Justia Civil Rights Opinion Summaries

Defendant, convicted of second-degree murder for the death of his two-week-old son after admitting to shaking the baby, obtained a reduction to involuntary manslaughter, but the Massachusetts Supreme Judicial Court reinstated the original verdict. The federal district court dismissed a habeas corpus petition. The First Circuit affirmed. The state court's conclusion that admission of the autopsy photographs was proper was not so arbitrary or capricious as to be an unreasonable application of clearly established federal law.

In 2003, the New Hampshire Department of Health and Human Services and a certified class of Medicaid-eligible children reached a settlement agreement and proposed a consent decree that outlined the Department's obligations to provide dental services to Medicaid-enrolled children in accordance with federal law. The district court approved the Decree in 2004. Between 2007 and 2010, the district court denied four motions alleging that the Department was not in compliance. The First Circuit affirmed, upholding the district court's requirement that the Class to file a motion for contempt to enforce the Decree; denial of a 2010 motion for contempt; denial of a request for an evidentiary hearing in 2010; and holding the Class to a clear and convincing burden of proof on its 2010 motion to modify or extend the Decree.

Maine has two procedures for involuntary psychiatric hospitalization. Section 3863 provides for temporary hospitalization without an adversary proceeding. For full-scale commitments Section 3864 requires a traditional adversary proceeding,culminating in a determination of whether the subject both is mentally ill and poses a danger to himself or others. Section 3864 commitment causes a loss of the right to possess firearms. Both defendants were hospitalized under section 3863. Each was indicted for possession of a gun following section 3863 hospitalizations. The district court denied their motions to dismiss, which argued Second Amendment right to bear arms and Fifth Amendment due process rights. The First Circuit reversed. The statutory bar to possession applies only to a person "who has been adjudicated as a mental defective" or "has been committed to a mental institution," and Section 3863 does not satisfy that definition.

Plaintiff, a tenured professor at the University-defendant, was arrested by campus police and charged with stalking and disorderly conduct after unleashing an expletive-filled tirade against a colleague whom he suspected of causing him to receive a parking ticket. Plaintiff was temporarily banned from campus, removed as department head, and required to attend an anger-management class. Although the charges were later dismissed, Collins sued for false arrest, defamation, and violation of his due process rights. The district court granted judgment for the defendants. The First Circuit affirmed, first rejecting an argument that the arrest was illegal because the "violation" was civil in nature. The warrant was supported by probable cause. Suspension with pay for two months was a minimal deprivation that did not entitle plaintiff to pre-deprivation process. Plaintiff was allowed to visit campus several times during the ban and was given adequate process for the minimal deprivation of liberty. An email indicating that plaintiff's presence on campus should be reported was not defamatory.

In 1981 defendant, a habitual sex offender, was sentenced to a term of perpetual imprisonment for rehabilitation, to last a minimum of 12 years. He was not released from prison until 2008. The district court dismissed his suit under 42 U.S.C. 1983. The First Circuit affirmed. The defendants, high-level government officials, enjoyed immunity. Defendant's general claims of failure to supervise did not state a claim; there was no evidence that specific defendants were even aware of his continuing incarceration.

In 2002 defendant was convicted under the Massachusetts aggravated rape statute, Mass. Gen. Laws ch. 265, 22(a). He exhausted state appeals. The district court denied a petition for habeas corpus. The First Circuit affirmed, rejecting a claim that the statute was void for vagueness as applied to the case, for failure to define "resulting in serious bodily injury." It was reasonable for the state court to conclude that the phrase was not a technical term and could be understood by non-lawyers.

Convicted of armed robbery of a convenience store, assault and battery, and intimidation of a witness, petitioner was sentenced to five to six years. His habeas corpus petition was denied in the district court. The First Circuit affirmed. The state appeals court's determination that a rational juror could have found that petitioner possessed a weapon at the time of the robbery was not objectively unreasonable, based on his words, "I'll blow you away," while holding his hand in his jacket, suggestive of a gun. Petitioner's statement, to a victim, that he would come back and kill him if he saw him on the news, was sufficient to support conviction for witness intimidation. The court noted that petitioner had beaten the victim, taken the victim's bicycle, and demanded that the victim give him the security tapes.

The airline sued federal employees, including an FAA principal maintenance inspector, claiming that intentional and improper delays with respect to inspections and certifications substantially destroyed its business. The district court dismissed most claims, but did not dismiss "Bivens" claims of violation of procedural due process rights and of retaliation for protected First Amendment activity. The First Circuit reversed, holding that the allegations were not sufficient to support denial of qualified immunity.

Plaintiff was employed as a custodial worker at a Coast Guard Air Station in Puerto Rico for four and one half years before being fired for allegedly pilfering various items. He filed suit against the federal government under the Federal Tort Claims Act, 28 U.S.C. 1346(b), 2671 , and the Administrative Procedure Act, 5 U.S.C. 701, alleging constitutional violations and negligence. The district court dismissed. The First Circuit affirmed. State law is the source of substantive liability under the FTCA; the Act does not waive immunity for constitutional tort claims. The district court, therefore, lacked subject matter jurisdiction.

DEA agents and local police went to a residence with a warrant to arrest a drug dealer, but no warrant to search. When the owner opened the door, they entered and spent 15-20 minutes questioning the owner's wife and looking for the drug dealer, who was not in the house. Agents seized a vehicle that had been used in a drug deal. The district court rejected Fourth Amendment claims, citing qualified immunity, and claims under the Federal Tort Claims Act, 28 1346(b), 2671-2680. The First Circuit affirmed. The agents' actions were not manifestly unreasonable.