Justia Civil Rights Opinion Summaries

Articles Posted in US Court of Appeals for the First Circuit
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The First Circuit affirmed Defendant's conviction of possession of child pornography, holding that the district court did not err in denying Defendant's motions to suppress and for a hearing pursuant to Franks v. Delaware, 438 U.S. 154 (1978). After agents executing a search warrant of Defendant's residence discovered digital files containing images and videos of child pornography on Defendant's computers Defendant filed a motion to suppress and, in the alternative, for a Franks hearing. The district court denied both motions. Defendant then entered a conditional guilty plea to possession of child pornography. The First Circuit affirmed, holding (1) there was no evidence that the affidavit contained egregious misrepresentations sufficient to necessitate a Franks hearing to attack the warrant application, let alone to render the warrant invalid due to a misrepresentation; and (2) the warrant was adequately supported and the evidence obtained was admissible. View "United States v. Larson" on Justia Law

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The First Circuit affirmed Defendant's convictions for one count of conspiracy to make false statements and to conceal in connection with healthcare benefit programs and two counts of false statements in connection with healthcare benefit programs, holding that the district court did not err in denying Defendant's motion to suppress or in instructing the jury. Specifically, the First Circuit held (1) the district court did not err in denying Defendant's motion to suppress data that the government had acquired pursuant to a warrant because even if the government's conduct violated the Fourth Amendment there was nothing in the record to show that any of the evidence introduce at trial should have been suppressed; and (2) the district court did not err in instructing the jury about the inferences that it could draw from the fact that a particular witness was not called to testify. View "United States v. Aboshady" on Justia Law

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The First Circuit affirmed the district court's grant of summary judgment on Appellant's federal law claims under the Age Discrimination and Employment Act, and on the state-law claims for discrimination, retaliation based on a complaint of age discrimination, and failure to investigate and vacated the summary judgment on the state law claims for retaliation based on a report of gender discrimination, breach of contract, intentional interference with contractual relations, and defamation, holding that the court erred in granting summary judgment as to these claims. This lawsuit arose from events that led to Appellant's retirement from his position as Fire Chief for the Fire Department of the Town of Marshfield, Massachusetts. The district court granted summary judgment in favor of the Town on all of Appellant's federal and state law claims. The First Circuit affirmed in part and vacated in part, holding (1) summary judgment was properly granted as to some of Appellant's claims; but (2) as to the remaining state law claims, there was no analogue to the common law claims in the federal law claims that were addressed, and rather than attempt to resolve the state law issues that were in dispute as to these claims, their dismissal was directed without prejudice. View "Robinson v. Town of Marshfield" on Justia Law

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The First Circuit affirmed the judgment of the district court denying Plaintiff's claims of sex discrimination and retaliation on summary judgment and declining Plaintiff's request to alter or amend that ruling under Fed. R. Civ. P. 59(e), holding that there was no reversible error in the proceedings below. This complaint stemmed from Plaintiff's unsuccessful pursuit of tenure within Harvard University's Anthropology Department. Plaintiff alleged that Harvard denied her tenure on the basis of sex discrimination and retaliation for engaging in protected conduct in violation of several state and federal antidiscrimination laws. The district court dismissed Plaintiff's claims on summary judgment and then denied Plaintiff's Rule 59(e) motion to alter or amend the summary judgment. The First Circuit affirmed, holding (1) the district court did not err in finding that Plaintiff did not meet her burden of showing Harvard's stated reason for denying tenure was merely pretext for discrimination; (2) because Plaintiff could not establish a causal link between her protected activity and the adverse employment decision, her retaliation claims failed; and (3) the district court did not err in denying Plaintiff's Rule 59(e) motion. View "Theidon v. Harvard University" on Justia Law

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The First Circuit affirmed the district court decision denying Appellant's petition for habeas corpus relief, holding that the state court's evaluation of Appellant's constitutional claim was not contrary to, nor involved an unreasonable application of, federal law. Appellant was convicted in Rhode Island state court on felony assault and firearms charges. The Rhode Island Supreme Court affirmed. Appellant then applied for postconviction relief based on the ineffective assistance of counsel. The trial justice denied relief, and the Supreme Court affirmed. Appellant later filed a petition for a writ of habeas corpus in federal court, claiming ineffective assistance of counsel in violation of the Sixth Amendment. The district court concluded that Appellant's counsel's performance was constitutionally deficient but that the state Supreme Court's conclusion that Appellant had failed to satisfy the prejudice prong was not an unreasonable application of clearly established federal law. The First Circuit affirmed, holding (1) the Rhode Island Supreme Court's use of the incurable prejudice standard did not lead to a decision "contrary to" federal law; and (2) the Supreme Court's application of Strickland was not unreasonable. View "Chum v. Coyne-Fague" on Justia Law

