Justia Civil Rights Opinion Summaries

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

Plaintiff filed suit against Puerto Rico’s Insurance Commissioner (Defendant), claiming that Defendant eliminated her job as a director within the Office of the Insurance Commissioner on account of her political affiliation. The district court denied Defendant’s motion for summary judgment as Plaintiff’s federal discrimination claims for damages, declaratory relief, and injunctive relief. In so holding, the court rejected Defendant’s argument that her qualified immunity defense entitled her to summary judgment on Plaintiff’s federal damages claim. The First Circuit reversed the district court’s denial of qualified immunity and remanded for further proceedings, holding that a reasonable official in Defendant’s position could have understood the First Amendment not to protect Plaintiff against politically motivated removal from her job. Remanded for further proceedings. View "Lopez-Erquicia v. Weyne-Roig" on Justia Law

Eight police officers, a police cadet, and a provisionally hired 911 operator (collectively, the Officers) alleged that they suffered adverse employment actions by the Boston Police Department as a result of a racially discriminatory hair drug test. The Officers advanced a “disparate impact claim” under Title VII of the Civil Rights Act. The district court concluded that there was no actionable disparate impact. The first time on appeal, the First Circuit held that the Officers prevailed as a matter of law under the first prong of the three-prong disparate impact inquiry of that inquiry and remanded the case to the district court to consider the next two prongs. On remand, the district court again summary judgment for the Department. On appeal for the second time, the First Circuit vacated the district court’s grant of summary judgment to the Department on the third prong of the disparate impact inquiry, holding that a material dispute of fact existed preventing summary judgment on this matter. Remanded. View "Jones v. City of Boston" on Justia Law

Brian Blackden, a freelance photographer who sends photos to several regional-media outlets, including Belsito Communications (Belsito), and Belsito filed suit alleging that James Decker, a New Hampshire State Trooper, violated their constitutional rights when he seized Blackden’s camera without a warrant at the scene of a vehicle crash. The trial judge concluded that even if Decker’s actions were unconstitutional under current law, he was entitled to qualified immunity from suit because constitutional standards as applied to a situation like this one were unclear at the time of the challenged conduct. The First Circuit affirmed, holding that Blackden failed to identify clearly established law as of the time of the challenged conduct showing beyond debate that the police officer’s specific acts violated the First Amendment. View "Belsito Communications, Inc v. Decker" on Justia Law

Petitioner, a native and citizen of Guatemala, was arrested and charged with removability on the basis that he had remained in the United States beyond the six months permitted by his visa. Defendant filed a motion to suppress, arguing that certain documents were obtained as the result of an egregious violation of the Fourth Amendment. An immigration judge denied the motion to suppress, concluding that Petitioner did not present a prima facie case that the search and seizure leading to his arrest amounted to an egregious violation of the Fourth Amendment. The Board of Immigration Appeals (BIA) affirmed. The First Circuit denied Petitioner’s petition for review, holding that, like the BIA, the Court need not decide whether there was any Fourth Amendment violation because, even if there were, the violation was not egregious. View "Corado-Arriaza v. Lynch" on Justia Law

Plaintiff, an African-American, filed an employment discrimination case against Amtrak, his employer, alleging that his opportunities for overtime were reduced because of his race and that he was subjected to a hostile work environment. The district court granted summary judgment in favor of Amtrak. The First Circuit affirmed, holding (1) Plaintiff failed to meet his initial burden of establishing a prima facie case of disparate treatment discrimination; and (2) even if Plaintiff’s complaints rose to the level of a hostile work environment, Plaintiff failed to demonstrate that he was subjected to any complained-of actions because of his race. View "Garmon v. National Railroad Passenger Corp." on Justia Law

Plaintiff filed a complaint against the Transportation Security Administration and other defendants alleging violations of federal statutes prohibiting discriminatory treatment of disabled persons. The statutory scheme authorizes court appointment of counsel, but the mechanism is subject to the district court’s broad discretion. The district court denied Plaintiff appointed counsel. Plaintiff sought interlocutory review of the decision denying him appointed counsel as a collateral order. The First Circuit dismissed this interlocutory appeal, holding that the factors identified by the Court in Appleby v. Meachum for not categorizing the denial of appointed counsel under 28 U.S.C. 1915(e) as a collateral order also apply to denial of appointed-counsel requested under 42 U.S.C. 2000a-3(a) and 12188(a)(1). View "Sai v. Transportation Security Administration" on Justia Law

Defendant was charged with one count of being a felon in possession of a firearm and ammunition. Defendant filed a motion to suppress a pistol and ammunition found after a search conducted at his house, arguing that the affidavit submitted by a special agent of the Bureau of Alcohol, Tobacco, and Firearms supporting an application for a warrant to search his residence was misleading. The district court denied the motion to suppress. Defendant subsequently pleaded guilty, reserving his right to challenge the denial of his suppression motion. The First Circuit affirmed, holding that, although certain aspects of the affidavit were troubling, the affidavit established probable cause by showing a fair probability that contraband or evidence of a crime would be found at Defendant’s residence. View "United States v. Fleury" on Justia Law