Justia Civil Rights Opinion Summaries

After a jury trial in the U.S. District Court, Appellant was convicted of possession of a firearm by a convicted felon and possession of a firearm with an obliterated serial number. Prior to trial, Appellant unsuccessfully moved to suppress incriminating statements he made to police over the course of several encounters, arguing that any waiver of his Miranda right to remain silent was a product of threats and coercion. On appeal, Appellant contended that the district court failed to instruct the jury, under 18 U.S.C. 3501(a), to “give such weight to the confession as the jury feels it deserves under all the circumstances.” The First Circuit Court of Appeals affirmed, holding (1) there was no meaningful difference between the instruction called for by section 3501 and the instruction given at Appellant’s trial; and (2) even if courts should follow more closely the precise language of section 3501, any error on the court’s part to do so in this case went unchallenged and was unlikely to have affected the outcome of Appellant’s trial. View "United States v. Colon" on Justia Law

After a jury trial in state court, Petitioner was found guilty of first-degree murder and sentenced to life imprisonment. After the Supreme Judicial Court affirmed on direct appeal, Petitioner filed a petition for habeas corpus in the federal district court, asserting (1) insufficient evidence supported his conviction; and (2) because the prosecutor argued at Petitioner’s state-court trial that Petitioner had shot and killed the victim but, at an earlier state-court trial, argued that Petitioner’s accomplice had shot and killed the victim, the prosecutor’s inconsistent approaches deprived him of his due process rights. The district court denied the petition. The First Circuit Court of Appeals affirmed, holding (1) the evidence presented in Petitioner’s state-court trial was adequate to support his conviction; and (2) the prosecution of Petitioner and his accomplice in different trials on materially inconsistent theories of guilt did not violate due process, as (i) state law permitted such a course of action, (ii) any potential inconsistency in result between Petitioner’s and his accomplice’s cases had been remedied by the time the Supreme Court heard Petitioner’s appeal, and (iii) the Commonwealth did not unfairly manipulate the evidence. View "Housen v. Gelb" on Justia Law

After Plaintiff applied unsuccessfully to be a firefighter in the Puerto Rico Firefighters Corps of the Commonwealth of Puerto Rico (“the Corps”) Plaintiff sued the Commonwealth, claiming that the Corps refused to hire her because of her gender. The parties eventually signed a settlement agreement pursuant to which the Corps agreed to employ Plaintiff as a transitory firefighter until the next training academy was held and to hire Plaintiff as a firefighter if she graduated from the academy. Thereafter, Plaintiff again sued the Corps, alleging that, during her transitory employment, the Corps subjected her to abuse in retaliation for her earlier suit. The district court dismissed Plaintiff’s complaint for failure to state a claim. Plaintiff appealed the dismissal of her claim for unlawful retaliation. The First Circuit Court of Appeals vacated the district court’s order, holding that Plaintiff’s complaint stated a plausible claim of unlawful retaliation in violation of Title VII of the Civil Rights Act. Remanded. View "Rodriguez-Vives v. P.R. Firefighters Corps" on Justia Law

After a jury trial, Petitioner was found guilty of second-degree murder. Petitioner’s conviction was affirmed on appeal by the state court. Petitioner subsequently sought a writ of habeas corpus in the federal district court, which denied habeas relief but issued a certificate of appealability as to three claims. The First Circuit Court of Appeals affirmed, holding (1) the state court did not abuse its discretion in concluding that the evidence adduced at trial was sufficient to support Petitioner’s conviction for second-degree murder; (2) the state court did not abuse its discretion when it declined to find a due process violation based on the unavailability of the victim’s larynx; and (3) the state court’s determination that certain statements made by the prosecutor did not constitute prosecutorial misconduct sufficient to warrant setting aside Petitioner’s conviction was not an unreasonable application of the law. View "Magraw v. Roden" on Justia Law

After a jury trial, Appellant was convicted of possessing with intent to defraud counterfeit United States currency. The First Circuit Court of Appeals affirmed the conviction, holding that the district court did not err in (1) admitting evidence seized by police during and after Appellant’s arrest ensuing from the officers’ investigative stop, as the officers had a reasonable suspicion of criminal activity sufficient to justify their actions; (2) denying Appellant’s motion for a judgment of acquittal, as sufficient evidence supported Appellant’s intent to defraud; and (3) issuing a jury instruction on the statutory element of fraudulent intent, as the instructions issued in this case were neither incorrect on the law nor unfairly prejudicial in favor of the government. View "United States v. Silva" on Justia Law

