Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was convicted of possessing firearms as a convicted felon, possessing a firearm with an obliterated serial number, and using a stolen identity to purchase those firearms. The First Circuit Court of Appeals affirmed Defendant's convictions and remanded for resentencing, holding (1) the district court did not abuse its discretion when it denied Defendant's motion for a third court-appointed attorney; (2) Defendant's waiver of his right to counsel was intelligent and knowing, and the court did not err in allowing him to proceed pro se; (3) the district court did not err in instructing the jury on the use of flight evidence; (4) the court did not abuse its discretion in failing to conduct an evidentiary hearing on Defendant's motion to suppress; and (5) Defendant's sentences on certain counts exceeded the statutory maximum. View "United States v. Francois" on Justia Law

Plaintiff applied for a special permit to open an adult entertainment establishment within an industrial district. By the terms of a City ordinance, adult entertainment was forbidden on sites within an industrial district. The City denied Plaintiff's application. The Zoning Board of Appeals denied Plaintiff's appeal for variances from the ordinances. At issue on appeal was whether the City's zoning ordinances violated the First Amendment by preventing Plaintiff from opening his adult entertainment establishment on land zoned industrial without providing an adequate opportunity elsewhere. The federal district court entered summary judgment for the City. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in calculating the land available to Plaintiff for adult use; and (2) the available land provided Plaintiff a reasonable opportunity to open an adult business. View "Lund v. Fall River, Mass." on Justia Law

Plaintiff was hired by Employer in 2000 and began working as part of a five-person sales team. In 2009, Employer reduced the sales team to two employees and terminated Defendant. Plaintiff was fifty-five years old at the time. Plaintiff subsequently file a complaint with the Massachusetts Commission Against Discrimination (MCAD), alleging age discrimination. MCAD dismissed Plaintiff's complaint for a lack of probable cause. Plaintiff then brought suit in state court, claiming age discrimination under Massachusetts law. Employer removed the case to the U.S. district court based on diversity jurisdiction. Thereafter, the district court granted Employer's motion for summary judgment. The Supreme Court affirmed, holding that the district court did not err (1) in partially denying Plaintiff's third motion to compel; (2) in quashing deposition notices for three of Employer's employees; and (3) in granting summary judgment to Employer. View "Woodward v. Emulex Corp." on Justia Law

Defendant worked in a doctor's office in Maine first as a billing clerk and then as a billing manager. When Defendant began running the billing process on her own, she started carrying out an "upcode" scam wherein she bilked money out of payers like MaineCare, Medicare, and others by changing the codes to overstate what services had been provided, thus fetching higher payments. Defendant was later arrested and pled guilty to healthcare fraud. At sentencing, the judge enhanced Defendant's sentence under U.S.S.G. 3B1.3, which is appropriate if a defendant used a position of trust in such a way that made the crime easier to carry out or cover up. The First Circuit Court of Appeals vacated the sentence and remanded because the sentencing judge did not explain the basis for his findings to the extent necessary to permit effective appellate review, and therefore, the Court could not confirm that an abuse-of-trust enhancement was inevitable on the record. View "United States v. Zehrung" on Justia Law

Defendant, a convicted sex offender, moved from the District of Columbia to Massachusetts without complying with the Sex Offender Registration and Notification Act (SORNA). Defendant was subsequently arrested and indicted for violating 18 U.S.C. 2250(a), which criminalizes a knowing failure to abide by SORNA's registration requirements. Defendant filed a motion to dismiss the indictment, arguing that SORNA exceeds Congress's constitutional authority, that it includes an unconstitutional delegation of legislative power, and that no regulations have validly applied SORNA to offenders whose convictions, like Defendant's, pre-date SORNA. The district court denied the motion. Defendant pled guilty to the charge but preserved his right to appeal the denial of his motion to dismiss the indictment. The First Circuit Court of Appeals affirmed the denial of Defendant's motion, holding that Defendant was subject to SORNA's registration requirements when he traveled to Massachusetts, and because he failed to register, his conviction under section 2250(a) was proper. View "United States v. Whitlow" on Justia Law

