Justia Civil Rights Opinion Summaries

Six nonbinary individuals born in Puerto Rico sought to amend their birth certificates to reflect a nonbinary gender marker ("X"), arguing that the existing Application for Gender Change, which only allowed selection of "male" or "female," discriminated against them. Their request followed an earlier federal court decision (Arroyo González v. Rossello Nevares) that required Puerto Rico to allow transgender binary individuals to amend their birth certificates, but did not address nonbinary persons. After their request was denied by the Director of the Demographic Registry, the plaintiffs filed suit, alleging violations of their constitutional rights under the Equal Protection and Due Process Clauses of the Fourteenth Amendment and the First Amendment.The United States District Court for the District of Puerto Rico reviewed cross-motions for summary judgment. The district court granted summary judgment to the plaintiffs on their Equal Protection claim, finding that Puerto Rico’s Birth Certificate Policy created a facial classification between binary and nonbinary individuals. The court applied rational basis review and concluded that Puerto Rico’s stated interests—including separation of powers and maintaining the integrity of public records—did not justify the exclusion of a nonbinary option. It found no rational basis for the policy and inferred animosity towards nonbinary persons, ordering Puerto Rico to amend its Application for Gender Change to include an "X" gender marker.The United States Court of Appeals for the First Circuit reviewed the district court’s summary judgment order de novo. The appellate court concluded that Puerto Rico's Birth Certificate Policy is supported by a rational basis, specifically Puerto Rico’s legitimate interest in protecting privacy rights. Because the plaintiffs did not demonstrate that the policy infringes on their privacy rights or that privacy rights are not furthered by the policy, the court found a rational relationship between the challenged classification and the government’s legitimate goals. The First Circuit vacated the district court’s order and remanded for further proceedings. View "de la Fuente Diaz v. Gonzalez Colon" on Justia Law

The appellant was convicted in the 1990s for bank and armored car robberies committed with a group that included Anthony Shea. These crimes involved frequent use of firearms, and in one particularly violent incident, two armored car guards were killed execution-style. The convictions included armed bank robbery, carjacking, Hobbs Act robbery and conspiracy, gun possession by a felon or drug user, and aiding and abetting the use of a firearm during a crime of violence under 18 U.S.C. § 924(c). The trial judge instructed the jury that several offenses were “crimes of violence” for the gun-use charge, but the verdict form did not specify which predicate offense the jury relied upon.Following his conviction, the United States District Court for the District of New Hampshire sentenced him to life imprisonment, applying enhancements under the Armed Career Criminal Act (ACCA) based on prior convictions. After the Supreme Court in Johnson v. United States struck down ACCA’s residual clause, a panel of the United States Court of Appeals for the First Circuit allowed the appellant to file a successive habeas petition. The district court subsequently vacated the ACCA-enhanced sentence and imposed a lower term, but declined to grant a full resentencing or to vacate the § 924(c) conviction, reasoning that the jury instruction error was harmless because valid predicate offenses remained.Upon appeal, the United States Court of Appeals for the First Circuit reviewed the denial of § 2255 relief de novo and for harmless error. It held that the district court's reliance on the harmless-error standard was correct and that the error in instructing on an invalid predicate offense did not have a substantial and injurious effect on the jury’s verdict, given the interrelated and coextensive nature of the valid and invalid predicates. The court further held that the appellant was not entitled to a certificate of appealability or to a full resentencing, as no substantial constitutional claim was raised regarding the district court’s choice of remedy. The judgment was affirmed and the request for a certificate of appealability denied. View "McDonald v. US" on Justia Law