Plaintiff filed an action against her former employer (Employer) for violations of Title VII, 42 U.S.C. 2000e et seq., and Mass. Gen. Laws ch. 151B, alleging that she was subject to sexual harassment while working for Employer and that she was terminated in retaliation for reporting the harassment. The district court granted summary judgment in favor of Employer. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in concluding that no reasonable juror could conclude that Plaintiff was subjected to sexual harassment while an employee for Employer; and (2) even if Plaintiff had made a prima facie case of retaliation, which she did not, Plaintiff did not meet her burden of showing that Employer’s legitimate, non-retaliatory reason for the termination was mere pretext. View "Ponte v. Steelcase Inc." on Justia Law

This matter began in a New Hampshire family court (“Family Court”) in 2006 and involved Plaintiff’s support obligations to his former wife and son. Due to Plaintiff’s financial evasiveness, the Family Court appointed a commissioner (“Commissioner”) to investigate and report Plaintiff’s gross income from 2006 forward. The Commissioner found Plaintiff’s income was higher than what Plaintiff had previously represented to the court. Consequently, the Family Court held Plaintiff in contempt for failure to pay past-due child support obligations and entered judgment in favor of Plaintiff’s ex-wife. The New Hampshire Supreme Court (NHSC) denied Plaintiff’s discretionary appeal. Plaintiff subsequently filed a complaint in the U.S. District Court seeking to enjoin the orders of the Family Court on constitutional grounds and to reverse the NHSC’s denial of his discretionary appeal. Plaintiff also asserted various claims against the Commissioner. The district court’s dismissed all of Plaintiff’s claims. The First Circuit Court of Appeals affirmed, holding (1) N.H. Sup. Ct. R. 3, which classifies appeals from child support orders as discretionary, does not violate the due process and equal protection clauses of the U.S. Constitution; and (2) the Commissioner was immune to suit for his acts as Commissioner in the matter. View "D'Angelo v. N.H. Supreme Court" on Justia Law

Plaintiff, the former captain of a village fire department, filed this action against the department, its fire chief, and the board of fire commissioners (collectively, Defendants) after the board chose to terminate Plaintiff’s employment. Plaintiff alleged political discrimination in violation of the First Amendment and 42 U.S.C. 1983, retaliation in violation of the Massachusetts Whistleblower Act, and tortious interference with contractual relations. The district court granted summary judgment for Defendants on all counts. The First Circuit Court of Appeals affirmed, holding that Defendants presented legitimate, business-related grounds for their employment decisions, and Plaintiff failed to demonstrate that the proffered explanations were pretextual. View "Pierce v. Cotuit Fire Dist." on Justia Law

Appellant filed an action against her former employer, The Children Place (TCP) and the TCP district manager (collectively, Appellees), alleging that she was fired, harassed, and not rehired on the basis of race. The district court granted summary judgment in favor of Appellees. The First Circuit Court of Appeals affirmed, holding (1) the district court did not abuse its discretion when it denied three of Appellant’s discovery-related motions; and (2) the district court did not err by granting Appellees’ motion for summary judgment as to (i) Appellant’s claims of race discrimination where Appellant was unable to rebut Appellees’ legitimate, nondiscriminatory basis for her termination with evidence of pretext and discriminatory motive, and (ii) Appellant’s retaliation claim in light of her failure to establish a prima facie case. View "Pina v. Children's Place" on Justia Law

Sixty-four-year-old Plaintiff was born anatomically male but suffered from severe gender identity disorder. In 1992, Plaintiff was convicted of murder and sentenced to life imprisonment. In 2000, Plaintiff filed a complaint against the Massachusetts Department of Correction (DOC), alleging that the DOC was denying her adequate medical care by not providing her with sex reassignment surgery. The district court subsequently issued an order requiring the Commissioner of the DOC to provide Plaintiff was sex reassignment surgery, finding that the DOC’s failure to provide the surgery violated Plaintiff’s Eighth Amendment rights. The DOC appealed. The First Circuit Court of Appeals affirmed, holding that the district court did not err in finding that Plaintiff had a serious medical need for sex reassignment surgery and that the DOC refused to meet that need for pretextual reasons unsupported by legitimate penological considerations in violation of Plaintiff’s Eighth Amendment rights. View "Kosilek v. Spencer" on Justia Law