Justia Civil Rights Opinion Summaries

In 2011, the FBI obtained a criminal complaint and warrant for Appellant's arrest. Several criminal charges were brought against Appellant, including sending letters to public officials threatening murder. The warrant was based on the use of a 2005 DNA profile of Appellant, which resulted in no charges against Appellant, that was used during the 2011 investigation and found to be a match to the DNA recovered from the threatening letters sent in 2011. Appellant filed a motion to suppress the fruits of the use of his 2005 DNA profile in securing the 2011 warrant. The trial court denied the motion. Appellant conditionally pled guilty to the charges and then appealed, arguing that the method of obtaining his DNA violated the Fourth Amendment. The First Circuit Court of Appeals affirmed the district court's denial of Appellant's motion to suppress, holding (1) the method of obtaining Appellant's 2005 DNA sample violated the Fourth Amendment; but (2) application of the exclusionary rule in this case would be outweighed by the resulting costs to the criminal justice system. View "United States v. Thomas" on Justia Law

After a jury trial, Petitioner was convicted of first-degree murder in state court. Petitioner's conviction was upheld on appeal. Petitioner subsequently filed a petition for a writ of habeas corpus in the federal district court, asserting (1) the prosecutor improperly commented on his failure to testify in violation of the Fifth Amendment, and (2) he received ineffective assistance of counsel because his attorney inadvertently failed to produce certain medical records to the prosecution during discovery, which prevented counsel from questioning the defense's witness, a psychiatrist, about them at trial. The district court denied the petition. The First Circuit Court of Appeals affirmed, holding (1) any error on the part of the prosecution was harmless; and (2) the omission of the records was not prejudicial, and whether or not Appellant's trial counsel made a strategic choice to omit the evidence this was not an error so serious that Defendant was deprived of his Sixth Amendment right to counsel. View "Pena v. Dickhaut" on Justia Law

Defendant was indicted in 2012 for possession of a firearm by a felon based on his prior predicate conviction in 1995 of a state felony. Defendant moved to dismiss the count, arguing that he could not be classified as a felon under 18 U.S.C. 922(g)(1) because he had his civil rights to sit on a jury and to hold public office restored as a matter of New Hampshire state law. At issue was whether Defendant's right to serve on a New Hampshire jury was restored before the date of the federal offense. The district court adopted Defendant's reading of New Hampshire's juror eligibility statutes and dismissed the felon in possession charge. The First Circuit Court of Appeals certified to the New Hampshire Supreme Court the question of law of whether Defendant's right to serve on a New Hampshire jury was restored as of the date of the federal crime under the New Hampshire Revised Statutes. View "United States v. Howe" on Justia Law

After a thirty-seven-day jury trial, Appellant was convicted of four terrorism-related counts and three counts premised on allegedly false statements and sentenced to a 210-month term of immurement. Defendant appealed, challenging, inter alia, his convictions on the four terrorism-related counts on the grounds that they were neither supported by the evidence nor constitutionally permissible. The First Circuit Court of Appeals affirmed, holding (1) the evidence was sufficient to convict Defendant on the four terrorism-related counts and on the false statement counts; (2) the trial court did not prejudicially err in its evidentiary rulings; (3) Defendant's convictions were constitutional; and (4) the district court did not err in sentencing Defendant. View "United States v. Mehanna" on Justia Law

Plaintiff filed suit against Kmart Corporation and Sears Holdings Corporation (collectively, Kmart), bringing a federal claim of racial discrimination under 42 U.S.C. 1981 and a pendent state law claim of negligent infliction of emotional distress. Plaintiff, an African-American woman, alleged that a white Kmart sales clerk insulted her with racial slurs and comments while she was placing items on hold in a layaway transaction. The district court dismissed the federal claim for failure to state a claim under section 1981 and dismissed without prejudice the state law claim. Plaintiff appealed the dismissal of her section 1981 claim. The First Circuit Court of Appeals affirmed, holding that Plaintiff failed to make out a section 1981 claim where her only allegation of harm she suffered was from the sales clerk's utterances, and nothing more. View "Hammond v. Kmart Corp." on Justia Law

