Justia Civil Rights Opinion SummariesArticles Posted in US Court of Appeals for the First Circuit
Woods v. Medeiros
The First Circuit affirmed the judgment of the district court denying Appellant's petition for a writ of habeas corpus, holding that Appellant was not entitled to relief.Appellant was convicted in Massachusetts of murder in the first degree. The Massachusetts Supreme Judicial Court affirmed. In his habeas petition, Appellant argued that testimony was erroneously introduced at trial that he had given to a grand jury without being advised of his privilege against self-incrimination. Appellant presented this same argument in his challenge to his conviction on appeal and in his appeal of the denial of his motion for a new trial, all without success. The district court denied Appellant's habeas petition. The Supreme Judicial Court affirmed, holding that Appellant's Fifth Amendment rights were not violated by the admission of his grand jury testimony. View "Woods v. Medeiros" on Justia Law
United States v. Sylvester
The First Circuit affirmed Defendant's conviction of one count of possession with intent to distribute various controlled substance and one count of possession of a firearm in furtherance of a drug-trafficking crime, holding that the district court did not err in denying Defendant's motion to suppress.Defendant sought to suppress drug evidence and a firearm seized pursuant to a search warrant for the car he was driving when he was arrested on an outstanding federal warrant. In his motion, Defendant argued that the search warrant for the car was invalid because it was issued based on an unlawful inventory search. The First Circuit affirmed the denial of Defendant's motion to suppress, holding that the district court did not err in concluding that (1) the officers had an objectively reasonable non-investigatory purpose; and (2) the inventory search of the car was unlawful. View "United States v. Sylvester" on Justia Law
Puig Martinez v. Novo Nordisk Inc.
The First Circuit affirmed the order of the district court granting summary judgment in favor of Novo Nordisk Inc. and dismissing Plaintiffs' age discrimination claims, holding that the district court did not err.During a global reorganization, Novo Nordisk terminated Plaintiffs from their jobs based in Puerto Rico and did not select Plaintiffs for post-reorganization positions. Plaintiffs brought this complaint alleging that Novo Nordisk violated Puerto Rico's statutes prohibiting age discrimination in employment and penalizing termination without just cause. The district court granted summary judgment in favor of Novo Nordisk on all of Plaintiffs' claims. The First Circuit affirmed, holding that summary judgment was properly granted. View "Puig Martinez v. Novo Nordisk Inc." on Justia Law
United States v. Austin
The First Circuit denied Defendant's appeal of his conviction for unlawful possession of a firearm by a prohibited person in violation of 18 U.S.C. 922(g) and 924(a)(2), holding that the district court did not commit plain error by accepting Defendant's guilty plea and in denying his motion to suppress.Following Defendant's plea, the Supreme Court decided Rehaif v. United States, 139 S. Ct. 2191 (2019), under which the government must prove that the defendant knew he had the relevant status prohibiting possession. On appeal, Defendant argued (1) under Rehaif, the district court committed plain error during his plea colloquy by failing to inform him that the government was required to prove that he knew he was prohibited from possessing firearms; and (2) the district court erred by denying his motion to suppress. The First Circuit affirmed, holding (1) the search warrant issued for Defendant's residence was supported by probable cause; and (2) the district court did not plainly err by accepting Defendant's guilty plea. View "United States v. Austin" on Justia Law
United States v. Torres-Santana
The First Circuit affirmed Defendant's eighteen-month sentence imposed for violating the conditions of his supervised release by committing a new crime, holding that Defendant had not suffered any prejudice from the delay in his supervised release revocation hearing.The revocation hearing concluded thirty months after the the United States Probation Office petitioned the district court to revoke supervised release and eight months after Defendant was taken into federal custody. On appeal, Defendant argued that his revocation hearing was unreasonably delayed in violation of his rights under Fed. R. Crim. P. 32.1 and the due process clause of the United States Constitution. The First Circuit affirmed, holding that Defendant's claim failed on the prejudice prong. View "United States v. Torres-Santana" on Justia Law
United States v. Millan-Machuca
The First Circuit affirmed the judgment of the trial court convicting Defendants - Rolando Millan-Machuca, Roberto Casado-Berrios, Miguel Rivera-Calcano, and Giordano Santana-Meledez - of racketeering and drug trafficking conspiracies, holding that Defendants' claims on appeal were unavailing.Specifically, the First Circuit held (1) the evidence was sufficient to support the convictions; (2) there was no merit to Defendants' claims of error in the admission of certain evidence; (3) Defendants' sentences were reasonable; and (4) Rivera-Calcano's claims of ineffective assistance of counsel at his sentencing hearing is dismissed without prejudice. View "United States v. Millan-Machuca" on Justia Law
Gonzalez-Bermudez v. Abbott Laboratories P.R. Inc.
