Justia Civil Rights Opinion Summaries

Plaintiff filed suit under 42 U.S.C. 1983, alleging First and Fourteenth Amendment violations concerning the rescission of a bid award for a potential, but unexecuted, insurance brokerage contract with the Puerto Rico government. The court affirmed the district court's grant of summary judgment on plaintiff's Fourteenth Amendment due process claim where he had no constitutionally protected property interest in the initial bid award; reversed the grant of summary judgment on plaintiff's First Amendment claim for political discrimination where there is a genuine issue of material fact as to whether plaintiff's political affiliation was a substantial or motivating factor for the adverse action; and remanded for further proceedings. View "Garcia-Gonzalez v. Puig-Morales" on Justia Law

Michael Dunn worked for Boston University (BU) from 1992 until 2010, at which time Dunn’s job was allegedly eliminated due to restructuring. Dunn brought suit against BU in Massachusetts superior court, claiming age discrimination in violation of both state and federal law. BU removed the case to federal district court. The district court granted summary judgment in favor of BU, concluding that Dunn had not made out a prima facie case that he was laid off because of his age. The First Circuit affirmed without ruling on the sufficiency of Dunn’s prima facie showing, holding that, even assuming that Dunn made a prima facie showing of age discrimination, Dunn failed to demonstrate a genuine issue of material fact as to whether BU’s stated reasons for discharging him were a pretext for unlawful discrimination. View "Dunn v. Trs. of Boston Univ." on Justia Law

After a jury trial, Defendant was convicted on three counts of distributing cocaine base. During trial, the court allowed testimony from a cooperating witness who purchased cocaine base from Defendant on three occasions, plus video and audiotapes of those transactions. The First Circuit affirmed the convictions, holding (1) the district court did not commit plain error in allowing the jury to review previously admitted audiotapes and video in the courtroom and in the presence of alternate jurors, the court, and the parties; (2) the district court did not commit plain error in failing to instruct the jury that it could not draw negative inferences from the fact that law enforcement officers possessed photographic images of Defendant; and (3) Defendant’s sentencing as a career offender did not violate the Sixth Amendment prohibition against judicial fact finding. View "United States v. Rodriguez" on Justia Law

Plaintiff filed a complaint against his employer, the U.S. Army, alleging that his direct supervisor harassed and discriminated against him on account of his disability. The Army dismissed the complaint as untimely, and the Equal Employment Opportunity Commission (EEOC) affirmed. Plaintiff subsequently filed a complaint with the district court, asserting discrimination, hostile work environment, and retaliation claims. The district court construed these claims as claims brought pursuant to the Rehabilitation Act. The district court found that Plaintiff’s administrative complaint was untimely filed and ordered that Plaintiff’s claimed be dismissed because Plaintiff failed to exhaust his administrative remedies and did not qualify for equitable tolling. The First Circuit affirmed the dismissal of Plaintiff’s claims, holding that the district court correctly found that Plaintiff’s administrative filing was untimely and did not abuse its discretion when it denied Plaintiff’s request for equitable tolling on the insufficiently supported basis of mental illness. View "Vazquez-Rivera v. Figueroa" on Justia Law

A civilian was shot without justification by an on-duty police officer, Javier Pagan-Cruz. Plaintiffs, the victim’s family, filed suit under 42 U.S.C. 1983 against Pagan, his two on-scene colleagues, and five supervisors for violating the victim’s Fourth Amendment rights by causing his wrongful death. The supervisory defendants filed a motion to dismiss under Fed. R. Civ. P. 12(c). The motion was granted in part and denied in part. The district court subsequently granted summary judgment to the supervisory defendants on the remaining claims against them. After a trial, the jury reached a verdict in favor of Plaintiffs against the remaining defendants. The First Circuit affirmed the grant of summary judgment against Plaintiffs’ supervisory liability claims against each of the supervisory defendants, holding that these defendants were not liable in this case under section 1983. View "Ramirez-Lluveras v. Rivera-Merced" on Justia Law

