Justia Civil Rights Opinion Summaries

The First Circuit affirmed the judgment of the district court dismissing Appellants' action for declaratory relief against the Governor of Rhode Island and various Rhode Island officials and agencies (collectively, Rhode Island), holding that the district court did not err.On behalf of a putative class of Rhode Island students attending K-12 schools, Appellants brought this action under the Equal Protection, Due Process, and Privileges and Immunities Clauses of the Fourteenth Amendment and the Republican Guarantee Clause of U.S. Const. art. IV, 4, claiming that Rhode Island failed to provide them with an adequate education to function productively in civic activities. The district court dismissed the action. The First Circuit affirmed, holding that the district court properly concluded that an adequate civics education is not a fundamental constitutional right and that Rhode Island's approach to civics education satisfies rational basis review. View "A.C. v. McKee" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's petition for habeas relief, holding that the district court did not err in its treatment of Defendant's claim for habeas relief based on Batson v. Kentucky, 476 U.S. 79 (1986).Defendant was convicted of first-degree murder and sentenced to life in prison. On appeal, Defendant raised a Batson claim of race-based discrimination in jury selection. The state court denied Defendant's appeal. Thereafter, Defendant filed a petition for habeas relief based on Batson. The federal district court denied relief. The First Circuit affirmed, holding that the Massachusetts Supreme Judicial Court did not unreasonably apply clearly established Supreme Court case law in concluding that Defendant did not establish the prima facie case of purposeful race-based discrimination required by Batson. View "Yacouba-Issa v. Calis" on Justia Law

The First Circuit granted Petitioner's petition for review of a decision by the Board of Immigration Appeals (BIA) affirming the denial of Petitioner's claims for asylum, withholding of removal, and protection under the United Nations Convention Against Torture (CAT), holding that the immigration judge's (IJ) credibility judgment was not supported by substantial evidence.The IJ rejected Petitioner's petition for relief based on an adverse credibility determination that primarily drew its support from a gang assessment database. The BIA affirmed. Petitioner then petitioned for review, arguing that the agency's reliance on the flawed gang package undermined the credibility finding and resulted in a due process violation. The First Circuit granted the petition after noting the flaws in the gang assessment database, including the database's reliance on an erratic point system built on unsubstantiated inferences, holding that neither the agency's adverse credibility determination nor its denial of Petitioner's claims was supported by substantial evidence. View "Ortiz v. Garland" on Justia Law

The First Circuit affirmed Defendant's conviction of possession with intent to distribute marijuana and possession of a firearm and ammunition by a convicted felon, holding that the district court did not err by not granting Defendant's motion to suppress.In his motion to suppress, Defendant sought to suppress evidence obtained after the execution of a search warrant at his residence, asserting errors and omissions in the underlying search warrant affidavit. The First Circuit affirmed the district court's denial of Defendant's motion, holding that the various motions that Defendant filed ultimately seeking to suppress the evidence seized from his residence were correctly denied. View "United States v. Maglio" on Justia Law

The First Circuit affirmed the decision of the district court entering summary judgment against the political discrimination claims brought by Plaintiffs, former Automobile Accident Compensation Administration (AACA) employees, against Defendants, the AACA and its former executive director, holding that the district court did not err.Plaintiffs were laid off pursuant to an agency-wide, facially-neutral layoff plan based on seniority. Plaintiffs brought this action under 42 U.S.C. 1983 alleging violations of their rights under the First, Fifth, and Fourteenth Amendments, along with violations of Puerto Rico law. The district court adopted Puerto Rico court decisions concluding that it was the Board of Directors, and not the Executive Director, that was responsible for the layoff plan, and then granted summary judgment for Defendants. The First Circuit affirmed, holding that the district court correctly concluded that Plaintiffs were barred from arguing in this litigation that the executive director was responsible for the layoff plan. View "Diaz-Baez v. Alicea-Vasallo" on Justia Law

