Justia Civil Rights Opinion Summaries

Plaintiff brought actions for civil liability under the Trafficking Victims Protection Act against four defendants. As to three defendants - Ashvinkumar Patel, Simal Patel, and Bijal, Inc. - the district court dismissed for failure to state a claim. The First Circuit reversed the district court’s judgment dismissing Plaintiff’s claims against defendants Bijal, Inc. and the Patels, holding (1) the allegations and inferences in the complaint sufficed as plausible support for pleading statutory violations by the Patel defendants in their own right and as agents for renting out Bijal’s motel space, and by Bijal in consequence of the Patels’ agency; and (2) therefore, the district court erred in granting the motion to dismiss and in denying reconsideration. View "Ricchio v. McLean" on Justia Law

Plaintiffs brought a lawsuit against their insurance carrier (Defendant), claiming that Defendant had incorrectly denied coverage. The case proceeded to a jury trial. The jury’s unanimous verdict was for Defendant. Thereafter, Plaintiffs filed a motion for a new trial after learning that the jury foreperson had a prior felony conviction, arguing that the juror was not qualified to serve on the jury under 28 U.S.C. 1865(b)(5). The district court denied the motion for a new trial, concluding that Plaintiffs had not shown that the juror’s service deprived them of a fundamentally fair trial. The First Circuit affirmed, holding that the juror’s inclusion was not fatal to the jury’s verdict, and therefore, the district court properly denied Plaintiffs’ new-trial motion. View "Faria v. Harleysville Worcester Insurance Co." on Justia Law

After a jury trial, Defendant was convicted of three counts of bank fraud and one count of conspiracy to commit bank fraud. The district court sentenced Defendant to ninety-three months’ imprisonment and ordered him to pay $532,152 in restitution. The First Circuit affirmed Defendant’s convictions, holding that the district court (1) did not abuse its discretion when it denied Defendant’s motion for substitution of counsel; (2) did not deprive Defendant of his Sixth Amendment right to an attorney by allowing Defendant to represent himself at trial; and (3) did not abuse its discretion when it declined to dismiss a juror for potential bias because there was no bias as a matter of law. View "United States v. Kar" on Justia Law

Brittany Irish and her mother Kimberly Irish brought this 42 U.S.C. 1983 action against ten Maine State Police officers after Brittany’s former boyfriend broke into her parents’ home, fatally shot her boyfriend, shot and seriously wounded Kimberly, abducted Brittany, and engaged in a shootout with the police during which another individual was fatally shot. The complaint alleged that the Irishes’ losses arose out of failures by Defendants to protect them “from dangers which Defendants themselves created.” The district court dismissed the Irishes’ complaint for failure to state a claim and also found that qualified immunity shielded the defendants from liability. The First Circuit vacated the district court’s ruling as to the individual police officers, holding that it could not be said that Plaintiffs failed to state a substantive due process claim or that Defendants were entitled to qualified immunity. Remanded with instructions for discovery. View "Irish v. State of Maine" on Justia Law

Israa Hassan, a United States citizen, filed an I-130 petition seeking permanent resident status for her noncitizen husband, Kamal Ali. U.S. Citizenship and Immigration Services (USCIS) denied the petition based on its determination that Ali’s prior marriage had been fraudulent. Ali and Hassan (together, Plaintiffs) filed a lawsuit alleging that USCIS had violated their Fifth Amendment procedural due process rights by denying the I-130 petition without sua sponte offering a pre-decision evidentiary hearing. The magistrate judge issued an order granting the government’s motion for summary judgment, concluding that, even assuming that Plaintiffs had a liberty interest in Ali having permanent resident status through the petition, due process did not require an evidentiary hearing. The First Circuit affirmed, holding that, even assuming that Plaintiffs were entitled to some form of constitutionally protected liberty interest in this matter, the district court properly held that Plaintiffs did not show how their preferred procedure would have made any difference to the outcome. View "Ali v. United States" on Justia Law

Defendant pled guilty to participating in a conspiracy to defraud the federal government. Defendant appealed, arguing that the district court erred in denying his motion to dismiss the indictment with prejudice based on violations of the Speedy Trial Act, the Speedy Trial Clause of the Sixth Amendment, and the Due Process Clause of the Fifth Amendment. The First Circuit vacated the district court’s decision on Defendant’s Sixth Amendment claim and remanded for reconsideration of that claim, holding that the district court was led astray by dicta in one of this Court’s prior opinions in calculating the length of delay relevant to evaluating the alleged Sixth Amendment violation. View "United States v. Irizarry-Colon" on Justia Law

After a jury trial, Defendant was convicted of possession of crack cocaine with intent to distribute. The First Circuit affirmed, holding (1) Defendant waived any argument regarding the district court’s denial of his motion to suppress text messages that the police obtained from Defendant’s cell phone pursuant to a search warrant; (2) the district court did not err in admitting evidence of Defendant’s prior drug conviction; (3) the district court did not err in allowing a police officer to provide expert testimony; and (4) the district court did not err in failing to instruct the jury on the lesser included offense of simple possession. View "United States v. Henry" on Justia Law

Defendant pled guilty to possession of child pornography and was sentenced to seventy-eight months’ imprisonment and ten years of supervised release. Defendant appealed, arguing that the district court erred in denying his motion to suppress because the search and seizure of computers and other items from his apartment violated the Fourth Amendment. The First Circuit affirmed, holding that the district court did not err in finding (1) FBI agents did not violate the curtilage of Defendant’s home; (2) Defendant consented to the search, and the FBI agents did not exceed the scope of that consent; and (3) the temporary seizure of Defendant’s apartment did not violate the Fourth Amendment. View "United States v. Perez-Diaz" on Justia Law

Defendant, a police officer acting under color of state law, took Plaintiff into protective custody, handcuffed him, transported him to a police station, and jailed him after attempting to evaluate whether Defendant was incapacitated by his consumption of alcohol. Plaintiff sued in federal district court, arguing that Defendant lacked probable cause to take him into protective custody. The district court granted Defendant’s motion for summary judgment on qualified immunity grounds, concluding that the law was not clearly established as to the need for probable cause. The First Circuit vacated the entry of summary judgment and remanded for further proceedings, holding (1) the state of preexisting law established that a reasonable officer must have probable cause to take an individual into protective custody, handcuff him, transport him to a police station, and confine him in a jail cell; (2) an objectively reasonable officer in this case would not have had adequate reason to believe that Plaintiff, though intoxicated, was incapacitated; and (3) therefore, the qualified immunity defense was not available to Plaintiff. View "Alfano v. Lynch" on Justia Law

Defendant pleaded guilty to participating in a conspiracy to import one or more kilograms of heroin into the United States and to launder the proceeds of that activity. Defendant was sentenced to 262 months in prison. On appeal, Defendant argued that the government violated the plea agreement during the sentencing hearing and that his counsel provided constitutionally ineffective assistance during the plea negotiations and at the sentencing hearing. The First Circuit (1) affirmed the sentence, holding that there was no breach of the plea agreement; and (2) dismissed the ineffective assistance of counsel claim without prejudice to its reassertion in a collateral proceeding, as there was no reason to make an exception in this case to the rule that this Court does not review ineffective assistance of counsel claims on direct appeal. View "United States v. Marin-Echeverri" on Justia Law