Justia Civil Rights Opinion Summaries

The First Circuit affirmed the ruling of the district court denying Plaintiffs' motion for a preliminary injunction in this case arising from a decision by the Speaker of the New Hampshire House of Representatives to enforce a House rule precluding any representative from participating in proceedings involving the full House, including House matters, other than in person, holding that there was no error.At issue in this COVID-19 pandemic-related case was whether Title II of the Americans with Disabilities Act (ADA) or section 504 of the Rehabilitation Act (RHA) authorizes a federal court to resolve a dispute among members of a state legislative body about whether votes on bills may be cast remotely rather than in person. The underlying suit named Sherman Packard, the Speaker of the House, in his official capacity. The district court denied a preliminary injunction based on the Speaker's assertion of legislative immunity. A panel of the First Circuit first vacated the injunction, but the Court subsequently granted a rehearing en banc. The First Circuit then affirmed, holding that the district court did not err in holding that the Speaker's assertion of legislative immunity prevented Plaintiffs from obtaining their requested relief. View "Cushing v. Packard" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Defendants, the Town of Marblehead and its buildings commissioner, and dismissing this lawsuit brought under the Religious Land Use and Institutionalized Persons Act (RLUIPA), holding that the district court did not err.St. Paul's Foundation and the Shrine of St. Nicholas the Wonderworker, Patron of Sailors, Brewers and Repentant Thieves (collectively, St. Paul's), brought this action alleging that Defendants substantially burdened St. Paul's religious exercise. Specifically, St. Paul's sought to reinstate a building permit that it had secured for the redevelopment of a site on which the Shrine of St. Nicholas was located but that had been suspended prior to the completion of that construction. The district court granted summary judgment in favor of Defendants. The First Circuit affirmed, holding that St. Paul's did not successfully advance a basis for reversing the summary judgment in this case. View "St. Paul's Foundation v. Ives" on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment in favor of Defendant, his former employer, and dismissing Plaintiff's complaint alleging that Defendant terminated his employment because of his age and because he received a liver transplant, holding that the district court did not err.Plaintiff filed a complaint alleging disability discrimination under the Americans With Disabilities Act (ADA) and age discrimination under the Age Discrimination in Employment Act (ADEA). The district court granted summary judgment for Defendant and dismissed the complaint. The First Circuit affirmed, holding that the evidence on the record did not support either Plaintiff's ADA claim or his ADEA claim. View "Lahens v. AT&T Mobility Puerto Rico, Inc." on Justia Law

The First Circuit affirmed Appellant's plea of guilty to one count of investment adviser fraud, four counts of wire fraud, and one count of aggravated identity theft, holding that there was no prejudicial error in the proceedings below.On appeal, Appellant argued that her plea was not knowing and voluntary, that the evidence was insufficient to convict her of wire fraud and aggravated identity theft, that several sentencing enhancements were improperly applied, and that her counsel was ineffective. The First Circuit affirmed, holding (1) there was no error in the district court's acceptance of Appellant's guilty plea; (2) Appellant's conduct clearly satisfied the statutory requirements for wire fraud and aggravated identity theft; and (3) Appellant's challenges to several aspects of her sentence were unavailing. View "United States v. Kitts" on Justia Law

The First Circuit affirmed in part and reversed in part the district court's grant of summary judgment in favor of Defendant on Plaintiff's federal and Massachusetts state law employment discrimination claims, holding that that court erred in granting summary judgment as to several of Plaintiff's claims.Plaintiff, a former employee of Defendant, an online home furnishings company with a principal place of business in Massachusetts, sued Defendant bringing claims under both Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq., and Mass. Gen. Laws ch. 151B, 4.1, 4.4, and 4.4A. The district court granted summary judgment for Defendant on all claims. The First Circuit reversed in part, holding that the district court (1) correctly granted summary judgment to Defendant on Plaintiff's state and federal claims for failing to remedy sexual harassment; and (2) erred in granting summary judgment to Defendant on Plaintiff's remaining claims. View "Forsythe v. Wayfair, LLC" on Justia Law

