Justia Civil Rights Opinion Summaries

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

Appellant, an officer with the Puerto Rico Police Department (PRPD), filed an employment discrimination claim against the Commonwealth of Puerto Rico, the PRPD, and several of her coworkers, alleging violations of various federal and Puerto Rico statutes. Appellant sought compensatory and punitive damages and an injunction barring the PRPD from further incrimination. The district court granted summary judgment for Defendants on all of Appellant’s claims. The First Circuit affirmed without reaching the merits of Appellant’s claims, holding that Appellant failed to adhere to procedural requirements relating to the dispositions of a magistrate judge as set forth by Fed. R. Civ. P. 72(b) and Puerto Rico Local Rule 72(d). View "Santos-Santos v. Torres-Centeno" on Justia Law

Mark Eves, the Maine Legislature Speaker of the House, obtained a contract of employment with Good Will-Hinckley (GWH), a Maine nonprofit that is largely funded by biennial grants from the state. Whether to disburse that grant money to GWH was left to the discretion of the Governor of Maine. Displeased at GWH’s decision to hire the Speaker, the Governor threatened to withhold GWH’s discretionary funding when payment would ordinarily be due. GWH subsequently terminated the Speaker’s employment contract. The Speaker sued the Governor for damages and injunctive relief, asserting that the Governor had retaliated against the Speaker’s exercise of his First Amendment rights. The federal district court dismissed all claims. The First Circuit (1) affirmed the dismissal with prejudice of the Speaker’s federal claims on qualified immunity grounds; and (2) vacated the district court’s judgment with respect to the dismissal with prejudice of the Speaker’s state claim, which the Court remanded to the district court for a dismissal without prejudice, holding that this matter is best left to the Maine courts. View "Eves v. LePage" on Justia Law

Defendant was convicted of Hobbs Act extortion, tax fraud, and making false statements to obtain federal worker’s compensation. Defendant appealed, arguing that the district court erred in denying her motion to suppress incriminating statements she made during her interview with two sheriff’s deputies because the statements were obtained through a custodial interrogation without the benefit of a Miranda warning and that her confession was involuntary. The district court denied the motion to suppress. The First Circuit affirmed, holding (1) Defendant was not subjected to a custodial interrogation, and therefore, it was not necessary to provide her with Miranda warnings; and (2) Defendant’s statements were voluntary. View "United States v. Swan" on Justia Law

In 2002, Appellant entered a guilty plea, pursuant to a plea agreement, to four counts of conspiracy to commit, and aiding and abetting, insurance and mail fraud. In 2011, Appellant consulted an immigration attorney to apply for naturalization. The attorney informed Appellant that his guilty plea barred him from becoming a United States citizen and that he was subject to mandatory removal based on his conviction. Appellant brought a petition for a writ of coram nobis, arguing that his attorney provided ineffective assistance by erroneously advising him that a probation sentence from his guilty plea would not affect his immigration status and that the prosecutor provided a similar assurance during plea negotiations. The district court denied the petition, concluding (1) Appellant’s Sixth Amendment claim was barred because its success depended on the retroactive application of Padilla v. Kentucky, and Padilla did not apply retroactively to Appellant’s claim in light of Chaidez v. United States; and (2) Appellant’s claim against the prosecutor lacked merit. The First Circuit vacated and remanded the claim, holding (1) Appellant’s claim against the prosecutor indeed lacked merit; but (2) Appellant’s Sixth Amendment claim was not barred by the retroactivity doctrine. Remanded. View "United States v. Castro-Taveras" on Justia Law

After a jury trial in a Massachusetts state court, Appellant was found guilty of unlawful possession of a firearm, unlawful possession of ammunition, and other offenses. The appeals court affirmed. Appellant later filed a petition for a writ of habeas corpus pursuant to 28 U.S.C. 2254, arguing that the state courts failed to apply the United States Supreme Court’s holding in Snyder v. Massachusetts and violated his due process and equal protection rights in denying his request to be present during the jury view of the crime scene. The First Circuit affirmed, holding that the appeals court’s decision did not contradict, nor was it an unreasonable application of, Snyder. View "Hyatt v. Gelb" on Justia Law

In 2014, New Hampshire amended a statute by forbidding citizens from photographing their marked ballots and publicizing those photographs (referred to as “ballot selfies”). Three New Hampshire citizens filed suit, arguing that the statute was a content-based restriction of speech that, on its face, violates the First Amendment. The district court ruled in favor of the plaintiffs. On appeal, the New Hampshire Secretary of State argued that the statute was justified to prevent vote buying and voter intimidation. The First Circuit affirmed, holding that the statute as amended is facially unconstitutional even applying only intermediate scrutiny, and the statute’s purposes cannot justify the restrictions it imposes on speech. View "Rideout v. Gardner" on Justia Law