The First Circuit affirmed the district court's judgment denying Defendant's motion to suppress evidence obtained during the execution of a no-knock search warrant at the apartment where he and his girlfriend lived, holding that the district court did not err.On appeal, Defendant argued that the district court erred by failing to suppress evidence obtained from the search of his backpack because his backpack was not properly subject to search and erred in failing to find that there was insufficient justification for the no-knock provision of the warrant. The First Circuit affirmed, holding (1) there was nothing improper about the search; and (2) the district court did not commit plain error by not ruling that the no-knock provision was unsupported. View "United States v. Congo" on Justia Law

The First Circuit reversed the judgment of the district court granting Defendant's motion to suppress evidence seized during a protective search of a car, holding that the actual-fear analysis set forth in United States v. Lott, 870 F.2d 778 (1st Cir. 1989), is no longer controlling.In Lott, the First Circuit held that officers cannot do a frisk for weapons where the officers were not actually concerned for their safety. The district judge in this case granted Defendant's motion to suppress after finding that while officers had an objectively reasonable basis to search the car, they had no subjective concerns for their safety. The First Circuit reversed the judge's evidence suppression and remanded the case for further proceedings, holding that Lott is abrogated to the extent that it is inconsistent with the opinion in this case. View "United States v. Guerrero" on Justia Law

The First Circuit affirmed the order of the district court dismissing Plaintiff's federal claims seeking to hold private parties liable as state actors under 42 U.S.C. 1983, holding that the district court did not err in granting Defendants' Fed. R. Civ. P. 12(b)(6) motion to dismiss.In this case arising from eviction proceedings, Plaintiff brought this suit against Management Administration Services Corporation and its administrator, alleging violations of the Fourth and Fourteenth Amendments related to a search of her apartment, violations of due process related to rent-adjustment negotiations and eviction proceedings, and pendant claims for emotional distress. In response to Defendants' motion to dismiss Plaintiff argued that Defendants were performing a function traditionally and exclusively reserved to the state. The district court dismissed the complaint. The First Circuit affirmed, holding that the complaint failed to allege sufficient facts to ground a plausible conclusion that the function Defendants performed was, by tradition, an exclusive prerogative of the state. View "Cruz-Arce v. Management Administration Services Corp." on Justia Law

The First Circuit affirmed the judgment of the district court denying Petitioner's petition for a writ of habeas corpus seeking to overturn his 2010 New Hampshire conviction for aggravated felonious sexual assault, holding that the district court properly rejected Petitioner's Sixth Amendment claim.In his habeas petition, Petitioner asserted that his Sixth Amendment right to autonomy to determine the objectives of his defense when his counsel took certain actions to present a defense at trial, despite Petitioner's instructions not to do so. The district court denied the petition. The First Circuit affirmed, holding that Petitioner was not denied autonomy to direct the objectives of his defense when his trial counsel presented an active defense contrary to Petitioner's express wishes. View "Kellogg-Roe v. Gerry" on Justia Law

In this vaccination dispute, the First Circuit denied the motion brought by Appellants seeking an injunction pending appeal, holding that Appellants were not entitled to the injunction.Appellants, eight employees of Mass General Brigham, Inc. (MGB), challenged MGB's application of its mandatory vaccination policy to them individually. The policy was issued in June 2021 requiring all MGB employees to be vaccinated against COVID-19 unless they qualified for a medical or religious exemption. After Appellants' requests for exemptions were denied and they still refused to get vaccinated, MGB placed them on unpaid leave. Appellants sued under Title VII of the Civil Rights Act and the Americans with Disabilities Act, arguing that MGB unlawfully denied their individual exemption requests. The district court denied Appellants' motion for a preliminary injunction, which would have required Appellants' reinstatement from unpaid leave status. The First Circuit denied Appellants' motion for injunction pending appeal, holding that adequate legal remedies foreclosed injunctive relief. View "Together Employees v. Mass General Brigham Inc." on Justia Law