Justia Civil Rights Opinion Summaries

In 2009, federal agents, acting without a warrant, placed a global positioning system (GPS) tracker on a car used by Craig Sparks. The agents located the car at the scene of a bank robbery and chased down the car on the highway after it fled, all by using the tracker. A subsequent search of the car revealed evidence tying Sparks and Michaud (Appellants) to the bank robbery. After Appellants were indicted for bank robbery, they moved to suppress the evidence obtained as a result of the placement of the GPS tracker on the car. The district court denied the motion, concluding that the case was governed by United States v. Knotts, which held that using a radio-based tracking device to tail a suspect's car was not a Fourth Amendment search. Appellants appealed, arguing that the U.S. Supreme Court's recent decision in United States v. Jones required reversal of the district court's decision. The First Circuit Court of Appeals affirmed without reaching the question, holding that the agents' conduct fit within the good-faith exception to the exclusionary rule, and therefore, the district court did not err in denying Appellants' motion to suppress. View "United States v. Sparks" on Justia Law

Plaintiffs were former employees of the Puerto Rico Administration of Juvenile Institutions. After an election that produced a regime change, Plaintiffs were ousted from their positions, notwithstanding solid qualifications and positive evaluations. Plaintiffs sued several government defendants, invoking 42 U.S.C. 1983 and alleged discrimination based on political affiliation in violation of the First Amendment. Plaintiffs also lodged pendent claims under Puerto Rico law. The district court ruled that the complaint failed to state a claim for relief because it did not assert facts sufficient to establish a prima facie case of political discrimination. The First Circuit Court of Appeals reversed in part, holding (1) the prima facie case is not the appropriate benchmark for determining whether a complaint has met the plausibility standard under Bell Atlantic v. Twombly; (2) the factual allegations in Plaintiffs' complaint, taken as true, state plausible section 1983 claims for political discrimination with respect to two of the defendants; and (3) the pendent claims against those two defendants, which were dismissed without prejudice when the district court declined to exercise supplemental jurisdiction, must be reinstated. Remanded. View "Rodriguez-Reyes v. Molina-Rodriguez" on Justia Law

Plaintiff, an Egyptian-American, filed a workplace discrimination suit against the Mohegan Council, Boy Scouts of America alleging that he was denied career advancement opportunities on account of his religion of Islam and his national origin. After a jury trial, the district court ruled in favor of Plaintiff. The First Circuit Court of Appeals affirmed, holding that the district court did not err in denying Mohegan Council's motion for judgment as a matter of law, where (1) the district court correctly found that Mohegan Council was an "employer" with the requisite fifteen or more employees under the Title VII of the Civil Rights Act of 1964; (2) Plaintiff's complaint with the Massachusetts Commission Against Discrimination was timely filed; and (3) sufficient evidence supported a finding of discrimination. View "Aly v. Mohegan Council, Boys Scouts of Am." on Justia Law

Defendants, both Chinese nationals, shipped tens of millions of dollars worth of sophisticated electronic components from the United States to China with little regard for whether the parts they sold were export-controlled. In 2008, Defendants were arrested and later indicted for thirty-four counts of export-related offenses. The two were ultimately convicted of, among other things, exporting without a license items designated as defense articles on the U.S. Munitions List and items controlled under the Commerce Control List, conspiracy to violate the Munitions List and Commerce Control List restrictions, and conspiracy to file materially false Shipper's Export Declarations (SED) with the Commerce Department. On appeal, Defendants argued that the federal government's arms export control system constituted a regulatory scheme that violated the Due Process Clause. The First Circuit Court of Appeals (1) affirmed the Commerce Control List convictions and SED convictions, holding that the federal government's arms export control system does not violate the Fifth Amendment's Due Process Clause; and (2) vacated the Munitions List convictions, holding that the district court erred by not submitting to the jury an element of the offense, and the error was not harmless. Remanded. View "United States v. Wu" on Justia Law

A drug interdiction in Caribbean waters by the United States Coast Guard ended with the arrest and indictment of multiple defendants, including Appellant. The Coast Guard determined that the vessel was "without nationality" and subject to the jurisdiction of the United States under the Maritime Drug Law Enforcement Act (MDLEA). Appellant was convicted of possession with the intent to distribute more than 1140 pounds of cocaine and heroin while on board a vessel in violation of the MDLEA. On appeal, Appellant argued that Congress lacked the authority under the Piracies and Felonies Clause to criminalize drug trafficking on board a vessel in international waters under the MDLEA without requiring a nexus between the conduct and the United States. The First Circuit Court of Appeals affirmed, holding that any jurisdictional error under the MDLEA related to Appellant's conviction did not constitute plain error in this case. View "United States v. Nueci-Pena" on Justia Law