After a jury trial, Appellant was convicted of distributing cocaine. On appeal, Appellant argued that two instances of prosecutorial misconduct deprived him of a fair trial. The First Circuit affirmed the conviction, holding (1) the prosecutor erred during closing argument rebuttal by offering “overzealous and inappropriate” statements regarding the credibility of the government’s witnesses, thus improperly vouching for the prosecution’s investigation and witnesses; (2) the prosecutor erred during closing arguments by playing an audio recording for the jury that had not been entered into evidence; but (3) neither of the errors affected Appellant’s conviction. View "United States v. Rojas" on Justia Law

The Maine State Prison has a longstanding practice of issuing footlockers with padlocks to most inmates. Appellants, inmates in the Prison, were each seriously injured in assaults by other inmates who used prison-issued padlocks as weapons. Appellants filed complaints in federal district court alleging that the failure of Appellees, officials in the Maine Department of Corrections, to take adequate measures to protect inmates from padlock assaults violated Appellants’ Eighth Amendment rights. The district court dismissed the complaints on summary judgment, concluding that there existed no genuine dispute of material fact as to whether providing inmates with padlocks subjected Appellants to conditions posing a substantial risk of serious harm in violation of the Eighth Amendment. The First Circuit affirmed, holding that the small number of assaults involving the use of prison-issued padlocks, without more, was not sufficient to sustain the conclusion that providing the padlocks to inmates rose to the level of constitutional violation. View "Lakin v. Barnhart" on Justia Law

Appellant was charged with conspiracy to possess with intent to distribute, conspiracy to commit robbery affecting interstate commerce, and felon in possession of a firearm. Appellant subsequently pleaded guilty to all counts. The First Circuit Court of Appeals affirmed, holding (1) the district court did not abuse its discretion in failing to sua sponte order a hearing on the issue of Appellant’s competency; (2) the district court adequately assessed whether Appellant’s plea was knowing and voluntary within the meaning of Fed. R. Crim. P. 11; (3) Appellant’s counsel did not provide ineffective assistance; and (4) the district court did not err in imposing a ten-year mandatory minimum sentence on the drug conspiracy count. View "United States v. Kenney" on Justia Law

Robert Snyder operated a business in a building that he owned in the city of Waltham, Massachusetts. After Snyder fired an employee who served as a member of the Waltham city council, the former employee complained to the city building department that Snyder’s use of his building violated a local land use ordinance. Code enforcement officers investigated Snyder’s use of his property and fined him under the ordinance. Snyder contested the fines in the district court, alleging that the city and five individuals violated his rights to equal protection under the Fourteenth Amendment by singling him out for differential treatment for reasons unique to him. The defendants moved for summary judgment on the basis of qualified immunity. The district court denied the motion. The First Circuit Court of Appeals reversed the district court’s denial of the two defendants’ motion for summary judgment, holding that the local government officials did not violate any clearly established federal law, and therefore, the defendants were entitled to qualified immunity. View "Snyder v. Collura" on Justia Law

After a jury trial in federal district court, Petitioner was convicted of child pornography and sentenced to 180 months’ imprisonment. The First Circuit Court of Appeals affirmed Petitioner’s conviction and sentence. Petitioner subsequently filed a petition under 28 U.S.C. 2255 collaterally attacking his conviction on four grounds. The district court rejected the petition. The First Circuit affirmed the district court’s denial of Petitioner’s petition for collateral relief, holding (1) because Petitioner did not show any prejudice, his ineffective assistance of counsel claim failed; (2) any error that the district court made in excluding certain testimony did not have a substantial and injurious effect on the jury’s verdict; (3) the conduct underlying Petitioner’s conviction was not constitutionally protected; and (4) Petitioner’s argument that he was actually innocent failed. View "Ortiz-Graulau v. United States" on Justia Law