Several parents and a grandparent of two female high school athletes challenged actions taken by officials of a New Hampshire public school district. The dispute arose after the parents wore pink "XX" wristbands during a girls' soccer game as a passive protest against the participation of a transgender athlete, in light of recent litigation about transgender students’ eligibility for girls’ sports. School administrators, concerned about possible harassment and disruption, instructed the protestors to remove the wristbands and later issued sanctions, including no-trespass orders preventing them from attending future school events.The United States District Court for the District of New Hampshire reviewed the plaintiffs’ request for a preliminary injunction. It analyzed the school’s actions under First Amendment principles applicable to limited public fora and determined that the administrators’ interpretation and enforcement of school policy did not constitute impermissible viewpoint discrimination. The district court denied the request for injunctive relief, concluding that the school’s interests justified its response to the protest.The United States Court of Appeals for the First Circuit examined whether the school district’s actions amounted to viewpoint discrimination against the plaintiffs’ passive speech. The court found that the protest did not materially disrupt the event or amount to harassment, and that the sanctions appeared motivated by disagreement with the protest’s message. The First Circuit held that the plaintiffs demonstrated a likelihood of success on their viewpoint discrimination claim, specifically regarding the sanctions imposed at the soccer game’s sidelines and adjacent parking lot. The court remanded the case to the district court for further proceedings to determine whether any interim relief, such as a declaratory judgment, is warranted. No costs were awarded. View "Fellers v. Kelley" on Justia Law

Several former residents and the owner of a certified sober home in Falmouth, Massachusetts, brought claims against local police officers after officers entered the home on three occasions between October 2019 and January 2020. The police responded to reports of overdoses or to serve arrest warrants, and the plaintiffs alleged that the officers conducted unlawful searches and seizures, detained and interrogated residents, and made threats. The plaintiffs argued that police actions stemmed from animus related to the owner’s prior complaints about police corruption.The plaintiffs initially filed suit in Massachusetts state court, alleging violations of the Fourth Amendment and the Massachusetts Declaration of Rights, as well as several state torts such as false arrest, invasion of privacy, and conspiracy. The case was removed to the United States District Court for the District of Massachusetts. After discovery, the district court granted summary judgment for the defendant officers on all claims except those related to a January 2020 entry. The court then revisited its prior order, addressing qualified immunity and granting summary judgment on the remaining federal claims, ultimately dismissing all claims against the Falmouth police officers.The United States Court of Appeals for the First Circuit reviewed the case de novo. The court concluded that many of the plaintiffs’ claims lacked sufficient factual support to survive summary judgment or were unsupported by specific evidence tying the alleged conduct to the defendant officers. Some claims were also deemed waived due to inadequate argument. The court held that the officers’ entries and searches were justified by consent or exigent circumstances, and that even if there were constitutional violations, the officers were protected by qualified immunity. The court also found that without an underlying tort, the conspiracy claim could not succeed. The First Circuit affirmed the district court’s grant of summary judgment in favor of the defendants. View "Hurley v. Curtis" on Justia Law

A correctional officer participated in a "forced cell move" at a federal medical facility, where a mentally ill and physically frail inmate, KT, was handcuffed behind his back. During the incident, the officer, equipped with a shield, entered the cell at high speed and struck KT in the chin and face, causing him to fall backward and suffer serious head and facial injuries. The event was captured on video. Prior to this, KT had spat on staff, including the officer, but was not threatening or aggressive at the time the force was used.The officer was indicted in the United States District Court for the District of Massachusetts on two counts of deprivation of rights under color of law. At the first jury trial, he was acquitted on one count, while the jury hung on the count concerning the shield strike, leading to a retrial. In the second trial, the district court excluded a training video the defense sought to introduce, finding it irrelevant and more prejudicial than probative, particularly since the circumstances in the video were materially different from those at issue. The jury convicted the officer on the remaining count. The district court denied post-trial motions and imposed a sentence of imprisonment and supervised release.On appeal to the United States Court of Appeals for the First Circuit, the officer challenged the sufficiency of the evidence, jury instructions, exclusion of the training video, and certain testimonial evidence, also alleging cumulative error. The First Circuit held that sufficient evidence supported the jury's finding that the officer acted maliciously and sadistically, violating the inmate's Eighth Amendment rights and meeting the willfulness standard under 18 U.S.C. § 242. The court found no error in the exclusion of the video, the jury instructions, or the evidentiary rulings, and determined that no cumulative error occurred. The conviction was affirmed. View "US v. Bourget" on Justia Law

