Justia Civil Rights Opinion Summaries

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

The First Circuit affirmed the judgment of the district court denying Appellant's motion to suppress evidence recovered during a traffic stop, holding that the district court did not err when it denied the motion to suppress.Appellant entered a conditional guilty plea to possession of a controlled substance with the intent to distribute, reserving the right to appeal the district court's denial of his motion to suppress both statements he made at the scene of his traffic stop and the physical evidence obtained during the stop. In denying the motion to suppress, the district court concluded that the law enforcement officer had reasonable suspicion to stop Defendant's car. The First Circuit affirmed, holding that the officer had a reasonable basis to believe Appellant had committed a traffic infraction and thus to perform a traffic stop. View "United States v. Miles" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendants' joint motion to dismiss the charges against them on retrial, holding that the district court did not err.Defendants - Raymond Garraway and Cordwell Bennett - were convicted for possession with intent to distribute marijuana. Defendants moved for a mistrial. The district court granted the motion on the basis of the prosecution's improper arguments made at closing. When the prosecution began to retry them, Defendants filed a joint motion to dismiss for violation of the Double Jeopardy Clause. The district court denied the motion, finding that the prosecution did not intend to provoke a mistrial. The First Circuit affirmed, holding that the record amply supported the district court's decision. View "United States v. Garraway" on Justia Law

The First Circuit affirmed Defendant's conviction of one count of possession of child pornography, holding that none of Defendant's claims on appeal had merit.Defendant, an employee of U.S. Customs and Border Protection, came under investigation for downloading child pornography on his home computer. On appeal, Defendant argued that the district court erred in (1) refusing to suppress incriminating statements Defendant made when interviewed at his workplace by federal agents and (2) denying a post-trial motion seeking a Franks hearing to review an error in an affidavit used to secure the search warrant leading to the discovery of the incriminating evidence on Defendant's home computer. The First Circuit affirmed, holding that the district court (1) did not commit reversible error in finding that Defendant's interview was not custodial; and (2) did not err in denying Defendant's delayed request for a Franks hearing. View "United States v. O'Neal" on Justia Law

The First Circuit affirmed the judgment of the district court ordering that Plaintiff's breach of contract claim be dismissed for failure to state a plausible claim and granting summary judgment for Defendants on all remaining counts, holding that there was no error.Plaintiff sued the City of East Providence, Rhode Island, its School Department, and the School Superintendent, asserting claims arising from what she alleged were unlawful discriminatory employment actions taken against her. The First Circuit resolved all claims in favor of Defendants. The First Circuit affirmed, holding (1) Plaintiff failed to plead even a prima facie case of discrimination; and (2) Plaintiff's claim of retaliatory employment discrimination was not supported by admissible evidence that would warrant putting the case to a jury. View "Lima v. City of East Providence" on Justia Law

The First Circuit affirmed the ruling of the district court rejecting Defendant's request for a Franks hearing before Defendant entered a conditional guilty plea to one count of possession of a firearm by a prohibited person, holding that the district court did not err in denying Defendant a Franks hearing.Defendant was charged with one count of possession of a firearm by a prohibited person and one count of possession with the intent to distribute cocaine. Prior to trial, Defendant filed a motion to suppress evidence seized pursuant to search warrants and sought a Franks hearing on the basis of two alleged material omissions from the warrant affidavit. The district court denied both Defendant's Franks motion and his motion to suppress. The First Circuit affirmed, holding that the district court did not err in ruling that Defendant had failed to make the threshold showing necessary to obtain a Franks hearing. View "United States v. Leonard" on Justia Law

The First Circuit vacated the federal convictions challenged on appeal by the two defendants in this case - Noel de Leon-De la Rosa and Juan Batista Johnson-Debel - holding that vacatur was required of Defendants' challenged convictions for different reasons.Defendants were both convicted of destruction of a controlleded substance while on a vessel and conspiracy to destroy a controlled substance while on a vessel (counts five and six). The First Circuit vacated Defendants' of counts five and six, holding (1) the evidence was sufficient to support the convictions; (2) the admission of Johnson's statement in the defendants' joint trial violated De Leon's rights under the Confrontation Clause to the Federal Constitution; and (3) as to Johnson's convictions, the district court constructively amended the indictment through its instructions to the jury. View "United States v. De Leon-De la Rosa" on Justia Law