasonable fact-finder could resolve the issues in Plaintiff's favor. View "Colon v. Tracey" on Justia Law

Appellant received a life sentence for his role in a large-scale drug operation that sold heroin, crack, cocaine, and marijuana at a public housing project in Puerto Rico. Appellant pled guilty to several drug offenses at the end of the first day of testimony. The First Circuit Court of Appeals vacated Appellant's sentence and remanded for resentencing before a different judge, holding (1) the imposition of a general sentence of life imprisonment on all counts when none of the crimes of conviction supported that penalty was improper, and the life term of imprisonment did not survive the plain error test; and (2) the district court erred in fixing Appellant's sentence by considering information obtained during an ex parte meeting with the probation department. View "United States v. Zavala-Marti" on Justia Law