Justia Civil Rights Opinion Summaries

Defendant was a Marine Corps veteran who worked as a civilian employee with the U.S. Department of Veterans Affairs. Defendant was convicted of fraud in connection with his own receipt of veterans benefits. Defendant appealed, contending (1) statements he made during an interview with a Criminal investigator for the Veterans Administration Office of the Inspector General were coerced because they forced him to choose between losing his job or surrendering his right to remain silent under the Fifth Amendment, and (2) the restitution he was ordered to pay as part of his sentence should have been offset by other benefits he might have claimed from the Veterans Administration. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in refusing to suppress statements Defendant made to the Veterans Administration investigator; and (2) the court's restitutionary order was proper. View "United States v. Palmquist" on Justia Law

A federal grand jury indicted Defendant of being a felon in possession of a firearm. Defendant moved to suppress the gun on the ground that the search that resulted in the discovery of the gun derived from an unlawful seizure. The district court granted the motion to suppress, finding that Defendant's encounter with law enforcement officers was at first consensual, but by the time it became a Terry stop, the officers lacked reasonable suspicion to permit the detention. The First Circuit Court of Appeals affirmed, holding that the district court did not err in concluding that the totality of the circumstances did not provide a reasonable suspicion to support Defendant's continuing detention at the time of the search that produced the firearm. View "United States v. Dapolito" on Justia Law

After exhausting her administrative remedies, Plaintiff, together with her husband and their conjugal partnership, sued Employer under Title VII, alleging sex discrimination in the form of hostile-work-environment harassment, and retaliation for challenging the harassment. A magistrate judge entered summary judgment for Employer on all claims. The Supreme Court affirmed, holding (1) ultimately, Plaintiff had no sex discrimination claim against Employer and so summary judgment was appropriate on that claim; (2) the evidence did not show that Employer infracted Title VII by retaliating against Employee for alleging that Employer discriminated against her on the basis of sex; and (3) Plaintiff could not prevail on her claim that the federal court judge was "bound" by Puerto Rico's summary-judgment policy. View "Medina-Rivera v. MVM, Inc." on Justia Law

Defendant, who had a 1994 conviction for criminal sexual assault, failed to register as required under the Sex Offender Registration and Notification Act (SORNA) when he moved to Puerto Rico in 2010. Defendant also had two prior failures to register as a sex offender in New Jersey and Florida, and he had an extensive criminal record, including a recent assault on an adult female. Defendant pled guilty to the federal charge of failure to register in this case. In sentencing Defendant, the district court imposed a particular condition of supervised release: that Defendant participate in a sex offender treatment and/or mental health treatment program arranged by the probation officer. The First Circuit Court of Appeals affirmed, holding that the district court did not abuse its discretion in imposing the sex-offender treatment, which was reasonably related to Defendant's present offense as well as to his criminal history. View "United States v. Morales-Cruz" on Justia Law

Defendant purchased a stolen handgun. Two days later, Defendant returned the gun in exchange for the money he paid. Based on the time he possessed the weapon, Defendant was indicted and convicted of one count of possession of a stolen firearm and was sentenced to a $100 special assessment, a one-month jail term, and a two-year term of supervised release. The First Circuit Court of Appeals vacated Defendant's conviction and remanded the case for a new trial, holding that the district court erred when it declined to instruct the jury on "innocent possession," which would have allowed Defendant to make out a defense of innocent possession of the stolen weapon. View "United States v. Baird" on Justia Law

Plaintiff, the former proprietor of a now-defunct bar and restaurant in Wrentham, Massachusetts, sued the Town of Wrentham and several town officials, alleging that Defendants maliciously imposed excessive regulatory requirements on his restaurant in retaliation for his opposition to certain town policies. Defendant filed causes of action for federal civil rights violations and violations of the state unfair trade practices law. The district court dismissed Defendant's complaint for failure to state a claim, concluding (1) the 42 U.S.C. 1983 claims were vague, failed to connect any of the alleged harms to any particular defendant, and did not establish a basis for municipal liability; and (2) the state law claim did not suggest any business contest or allege any unfair act or deceptive practice. The First Circuit Court of Appeals affirmed, holding that the district court did not err in its judgment. View "Gianfrancesco v. Town of Wrentham" on Justia Law