The First Circuit affirmed in part and reversed in part the judgment of the district court granting judgment in favor of Plaintiff in this discrimination and retaliation action, holding that Defendant was entitled to judgment as a matter of law in part.Plaintiff filed suit against Abbott Laboratories alleging age discrimination and retaliation under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621-34, Puerto Rico Law 100 and Puerto Rico Law 155. A jury found for Plaintiff and awarded $4 million for emotional distress and $250,000 for back pay. The district court entered judgment against Abbott on all counts but reduced the damages to just over $500,000. The First Circuit reversed in part, holding (1) Abbott was entitled to judgment as a matter of law on Plaintiff's ADEA claims and her corresponding claims under Law 100 and Law 115; but (2) Abbott failed to preserve its challenge to a separate finding that Abbott retaliated against Plaintiff for reporting to the State Insurance Fund. View "Gonzalez-Bermudez v. Abbott Laboratories P.R. Inc." on Justia Law
Casco, Inc. v. John Deere Construction & Forestry Co.
The First Circuit affirmed the judgment of the district court dismissing Casco, Inc.'s claim for dolus under Article 1902 of the Puerto Rico Civil Code, P.R. Laws Ann. tit. 31, 3408, awarding relief to Casco on its claims for unjust impairment and unjust termination under Puerto Rico's Dealer Protection Act, P.R. Laws Ann. tit. 10, 278 (Law 75) and granting judgment on John Deere Construction & Forestry Company's counterclaim to recover amounts owed to it by Casco, holding that Casco was not entitled to relief on its allegations of error.Specifically, the First Circuit held (1) the jury's findings of liability against Deere under Law 75 were not unreasonable, and the district court correctly denied Deere's post-judgment motions regarding the Law 75 claims; (2) the district court properly dismissed Casco's dolus claim as not legally viable; (3) the district court correctly granted relief on Deere's counterclaim; and (4) the district court did not abuse its discretion by declining to upset the jury award or order a new trial on damages. View "Casco, Inc. v. John Deere Construction & Forestry Co." on Justia Law
Joseph v. Lincare, Inc.
The First Circuit vacated the order of the district court granting summary judgment in favor of Lincare, Inc. and rejecting Jeffrey Joseph's racial discrimination challenge to the termination of his employment, holding that the district court erred in excluding several documents from the summary judgment record and that Joseph had enough evidence to warrant a trial.On appeal, Joseph argued, among other things, that the district court erred in excluding several documents as unauthenticated hearsay evidence and in granting summary judgment. The First Circuit agreed and remanded the case for further proceedings, holding (1) the district court erred in excluding the documents as "unauthenticated and hearsay evidence," and the error was not harmless; and (2) the record, supplemented with the stricken documents, provides a reasonable basis for a jury finding in Joseph's favor. View "Joseph v. Lincare, Inc." on Justia Law
Thompson v. Gold Medal Bakery, Inc.
The First Circuit affirmed the judgment of the district court granting summary judgment to Gold Medal Bakery, Inc. and dismissing Robert Thompson's claims brought after he was fired, holding that the district court did not err or abuse its discretion.After he was fired, Thompson brought this complaint alleging that Gold Medal terminated his employment in violation of the anti-retaliation provision of the Family and Medical Leave Act (FMLA) and federal and state disability discrimination laws. The district court granted summary judgment to Gold Medal on all claims. The First Circuit affirmed, holding (1) the district court properly determined that, as a matter of law, Thompson could not establish that he was a "qualified individual" under the Americans with Disabilities Act at the time of his firing; (2) the district court did not err in granting summary judgment to Gold Medal on Thompson's FMLA retaliation claim; and (3) Thompson's remaining arguments were unavailing. View "Thompson v. Gold Medal Bakery, Inc." on Justia Law