Justia Civil Rights Opinion Summaries

Defendant was convicted on charges of conspiracy and tax evasion. Defendant appealed, arguing that the district court erred in (1) denying his motion to suppress because the premises search conducted by armed agents of the Internal Revenue Service was unlawful, and (2) instructing the jury. The First Circuit Court of Appeals affirmed the district court’s judgment, holding (1) the district court did not err in refusing to grant Defendant’s motion to suppress, as the performance of the search by armed agents did not constitute an unreasonable intrusion into Defendant’s dwelling where the agents entered the home and conducted the search pursuant to a warrant; and (2) the district court properly instructed the jury. View "United States v. Adams" on Justia Law

After a jury trial, Defendants, Catherine Floyd and William Dion, were convicted of conspiracy to defraud the United States of payroll and income taxes and endeavoring to obstruct and impede the Internal Revenue Service (IRS). The First Circuit Court of Appeals affirmed, holding (1) there was sufficient evidence to support the convictions; (2) the district court did not err in failing to suppress certain evidence; (3) the district court did not err in denying Defendants’ motions for severance and in trying Defendants jointly with their coconspirator; (4) Defendants’ claim that the IRS’s failure to comply with the Federal Register Act engendered dismissal of some of the charges was without merit; and (5) the district court did not err in sentencing Dion. View "United States v. Dion" on Justia Law

After a jury trial, Defendant was convicted of producing, possessing, and distributing child pornography. Defendant was sentenced to 340 months of imprisonment followed by fifteen years of supervised release. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in applying the exception to the marital communications privilege for offenses committed against the child of either spouse to certain statements Defendant made to his former wife and in admitting the former wife’s testimony regarding the statements; (2) the district court did not err in admitting file and chat room names that were suggestive of child pornography where no images were recovered; (3) the evidence was sufficient to sustain all three charges; and (4) under the applicable United States Sentencing Guidelines, the sentence imposed in this case was both procedurally and substantively reasonable. View "United States v. Breton" on Justia Law

After a jury trial in a Massachusetts state court, Petitioner was convicted of second-degree murder and sentenced to life imprisonment. The Massachusetts Appeals Court (MAC) affirmed. The federal district court granted Petitioner’s petition for a writ of habeas corpus by reaching the merits of Petitioner’s arguments on its own without deferring to the state court decision as required by the Antiterrorism and Effective Death Penalty Act, concluding (1) the MAC did not adjudicate Petitioner’s due process claims as presented at trial on the merits, and (2) constitutional error on the part of the trial court was not harmless. The First Circuit Court of Appeals reversed the petition for habeas corpus relief, holding (1) although the MAC did not expressly discuss Petitioner’s arguments regarding the admissibility of evidence under Chambers v. Mississippi, the MAC correctly rejected the argument on the merits; and (2) to the extent the MAC found in a footnote that Petitioner asserted on appeal a new third-party culprit theory of admissibility that was never raised in the trial court, review of the third-party culprit theory was procedurally barred. View "Hodge v. Mendonsa" on Justia Law

Defendants pleaded guilty to conspiracy to possess, possession of, and use of counterfeit access devices. Defendants appealed the denial of their motion to suppress evidence obtained in connection with the stop and search of their vehicle, arguing (1) law enforcement officers lacked reasonable suspicion for the stop; (2) the warrantless search of the vehicle and the ensuing search warrant obtained for the vehicle were not based on probable cause; (3) law enforcement violated the Fifth Amendment by failing to inform Defendants of their Miranda rights; and (4) evidence and statements obtained through the stop and interrogation should be suppressed as fruits of the poisonous tree. The First Circuit Court of Appeals affirmed, holding (1) the stop of Defendants' vehicle did not violate the Fourth Amendment, and accordingly, the warrant issued for the search of the vehicle was not tainted by an illegal stop; (2) Defendants could not object to the search or seek suppression of the evidence obtained in the search because they failed to establish they had a reasonable expectation of privacy in the vehicle searched after the stop; and (3) the admission of statements obtained through the questioning of Defendants did not violate the Fifth Amendment. View "United States v. Campbell" on Justia Law

