Justia Civil Rights Opinion Summaries

The First Circuit affirmed the order of the district court dismissing Plaintiff's suit brought against Defendant, his employer, asserting claims of age-based discrimination under the Age Discrimination in Employment Act (ADEA) and Puerto Rico's statutory analog, holding that this Court will not adopt any version of the single filing rule that would excuse the procedural failings associated with Plaintiff's suit.In moving to dismiss the complaint, Defendant asserted that Plaintiff neglected to first file a complaint with the Equal Employment Opportunity Commission and therefore failed to exhaust his administrative remedies before filing suit. Plaintiff argued in response that the district court should adopt and apply the "single filing rule," otherwise known as the "piggyback rule," which would allow him to vicariously satisfy his exhaustion obligation by relying upon a timely-filed administrative complaint against his employer made by a similarly-situated plaintiff. The district court declined to adopt the single filing rule, dismissed Plaintiff's ADEA claims, and declined to exercise supplemental jurisdiction over his Puerto Rico law claims. The First Circuit affirmed, holding that the district court correctly dismissed the complaint. View "Perez-Abreu v. Metropol Hato Rey LLC" on Justia Law

The First Circuit affirmed the federal convictions and sentences of Defendants - Herzzon Sandoval, Edwin Guzman, Erick Argueta Larios, and Cesar Martinez - stemming from a federal criminal investigation into La Mara Salvatrucha, a transnational criminal organization, in Massachusetts, holding that there was no prejudicial error.Specifically, the First Circuit held (1) Defendants' sufficiency of the evidence challenges to their respective convictions were without merit; (2) there was no merit to Defendants' claims that the district court erred in denying a motion for a continuance due to pretrial publicity or in denying their motion for a mistrial; (3) Defendants' challenges to the court's evidentiary rulings failed; (4) challenges concerning purported misstatements of the evidence in the government's closing argument and purported instructional errors provided no basis for overturning Defendants' convictions; and (5) Defendants' challenges to their sentences failed. View "United States v. Sandoval" on Justia Law

The First Circuit affirmed the judgment of the district court denying Petitioner's petition for a writ of habeas corpus under 28 U.S.C. 2254, as amended by the Antiterrorism and Effective Death Penalty Act (AEDPA), holding that the district court did not err in denying the petition.In his habeas petition, Petitioner alleged that the trial court violated his constitutional rights to a complete defense and to have effective assistance of counsel. The district court denied the petition. The First Circuit affirmed, holding (1) the exclusion of certain medical evidence, even if error, was harmless beyond a reasonable doubt; and (2) trial counsel was not constitutionally deficient for not consulting or calling a child abuse expert who could testify to the effects of Munchausen Syndrome by Proxy on fathers like Petitioner. View "Strickland v. Goguen" on Justia Law

The First Circuit affirmed the drug conspiracy and distribution convictions of five members of a drug trafficking organization, holding that none of the issues raised by the five defendants translated into reversible error warranting vacatur of their convictions or sentences.Fifty-five individuals were indicted on charges of conspiracy to distribute heroin, cocaine, cocaine base, marijuana, and prescription pills. By the time a jury trial began most of the defendants had pleaded guilty. Five of the defendants who were ultimately convicted appealed their convictions, and some of them appealed their sentences. The defendants were Joel Rivera-Alejandro, Carlos Rivera-Alejandro, Juan Rivera-George, Suanette Ramos- Gonzalez, and Idalia Maldonado-Pena. The First Circuit affirmed the judgments in their entirety, holding that there was no reversible error in this case. View "United States v. Maldonado-Pena" on Justia Law

The First Circuit dismissed this appeal arising in connection with a lawsuit alleging that the Equal Rights Amendment (ERA) is now part of the United States Constitution, holding that none of the plaintiffs met their burden at the pleading stage with respect to federal constitutional requirements.Plaintiffs were Equal Means Equal, a national nonprofit organization, The Yellow Roses, a student organization based in Massachusetts, and Katherine Weitbrecht, a resident of Massachusetts. Plaintiffs brought this action against David Ferriero, in his official capacity as Archivist of the United States, alleging that, after Virginia ratified the ERA in 2020, the Archivist violated 1 U.S.C. 106b when he refused to publish it and certify its adoption. The district court dismissed the claims for lack of subject matter jurisdiction. The First Circuit affirmed, holding that Plaintiffs failed to plead sufficient facts to establish standing under Article III of the United States Constitution to bring this action in federal court. View "Equal Means Equal v. Ferriero" on Justia Law

