Justia Civil Rights Opinion Summaries

Articles Posted in US Court of Appeals for the First Circuit
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In this case, the plaintiffs, Susan Johnson and Jocelyne Welch, brought an action against the City of Biddeford, Chief of Police Roger P. Beapure, and Officer Edward Dexter of the Biddeford Police Department, alleging a violation of substantive due process rights under the state-created danger test. Johnson and Welch's action stems from a violent incident involving their landlord, James Pak. Pak became agitated about the number of cars parked in the driveway of the property he rented to Johnson and her son, Thompson. During a confrontation, Pak made gun-shaped hand gestures and said "bang." Thompson called the police and Officer Dexter responded.Officer Dexter spoke with both parties separately. During his conversation with Pak, Pak expressed his anger and frustration, making various threatening remarks. Despite these threats, Officer Dexter did not arrest, detain, or initiate a mental health intervention for Pak. After speaking with Pak, Officer Dexter returned to Johnson and Thompson's apartment, informing them that Pak was "obviously extremely upset" but did not relay the specific threats made by Pak. A few minutes after Officer Dexter left, Pak entered Johnson and Thompson's apartment and shot Johnson, Thompson, and Welch.On appeal, the United States Court of Appeals for the First Circuit held that Officer Dexter was entitled to qualified immunity against the plaintiffs' claim of violation of substantive due process rights under the enhancement-of-danger prong of the state-created danger test. The court found that a reasonable officer in Dexter's position would not have understood, based on the facts of the case, that he was violating any such rights by his actions and inactions. View "Johnson v. City of Biddeford" on Justia Law

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In this case, the plaintiff, an African-American male, brought an employment discrimination lawsuit against his former employer, Genzyme Therapeutic Products, LP, and one of its executives. The plaintiff alleged racial discrimination, harassment, and retaliation. The district court granted summary judgment in favor of the defendants, finding that the plaintiff failed to provide sufficient proof that the employer's stated rationale for certain adverse employment actions was pretextual. The court also found that the plaintiff did not provide enough evidence to demonstrate a causal connection between the alleged protected conduct (filing a complaint against another employee for racial discrimination) and the adverse action (a poor performance review).On appeal, the United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court held that the plaintiff failed to establish that there was a genuine issue of material fact as to whether the employer's proffered reason for the negative performance review was a pretext for discrimination. The court noted that the plaintiff's argument relied heavily on speculation and conjecture rather than definite and competent evidence. The court also highlighted that even if the plaintiff's direct manager thought he was deserving of a higher rating, this did not shed light on the executive's view, nor did it allow a reasonable juror to find that the executive's stated rationale was pretextual. The court concluded that a single racially tinged comment made by the executive was not sufficient to prove discriminatory intent. View "Boykin v. Genzyme Therapeutic Products, LP" on Justia Law

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In the case before the United States Court of Appeals for the First Circuit, plaintiff Shawn McBreairty claimed that a local school-board policy violated his First Amendment rights by restricting what he could say at the board's public meetings. McBreairty sought a temporary restraining order and preliminary injunction against the policy. The defendants were the School Board of Regional School Unit 22 in Maine and Heath Miller, the Board's chair. The policy in question prohibited public complaints or allegations against any school system employee or student during board meetings. It also allowed the Chair to terminate any presentation that violated these guidelines or the privacy rights of others.McBreairty had been stopped from criticizing school employees during two separate board meetings. Each time, after he mentioned a teacher's name and criticized their practices, the Chair warned him to stop, the video feed was cut, and the police were contacted to remove him from the premises. He was not arrested or charged with any crime on either occasion.The District Court denied McBreairty's request for a temporary restraining order and preliminary injunction. He then appealed this decision. While this appeal was pending, the School Board amended the policy in question.The Court of Appeals vacated the decision of the District Court, not on the merits of McBreairty's First Amendment claims, but on the grounds that he lacked standing to seek the injunctive relief at issue. The Court reasoned that McBreairty did not sufficiently demonstrate an intention to engage in the allegedly restricted speech at future board meetings, which is necessary to establish a concrete, live dispute rather than a hypothetical one. The Court thus concluded that it did not have jurisdiction to hear the case under Article III of the Constitution. The case was remanded to the District Court for further proceedings. View "McBreairty v. Miller" on Justia Law

