Justia Civil Rights Opinion Summaries

Plaintiff was allegedly raped and assaulted by an officer of the Fall River Police Department. Plaintiff filed federal civil rights and state law negligence claims against the City of Fall River, Massachusetts, and Daniel Racine, the Fall River Police Chief. The district court dismissed the claims against Racine and the City for failure to state a claim. Plaintiff appealed the dismissal of the 42 U.S. 1983 claims against Racine and the City and her negligent hiring, training, and supervision claim against the City. The First Circuit affirmed, holding that the complaint failed to state a plausible claim for holding Racine and the City liable under section 1983 or under the law of negligence in Massachusetts. View "Saldivar v. Racine" on Justia Law

Defendant entered a conditional guilty plea to being a felon in possession of a firearm, reserving his right to appeal the denial of his motion to suppress. Defendant appealed, arguing that the trial court erred in failing to suppress (1) evidence obtained after a stop and frisk of Defendant; and (2) Defendant’s statement that he was “drug dealer” in answer to the booking officer’s question about his employment. The First Circuit affirmed the trial judge’s refusal to suppress the incriminating evidence and comment, holding (1) there was no constitutional violation in the stop and frisk of Defendant; and (2) the booking exception to Miranda applied to the employment question asked of Defendant. View "United States v. Sanchez" on Justia Law

Plaintiffs - all minors at the relevant times - were all trafficked through advertisements posted on Backpage.com. Plaintiffs filed suit against Backpage, alleging that Backpage tailored its website to facilitate sex traffickers’ efforts to advertise their victims on the website, leading to Appellants’ victimization. Specifically, Plaintiffs alleged that Backpage engaged in sex trafficking of minors as defined by the Trafficking Victims Protection Reauthorization Act and its Massachusetts counterpart, violations of Mass. Gen. Laws ch. 93A, and abridgments of intellectual property rights. The district court dismissed the action for failure to state claims upon which relief could be granted. The First Circuit affirmed, holding that the facts alleged here did not state grounds that Plaintiffs were plausibly entitled to relief on their claims. View "Doe No. 1 v. Backpage.com, LLC" on Justia Law

After a trial in 2003, Petitioner was convicted of rape in a Massachusetts state court. The Supreme Judicial Court (SJC) affirmed. In 2008, Petitioner sought a new trial claiming that his counsel on appeal had been ineffective for failing to argue that Petitioner’s speedy-trial rights had been violated. The superior court denied the motion, and the SJC affirmed. In 2013, Petitioner filed a petition for habeas corpus in federal district court, claiming that his Sixth Amendment rights to a speedy trial and effective assistance of counsel were violated during his trial. The district court denied the petition. The First Circuit affirmed, holding the SJC’s conclusion that Petitioner’s constitutional speedy-trial rights had not been violated and that Petitioner had not received ineffective assistance of counsel did not violate the standards of the Antiterrorism and Effective Death Penalty Act. View "Butler v. Mitchell" on Justia Law

After a jury trial, fugitive James “Whitey” Bulger, the former head of an organized crime syndicate in Boston, was found guilty of racketeering, the murder of eleven individuals, multiple instances of extortion and money laundering, and narcotics distribution and conspiracy. Bulger was sentenced to life in prison. Bulger appealed, alleging that he was deprived of his right to a fair trial when the trial court and the government erred in various ways both prior to and during trial. The First Circuit affirmed, holding that Bulger received a fair trial and that none of the court’s or government’s alleged errors warranted reversal of Bulger’s conviction. View "United States v. Bulger" on Justia Law