The First Circuit affirmed Defendant's conviction of possession with intent to distribute cocaine, fentanyl, and methamphetamines, holding that Defendant's challenges on appeal were unavailing.During a probation compliance check in Defendant's apartment state probation officers discovered a black case containing illegal narcotics. The police then obtained and executed a warrant to search Defendant's apartment and his two cellphones for evidence of drug dealing. On appeal, Defendant argued, among other things, that there was no probable cause to search his cellphones and that the warrant did not adequately specify which files on the phones would be searched. The First Circuit affirmed, holding (1) the trial court did not err in denying Defendant's motion to suppress evidence recovered from the cellphones; (2) there was sufficient evidence to support the convictions; and (3) Defendant was not entitled to relief on his remaining allegations of error. View "United States v. Lindsey" on Justia Law

The First Circuit affirmed Defendant's conviction of possession of a firearm in furtherance of a drug trafficking crime and possession of a controlled substance with intent to distribute entered after Defendant pled guilty pursuant to a plea agreement, holding that Defendant's argument that his plea was invalid was without merit.On appeal, Defendant argued that his plea was invalid because he entered it without knowing that he was waiving his right to appeal the trial court's denial of his motion to suppress the drugs, gun, and statements he had made following his arrest. The First Circuit affirmed, holding that, even if there was error, it was not clear or obvious. View "United States v. Casiano-Santana" on Justia Law

The First Circuit affirmed the judgment of the district court holding that the Federal National Mortgage Association (Fannie Mae) and the Federal Housing Finance Agency (FHFA) were not subject to Appellants' Fifth Amendment claims, holding that there was no error.Appellants obtained loans secured by mortgages on their real property in Rhode Island. The loans and mortgages were later sold to Fannie Mae while the FHFA was acting as Fannie Mae's conservator. Consistent with Rhode Island law, when Appellants defaulted on their loans Fannie Mae conducted nonjudicial foreclosure sales of the mortgaged properties. Appellants brought suit in a federal district court, arguing that the nonjudicial foreclosure sales violated their procedural due process rights under the Fifth Amendment. The district court dismissed those claims. The First Circuit affirmed, holding that FHFA and Fannie Mae were not government actors subject to Appellants' due process claims. View "Montilla v. Federal National Mortgage Ass'n" on Justia Law

The First Circuit vacated the judgment of the district court granting summary judgment in favor of Defendant in this case alleging a violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., holding that genuine issues of material fact precluded summary judgment.Plaintiff, who was Black, sued Bridgewater State university's Board of Trustees and Office of Equal Opportunity and a University administrator (collectively, Defendants) alleging that she was not hired for a University position because of her race. The district court granted summary judgment in favor of Defendants. The First Circuit reversed, holding that Plaintiff's aggregate package of proof sufficed to survive Defendants' motion for summary judgment. View "Taite v. Bridgewater State University" on Justia Law

The First Circuit reversed the order of the district court excluding two documents from the summary judgment record and granting summary judgment for Defendant on all of Plaintiff's claims, holding that the district court erred in excluding the two documents from the summary judgment record.Defendant terminated Defendant's employment after he had been employed for thirty-three years. Plaintiff brought this lawsuit alleging wrongful termination of his employment under state law and age discrimination under federal and state law. Defendant moved to strike two of Plaintiff's documents on the grounds that they had been produced after the discovery cut-off date and that they were not properly authenticated. The district court granted the motion to strike the documents and then granted Defendant's motion for summary judgment. The First Circuit reversed the order excluding the documents and vacated the entry of summary judgment, holding that the court erred in striking the documents and that material issues of fact precluded summary judgment. View "Zampierollo-Rheinfeldt v. Ingersoll-Rand de Puerto Rico, Inc." on Justia Law