Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was convicted of one count of the crime of possession of a firearm by a felon. Defendant appealed the district court’s denial of his motion to suppress the evidence of a pistol found in his possession by state law enforcement authorities because it was obtained pursuant to an invalidated arrest warrant and in violation of his Miranda rights. The First Circuit Court of Appeals affirmed, holding that, pursuant to the good faith exception to the exclusionary rule articulated most recently in Herring v. United States, the evidence did not warrant exclusion because the officers acted in good faith and relied on a warrant that was facially valid at the time they detained Defendant. View "United States v. Echevarria-Rios" on Justia Law

After a jury trial, Appellant was convicted of aiding and abetting interference with commerce by threats of violence and using a firearm during the commission of a crime of violence. On appeal, Appellant argued, among other things, that the district court violated his Sixth Amendment right to counsel of choice because the court forbade him from retaining new counsel without giving him an opportunity to be heard on the issue. The First Circuit Court of Appeals agreed with Appellant and vacated his conviction, holding that the district court violated Appellant’s right to counsel when it forbade Appellant from retaining substitute defense counsel without conducting any inquiry into Appellant’s conflict with present counsel. View "United States v. Diaz-Rodriguez" on Justia Law

On February 26, 2010, Plaintiff, who worked for the Parole Board of Puerto Rico, was terminated pursuant to Law 7, which implemented a brute-force reduction in the size of the government to improve Puerto Rico’s dire financial straits. On February 3, 2011, the union to which Plaintiff belonged prevailed on its suit in which it sought to reinstate Plaintiff and other unionized Parole Board employees. Although Plaintiff was reinstated to her position, eight months later she sued the members of the body charged with implementing Law 7, alleging that they had deprived of her due process of law in violation of 42 U.S.C. 1983. The federal district court dismissed Plaintiff’s section 1983 claim with prejudice on the grounds that it was time-barred under the applicable statute of limitations. The First Circuit Court of Appeals affirmed the district court’s order of dismissal, holding that the court did not err in dismissing Plaintiff’s action. View "Alamo-Hornedo v. Puig" on Justia Law

Plaintiff was charged in state court with offenses related to the manufacture and possession of marijuana after a neighbor reported to the police that the door was wide open at Plaintiff’s vacant home, and the police entered the home. The charges were dropped when a state court judge suppressed the evidence found in Plaintiff’s home. Plaintiff subsequently sued the Town of Eastham, two police officers, and a crime-scene investigator who had assisted in the search in the federal district court, alleging, among other claims, that Defendants had deprived him of his Fourth Amendment rights in violation of 42 U.S.C. 1983. The district court dismissed the complaint, holding that the officers who searched Plaintiff’s home were entitled to qualified immunity. The First District Court of Appeals affirmed, holding that because there is no clearly established law that would deter reasonable police officers from affecting an entry such as the one in this case, the individual defendants were entitled to qualified immunity. View "Macdonald v. Town of Eastham" on Justia Law

Defendant confessed to participating in the arson of an African-American church following a seven-hour interrogation. Defendant was subsequently convicted in federal court of conspiracy against civil rights, damage to religious real property, and the use of a fire to commit a felony. Defendant appealed, arguing that the district court erred in denying his motion to suppress the incriminating statements made in his confession because they were obtained through agents’ coercive tactics and in violation of his right to prompt presentment. The First Circuit Court of Appeals affirmed, holding (1) under the circumstances of this case, the agents’ interrogative tactics did not amount to coercion in violation of Defendant’s Fifth Amendment rights; and (2) Defendant’s interrogation did not violate his right to prompt presentment. View "United States v. Jacques" on Justia Law

Plaintiff was a real estate broker in Puerto Rico who was a vocal critic of the Puerto Rico Real Estate Examining Board. After the Board denied Plaintiff’s application for a license to establish a bilingual real estate school, Plaintiff filed suit against the Board and several individuals associated with it, claiming that the Board denied her a license in retaliation for her public criticism of the Board, thereby violating her First Amendment rights. The district court dismissed the complaint for failure to state a claim upon which relief could be granted, concluding that the Board had a legitimate non-discriminatory reason - the tardiness of Plaintiff’s application - for rejecting the application. The First Circuit Court of Appeals reversed vacated the district court’s judgment, holding that Plaintiff’s allegations plausibly stated a claim under 42 U.S.C. 1983. Remanded. View "Maloy v. Ballori-Lage" on Justia Law

