Justia Civil Rights Opinion Summaries

Plaintiff, a former graduate student intern at the John A. Volpe National Transportation System Center, sought access to the Volpe Centers propriety data through a Cooperative Research and Development Agreement (CRADA) to continue her thesis, but the CRADA was never executed. Plaintiff brought an employment discrimination suit against the Secretary of Transportation, alleging that, by failing to execute the CRADA, the Secretary discriminated against her on the basis of her sex, race, or national origin. The district court granted summary judgment against Plaintiff on the CRADA claim. The First Circuit affirmed, holding that summary judgment was proper. View "Tyree v. Lahood" on Justia Law

Defendant entered a conditional guilty plea to conspiracy to distribute and possess with intent to distribute twenty-eight grams or more of cocaine base and possession of a firearm in furtherance of a drug trafficking crime. Defendant appealed, arguing that the district court erred in denying his motion to suppress evidence obtained by law enforcement officers while executing a warrant for his arrest. The First Circuit agreed with Defendant and reversed the denial of his motion to suppress, holding that the officers had insufficient grounds to justify entering Defendant’s girlfriend’s apartment without consent to execute the arrest warrant. Remanded. View "United States v. Young" on Justia Law

After a jury trial, Defendant was convicted of one count of possession of cocaine with intent to distribute. The district court sentenced Defendant to a term of imprisonment of forty-one months. The First Circuit affirmed, holding (1) the district court did not err in denying Defendant’s pre-trial motion to suppress evidence obtained upon the seizure of the car Defendant was driving; (2) the district court did not abuse its discretion in permitting the prosecution to use in its rebuttal a piece of evidence that the government delayed in disclosing, and the government did not act in bad faith in disclosing the evidence when it did; (3) the prosecutor did not commit plain error by questioning Defendant about facts not in evidence; and (4) Defendant’s challenges to his sentence were without merit. View "United States v. Mercer" on Justia Law

After a joint jury trial, Alexis Candelario-Santana (Candelario) and David Oquendo-Rivas (Oquendo) (together, Defendants) were found guilty of numerous crimes stemming from a drug-related mass shooting carried out in furtherance of a Racketeer Influenced and Corrupt Organizations Act. Both defendants received life sentences. The First Circuit affirmed Oquendo’s convictions but vacated and remanded as to Candelario, holding (1) the district court’s closure of the courtroom to facilitate a reluctant witness’s testimony constituted a constitutionally impermissible closure, effecting structural error; (2) there was no prejudicial error related to Oquendo’s case; and (3) the evidence was sufficient to support Oquendo’s convictions. View "United States v. Candelario-Santana" on Justia Law

When Plaintiff observed that a company named 110, Inc. was operating a substance abuse treatment facility next door to his residence, he argued that the Town of Wenham’s unilateral, non-public approval of 110, Inc.’s use was unlawful. Plaintiff filed a complaint in state court, alleging four causes of action. The Town removed the case to federal court. The district court subsequently granted the Town’s motion to dismiss some of Plaintiff’s claims. The court concluded that the complaint failed to state a claim under 42 U.S.C. 1983 for the deprivation of property without due process and that Plaintiff’s declaratory judgment claim had been rendered moot. The First Circuit (1) affirmed the dismissal of Plaintiff’s federal claim, holding that Plaintiff was not deprived of any constitutionally protected property interest without due process of law; (2) vacated the district court’s determination that one state law claim was moot; and (3) otherwise affirmed the remand of the remaining state law claim to state court. View "Miller v. Town of Wenham, Mass." on Justia Law

After her employment was terminated, Employee filed sexual harassment, gender discrimination, and retaliation claims under federal and Puerto Rico law against her former employer (Employer) and its co-owners and administrator. The district court granted summary judgment in favor of Employer on Employee’s federal claims and dismissed Employee’s remaining claims. The district court later awarded attorneys’ fees to the defendants. The First Circuit affirmed, holding that the district court (1) did not abuse its discretion in holding Employee to the local rules’ ordinary page limits; (2) acted within its discretion in awarding attorneys’ fees to the prevailing defendants; and (3) did not err in rejecting Employee’s motions to set aside the summary judgment order and the fees award. View "Fontanillas-Lopez v. Morel Bauza Cartagena & Dapena" on Justia Law