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A pregnant inmate, Lidia Lech, filed a lawsuit against several healthcare providers and staff at the Western Massachusetts Regional Women's Correctional Center (WCC), alleging that they ignored her serious medical symptoms and denied her requests to go to the hospital, resulting in the stillbirth of her baby. The district court permitted most of Lech's claims to proceed to trial, but granted summary judgment in favor of one of the correctional officers. The jury returned a verdict in favor of the defense. On appeal, the United States Court of Appeals for the First Circuit found that the district court abused its discretion in two evidentiary rulings. The first error was allowing the defense to use Lech's recorded phone calls to impugn her character for truthfulness. The second error was excluding testimony from Lech's friend, which would have corroborated her version of events. The court concluded that at least one of these evidentiary rulings was not harmless, vacated the jury verdict, and remanded for a new trial against most of the defendants. However, the court affirmed the district court's grant of summary judgment to the correctional officer, as well as the jury verdict in favor of one of the medical providers. View "Lech v. Von Goeler" on Justia Law

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Clare Mundell worked as a licensed clinical psychologist for Acadia Hospital in Maine. She discovered that her male colleagues were paid significantly more than her for comparable work. Mundell brought a sex discrimination action against Acadia under federal and state law, specifically the Maine Equal Pay Law ("MEPL"). The district court found Acadia liable under the MEPL and awarded Mundell treble damages. On appeal, Acadia argued that the district court erred in holding that Mundell could prevail without establishing Acadia's discriminatory intent and because Acadia claimed a reasonable-factor-other-than-sex defense to explain the pay difference. The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court held that the MEPL does not impose an intent requirement on a plaintiff, nor does it permit a defendant to rely on a catch-all affirmative defense such as market factors to explain pay disparity. The court also concluded that treble damages are available for MEPL violations. View "Mundell v. Acadia Hospital Corp." on Justia Law

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In a case involving an attorney father, Scott D. Pitta, and the Bridgewater-Raynham Regional School District, the United States Court of Appeals for the First Circuit affirmed the district court's dismissal of Pitta's claim that he had a First Amendment right to video record a private meeting discussing his child's Individualized Educational Program (IEP). The court found that an IEP Team Meeting does not occur in a public space, is closed to the public, and involves discussion of highly sensitive information about a student. Furthermore, the court stated that public school teachers and administrators carrying out their IEP obligations are not akin to the "public officials" in previous cases that established a First Amendment right to record. The court also noted that Pitta's claimed right to record was not linked to the public's right to receive information. Finally, the court reasoned that even if there were a First Amendment right to record such meetings, the school district's prohibition of video recording served a significant governmental interest and was narrowly tailored to promoting candid conversations and protecting sensitive information during IEP discussions. View "Pitta v. Medeiros" on Justia Law

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In November 2010, Mario Cruzado was brought in for questioning by Boston police regarding the death of Frederick Allen III, a gay, African-American man. During the interview, Cruzado used a racial slur when referring to a picture of Allen. In 2012, Cruzado was charged and convicted of first-degree murder for killing Allen and was sentenced to life imprisonment. Cruzado's conviction was based, in part, on the recorded police interview, which was admitted as evidence to show Cruzado's racial animus and thus his motive for the killing. Cruzado appealed his conviction and the denial of his motion for a new trial, arguing that the admission of the recorded police interview violated his right to due process.The Massachusetts Supreme Judicial Court (SJC) consolidated Cruzado's appeals and denied them, holding that the state trial court did not abuse its discretion in determining that the probative value of the evidence outweighed its prejudicial effect. The SJC also stated that Cruzado's argument that the admission of the racial slur violated his due process rights was unavailing, as the slur came from his own mouth. Cruzado then filed a federal petition for writ of habeas corpus, which was denied by the United States District Court for the District of Massachusetts.In an appeal to the United States Court of Appeals for the First Circuit, Cruzado argued that the admission of the recorded police interview violated his right to due process. The Court held that Cruzado's due process rights were not violated, as the racial slur held substantial probative value in demonstrating whether the crime may have been partially motivated by racial animus. The Court also noted that the potential prejudicial effect of the racial slur was mitigated by the trial judge conducting an individual voir dire of potential jurors to eliminate potential bias and that Cruzado did not request a limiting instruction to disregard or not infer anything from his use of the racial slur. Therefore, the United States Court of Appeals for the First Circuit affirmed the District Court's rejection of Cruzado's petition for habeas relief. View "Cruzado v. Alves" on Justia Law