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The First Circuit affirmed the decision of the district court granting summary judgment to Defendants on Plaintiff's Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621, and relinquishing supplemental jurisdiction over his claims under Puerto Rico law, holding that a reasonable jury could not find pretext discrimination and that the district court did not abuse its discretion in declining to exercise continued supplemental jurisdiction. In his complaint, Plaintiff alleged that he was fired on account of his age. The district court concluded that Plaintiff failed to put forth evidence that he was complying with the legitimate job performance expectations for his position and therefore failed to make a prima facie showing of discrimination. The First Circuit affirmed, holding (1) assuming that Plaintiff established a prima facie case, Plaintiff failed to show that his poor performance reviews were pretextual; and (2) while retention was an option, the district court did not exceed the boundary of its discretion in declining to exercise continued supplemental jurisdiction. View "Santana-Vargas v. Banco Santander Puerto Rico" on Justia Law

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The First Circuit affirmed in part and vacated in part the judgment of the district court entered judgment for the pleadings on all of Plaintiff's claims, holding that Plaintiff's state certiorari claim did not fail to state a claim on the pleadings. Plaintiff, a former City of Haverhill police officer, brought this action against the city's chief of police and the city's mayor after Plaintiff was denied his request for an identification card to allow him to carry a concealed firearm across state lines under the Law Enforcement Officers Safety Act. Defendants removed the case to federal district court, which entered judgment on the pleadings for Defendants on all four of Plaintiff's claims. The First Circuit directed the dismissal of Plaintiff's state certiorari claim without prejudice for lack of jurisdiction and otherwise affirmed, holding (1) Massachusetts has, in its state certiorari procedure, provided a constitutionally adequate remedy precluding assertion of a federal procedural due process claim in this case; (2) Plaintiff failed to plead facts sufficient to support his federal substantive due process claim; (3) the district court properly dismissed Plaintiff's 42 U.S.C. 1983 due process claim; and (4) Plaintiff's negligence claim and purported equity claim plainly failed to assert a claim under state law. View "Lambert v. Fiorentini" on Justia Law

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The First Circuit affirmed the decision of the district court granting summary judgment to the Administrator of the United States General Services Administration (GSA) and dismissing the discrimination and retaliation claim brought by Plaintiff, a former employee of that agency, holding that summary judgment was properly granted on Plaintiff's claims. Specifically, the Court held (1) the district court did not err in granting summary judgment to the GSA on Plaintiff's sex discrimination claims under Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq.; (2) the district court did not err in granting summary judgment to the GSA on Plaintiff's age discrimination claims under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq.; and (3) Plaintiff's retaliation claims under Title VII and the ADEA also lacked merit. View "Paul v. Murphy" on Justia Law

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The First Circuit affirmed Defendant's conviction of conspiracy to possess with intent to distribute and to distribute oxycodone, holding that the district court did not err in denying Defendant's motion to suppress. The motion to suppress centered around a series of five search warrants federal law enforcement officers executed as part of an investigation into an oxycodone-distribution conspiracy involving Defendant. The officers obtained location data for Defendant's cell phones and recovered a significant amount of cash stored in a hidden compartment in Defendant's vehicle. This information led to charges that Defendant was the New York-based oxycodone supplier for his co-conspirators' Massachusetts operation. Defendant filed, without success, a motion to suppress, arguing that the first warrant for cellular location data, which served as the foundation for the subsequent warrants, was not supported by probable cause. Defendant was subsequently convicted. The First Circuit affirmed, holding that the warrant for Defendant's vehicle was properly issued, and therefore, the evidence seized from the vehicle was properly admitted at trial. View "United States v. Bregu" on Justia Law

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The First Circuit affirmed Defendant's conviction of interstate transportation of a minor with intent to engage in criminal sexual activity, holding that the district court did not err in denying Defendant's motion to suppress the confession he made during the second phase of his custodial interrogation. In support of his motion to suppress Defendant argued that the interrogation violated his Fifth Amendment rights as set forth in Miranda v. Arizona, 384 U.S. 436 (1966), and Edwards v. Arizona, 451 U.S. 477 (1981). The district court denied the motion, finding that Defendant initiated the second phase of the interview, that Defendant did not thereafter reinvade his right to counsel, and that Defendant knowingly and voluntarily waived his Miranda rights before confessing. The First Circuit affirmed, holding that Defendant's confession was admissible at trial for all of the reasons determined by the district court. View "United States v. Carpentino" on Justia Law