The First Circuit affirmed the judgment of the district court rejecting the jury's advisory verdict in this case, holding that Plaintiff was not entitled to relief on his claims of error.Plaintiff, a former intelligence specialist, sued his former employer, the United States Attorney's Office for the District of Puerto Rico pursuant to Title VII of the Civil Rights Act, alleging discriminatory retaliation and constructive discharge resulting from a hostile work environment. After a jury returned a verdict on liability for retaliation and awarding the statutory maximum in damages, the district court charged the jury to return an advisory verdict on the issue of damages for constructive discharge. The jury returned a verdict in favor of Plaintiff as to that issue, and thereafter, Plaintiff sought a judgment of front and back pay. The district court rejected the jury's advisory verdict, concluding that the verdict was not supported by the evidence, that Plaintiff was not constructively discharged, and that Plaintiff was not entitled to front or back pay. The First Circuit affirmed, holding (1) Plaintiff waived his objection to the district court's decision to submit the constructive discharge issue to an advisory jury; and (2) the district court's factual findings were not clearly erroneous. View "Reyes-Caparros v. Garland" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment in favor of the Town of Brookline, Massachusetts on Plaintiff's claim brought pursuant to 42 U.S.C. 1983 alleging discrimination on the basis of race in violation of the Fourteenth Amendment's Equal Protection Clause, holding that the district court did not err in granting summary judgment.Plaintiff brought this action alleging that Brookline violated his equal protection rights in terminating his employment. The district court granted summary judgment in favor of the Town. The First Circuit affirmed, holding that Plaintiff's evidence failed to establish that the Town's proffered reasons for failing to accommodate and then dismissing Plaintiff were a pretext for race discrimination. View "Fincher v. Town of Brookline" on Justia Law

The First Circuit affirmed Defendant's conviction for being a felon in possession of a firearm, holding that the district court did not err in denying Defendant's motion to suppress.Upon executing a no-knock search warrant following reports of discharged shots the police found two shotguns and related paraphernalia in Defendant's bedroom. In his motion to suppress, Defendant argued that the police exceeded the scope of the warrant by searching his bedroom, which was located on the third floor of the building, because the searched warrant was for "88 Foundation St. 2nd floor." The district court denied the motion, concluding that the good-faith exception to the exclusionary rule applied. The First Circuit affirmed, holding that the officers reasonably believed that the warrant permitted the search of Defendant's third-floor bedroom. View "United States v. Pimentel" on Justia Law

The First Circuit affirmed Defendants' convictions for conspiring to distribute twenty-eight grams or more of cocaine base, holding that neither Defendant was entitled to relief on his claims of error.Defendants Juan Pena and Rosnil Ortiz were convicted for conspiring to distribute twenty-eight grams or more of cocaine base. On appeal, Defendants argued that the district court erred in allowing the jury to consider certain video recordings and the "out-of-court" statements captured therein. The First Circuit affirmed, holding that the district court (1) did not commit reversible error in admitting certain portions of two videos and the audio statements therein; (2) did not deny Defendants' constitutional rights to confront witnesses and to present a complete defense by excluding certain statements, as Defendants intended to use them; and (3) did not deprive Defendants of their right to an impartial tribunal by instructing the jury mid-cross-examination that it was proper for law enforcement agents to use confidential informants and to take drug weight into account when directing controlled drug purchases. View "United States v. Pena" on Justia Law

The First Circuit affirmed Defendant's conviction of one count of conspiracy to possess with intent to distribute and to distribute 500 grams or more of cocaine, in violation of 21 U.S.C. 846, and one count of possession with intent to distribute 500 grams or more of cocaine, in violation of 21 U.S.C. 841(a)(1), holding that there was no error.Specifically, the First Circuit held (1) the district court did not err in denying Defendant's motion to suppress evidence obtained during a traffic stop and admitting items seized from the vehicle at trial; (2) the district court did not manifestly abuse its discretion in admitting certain statements of lay witnesses; (3) the proceedings did not contravene Defendant's constitutional right to a speedy trial; and (4) Defendant's absence at certain pre-trial proceedings did not violate his statutory or constitutional presence rights. View "United States v. Reyes" on Justia Law