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This case involves the Boston Parent Coalition for Academic Excellence Corp., which challenged the temporary admissions plan for three selective public schools in Boston. The admissions plan was based on students' grade point averages (GPAs), zip codes, and family income, rather than on standardized test scores. The Coalition claimed that the plan had a disparate impact on White and Asian students and violated the Equal Protection Clause of the Fourteenth Amendment and Massachusetts law.The United States Court of Appeals for the First Circuit found that the Coalition's claim lacked merit. It held that the Coalition failed to show any relevant disparate impact on White and Asian students, who were over-represented among successful applicants compared to their percentages of the city's school-age population. The court also found that the Coalition failed to demonstrate that the plan was motivated by invidious discriminatory intent. It pointed out that the Plan's selection criteria, which included residence, family income, and GPA, could hardly be deemed unreasonable.The court noted that any distinction between adopting a criterion (like family income) notwithstanding its tendency to increase diversity, and adopting the criterion because it likely increases diversity, would, in practice, be largely in the eye of the labeler. It emphasized that the entire point of the Equal Protection Clause is that treating someone differently because of their skin color is not like treating them differently because they are from a city or from a suburb.The court also rejected the Coalition's appeal of the district court's denial of its motion under Federal Rule of Civil Procedure 60(b), which sought relief from the judgment based on newly discovered evidence that some members of the School Committee harbored racial animus. The court found that the district court did not abuse its discretion in denying the motion, as the Coalition had failed to show that the newly discovered evidence was of such a nature that it would probably change the result were a new trial to be granted.The court therefore affirmed the judgment of the district court. View "Boston Parent Coalition for Acad. Excellence Corp. v. The School Committee of the City of Boston" on Justia Law

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A plaintiff, Elvin Torres-Estrada, brought claims against several Federal Bureau of Investigation (FBI) agents and the United States under the Federal Tort Claims Act (FTCA) and Bivens, alleging violations of his constitutional and statutory rights. The district court dismissed his complaint, arguing that some of his claims were not filed within the required time frame and that the FTCA's discretionary function exception stripped the court of jurisdiction over his other claims. Torres-Estrada appealed the dismissal, arguing that his claims are timely, the discretionary function exception does not apply, and even if it does, it does not cover the alleged misconduct of the FBI.The United States Court of Appeals for the First Circuit held that the district court erred in its interpretation of the discretionary function exception. The court explained that this exception does not serve as a bar to FTCA tort claims that plausibly allege constitutional violations. In addition, at least two of Torres-Estrada's claims could be subject to the "continuing violation" doctrine, which means the district court erred in dismissing his claims as untimely without considering this doctrine. Given that new facts have emerged throughout the litigation, the court granted Torres-Estrada leave to amend his complaint. Therefore, the court affirmed in part, reversed in part, and remanded the case for further proceedings.The background facts of the case are that Torres-Estrada was detained at the Metropolitan Detention Center (MDC) in Guaynabo, Puerto Rico, pending prosecution for drug and money laundering offenses. During this time, he was investigated by the FBI as a potential suspect in the murder of a correctional officer at the MDC. Torres-Estrada alleges that the FBI violated his rights through various actions, including the use of informants to elicit incriminating statements about the murder, subjecting him to invasive body searches, and maintaining records falsely linking him to the murder. View "Torres-Estrada v. Cases" on Justia Law

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The First Circuit affirmed the decision of the district court granting summary judgment to Defendants, several city officials of the City of Gloucester, Massachusetts, in this First Amendment action brought by Plaintiff, the Harbormaster of the city, holding that Defendants were entitled to qualified immunity.In his complaint, Plaintiff claimed that Defendants violated his rights under the First Amendment by retaliating against him for his giving expert testimony in a maritime tort dispute. The district court granted summary judgment for Defendants, concluding that they were entitled to qualified immunity. The First Circuit affirmed, holding that, at the time of the alleged retaliation, the law did not clearly establish that the value of Plaintiff's speech outweighed the city's interest in the efficient provision of public services by the Harbormaster's office. View "Ciarametaro v. City of Gloucester" on Justia Law