Petitioner was convicted in Massachusetts Superior Court of first degree murder by reason of extreme atrocity or cruelty. Defendant filed a motion for a new trial, alleging ineffective assistance of counsel, and requested an evidentiary hearing on his claim. The superior court denied the motion for a new trial without holding an evidentiary hearing. The Massachusetts Supreme Judicial Court affirmed. Petitioner subsequently field a petition for writ of habeas corpus in the U.S. district court, reiterating his ineffective assistance claims and arguing that that Massachusetts court's denial of his request for an evidentiary hearing on these claims violated his due process rights. The district court dismissed the petition, concluding that the state court record was sufficient to resolve the case. The First Circuit Court of Appeals affirmed because Petitioner's claim was adjudicated on the merits by the Supreme Judicial Court, and Petitioner failed to raise a substantial issue that might require an evidentiary hearing. View "Garuti v. Roden" on Justia Law

On August 6, Appellant was arrested in Maine and charged by the State for firearm-related crimes. On August 26, the United States ("government") charged Appellant with possession of a firearm by a convicted felon. On August 29, the State dismissed the related State charges. Appellant remained incarcerated by the State for the next month despite the fact the State had dismissed all charges against him. Finally, on October 3, Appellant was arrested by U.S. Marshals and brought before a federal judge. On October 26, a federal grand jury returned an indictment charging Appellant, and Appellant waived his right to contest the government's motion to detain him pending trial. Appellant subsequently filed a motion to dismiss the federal indictment on speedy-trial grounds. The district court denied the motion. The First Circuit Court of Appeals affirmed, holding (1) because Appellant did not enter federal custody until October 3, his October 26 indictment occurred within thirty days of his arrest on federal charges and, therefore, did not violate the Speedy Trial Act; and (2) the district court did not err by failing to impose sanctions against the government for its purported failure to notify Appellant that it had lodged a federal detainer against him. View "United States v. Lewis" on Justia Law

A federal law enforcement officer made a lawful traffic stop of Appellant, but by the time the officer stopped Appellant, he and Appellant were outside the jurisdiction in which the officer was authorized to make arrests. The officer could see that Appellant was intoxicated and arrested Appellant. Appellant was subsequently charged with operating a motor vehicle under the influence, unsafe operation of a motor vehicle, and refusal to submit to a breath test. Appellant moved to suppress the evidence from his arrest on the grounds that the officer lacked the authority to arrest him. The magistrate judge agreed that the officer lacked statutory authority to arrest Appellant but refused to suppress the evidence because the arrest was not an unreasonable seizure. The district judge affirmed the magistrate judge's decision not to suppress the evidence. The First Circuit Court of Appeals affirmed, holding that Appellant's arrest did not constitute the kind of invasion of privacy that the Fourth Amendment prohibits. View "United States v. Ryan" on Justia Law

The City of Providence, Rhode Island enacted two ordinances to reduce tobacco use by young people. The Price Ordinance restricted the City's tobacco and cigarette retailers from reducing prices on tobacco products through coupons and multi-pack discounts. The Flavor Ordinance restricted sales of certain flavored tobacco products other than cigarettes. The National Association of Tobacco Outlets challenged the ordinances, alleging, inter alia, that the ordinances were preempted by federal and state law. The district court upheld the ordinances. The First Circuit Court of Appeals affirmed, holding (1) because the Price Ordinance was an appropriate regulation of price, it fell outside the First Amendment; (2) because the Flavor Ordinance was an appropriate sales regulation, it was not preempted; and (3) neither ordinance conflicted with state law. View "Nat'l Ass'n of Tobacco Outlets, Inc. v. Providence, R.I." on Justia Law

Defendant pleaded guilty to conspiracy to commit promotional money laundering pursuant to a plea agreement. Defendant stipulated to the amount of money laundered and received a prison sentence within the range of the federal sentencing guidelines. Defendant appealed, seeking to vitiate his guilty plea on grounds that the record failed to establish a sufficient factual basis for his plea and asserting a claim of sentencing error. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in accepting Defendant's guilty plea, as sufficient facts supported the plea; and (2) there was no sentencing error where Defendant's stipulation removed any necessity for independent proof of the stipulated facts. View "United States v. Torres-Vazquez" on Justia Law