Justia Civil Rights Opinion Summaries

First Circuit rejects civil rights claims relating to retention of property in car towed for an evidentiary search.Chelmsford police located Denault’s 2000 Nissan parked in Testa’s Lowell driveway. Denault, the suspect in a crime, was in custody. Testa was the mother of Denault's children. The officers had Denault's car towed and secured a warrant. Days later, they executed the warrant; having determined that the car did not contain evidence, they released it to Christopher's Towing. The officers had no contact with Denault. They did not supply, and Christopher's Towing did not request, Denault’s contact information. Testa repeatedly tried to recover the car and her belongings, particularly child booster seats. Testa claims that officers refused to discuss returning the car or its contents unless Testa agreed to be questioned in connection with the Denault investigation; they never informed her that they had released the car. Three months later, Denault's mother showed Tesla a Notice of Abandoned Vehicle sent to Denault's last known address, indicating a lien of $4797.82 for towing, storage, and processing. Neither Testa nor Denault could pay. They sued under 42 U.S.C. 1983 and the Massachusetts Civil Rights Act. They ultimately prevailed on a common-law conversion claim against one officer for $2225. The First Circuit affirmed, noting the “confusing” record and that the plaintiffs had waived claims relating to the initial seizure. View "Denault v. Ahern" on Justia Law

A plaintiff may not bring claims for damages under 42 U.S.C. 1981 against state actors, including defendants sued in their official capacities as government officials.The First Circuit affirmed the district court’s dismissal of Plaintiff's section 1981 claims against employees of the City of Boston. Plaintiff, who represented the estate of her late father, challenged her father’s termination from his employment with the Department of Public Works. The district court dismissed the section 1981 claims, concluding that section 1981 provides no implied private right of action for damages against state actors. The First Circuit affirmed, holding that Jett v. Dallas Independent School District compelled the result reached by the district court. View "Buntin v. City of Boston" on Justia Law

While they were investigating a suspected drug-trafficking operation, federal DEA agents made a warrantless entry into an apartment that, as it turned out, served as a stash house for a second, more substantial, drug-trafficking operation. Defendant, a participant in the second drug-trafficking operation, was charged with conspiring to possess with intent to distribute and to distribute one kilogram or more of heroin. Defendant moved to suppress the evidence gathered from the apartment. The district court denied the motion, concluding that probable cause and exigent circumstances justified the warrantless entry. The First Circuit affirmed, holding that the record supported the district court’s determination that the combination of probable cause and exigent circumstances justified the DEA agents’ warrantless entry into the apartment. View "United States v. Almonte-Baez" on Justia Law

Plaintiff appealed the district court’s grant of summary judgment in favor of her former employer, AstraZeneca Pharmaceutical LP, on Plaintiff’s claims that AstraZeneca violated the Americans with Disabilities Act (ADA) and several provisions of Puerto Rico law. Plaintiff attempted to persuade the First Circuit that there existed several material factual disputes in this case. The First Circuit affirmed the summary judgment, holding (1) AstraZeneca was entitled to summary judgment on both Plaintiff’s ADA disability discrimination claim and her ADA retaliation claim; and (2) Plaintiff failed to shoulder her burden to proceed to trial on her claims sounding in Puerto Rico law. View "Delgado-Echevarria v. AstraZeneca Pharmaceutical LP" on Justia Law

The First Circuit affirmed the district court’s grant of summary judgment to the City of Portland on Plaintiff’s claim that the City unconstitutionally denied him the opportunity to apply for a permit for his taxi to pick up passengers at the Portland International Jetport on the basis of his race and national origin. The district court ruled that Plaintiff did not have standing to bring his constitutional challenge because Plaintiff had not established a likelihood that he was “ready and able” to apply for the permit. The First Circuit affirmed, holding that there was no genuine issue of material fact regarding the likelihood that Plaintiff would seek the permit. View "McDonough v. City of Portland" on Justia Law

Appellant was employed by Appellees as a social worker when she suffered a work-related injury. Appellant sued Appellees, alleging that they failed to accommodate her disability in violation of the American with Disabilities Act (ADA). The district court granted summary judgment in favor of Appellees, concluding that Appellant did not qualify as a disabled individual under the ADA and that she was one responsible for the breakdown in communications concerning her accommodations. The First Circuit affirmed, holding that the district court correctly found that Appellees could not be held liable for their failure to accommodate because Appellant was responsible for the breakdown in communications. View "Ortiz-Martinez v. Fresenius Health Partners PR, LLC" on Justia Law

After a jury trial, Defendant was convicted of conspiracy to commit racketeering, conspiracy to commit murder in aid of racketeering, and other charges related to his membership in a crime syndicate. Defendant appealed, raising fifteen claims of error. The First Circuit affirmed, holding, inter alia, (1) Defendant failed to meet his burden of showing grand jury abuse by the government; (2) the government did not improperly join certain charges; (3) the district court did not err in denying Defendant’s motion to suppress; (4) there was no violation of Defendant’s right to conflict-free counsel; (5) the district court did not violate Defendant’s Sixth Amendment right to participate in his own defense; (6) the district court did not violate Defendant’s rights under the Confrontation Clause; (7) there was no evidentiary error; (8) the evidence was sufficient to support the convictions; (9) Defendant failed to show plain error in his claims of prosecutorial misconduct; and (10) the court properly sentenced Defendant. View "United States v. Ponzo" on Justia Law

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