This suit arose from a 2010 change to the certification and enrollment process for providers in the Commonwealth's Supplemental Educational Services program, funded under federal law. Appellant, a certified educational services provider based in Puerto Rico, filed a civil rights action pursuant to 42 U.S.C. 1983 against Defendant, personally and in his official capacity as Puerto Rico's Secretary of Education, alleging that the change in the certification and enrollment process unilaterally and arbitrarily disadvantaged Appellant vis-a-vis its competitors. The district court dismissed the amended complaint in its entirety, finding that it lacked sufficiently well-pled facts to support a plausible claim that Defendant had violated Appellant's due process, equal protection, or commercial free speech rights. The First Circuit Court of Appeals affirmed on alternate grounds, holding that Defendant was entitled to qualified immunity as to all claims. View "Rocket Learning, Inc. v. Rivera-Sanchez" on Justia Law

Plaintiff, an instructor in graphics who did not have a Ph.D., was denied a tenure-track position at the University of Puerto Rico. Three others, all of whom had Ph.D.s as the description required, did receive tenure-track positions. Plaintiff filed administrative discrimination charges, followed by a Title VII lawsuit against the University. The district court granted summary judgment for the University. The First Circuit Court of Appeals affirmed, holding that the Ph.D. requirement for tenure-track positions was a legitimate, nondiscriminatory reason for the University's actions and that Plaintiff did not meet her burden of showing that the articulated reason was pretextual. View "Johnson v. Univ. of P.R." on Justia Law

After a jury trial, Defendant was convicted of first degree murder based on extreme atrocity or cruelty. The jury rejected Defendant's insanity defense. After unsuccessfully filing a motion for a new trial and a motion to consider, Defendant filed this habeas corpus petition, alleging several errors on the part of the motion judge. The district court denied the petition. The First Circuit Court of Appeals affirmed, holding that the motion judge did not err in ruling (1) the trial court did not need to hold a competence hearing sua sponte; (2) trial counsel was not constitutionally deficient; (3) the trial court did not need to inquire into Defendant's waiver of his right to testify; and (4) appellate counsel was not constitutionally deficient. View "Rosenthal v. O'Brien" on Justia Law

This action arose out of Plaintiffs' alleged breach of a conservation restriction appurtenant to their Hudson, Massachusetts home. Plaintiffs and members of the Hudson Conservation Commission clashed over Plaintiffs' compliance efforts. In the meantime, a Hudson Police captain filed charges against Plaintiff for criminal harassment and threat to commit a crime based on Plaintiff's alleged misconduct to his neighbors. All charges were later dropped against Plaintiff. Plaintiffs subsequently filed a 42 U.S.C. 1983 suit against the Town of Hudson, the Commission, and several state and local officials, alleging that Commission members, an administrator, and a building inspector violated the equal protection clause by selectively enforcing local laws against them and that the conduct of town officials and other defendants were so outrageous as to constitute substantive due process violations. The district court dismissed the suit. The First Circuit Court of Appeals affirmed, holding that Plaintiffs' complaint did not plead facts sufficient to support any of their federal claims. View "Freeman v. Town of Hudson" on Justia Law

After a jury trial, four defendants (Defendants) were convicted of one count of conspiracy to possess with intent to distribute narcotics and one count of conspiracy to use or carry firearms in furtherance of a drug trafficking crime. After considering all of the evidence, including evidence of seven murders committed in furtherance of the narcotics conspiracy, the district court sentenced each Defendant to life imprisonment on the first count and ten years' imprisonment on the second count, to be served consecutively. The First Circuit Court of Appeals affirmed, holding (1) the evidence was sufficient to support the guilty verdicts as to each defendant; (2) the district court did not err in imposing the life sentences as to three of the defendants; and (3) the court did not err in denying severance as to the fourth defendant. View "United States v. Rodriguez-Reyes" on Justia Law