The defendant was indicted by a federal grand jury in Massachusetts on three counts: being a prohibited person in possession of a firearm and ammunition, and two counts of possession with intent to distribute controlled substances. The first drug count was based on drugs found during his arrest, and the second on drugs found at his residence during a search. He moved to suppress evidence seized from his home, arguing the search violated the Fourth Amendment, but the district court denied the motion, finding the search was conducted under a valid warrant and in good faith. He also sought dismissal of the firearm charge, claiming the statute was unconstitutional under the Second Amendment, but that motion was denied. He then pleaded guilty to all counts.The United States District Court for the District of Massachusetts grouped the convictions for sentencing under the United States Sentencing Guidelines. The presentence report applied several enhancements, including one for being a career offender based on prior convictions. The defendant objected, arguing he had only one qualifying conviction and that a 2008 Massachusetts conviction for possession with intent to distribute cocaine should not count, because the definition of “controlled substance” had changed under federal law. The district court rejected his objections, but stated it would have imposed the same sentence even if it had accepted his arguments. The court ultimately imposed a below-Guidelines sentence of 96 months.The United States Court of Appeals for the First Circuit held that the district court erred in applying the career offender enhancement because the relevant Massachusetts conviction did not qualify as a “controlled substance offense” under the Guidelines at the time of federal sentencing, since the substance at issue was no longer federally controlled. Nevertheless, the error was harmless because the district court made clear it would have imposed the same sentence regardless. The court affirmed the convictions and sentences. View "US v. Fulcar" on Justia Law

A Christian church in Maine operates a private K–12 school that adheres closely to its religious beliefs, including requiring students and staff to conform to a statement of faith and specific codes of conduct and dress. The school is willing to admit students of any background if their families support its religious philosophy, but it maintains policies that exclude students who are openly gay or transgender and requires employees to be co-religionists. The school sought to participate in Maine’s tuition-assistance program, which allows public funds for private education in certain circumstances, but did not apply because of state nondiscrimination laws it believed would conflict with its religious practices.The United States District Court for the District of Maine denied the school’s motion for a permanent injunction against several provisions of the Maine Human Rights Act (MHRA), finding either no case or controversy or no constitutional violation. The case reached the United States Court of Appeals for the First Circuit after the parties stipulated to final judgment based on the preliminary injunction record, reserving all appellate rights.The United States Court of Appeals for the First Circuit reviewed whether the MHRA’s rules on employment, religious expression, religious nondiscrimination, and sexual orientation/gender identity nondiscrimination violate the First Amendment as applied to the school. The court held there was no case or controversy regarding the employment rule due to existing carveouts. It affirmed the district court’s rejection of the school’s challenges to the religious nondiscrimination and sexual orientation/gender identity rules, finding no constitutional violation. However, the court determined that the religious expression rule violates the school’s free-exercise rights and must be enjoined as applied to the school. The judgment was affirmed in part and reversed in part, and the case was remanded for entry of a permanent injunction against enforcement of the religious expression rule. View "Crosspoint Church v. Makin" on Justia Law

