Justia Civil Rights Opinion Summaries

The First Circuit dismissed this appeal, in which Appellant sought to override an appeal waiver and to proceed with an appeal based on the alleged ineffective assistance of his counsel, holding that ineffective assistance of counsel claims not raised in the district court and not within an exception to United States v. Mala, 7 F.3d 1058 (1st Cir. 1993), are insufficient to overcome an appeal waiver.Defendant agreed to plead guilty to conspiracy to commit bank fraud and to failure to appear in court pursuant to a plea agreement that contained a waiver-of-appeal provision. After sentencing, Defendant appealed, asserting for the first time that his counsel afforded him ineffective assistance both at the time he entered his plea and at sentencing. The First Circuit dismissed the appeal, holding that Defendant's ineffective assistance of counsel allegations fell within the Mala rule and could not surmount his waiver of appeal. View "United States v. Staveley" on Justia Law

The First Circuit reversed the order of the district court denying Defendant's motion for summary judgment as to Plaintiff's whistleblower retaliation claim brought under section 1514A of the Sarbanes-Oxley Act, holding that Plaintiff could not satisfy his burden of bringing a claim for whistleblower retaliation under section 18 U.S.C. 1514A.Plaintiff, a former employee of Defendant, sued Defendant for whistleblower retaliation under section 1514A, but his particular whistleblower claim was based on an alleged violation of 15 U.S.C. 78m(b)(2), (5). Defendant moved for summary judgment following the completion of discovery, arguing that Plaintiff's action did not fall within any of the definitions of protected activity under section 1514A. The district court denied the motion as to the whistleblower retaliation claim. The First Circuit reversed and remanded with instructions to enter summary judgment in favor of Defendant, holding that Plaintiff's conduct was not "protected activity" under section 1514A. View "Baker v. Smith & Wesson, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's habeas petition, holding that the Massachusetts state court reasonably applied federal law in deeming the Commonwealth's proof constitutionally adequate.After a jury trial, Defendant was convicted of first-degree murder on a theory of felony murder based on a predicate of armed robbery and sentenced him to a term of life imprisonment on the felony murder charge. The Massachusetts Supreme Judicial Court (SJC) affirmed the conviction. Petitioner sought federal habeas review in the federal district court. The district court denied the petition. The First Circuit affirmed, holding that the district court did not err in denying Appellant's application for habeas relief. View "Webster v. Gray" on Justia Law

In this lawsuit challenging both the residency and voter-registration requirements under Maine law the First Circuit affirmed the order issuing a preliminary injunction preventing the residency requirement and voter-registration requirement from being enforced, holding that there was no error.In 2020, Plaintiffs brought this action against the Secretary of State of Maine and the Deputy Secretary of State of Maine for the Bureau of Corporations in their official capacities, alleging that, by restricting who may be a circulator, Maine's residency and voter-registration requirements violate the First Amendment, as incorporated against the states by the Due Process Clause of the Fourteenth Amendment. The district court granted Plaintiffs' request for a preliminary injunction. The First Circuit affirmed, holding that Plaintiffs established that they were likely to succeed on the merits of their claims. View "We The People PAC v. Bellows" on Justia Law

The First Circuit affirmed Defendant's conviction for four offenses relating to Defendant's possession of a handgun with an obliterated serial number and drugs found within the bag that he was carrying, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant challenged the denial of his motion to suppress evidence recovered during his arrest, alleging that his seizure violated his Fourth Amendment rights and that he was coerced into handing over the bag to law enforcement. The First Circuit affirmed, holding (1) the officer lacked reasonable suspicion to justify the initial seizure of Defendant but an intervening voluntary act provided independent probable cause to arrest Defendant; (2) suppression was not warranted under the fruit-of-the-poisonous-tree doctrine; and (3) the district court did not abuse its discretion in imposing limitations on cross-examination during the trial. View "United States v. Sierra-Ayala" on Justia Law

The First Circuit affirmed the district court's judgment dismissing Plaintiffs' lawsuit asserting race-based discrimination and retaliation in violation of Title VII of the Civil Rights Act, holding that the district court did not err in dismissing the suit for failure to state a claim.Plaintiffs represented a putative class of employees employed by Whole Foods and Amazon who were disciplined for wearing face masks with the message "Black Lives Matter." In their lawsuit, Plaintiffs alleged that the manner in which their employers enforced a previously unenforced dress code policy constituted race-based discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964. The district court dismissed all claims. The First Circuit affirmed, holding that Plaintiffs did not adequately plead claims for racial discrimination and retaliation under Title VII. View "Frith v. Whole Foods Market, Inc." on Justia Law

The First Circuit vacated the judgment of the trial judge denying Defendants' motion for a new trial based on improper comments by the prosecutor, holding that the district court's denial of the new trial motions was plain error.Defendants Edward Canty, III and Melquan Jordan were prosecuted on charges that they had conspired to distribute and possess with intent to distribute both heroin and cocaine base. During their criminal trial, the prosecutor made four types of improper comments during the opening and closing statements and at rebuttal, to which Defendants did not object. After they were convicted Defendants moved for a new trial based on the improper comments by the prosecutor. The trial judge denied the motions under plain error review. The First Circuit vacated the decision below, holding that the fairness, integrity, and public reputation of the proceedings were seriously affected, requiring remand for a new trial. View "United States v. Canty" on Justia Law

The First Circuit affirmed Defendant's conviction and sentence for one count of possession of child pornography, holding that Defendant suffered no prejudice from any claims deficient performance of his trial counsel.Pursuant to a plea agreement, Defendant pleaded guilty to one count of possession of child pornography. The trial court sentenced him to an under-Guidelines-range sentence of forty-six months. Defendant appealed, arguing that he received ineffective assistance of counsel during his sentencing proceedings because counsel failed to object to the four-level enhancement under U.S.S.G. 2G2.2(b)(4)(B) on constitutional grounds. The First Circuit affirmed, holding that Defendant's claims of ineffective assistance of counsel were unavailing. View "United States v. Messner" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's petition for habeas corpus, in which he alleged ineffective assistance of counsel, holding that Appellant failed to establish that his counsel's performance was deficient under Strickland v. Washington, 466 U.S. 668 (1984).After a retrial, Appellant was convicted of two counts of attempting to kill a federal witness with intent to prevent testimony and communication with law enforcement. The First Circuit affirmed. Appellant later filed a motion under 28 U.S.C. 2255 to vacate his conviction based on ineffective assistance of counsel. The district court denied relief. The First Circuit affirmed, holding that Appellant's claims of ineffective assistance of counsel were unavailing. View "Watson v. United States" on Justia Law

The First Circuit denied a writ of habeas corpus sought by Petitioner under 28 U.S.C. 2254 to vacate her conviction for murder in the first degree, holding that there was no error.Petitioner was convicted of first-degree murder based on deliberate premeditation and extreme atrocity or cruelty and was sentenced to life imprisonment without the possibility of parole. Petitioner later filed a habeas petition claiming ineffective assistance of counsel. The district court denied the petition. The First Circuit affirmed, holding that there was no prejudice on any of the alleged errors claimed by Petitioner. View "Field v. Hallett" on Justia Law