At issue in this case was Puerto Rico's controlled access law, which authorized gated communities, called urbanizations, which could control access to public streets within their confines. In 2004, Appellants, religious organizations, brought suit under 42 U.S.C. 1983, alleging that the controlled access regime unconstitutionally impeded their ability to proselytize from house to house. The suit was brought against several Commonwealth defendants and thirty-three municipalities and urbanizations. In Watchtower I, the First Circuit Court of Appeals determined that the CAL was constitutional on its face but that some municipalities and urbanizations were applying the law in ways that bore unreasonably on Jehovah's Witnesses' access to public streets. On remand, the district court dismissed the Commonwealth defendants. Appellants appealed the order dismissing the Commonwealth defendants. The First Circuit Court of Appeals dismissed Appellants' appeal for lack of jurisdiction, as the order was not final and the order did not have the practical effect of refusing injunctive relief and thus was not immediately appealable. View "Watchtower Bible & Tract Soc'y of N.Y., Inc. v. Colombani" on Justia Law

After a jury trial, Appellants were each convicted under 18 U.S.C. 1347 and 1349 for making fraudulent claims to, and obtaining payment from, insurance companies participating in Massachusetts' no-fault automobile insurance program. The First Circuit Court of Appeals affirmed Appellants' convictions, holding that the district court (1) correctly determined that the defrauded insurance companies constituted "health care benefit programs" within the jurisdictional reach of section 1347; (2) did not err in concluding that Appellants' scheme affected interstate commerce as is required for a constitutionally valid application of section 1347; and (3) did not violate Appellants' Fifth and Sixth Amendment rights in denying proposed voir dire questions concerning the ethnic minority group to which they belonged. View "United States v. Gelin" on Justia Law

After a vehicle pursuit, an officer of the Yarmouth, Massachusetts Police Department shot and killed Andre Martins. Plaintiff, individually and as administratrix of Martins' estate, brought a civil rights action against the officer and the Town of Yarmouth (collectively, Defendants). Defendants filed a motion for summary judgment, arguing that Plaintiff failed to establish that the officer's use of force violated Martins' constitutional rights and that, in the alternative, the officer was entitled to qualified immunity. The district court denied the motion. The First Circuit Court of Appeals dismissed Defendants' interlocutory appeal for lack of jurisdiction, holding that Defendants (1) failed to establish that, within the Scott v. Harris framework, Plaintiff's account of the shooting was so discredited by the record that no reasonable jury could believe her; and (2) failed to convince the Court that they were entitled to immunity. View "Campos v. Van Ness" on Justia Law

Plaintiff, her son Kyle, and Kyle's girlfriend Catherine lived together. In 2008, Kyle was the driver of a vehicle involved in an accident in New Hampshire. Defendant was among the police officers who responded to the scene. Kyle was then arrested. Catherine, who witnessed the accident, and Plaintiff went to the police station. Defendant warned Catherine against leaving the police department and threatened to obtain a warrant for her arrest if she left. Plaintiff, however, counseled Catherine to leave and escorted her out of the police station. Defendant subsequently filed a criminal complaint charging Plaintiff with witness tampering. The charge was later dismissed. Plaintiff then filed an action against Defendant in the U.S. district court for false arrest under the Fourth Amendment and malicious prosecution under state law. The district court granted summary judgment for Defendant, concluding that Defendant was entitled to qualified immunity on the federal constitutional claim and official immunity on the state-law claim. Finding no error, the First Circuit Court of Appeals affirmed. View "Moses v. Mele" on Justia Law