Justia Civil Rights Opinion Summaries

An undercover United States Customs Task Force operation involving efforts on land, at sea, and in the air ended with the arrests of Defendants, Saturnino Tatis-Nunez, Cesar Hernandez-De la Rosa, Carols Espinal-Almeida, and Jacobo Peguero-Carela. Each defendant was indicted on, and ultimately convicted of, one count of conspiracy to possess with intent to distribute, and one count of conspiracy to import, 418 kilograms of cocaine. All Defendants appealed, raising a myriad of challenges that spanned jury voir dire to sentencing. After considering each claimed error, the First Circuit Court of Appeals affirmed Defendants' convictions and sentences, holding that none of Defendant's claims of error had merit. View "United States v. Espinal-Almeida" on Justia Law

Following a bench trial, Appellant was convicted of thirteen counts for crimes involving child pornography. Appellant appealed, challenging various rulings rulings by the district court before and after the trial. This case presented complex questions of first impression in the First Circuit regarding the admissibility of evidence in the wake of the Supreme Court's recent Confrontation Clause jurisprudence. After careful review, the First Circuit Court of Appeals concluded that the admission of certain evidence violated Appellant's Confrontation Clause rights, and the admission of this evidence was harmless as to some counts of conviction but not as to others. The Court thus reversed Appellant's convictions on certain counts and remanded for resentencing or a new trial. View "United States v. Cameron" on Justia Law

Appellant, a federal prisoner, appealed from the district court's denial of his 28 U.S.C. 2255 petition, which was largely focused on a variety of ineffective assistance of counsel claims. Appellant also appealed from the court's denial, as untimely, of his second motion to amend the petition. Appellant asserted on appeal that the second motion to amend was timely and that he should have been allowed to pursue a claim that he was improperly subject to sentencing as an armed career criminal because one prior offense was not a predicate in light of Johnson v. United States. The First Circuit Court of Appeals affirmed both decisions, holding (1) the second motion to amend did not raise an independent Johnson theory and thus the claim was forfeited; and (2) the second motion to amend was untimely. View "Turner v. United States" on Justia Law

Defendant defrauded a number of investors in a series of schemes that used the mails. All told, investors lost about six million dollars. Defendant also laundered money he received from the fraud by buying himself a $180,000 sport car. A federal jury convicted Defendant of seven counts of mail fraud and one count of money laundering. Defendant was sentenced to 192 months imprisonment and ordered to pay $6,030,145 in restitution and to forfeit certain property. The First Circuit Court of Appeals affirmed Defendant's convictions, denied his request for a new trial, and affirmed his sentence, holding (1) because the only identified error in evidentiary rulings was harmless, Defendant was not entitled to a new trial on the basis of cumulative error; and (2) the district court correctly calculated the number of victims and the amounts of forfeiture and of restitution. View "United States v. DeSimone" on Justia Law

Appellant was indicted in federal district court on two counts of being a felon in possession of firearms and ammunition. Appellant moved to suppress the ammunition as well as inculpatory statements he made in connection with his arrest. After an evidentiary hearing, the district court denied the motion. Appellant subsequently entered a conditional guilty plea on both counts, reserving his right to appeal the denial of his suppression motion. Appellant then appealed. The First Circuit Court of Appeals affirmed, holding that the district court properly declined to grant Appellant's suppression motion, as the stop that led to the discovery of the ammunition (1) was justified at its inception and did not constitute an unlawful seizure, and (2) was not transformed into a de facto arrest requiring Miranda warnings. View "United States v. Rabbia" on Justia Law

After they were fired from their jobs, Appellants filed suit in federal district court against their former employer (Employer) and against the severance plan (Plan) established by Employer pursuant to ERISA. The complaint asserted federal claims under ERISA, ADEA, ADA, and other federal laws, and also asserted a breach of contract claim, an employment discrimination claim, and an unjustified dismissal claim under Puerto Rico law. The district court granted Appellees' motion for summary judgment. Appellants challenged that ruling as well as a number of the district court's other orders. The First Circuit Court of Appeals affirmed, holding that there was no error in the management of this case or the grant of Appellees' motion for summary judgment. View "Cruz v. Bristol-Myers Squibb Co., PR, Inc." on Justia Law

A jury convicted Defendant of participating in an oxycodone distribution conspiracy, and he received a sentence of 210 months. On appeal, Defendant raised several challenges to his conviction and sentence, the most important of which was that the district court erred in refusing to suppress evidence that Drug Enforcement Administration (DEA) agents obtained from Defendant's cellular telephone, without a warrant, two weeks after they seized the phone. The First Circuit Court of Appeals affirmed, holding (1) any error on the suppression issue was harmless, and therefore the Court did not need to address whether the agents' activity was lawful under the Fourth Amendment; and (2) Green's other claims also lacked merit. View "United States v. Green" on Justia Law

Appellant sought review of his conviction on a charge of conspiracy to collect debts by extortionate means and collection of debts by extortionate means. On appeal, Appellant claimed (1) the trial was tainted by the trial judge's rulings relating to allegations of juror taint and by supposed mistakes in the judge's instructions - or failure to give instructions - to the jury; (2) the district court erred in instructing the jury on the elements of extortionate debt collection; and (3) the district court failed sua sponte to instruct the jury to disregard a specific sidebar exchange that Appellant claimed the jury overheard. The First Circuit Court of Appeals affirmed, holding that all of Appellant's claims failed on the merits. View "United States v. Dehertogh" on Justia Law

In this appeal from the denial of a preliminary inunction, plaintiff labor unions claimed that sections 6.007-.010 of Law 222, Puerto Rico's campaign finance law, placed an unconstitutional burden on the union's First Amendment right to engage in political speech. Both the district court and the government declined to address the merits of Plaintiffs' claims. The First Circuit Court of Appeals issued an appellate injunction enjoining enforcement of the challenged provisions of Law 222 pending the final disposition of this appeal. In this opinion the First Circuit outlined the reasons it ordered entry of the appellate injunction, holding, among other things, that it was incumbent upon the district court to engage with the merits of Plaintiffs' claims. The Court also ordered the district court to enter a preliminary injunction enjoining the enforcement of certain sections of the law. View "Puertorriqueno v. Fortuno" on Justia Law

Appellant was convicted for traveling in interstate commerce and then knowingly failing to update his sex offender registration at his destination as required by the Sex Offender Registration and Notification Act (SORNA). The district court sentenced Appellant to thirty-five months' imprisonment consecutive to his state sentence for violating probation by failing to update his Massachusetts sex offender registration. Appellant appealed his conviction and sentence, arguing, inter alia, that SORNA's registration requirements impermissibly increased his punishment for his earlier sexual offenses. SORNA was enacted in 2006. Appellant's previous offenses took place in 1990 and 1996. The First Circuit Court of Appeals affirmed, holding (1) SORNA does not violate the Ex Post Facto Clause; (2) SORNA does not reach beyond the limits of Congress' power under the Commerce Clause; (3) SORNA as applied to Appellant did not violate Appellant's due process rights; and (4) the district court did not abuse its discretion in deciding to make Appellant's sentence consecutive to, rather than concurrent with, his thirty-month sentence. View "United States v. Parks" on Justia Law