Justia Civil Rights Opinion Summaries

Plaintiff - a former police officer with the City of Quincy, Massachusetts - brought this action against the City, its chief of police, and a police captain, (collectively, Appellees), alleging, among other claims, that Appellees retaliated against him for exercising his First Amendment rights by making statements to various news organizations regarding a dog ordinance issue. The district court granted summary judgment in favor of Appellees. The First Circuit affirmed, holding (1) Plaintiff failed to proffer sufficient facts to survive a motion for summary judgment on his 42 U.S.C. 1983 claim; (2) Plaintiff’s Massachusetts Civil Rights Act claim also failed at the summary judgment stage; and (3) Plaintiff’s defamation claim was properly subjected to summary judgment. View "McGunigle v. City of Quincy" on Justia Law

After a jury trial, Defendant was convicted of possessing drugs with intent to distribute and possessing a firearm in furtherance of a drug trafficking crime. Defendant appealed his conviction and sentence, asserting that judicial misconduct, inadequate preparation time, and ineffective assistance of counsel denied him a fair proceeding. The First Circuit affirmed Defendant’s conviction but remanded the action for further proceedings, holding (1) the trial judge’s conduct of the trial did not prejudice Defendant; (2) the district court did not abuse its discretion in denying Defendant’s motion to continue the trial date; and (3) there were sufficient signs of attorney ineffectiveness to remand for an evidentiary hearing. View "United States v. Marquez-Perez" on Justia Law

Plaintiffs filed a class action suit on behalf of approximately 1.5 million Puerto Rican residents who are customers of Autoridad de Energia Electrica de Puerto Rico (PREPA), alleging that PREPA used a portion of its overall revenue to subsidize municipalities’ energy use. Plaintiffs claimed violations of the Takings Clause and their procedural due process rights because PREPA deprived them of their property interest in electricity and/or the funds they paid for electricity. The district court granted summary judgment for PREPA,concluding that Plaintiffs had not identified a valid property interest, that no taking had occurred, and that no valid procedural due process claim existed. The First Circuit affirmed on other grounds, holding that because Plaintiffs did not identify a valid property interest, they did not have standing to bring the takings and due process claims. View "Santiago-Ramos v. Autoridad de Energia Electrica de P.R." on Justia Law

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