Petitioner pleaded guilty to two counts of carjacking resulting in death. The jury sentenced Petitioner to death under the Federal Death Penalty Act (FDPA). Due to jury taint, Petitioner’s sentence was vacated and his case remanded for further proceedings. The government subsequently filed an amended notice of intent to seek the death penalty, as required by the FDPA. The amended notice listed the factors that the government believed justified the death penalty, largely tracking the original notice. Petitioner filed a motion in limine to dismiss or strike two non-statutory aggravating factors the prosecutor intended to present in a second penalty-phase proceeding under the FDPA. The district court denied the motion. Petitioner appealed, arguing that because the jury in his first penalty-phase proceeding did not find unanimously that the government proved these two aggravating factors beyond a reasonable doubt, their introduction at the new penalty-phase proceeding was barred by double jeopardy principles. The First Circuit affirmed, holding that the Double Jeopardy Clause did not bar the government from alleging those non-statutory aggravating factors again at Petitioner’s new penalty-phase proceeding. View "Sampson v. United States" on Justia Law

At issue in this case was whether one of the Commonwealth of Puerto Rico’s special-purpose public corporations, the Puerto Rico Ports Authority (PRPA), is an arm of the Commonwealth that enjoys sovereign immunity under the Eleventh Amendment. Daniel Grajales and his family alleged that PRPA subjected Daniel to political discrimination and unlawfully terminated his employment for reasons related to political discrimination and retaliation. After many procedural “twists and turns,” the district court granted PRPA’s motion to dismiss, concluding that PRPA was an arm of the Commonwealth and thus immune from suit under Eleventh Amendment immunity principles. The First Circuit reversed, holding that PRPA was not entitled to claim the Commonwealth’s immunity as an arm of the Commonwealth. Remanded. View "Grajales v. P.R. Ports Auth." on Justia Law

Plaintiff, a Puerto Rico Police Department law enforcement officer, filed a complaint alleging that Defendants, his superior officers, violated the Establishment Clause by holding a group prayer while on duty and punishing Plaintiff for his non-conformance. Defendants moved to dismiss the complaint on the grounds that the complaint failed to allege plausibly a constitutional violation, and invoking qualified immunity. The district court denied the motion on both grounds. Appellants filed this interlocutory appeal to challenge the court’s denial of qualified immunity. The First Circuit affirmed, holding that the district court did not err in rejecting Defendants’ qualified immunity defense. View "Marrero-Mendez v. Calixto-Rodriguez" on Justia Law

Defendant pleaded guilty to possessing child pornography. The district court sentenced Defendant to 135 months in prison. At a second change-of-plea hearing, Defendant acknowledged that the indictment charged “pornography involving prepubescent minors.” Defendants was sentenced to fifteen years of supervised release. Defendant appealed, arguing, inter alia, that the district court violated the Double Jeopardy Clause by permitting the prosecution to continue via a second change-of-plea hearing because his “first plea was to possession of child pornography and not to possession of prepubescent child pornography.” The First Circuit affirmed Defendant’s conviction and prison sentence but vacated one of the conditions of Defendant’s supervised release, holding (1) the Double Jeopardy Clause did not bar the government from “continuing its prosecution” of Defendant on the greater offense, even assuming that Defendant’s initial plea was to a lesser-included offense; (2) the district court did not commit clear or obvious error in “vacat[ing]” Defendant’s first plea and accepting the second after the presentence report had issued; (3) Defendant’s ineffective assistance of counsel claim is not reviewable on direct appeal; (4) the prosecutor did not breach the plea agreement at the sentencing hearing; and (5) the district court did not err in sentencing Defendant. View "United States v. Gall" on Justia Law