Justia Civil Rights Opinion Summaries

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