Justia Civil Rights Opinion Summaries

In 1982, Jimenez was convicted of the parolable offense of second degree murder for killing a police officer and simultaneously acquitted of murder in the first degree, conviction of which would have carried no possibility of parole. The Massachusetts Parole Board denied his parole applications in 1999, 2004, and 2009. He sued under 42 U.S.C. 1983, claiming violations of due process and equal protection and infringements of guarantees under the Commonwealth's constitution. The defendants are the six members of the Board, named in their official capacities, each of whom voted to deny parole. The district court dismissed for failure to state a claim for constitutional violations, finding specific relief barred by the section 1983 prohibition of injunctions against judicial officers. The First Circuit affirmed. There is nothing shocking or arbitrary about the parole board’s discretion. A state may rationally take the position that a law enforcement officer’s constant exposure to violence calls for a more powerful deterrent to homicidal behavior than the general laws of homicide provide.

Defendant, convicted of first degree murder in Massachusetts, exhausted state appeals. No physical evidence linked him to the crime, but circumstantial evidence included his threats to kill the victim, testimony that the victim was last seen getting into a car with defendant, and defendant’s statements indicating guilt. The district court rejected his habeas corpus petition, 28 U.S.C. 2254 petition, which was based on an argument that the Massachusetts Supreme Judicial Court applied a beyond a reasonable doubt standard contrary to that articulated by the Supreme Court in Jackson v. Virginia, 443 U.S. 307 (1979), in evaluating his claim that there was insufficient evidence presented at trial to support his conviction or incorrectly applied the correct standard. The First Circuit affirmed, holding that there was sufficient evidence to support the conviction.

UPRLS hired plaintiff as an assistant professor, with possibility of tenure after five years. During her probation, plaintiff, with a male professor, worked in the school's Legal Aid Clinic. Plaintiff's co-teacher had a sexual relationship with a student, who became pregnant as a result. Near the end of her probation, plaintiff requested a one-year extension. The dean questioned plaintiff about her knowledge of the relationship between her co-teacher and the pregnant student and chastised her for failing to report. There was no internal regulation prohibiting student-teacher relationships or mandating reporting. The Dean recommended the extension, but added comments questioning her judgment and maturity. When plaintiff learned of these comments, she wrote to the Chancellor and others, denouncing the comments. The dean reversed his position. A committee was formed and voted to deny the extension. After obtaining a right-to-sue letter from the EEOC, plaintiff sued UPRLS and individuals, alleging gender-based discrimination and retaliation under the Civil Rights Act, 42 U.S.C. 2000e-2(a), 2000e-3(a). The district court dismissed. The First Circuit affirmed. The allegations did support a reasonable inference that plaintiff was engaging in protected conduct when she opposed the dean’s remarks or that defendants’ actions were based on gender.

Petitioner, an Orthodox Jew, is serving a life sentence for murder without the possibility of parole, sought a transfer back to the prison in which he was previously held. Before the transfer, he regularly participated in Jewish religious activities, followed dietary restrictions, and met individually with a visiting rabbi. After the transfer to a prison in a less-populated area, the prison chaplain made efforts, largely fruitless, to provide Jewish services. Only one other practicing Jewish inmate was housed at the facility. The district court denied a preliminary injunction under the Religious Land Use and Institutionalized Persons Act, 42 U.S.C. 2000cc. The First Circuit affirmed. Petitioner's disadvantages depend importantly on proximate actions and decisions not attributable to the government and are too attenuated from the transfer decision to be considered government imposed burdens under RLUIPA. He was not transferred for the purpose of restricting his religious opportunities or in retaliation for the exercise of his First Amendment rights.

Plaintiff, a police department employee, made claims of sexual harassment and emotional abuse. The district court issued a scheduling order, closing discovery as of November 18, 2010. When defense counsel encountered an emergency, the court reset the date to January 28, 2011. In November, defendants served plaintiffs with interrogatories and requests for production of documents. The court extended discovery closure date to February 28, 2011. On February 24, plaintiffs moved to extend this deadline by 30 days, claiming that their lawyer had no time to devote to their case. The court extended the discovery closure date to March 25, but stated that plaintiffs must provide answers to outstanding interrogatories and requests for production of documents no later than February 28 and that failure to answer by that date would result in dismissal, with prejudice. On March 1, defendants informed the court that plaintiffs had not complied. The court extended the deadline by 10 days. On March 16, defendants informed the court that the interrogatories remained unanswered and that the documents had not been produced. The next day the court dismissed the action with prejudice. The First Circuit affirmed.