Plaintiffs, committed animal rights activists, filed this action seeking declaratory and injunctive relief that the Animal Enterprise Terrorism Act (“Act”), which criminalizes “force, violence, and threats involving animal enterprises,” violates the First Amendment. Plaintiffs had never been prosecuted or threatened with prosecution under the Act but claimed that fear of future prosecution and present self-restraint caused them to suffer injury in fact. The district court dismissed the complaint, holding that Plaintiffs failed to establish an injury in fact as required by Article III. The First Circuit Court of Appeals affirmed, holding that Plaintiffs’ unsubstantiated and speculative fear of prosecution under the Act was not a basis for standing under U.S. Const. art. III. View "Blum v. Holder" on Justia Law

A law enforcement officer placed a GPS device on Defendant’s vehicle without a warrant and used that device to track Defendant’s movements for forty-seven days. The GPS monitoring ultimately led to Defendant being charged with, and pleading guilty to, possessing and conspiring to possess heroin with the intent to distribute it. After Defendant moved to suppress the evidence obtained as a result of the warrantless GPS monitoring, the Supreme Court decided United States v. Jones, which held that the installation and use of a GPS tracker on an automobile constitutes a Fourth Amendment search. The district court denied Defendant’s motion to suppress, determining that the exclusionary rule should not apply in this case because the officers had relied in good faith on pre-Jones legal precedent. Before the parties briefed the case on appeal, the First Circuit Court of Appeals decided United States v. Sparks, in which the Court held that eleven days of pre-Jones warrantless GPS tracking fell under the good-faith exception to the exclusionary rule. The First Circuit affirmed, holding that, for the reasons articulated in Sparks and United States v. Baez, another case decided today, the exclusionary rule applied to the officers’ warrantless GPS monitoring of Defendant's vehicle. View "United States v. Oladosu" on Justia Law

Defendant pled guilty to four counts of arson. On appeal, Defendant argued that the district court erred by denying his motion to suppress evidence that the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) obtained by monitoring his automobile using a global positioning system (GPS) device. The ATF began the GPS tracking, without a warrant, in August 2009 and continued for nearly one year. After Defendant filed his notice of appeal, the First Circuit Court of Appeals decided United States v. Sparks, in which the Court held that the warrantless installation of a GSP device on a defendant’s car and the use of that device to monitor the defendant’s movements for eleven days fell within the good-faith exception to the exclusionary rule because the monitoring had occurred before the U.S. Supreme Court decided United States v. Jones, which held that the installation and use of a GPS tracker on an automobile constitutes a Fourth Amendment search. In the instant case, the First Circuit affirmed the denial of Defendant’s suppression motion, holding that this case fell within the rule laid out in Sparks, although the pre-Jones warrantless GPS tracking was of a significantly longer duration than that in Sparks. View "United States v. Baez" on Justia Law

Harold Evans-Garcia and Eric Joel Carrion-Cruz (together, Defendants) were each convicted of a carjacking resulting in death and sentenced to life imprisonment without the possibility of parole. Both Defendants committed the crimes when they were younger than eighteen years old. Each of them unsuccessfully appealed and petitioned for habeas relief. Subsequently, the U.S. Supreme Court decided Miller v. Alabama, in which the Court held that the Eighth Amendment to the U.S. Constitution forbids a sentencing scheme that mandates life imprisonment without the possibility of parole for juvenile offenders. Thereafter, Defendants sought certification to pursue a new habeas petition to secure a potential reduction in their sentences pursuant to Miller. The First Circuit Court of Appeals granted certification to Evans-Garcia but denied it to Carrion-Cruz, holding (1) Evans-Garcia made a prima facie case showing that the new rule announced in Miller qualified as a basis for habeas relief on a second or successive petition; but (2) Carrion-Cruz’s request must be denied because he was not sentenced pursuant to any statute or guideline that mandated a sentence of life without parole. View "Evans-Garcia v. United States" on Justia Law