Justia Civil Rights Opinion Summaries

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

Plaintiff, a former employee of the Transportation Security Administration, filed suit against David Johnson, the Supervisory Air Marshal in Charge at the Boston Field Office of the Federal Air Marshals Service where Plaintiff worked, and the Department of Homeland Security (DHS), alleging sex discrimination and sex harassment in violation of Title VII of the Civil Rights Act of 1964. The district court dismissed Johnson from the suit and subsequently granted summary judgment in favor of DHS. The Supreme Court reversed the entry of summary judgment, holding (1) the district court erred by requiring Plaintiff to present direct evidence to establish sex discrimination under the mixed-motives theory; (2) the district court erred by requiring Plaintiff to show that Johnson’s conduct was both severe and pervasive to establish sex harassment; and (3) there was sufficient circumstantial evidence from which a reasonable jury could find in Plaintiff’s favor on both of her claims. Remanded. View "Burns v. Johnson" on Justia Law

Defendant pleaded guilty to a federal indictment charging him with possession of a firearm and ammunition by an unlawful user of a controlled substance and possession of a machine-gun. Before sentencing, the probation department prepared a presentence investigation report (the PSI report) that contained information about Defendant’s participation in a musical group that recorded songs that promote violence and drugs. Defendant objected to the PSI report on the ground that consideration of his performances with the musical group would violate his First Amendment rights. The sentencing court ruled that it could consider Defendant’s musical pursuits in deciding the sentence and then sentenced Defendant to a ninety-six-month term of immurement, which was more than three times the top of the Guidelines Sentencing Range. The First Circuit vacated Defendant’s sentence and remanded for resentencing, holding that the sentencing court’s sentencing rationale was implausible because the court heavily relied on protected conduct that was not tied through extrinsic evidence to any relevant sentencing factor. View "United States v. Alvarez-Nunez" on Justia Law

Defendant was convicted under a Massachusetts statute of possessing child pornography as a repeat offender. The Massachusetts Appeals Court (MAC) affirmed. Defendant later filed a petition for federal habeas relief under 28 U.S.C. 2254. The district court denied the petition. The First Circuit affirmed, holding (1) Defendant’s claim that possession falls within the protection of the First Amendment when the photograph depicts a merely nude minor but is not an expression of lewdness was unavailing; (2) the MAC did not act contrary to or unreasonably apply clear law as declared by the Supreme Court or apply it to facts and factual inferences not reasonably supported by the evidence; and (3) the certificate of appealability the district court granted Defendant did not extend to a claim that the evidence was inadequate to support a finding beyond a reasonable doubt of every element of the offense. View "Sullivan v. Marchilli" on Justia Law