Justia Civil Rights Opinion Summaries

Articles Posted in US Court of Appeals for the First Circuit
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The First Circuit vacated the judgment of the district court in favor of Defendant on Plaintiff's claim that Defendant failed properly to accommodate his disability under the Americans with Disabilities Act (ADA), 42 U.S.C. 1210 et seq., and the Maine Humans Rights Act (MHRA), Me. Rev. Stat. 5, 4551 et seq., holding that the district court committed prejudicial error in instructing the jury.On appeal, Plaintiff argued that the district court erred in instructing the jury that to succeed on a claim that an employer failed to provide a reasonable accommodation, a plaintiff must prove that he needed an accommodation to perform the essential functions of his job. The First Circuit agreed, holding (1) by instructing the jury that an employee must demonstrate that he needed an accommodation to perform the essential functions of his job, the district court wrongly limited Plaintiff's potential liability; and (2) the error was prejudicial. View "Bell v. O'Reilly Auto Enterprises, LLC" on Justia Law

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The First Circuit affirmed the judgment of the district court denying Defendants' motions for judgment as a matter of law or, in the alternative, for a new trial or remittitur, holding that the trial court properly found Defendants liable for conspiracy to violate Plaintiff's civil rights.Plaintiff suffered a head injury at the Andover, Massachusetts State Police Barracks. Plaintiff filed this action against the three officers involved in his booking, including Trooper James J. Foley, alleging several federal and state causes of action. After a trial, the jury found Foley liable on six claims, including the use of excessive force, and all three officers liable for conspiracy to violate Plaintiff's civil rights. On appeal, Defendants argued that the district court erred in denying their motions for judgment as a matter of law or, in the alternative, for a new trial or remittitur. The First Circuit affirmed, holding that the district court (1) correctly denied Defendants' post-verdict motions for judgment as a matter of law on each of the counts for which they were found liable; (2) did not abuse its discretion in declining to order a new trial; and (3) did not err in denying Foley's motion for remittitur. View "Sanchez v. Foley" on Justia Law

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The First Circuit reversed the decision of the district court denying Defendant's motion to dismiss his indictment under the Double Jeopardy Clause of the United States Constitution based on his prior conviction in a Commonwealth court for a local drug offense, holding that Defendant met his burden to make a prima facie case that he had been prosecuted twice for the same conduct under equivalent criminal laws.On March 15, 2016, Defendant pleaded guilty to a violation of Article 406 of the Puerto Rico Controlled Substances Act. About sixteen months later, Defendant was named in a federal indictment charging him with five drug-related federal offenses, including conspiracy to possess with intent to distribute controlled substances, in violation of 21 U.S.c. 846. Defendant moved to dismiss the section 846 conspiracy count on double jeopardy grounds, alleging that his prior Article 406 conviction was for the same criminal conduct that the section 846 count charged him with committing. The district court denied the motion. The First Circuit reversed, holding that Defendant met his burden of presenting evidence to establish a prima facie non frivolous double jeopardy claim, and the government failed to meet its burden to rebut it. View "United States v. Reyes-Correa" on Justia Law

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The First Circuit reversed Defendant's conviction for transporting a minor in interstate or foreign commerce or in any commonwealth, territory or possession of the United States with the intent to engage in criminal sexual activity, holding that the trial judge violated Defendant's Sixth Amendment right to in-person confrontation when he allowed the victim to testify by two-way close-circuit television and without making specific on the record findings.Specifically, the First Circuit held (1) 2423(a)'s ban on transporting a minor to commit a sex crime applies to transportation without Puerto Rico, which is a "commonwealth" of the United States under the statute; (2) there was sufficient evidence to support the conviction; (3) the judge properly instructed the jury on the elements of the Puerto Rico crimes the government alleged Defendant had intended to commit at her destination; but (4) the judge violated Defendant's right to confront the victim in person absent a compelling need for remote testimony, and the error was not harmless beyond a reasonable doubt. View "United States v. Cotto-Flores" on Justia Law

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The First Circuit held that the district court did not abuse its discretion in granting a preliminary injunction prohibiting Defendants - Maine's Cape Elizabeth School District and officials of Cape Elizabeth High School - from suspending A.M., a student at the high school, holding that the district court did not abuse its discretion in issuing the preliminary injunction.A.M. anonymously posted a sticky note on a mirror at the high school girls' bathroom stating, "There's a rapist in our school and you know who it is." Defendants determined that the note constituted bullying under the school's policies and imposed a three-day suspension on A.M. Through her mother, A.M. filed a complaint requesting that the district court enjoin Defendants from suspending her, arguing, among other things, that the suspension violated her right to free expression under the First Amendment. A.M. also moved for a preliminary injunction. The district court granted a preliminary injunction based on A.M.'s First Amendment claim. The First Circuit affirmed, holding that A.M. showed a likelihood of success in demonstrating that her sticky note was constitutionally protected speech. View "Norris v. Cape Elizabeth School District" on Justia Law