After the 2020 mayoral election in Maricao, Puerto Rico, the Popular Democratic Party candidate, Wilfredo Ruiz-Feliciano, assumed office, replacing the New Progressive Party incumbent. Odette López Collazo, a longstanding NPP member who had served as Internal Auditor since 1994, was not reappointed by the new mayor. López Collazo alleged that her non-reappointment was due solely to her political affiliation and constituted political discrimination in violation of her First and Fourteenth Amendment rights. She also asserted related claims against other municipal officials regarding the failure to pay out her accrued leave, but only the claim against Ruiz-Feliciano for political discrimination remained at issue in this appeal.The United States District Court for the District of Puerto Rico granted summary judgment in favor of Ruiz-Feliciano. The court concluded that First Amendment protections against political discrimination did not apply to a decision not to hire or reappoint, and further reasoned that because the Internal Auditor position was a “trust” position under Puerto Rico law, the mayor could hire and fire at will, including for political reasons. López Collazo moved for reconsideration, which was denied, and then sought partial final judgment under Rule 54(b) to appeal. After resolving procedural questions regarding finality, all claims but the political discrimination claim against Ruiz-Feliciano were dismissed with prejudice, and the appeal proceeded.The United States Court of Appeals for the First Circuit reviewed the district court’s grant of summary judgment de novo. The Court of Appeals held that First Amendment protections do apply to a failure to hire or reappoint a public employee, and that legislative classification of a position as a “trust” position is not dispositive in determining whether political affiliation is an appropriate requirement. The appellate court vacated the district court’s summary judgment and remanded for further proceedings. View "Lopez Collazo v. Ruiz-Feliciano" on Justia Law

The case centers on Tyler Jon Taker, a resident of Maine, who became subject to a state court order for protection from abuse, which he agreed to. This order prohibited him from possessing firearms and certain other weapons until March 22, 2026. While the protective order was in effect, Taker applied for a concealed handgun permit, but his application was denied by the local police chief due to the existence of the order. Taker then filed a federal lawsuit against various federal, state, and local officials, seeking declaratory and injunctive relief from federal and state statutes that prohibit individuals with certain convictions or protective orders from possessing firearms. He also sought damages against the police chief under 42 U.S.C. § 1983 for the denial of his concealed carry permit.The United States District Court for the District of Maine dismissed Taker’s claims. The court found that Taker was not a law-abiding citizen due to his prior felony drug conviction and that the statutes prohibiting his possession of firearms were consistent with historical tradition and thus constitutional. The District Court did not specify whether it dismissed for failure to state a claim or lack of subject matter jurisdiction but appeared to rule on the merits. Taker appealed this dismissal.The United States Court of Appeals for the First Circuit reviewed the case. The court held that Taker lacked Article III standing to pursue declaratory and injunctive relief because the protective order itself independently barred him from possessing firearms, so the relief sought would not redress his alleged injury. As for the damages claim against the police chief, the court found that the chief was entitled to qualified immunity because Taker’s constitutional rights were not clearly established in this context. The First Circuit affirmed the dismissal of the damages claim, vacated the dismissal of the declaratory and injunctive claims, and remanded with instructions to dismiss those claims for lack of jurisdiction. View "Taker v. Blanche" on Justia Law

Two individuals attended a demonstration in San Juan, Puerto Rico, on May 1, 2018, where they allege that officers of the Puerto Rico Police Bureau used excessive force against them, including the use of tear gas and rubber bullets. In April 2019, they filed lawsuits in the United States District Court for the District of Puerto Rico, asserting violations of their constitutional rights and seeking both injunctive and monetary relief. The suits named the then-Governor and other officials and employees of the Commonwealth, including police officers, as defendants, with claims brought against some defendants in their personal capacities.During this time, the Commonwealth of Puerto Rico was undergoing bankruptcy-like restructuring under Title III of PROMESA, and, in 2022, the Title III court confirmed a Plan of Adjustment, which discharged certain claims against the Commonwealth and enjoined pursuit of those claims. The district court stayed the plaintiffs’ lawsuit pending a determination of whether the Plan discharged their claims. On September 30, 2025, the Title III court held that the Plan did not discharge personal-capacity claims against Commonwealth officials or employees, thus allowing the plaintiffs to proceed. The Financial Oversight and Management Board appealed this decision.The United States Court of Appeals for the First Circuit reviewed the Title III court’s factual findings for clear error and its legal conclusions de novo. The appellate court held that the discharge and related injunction in the confirmed Plan of Adjustment do not apply to claims against Commonwealth officers or employees sued in their personal capacities. The court reasoned that discharging such claims would amount to a non-consensual third-party release, which the Plan expressly does not provide. Accordingly, the First Circuit affirmed the Title III court’s decision in full. View "Hernandez Zorilla v. FOMB" on Justia Law