Plaintiff began working for the police department in 1986. Although he was a member of NPP, one of Puerto Rico's two major political parties, he received promotions while NPP's main rival, PDP, dominated the executive branch. In 2008, he was promoted to the rank of Commander. His career path became rocky when his party, NPP, won the 2008 general election. New leadership eliminated unspecified duties, retrieved his official cellphone and departmental car, evicted him from his office, and reassigned him to mundane tasks that he viewed as beneath the dignity of his rank. He was not discharged nor stripped of rank, and he did not allege that his compensation was diminished. The district court dismissed his suit under 42 U.S.C. 1983. The First Circuit affirmed, finding no plausible claim of political discrimination. Plaintiff did not allege deprivation of a constitutionally protected interest.

A disabled child, born in 1996, was a student in the Sutton public school system from 1999 until 2005, when his parent were dissatisfied with the individualized education program developed under the Individuals with Disabilities Education Act, 20 U.S.C. 1400-1491, and the services he was receiving. They removed him from the school and enrolled him in a private learning center. The Massachusetts Bureau of Special Education Appeals determined that the 2005 IEP complied with the IDEA. The district court upheld the decision on summary judgment. The First Circuit affirmed, rejecting an argument that the court could not determine compliance without first determining the child's potential for learning and self-sufficiency. The district court properly concluded that the child's potential was unknowable and that the IEP was reasonably calculated to confer educational benefits. The parents did not raise triable claims under the First Amendment, the Rehabilitation Act of 1973, Titles II and V of the Americans with Disabilities Act, or 42 U.S.C. 1983 and 1985; plaintiffs “cannot disguise an IDEA claim in other garb.”

Plaintiff began working as a letter carrier in 1980. In 1987, she tripped at work and injured her back. Her workers' compensation claim was allowed and she began to work four hours a day instead of eight. Plaintiff could walk, sit, and stand for up to one hour continuously or up to four hours intermittently. After a 2003 medical exam, plaintiff declined to agree to work five hours and, feeling that her supervisor had bullied her, filed an EEOC complaint. An ALJ ruled in favor of the Postal Service; the EEOC Office of Federal Operations affirmed. In 2008, she sued, alleging: hostile work environment harassment based on disability (Rehabilitation Act, 29 U.S.C. 794(a)); retaliation in violation of the Rehabilitation Act; failure to accommodate a disability in violation of the Rehabilitation Act; hostile work environment harassment based on gender (Title VII of the Civil Rights Act, 42 U.S.C. 2000e-16); and retaliation in violation of Title VII. The district court entered summary judgment for the Postmaster General. The First Circuit affirmed, reasoning that plaintiff was able to do her job and that she was not regarded as disabled.

PBA is a commonwealth-created public corporation that plans and maintains of physical facilities related to government services. During a reorganization, PBA's board eliminated some positions and created new ones. Plaintiff, a member of the NPP, one of Puerto Rico's two main political parties, applied for three PBA jobs after his position was eliminated. Those who interviewed him were PDP (the other political party) sympathizers. Plaintiff was offered one of the jobs, but considered it a demotion. He was reclassified, like many PBA staffers in both political camps. While his suit under 42 U.S.C. 1983, 1985, and 1988 was pending, plaintiff was promoted into another PBA position. The district court entered summary judgment for defendants. The First Circuit affirmed, noting that plaintiff had no property interest in his particular job functions and that there was no evidence that the reorganization decisions were based on loyalties to political parties.

Defendant was 16 years old at the time of the 1986 shooting deaths of two men, but after a hearing in juvenile court, he was transferred for adult criminal proceedings. His first conviction was vacated in 1992. He was convicted again in 1994, and sentenced to life imprisonment. The state supreme court affirmed the juvenile court's transfer decision, his conviction, and his life sentence. In 1999, he filed a motion for a new trial, asserting ineffective assistance of counsel. The trial court rejected the motion and the supreme court affirmed. In 200 he filed a federal petition for habeas corpus. The district court denied the petition. The First Circuit affirmed, stating that it is barred from reviewing the state court decision because it rests on an independent and adequate state ground.