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The First Circuit vacated the district court's dismissal of Plaintiff's claim for a violation of Title IX, 20 U.S.C. 1961 et seq., and affirmed the district court's dismissal of the other claims, holding that Plaintiff's allegations told a plausible story of deliberate indifference by school officials to repeated and severe sexual harassment.Plaintiff alleged that she was the victim of several incidents of sexual assault and harassment while she was a student at the Pawtucket Learning Academy in Rhode Island. Plaintiff sued twenty-one defendants under sixteen different counts. The district court dismissed the entire action. The First Circuit vacated the judgment in part, holding that based on the facts set forth in Plaintiff's complaint it was plausible that a fact-finder could find that the conduct of school officials caused Plaintiff's harassment in some way or made Plaintiff liable or vulnerable to harassment. View "Doe v. Pawtucket School Department" on Justia Law

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The First Circuit reversed the decision of the district court denying Defendant's motion to suppress evidence obtained through a search and seizure of his vehicle, holding that the warrantless seizure of Defendant's vehicle was unlawful.Defendant was convicted of possession of marijuana and unlawful possession of a firearm by a prohibited person. On appeal, Defendant argued that law enforcement officers had no right to seize and tow his car, thereby setting it up for the inventory search that produced the evidence leading to his conviction. The First Circuit agreed, holding (1) the community caretaking exception to the warrant requirement did not apply in this case; (2) the government did not have probable cause to seize the vehicle pursuant to the Puerto Rico Uniform Forfeiture Act; and (3) the doctrine of inevitable discovery did not apply to justify the warrantless seizure of Defendant's vehicle. View "United States v. Del Rosario-Acosta" on Justia Law

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In this case involving the bombing at the 2013 Boston Marathon, the First Circuit vacated Dzhokhar Tsarnaev's death sentences and reversed his three convictions for carrying a firearm during crimes of violence, holding that the judge did not meet the standard set by Patriarca v. United States, 402 F.2d 314, 318 (1st Cir. 1968), and erred in denying Tsarnaev's post-trial motion for judgments of acquittal.A jury convicted Tsarnaev of all charges for which he was indicted arising from the Boston Marathon bombing. The district judge imposed a sentence of death on six of the death-eligible counts. On appeal, Tsarnaev argued, among other things, that the judge erred in the way he handled Tsarnaev's venue-change motions and the jury-selection process. The First Circuit held (1) the trial judge in this high-profile case did not fully comply with Patriarca by running a voir dire sufficient to identify prejudice, which provided a sufficient ground to vacate Tsarnaev's death sentences; and (2) because not each of the underlying offenses constituted a crime of violence, three of Defendant's convictions for carrying a firearm for crimes of violence are reversed. View "United States v. Tsarnaev" on Justia Law

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The First Circuit affirmed Defendant's plea-based conviction for conspiracy to possess with intent to distribute, holding that Defendant's prosecution did not violate constitutional double jeopardy protections.In 2011, Defendant pleaded guilty in the United States District Court of the District of Puerto Rico to conspiracy to possess with intent to distribute. In 2016, Defendant pleaded guilty in the United States District Court of the District of Puerto Rico to a drug trafficking conspiracy charge. Defendant appealed, arguing that his double jeopardy rights were violated because the two conspiracy prosecutions concerned conduct at the same "places" and charged him with violations of "the same statutory provision." The First Circuit affirmed, holding that there was a rational basis to conduct that the two conspiracies were distinct. View "United States v. Perez-Gonzalez" on Justia Law

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The First Circuit affirmed Defendant's convictions and sentence for robbing an individual of a United States passport, brandishing a firearm during a crime of violence, and possession of a firearm by a convicted felon, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the First Circuit held (1) the district court did not abuse its discretion when it denied Defendant's request for substitution of counsel; (2) Defendant's conviction under 18 U.S.C. 2112 for robbery properly served as the predicate "crime of violence" for Defendant's sentence for brandishing a firearm under 18 U.S.C. 924(c)(3)(A); and (3) under a plain error standard, Defendant did not establish a prima facie nonfrivolous double jeopardy claim. View "United States v. Almonte-Nunez" on Justia Law