Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was convicted of the murder of his wife. Eight days later, Defendant was indicted by a federal grand jury on three counts of making false statements to a federal officer. One week later, a Puerto Rico Commonwealth court sentenced Defendant to 109 years’ imprisonment for the murder. Defendant moved to transfer the federal trial to another venue, arguing that the pretrial publicity about his murder conviction prevented a fair and impartial jury in Puerto Rico. The trial court overruled the motion to change venue. After a trial, the jury convicted Defendant of all three false-statement counts, but the court granted a motion of acquittal on two counts. The First Circuit reversed, holding that the district court abused its discretion by denying Defendant’s motion to change venue, as there was a significant risk that the level of prejudice permeating the trial was so high that Defendant could not possibly have received an impartial trial. Remanded. View "United States v. Casellas-Toro" on Justia Law

Plaintiff filed suit against officials at the University of Massachusetts at Dartmouth after the university had commenced termination proceedings against him, alleging, inter alia, claims under 42 U.S.C. 1983 for violations of his First and Fourteenth Amendment rights. Plaintiff then filed a second amended complaint along with an amended motion for preliminary injunction requesting that the termination proceedings be halted and Plaintiff be reinstated to his position. Defendants moved to dismiss the amended complaint. The district court granted in part and denied in part the motion to dismiss and sua sponte combined the motion for preliminary injunction with a trial on the merits. The university subsequently terminated Plaintiff. During the pendency of Plaintiff’s interlocutory appeal of the district court’s order combining the preliminary injunction hearing with the trial, the district court proceeded with the case. The First Circuit dismissed the appeal, holding that the Court had no jurisdiction over the underlying decision to consolidate the motion for preliminary injunction with trial. Therefore, the Court also lacked jurisdiction over the district court’s denials of Plaintiff’s motions to reconsider its order. View "Nwaubani v. Grossman" on Justia Law

After a jury trial, Appellant was convicted of transportation, receipt, and possession of child pornography. The First Circuit affirmed on appeal. Appellant later filed a petition for a writ of habeas corpus under 28 U.S.C. 2255 claiming that the jury selection process for his trial violated his Fifth Amendment right to be present and his Sixth Amendment right to a public trial. Appellant did not raise either the Fifth Amendment or the Sixth Amendment claim at trial or on direct appeal. The district court denied habeas relief. The First Circuit affirmed, holding that Appellant could not overcome his procedural default from not pursuing either his Fifth Amendment or Sixth Amendment claim at trial or on appeal. View "Wilder v. United States" on Justia Law

Appellants, Boston police officers, made a warrantless entry into a dwelling in the Brighton neighborhood of Boston, Massachusetts. Plaintiff, the only person inside, was eventually arrested. Plaintiff was eventually acquitted on criminal charges resulting from his arrest. Thereafter, Plaintiff sued Appellants, alleging that the search of his residence was unreasonable and that the officers violated his civil rights through the use of excessive force. The jury found for Plaintiff on both of his claims and awarded him $50,000 in damages. The district court subsequently awarded Plaintiff attorneys’ fees and costs. The First Circuit affirmed, holding (1) Appellants' actions did not fall within the community caretaking exception, and therefore, qualified immunity was inapplicable; and (2) the attorneys’ fee award fell within the universe of reasonable awards. View "Matalon v. Hynnes" on Justia Law

Plaintiffs were employees of Puerto Rico National Processing Service Center (PR-NPSC), run by the Federal Emergency Management Agency (FEMA). Plaintiffs filed this lawsuit alleging that FEMA’s actions in implementing a rotational staffing plan at the PR-NPSC and in eventually closing the facility discriminated against them on the basis of national origin and constituted unlawful retaliation in violation of Title VII. The district court granted summary judgment to Defendants. The First Circuit affirmed, holding (1) Plaintiffs’ disparate impact claims failed because the challenged actions were job-related and consistent with business necessity, and Plaintiffs failed to show that there were alternatives available to FEMA that would have had less disparate impact and served FEMA’s legitimate needs; and (2) both retaliation claims failed because Plaintiffs did not show that the allegedly adverse employment actions were causally related to any protected conduct. View "Abril-Rivera v. Johnson" on Justia Law

After a second trial, Defendant was convicted of conspiracy to possess with intent to distribute five kilograms or more of cocaine and possession with intent to distribute five kilograms or more of cocaine. Defendant was sentenced to 196 months of incarceration. The First Circuit affirmed Defendant’s conviction and sentence, holding (1) it was not plain error for the district court to admit an unexecuted draft contract into evidence; (2) the district judge did not err by commenting on the draft contract; (3) there was no violation of the Jones Act, and Defendant suffered no prejudice in the admission of English testimony peppered with Spanish colloquialisms; (4) the prosecutor’s closing and rebuttal arguments did not constitute prosecutorial misconduct; and (5) Defendant’s sentence was neither procedurally nor substantively unreasonable. View "United States v. Carela" on Justia Law

Massachusetts state police confiscated firearms owned by Russell Jarvis and James Jarvis, Massachusetts gun owners, and transferred custody of the confiscated firearms to Village Gun Shop, Inc. (the Gun Shop), which operates a bonded warehouse for the storage of firearms and ammunition. Massachusetts local police confiscated firearms owned by Robert Crampton, a Massachusetts gun owner, and transferred the guns to the Gun Shop for storage. When Crampton and the Jarvises failed to pay storage charges, the Gun Shop sold their firearms at public auction. The Jarvises, Crampton, and Commonwealth Second Amendment, Inc. brought suit in federal district court against the Gun Shop alleging that their Fourteenth Amendment right to due process had been violated. Plaintiffs moved for partial summary judgment against the Gun Shop, arguing that the Gun Shop was a state actor that could be held liable for damages under section 1983. The district court granted summary judgment on the state action issue to the Gun Shop. The court subsequently entered final judgment in favor of the Gun Shop. The First Circuit affirmed, holding that the Gun Shop may not be liable as a state actor under section 1983. View "Jarvis v. Village Gun Shop, Inc." on Justia Law

Plaintiff was fired from Servicios Legales de Puerto Rico, Inc. (SLPR), a non-profit legal services organization where she had worked for nearly twenty-eight years. Plaintiff was sixty-three years old at the time she was terminated. Plaintiff filed an employment discrimination complaint in federal court alleging that SLPR wrongfully terminated her on the basis of her age in violation of the Age Discrimination in Employment Act. The district court entered summary judgment in favor of SLPR. The First Circuit affirmed on the ground that Plaintiff failed to establish a prima facie case for age discrimination. View "Del Valle-Santana v. Servicios Legales de P.R., Inc." on Justia Law

Defendant’s vehicle was stopped and searched by officers with the Maine Drug Enforcement Agency, the Maine Police, and the Portland Police Department. The search involved the use of a drug-sniffing dog and resulted in the discovery of cocaine and a firearm. Defendant pleaded guilty to one count of possession with intent to distribute 500 grams or more of cocaine and one count of possession of a firearm in furtherance of a drug trafficking crime. Defendant appealed, challenging the district court’s denial of his motion to suppress and the court’s denial of his motion for discovery of records. The First Circuit affirmed, holding that the district court did not err in finding that the warrantless search and seizure of Defendant’s vehicle were justified by the automobile exception. View "United States v. White" on Justia Law