As part of an investigation into the 2008 tax liability of Defendant and his wife, the IRS served a summons on Defendant requiring him to appear for an interview and to produce banking and financial records. Defendant refused to answer any questions and did not provide the requested documents. The government filed a petition to enforce the portion of the summons seeking the production of the documents. In response, Defendant asserted a Fifth Amendment claim of privilege over his compelled act of producing the documents. The district court ultimately ordered Defendant to produce all of the requested documents, including those covered and those not covered by the Bank Secrecy Act (BSA). The First Circuit affirmed the district court’s enforcement of the summons as to documents required to be kept under the BSA and vacated the enforcement of the summons for documents not subject to the BSA, holding that a taxpayer must comply with an IRS summons for documents he or she is required to keep under the BSA, where the IRS is civilly investigating the failure to pay taxes and the matter has not been referred for criminal prosecution. View "United States v. Chen" on Justia Law

Plaintiff sued the Commonwealth of Puerto Rico and three other Puerto Rico governmental entities under Title II of the Americans with Disabilities Act, alleging that, in ordering her committed to a psychiatric hospital, Defendants discriminated against her and denied public services to her because she was “regarded as” having a physical or mental impairment within the meaning of the ADA. The district court dismissed Plaintiff’s suit as time-barred after applying the one-year Puerto Rico statute of limitations. At issue on appeal was whether the limitations period set forth in 28 U.S.C. 1658 applied to Plaintiff’s case. The First Circuit reversed, holding that Plaintiff’s claims are governed by the catch-all limitations period set forth in section 1658. Remanded. View "Mercado v. Commonwealth of P.R." on Justia Law

After a jury trial, Defendant was convicted of being a felon in possession of a firearm. The district court sentenced Defendant to seventy-four months of imprisonment. Defendant appealed, challenging primarily the denial of his pretrial motion to bar a government witness from identifying him at trial. The Supreme Court affirmed the conviction but vacated the sentence, holding (1) the admission of the identification evidence did not violate Defendant’s due process rights, as the existence of the video recording of the witness’s pretrial identification of Defendant in a photo array guarded against the harm that the district court might have otherwise guarded against by excluding the identification; (2) the record is not fully developed to establish Defendant’s claim of ineffective assistance in relation to sentencing, and so Defendant’s sentence must vacated to allow consideration of the Stickland v. Washington issue on remand; and (3) there was no merit to Defendant’s remaining claims. View "United States v. Constant" on Justia Law

While working for Wal-Mart Stores East, L.P., Plaintiff claimed a disability arising from her “pregnancy status.” Plaintiff, however, claimed she could perform the essential functions of her job with a reasonable accommodation. Wal-Mart refused Plaintiff’s accommodation request and later terminated her. Plaintiff brought this action against Wal-Mart claiming violations of the Americans with Disabilities Act (ADA) and the New Hampshire Civil Rights Act. The district court granted summary judgment in favor of Wal-Mart on all claims. The First Circuit affirmed, holding (1) the trial judge correctly granted summary judgment to Wal-Mart on the ADA claim, as Plaintiff failed to create a trial worthy issue as to whether she could have performed an essential function of her job with or without reasonable accommodation; and (2) Plaintiff’s challenges to the dismissal of her state-law claims of unlawful disability discrimination and retaliation were without merit. View "Lang v. Wal-Mart Stores East, L.P." on Justia Law

Defendant was arrested for driving under the influence. Shortly after he was brought by Puerto Rico Police Department officers to the police station, he died in a holding cell. Defendant’s family members and estate filed suit, alleging that Defendants - Officer Perez, Sergeant Rodriguez, and Superintendent Toledo - used excessive force against Defendant and denied him needed medical care in violation of 42 U.S.C. 1983. The district court granted summary judgment in favor of Defendants on the grounds of sovereign immunity and insufficient evidence. Plaintiffs appealed, challenging only the district court’s decisions on the excessive force and denial of medical care claims and supervisory liability. The First Circuit (1) reversed and remanded for trial Plaintiffs’ claims against Perez and Rodriguez, holding (i) Perez and Rodriguez were not entitled to qualified immunity on the excessive force claim or the denial of medical care claim; and (2) affirmed the district court’s grant of summary judgment on Plaintiffs’ claims against Toledo, holding that Plaintiffs did not adequately plead facts going to Toledo’s liability. View "Miranda-Rivera v. Toledo-Davila" on Justia Law