Defendant pled guilty to one count of importing codone. The guilty plea was based on an incident in which, based on tips from three confidential informants (CIs), federal agents apprehended Defendant at the Canadian border, handcuffed him to a hospital bed, and monitored Defendant's bowel movement, in which Defendant passed a condom containing 104 eighty-milligram and five forty-milligram oxycodone pills. The district court assigned Defendant a drug quantity equivalent to 2,637 eighty-milligram oxycodone pills based in part on uncharged conduct described by the CIs and sentenced Defendant to 108 months in prison. The First Circuit Court of Appeals affirmed, holding that the district court did not err in (1) denying Defendant's motion to force the government to disclose the CIs' names, as the court correctly weighed the correct factors in finding that the government's interest in preserving the CIs' anonymity tipped the scale against disclosure; and (2) calculating the drug quantity attributable to Defendant, as the CIs' statements were sufficiently reliable. View "United States v. Mills" on Justia Law

Defendant entered a plea of guilty to distributing cocaine base pursuant to a binding plea agreement. More than seven months later, Defendant filed a motion to vacate his guilty plea, which the district court denied. The court subsequently sentenced Defendant to serve ninety months in prison. Defendant appealed, arguing that his plea was neither voluntary nor knowing because he did not realize at the time he entered it that the sentencing guidelines were merely advisory. The First Circuit Court of Appeals affirmed, holding that the district court did not err in denying Defendant's motion to vacate his guilty plea, as (1) the proffered reason for revoking the plea was implausible; and (2) the waiver of appeal provision contained in the plea agreement was valid, and enforcement of the waiver would not result in a miscarriage of justice. View "United States v. Chambers" on Justia Law

After a jury trial, Defendant was found guilty of bank burglary. In sentencing Defendant, the district court applied a sentencing guideline intended for cases of robbery, rather than the burglary guideline Defendant proposed. The resulting sentence was roughly twice what it would have been under the burglary guideline. Defendant appealed, challenging the constitutionality of the district court's decision to sentence him under a guideline intended for robbery. Without reaching Defendant's constitutional claim, the First Circuit Court of Appeals remanded for resentencing because, under the sentencing guidelines and the introduction to the guidelines' statutory appendix, where the guidelines specify more than one offense guideline for a particular statutory offense and no plea agreement stipulates to a more serious offense, the district court must select the most appropriate guideline based only on conduct charged in the indictment. View "United States v. Almeida" on Justia Law

Plaintiff, an international affairs specialist at the Puerto Rico State Department, filed a complaint against the Department, ten of its employees, the Commonwealth (collectively, the State Department defendants), and the Puerto Rico Ports Authority. Plaintiff alleged that the State Department defendants had discriminated against her due to her political views and that they had denied her the rights and benefits to which she was entitled under federal and local law. As against the Ports Authority, Plaintiff alleged it slandered her by publishing false information regarding an arrest for marijuana, which prevented her from fulfilling her work duties. The district court found that Plaintiff's complaint failed to state a claim upon which relief could be granted and dismissed the complaint. Plaintiff appealed, requesting a reversal of the district court's refusal to grant leave to amend the complaint based upon its finding that amendment would be futile. The First Circuit Court of Appeals affirmed, holding that the district court did not abuse its discretion in denying the requested amendment. View "Flores-Silva v. McClintock-Hernandez" on Justia Law

Defendant was indicted for drug-trafficking charges. Through a succession of court-appointed attorneys, Defendant filed motions to suppress certain evidence and to dismiss the indictment on speedy trial grounds. The district court denied the motions, and Defendant entered a conditional guilty plea to the charges. Prior to sentencing, Defendant moved pro se to withdraw his guilty plea and requested a new court-appointed attorney, which the district court appointed. The court then rejected Defendant's motion and sentenced Defendant to 240 months in prison. The First Circuit Court of Appeals affirmed, holding that the district court (1) did not err in denying Defendant's motion to suppress; (2) did not err in refusing to dismiss the indictment on speedy trial grounds; (3) did not abuse its discretion in concluding Defendant had not shown a fair and just reason for withdrawing his guilty plea; and (4) did not err in sentencing Defendant. View "United States v. Gates" on Justia Law