Justia Civil Rights Opinion Summaries

Articles Posted in US Court of Appeals for the First Circuit
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The First Circuit affirmed the judgment of the district court dismissing Appellant's claims for mandamus and relief under the Administrative Procedure Act (APA), vacated the dismissal of Appellant's equal protection and due process claims and held that certain of the challenged rules challenged by Appellant were arbitrary and unenforceable.Appellant, a law firm, sued the Social Security Administration (SSA) challenging "the [SSA]'s byzantine and irrational rules that govern payment pf attorney's fees in Social Security disability cases." The district court dismissed Appellant's mandamus and APA claims on the grounds that sovereign immunity barred the mandamus claim and that the firm's challenges to the agency's fee-paying procedures were statutorily barred. The court later granted summary judgment for the SSA on the remaining three claims. The First Circuit held (1) mandamus relief was unavailable here because Appellant had another avenue for obtaining relief; and (2) the SSA's practice of denying attorneys fees under certain circumstances was arbitrary, and therefore, the rule must be eliminated. View "Marasco & Nesselbush, LLP v. Collins" on Justia Law

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The First Circuit affirmed the sentence Defendant received upon resentencing after he was convicted on two drug-related charges, holding that there was no error in the proceedings.This Court previously vacated Defendant's sentence. On remand, the district court imposed a low-end eighty-four-month term of immurement to be followed by six years of supervised release. Defendant appealed, challenging his six-year mandatory minimum term of supervised release. The First Circuit affirmed, holding (1) the district court did not err by failing to make a necessary finding; and (2) the court did not find facts that should have been reserved for a jury. View "United States v. Rabb" on Justia Law

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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

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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

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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

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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

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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

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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

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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

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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