Defendants in this consolidated appeal were gang members who were involved in a deadly drug conspiracy in Puerto Rico. Each Defendant was indicted for conspiring to possess and distribute illegal drugs within 1,000 feet of a public-housing facility, and three of the five defendants were indicted for aiding and abetting the use or carrying of a firearm during and in relation to a drug crime or the possession of a firearm in furtherance of that crime. After a jury trial, each defendant was essentially found guilty as charged. Only one defendant was found not guilty of participating in drug-related conspiracy activities within 1,000 feet of a public-housing project. Defendants' appeals raised numerous issues, which the First Circuit Court of Appeals sorted out person by person. In summary, the First Circuit affirmed the district court's judgment in all respects, holding that Defendants were "lawfully tried, convicted, and sentenced." View "United States v. Acosta-Colon" on Justia Law

Plaintiff brought several claims against Defendant, her former employer. Several claims were dropped or dismissed, and only two discrimination claims went to trial. Plaintiff obtained a jury verdict in her favor on her state law claim. Plaintiff subsequently sought reasonable attorney's fees and costs. The district court reduced Plaintiff's fees to account for time counsel spent on Plaintiff's unsuccessful claims. The court then made a second reduction to account for Plaintiff's rejection of a settlement offer. The First Circuit Court of Appeals set aside the second reduction. On remand, Plaintiff filed two Fed. R. Civ. P. 60(a) motions to correct the judgment. The district court granted the second motion and proportionately reduced Plaintiff's lodestar only to the extent that fees were incurred when some or all of the unsuccessful claims remained pending. The First Circuit affirmed, holding that the district court (1) was not precluded from granting Plaintiff's Rule 60(a) motion by the mandate rule; (2) did not disobey the remand order; and (3) did not abuse its discretion in awarding fees allegedly disproportionate to the damages that Plaintiff recovered. View "Diaz v. Jiten Hotel Mgmt., Inc." on Justia Law

For several years, Defendant was engaged in a fraudulent scheme to obtain computer parts from several computer companies. After obtaining the computer parts, Defendant sold the parts online for profit. After a jury trial, Defendant was convicted of wire fraud, possession of stolen property, and aggravated identity theft. The First Circuit Court of Appeals affirmed the convictions, holding (1) the district court did not err in denying Defendant's motion to suppress the fruits of a search warrant on the basis that it violated the Fourth Amendment's particularity requirement; and (2) the evidence was sufficient to convict Defendant of aggravated burglary theft, and therefore, the district court did not err in denying Defendant's motion for a judgment of acquittal. View "United States v. Kuc" on Justia Law

After a jury trial, the jury returned a conviction finding Defendant guilty of wire fraud and mail fraud. The district court upset the conviction and ordered a new trial, concluding that the government's closing argument was improper and may have tainted the jury's verdict. When the case was retried, the jury again convicted Defendant of the charges. The district court again granted a new trial, determining that the government's different closing argument led the jury to convict on an improper basis. The First Circuit Court of Appeals reversed and reinstated the jury's verdict of conviction, holding that the government's comments in its closing argument at the second trial were not improper. Remanded for sentencing. View "United States v. Carpenter" on Justia Law

After a jury trial, four former San Juan Municipal Police Department officers (Appellants) were convicted of several charges arising from the excessive use of force against a citizen who was beaten to death while in police custody. Appellants challenged their respective convictions and sentences on appeal. The First Circuit Court of Appeals affirmed the convictions and sentences, ultimately finding none of Appellants' arguments meritorious. Among the various arguments advanced by Appellants was that the district court erred when sentencing one Appellant by using the less favorable U.S. Sentencing Guidelines in effect on the date of sentencing rather than the Guidelines manual in effect at the time of the offense. The Court held that the "one book" rule of the Guidelines does not violate the Ex Post Facto Clause of the Constitution as applied to a series of grouped offenses such as Appellant's. View "US v. Pagan-Ferrer" on Justia Law