Justia Civil Rights Opinion Summaries

In this civil action brought by plaintiffs seeking to enjoin policies governing searches of electronic devices at the United States' borders, the First Circuit found no violations of either the Fourth Amendment or the First Amendment.The border search policies challenged her allow border agents to perform basic searches of electronic devices without reasonable suspicion and advanced searches with reasonable suspicion. The First Circuit joined the Eleventh Circuit in holding that advanced searches of electronic devices at the border do not require a warrant or probable cause and joined the Ninth and Eleventh Circuits in holding that basic border searches of electronic devices are routine searches that may be performed without reasonable suspicion. The Court then affirmed in part, reversed in part and vacated in part the judgment of the district court, holding that the court erred in narrowing the scope of permissible searches of electronic devices at the border. View "Alasaad v. Wolf" on Justia Law

The First Circuit affirmed the judgment of the district court upholding the jury verdict awarding Plaintiff compensatory on his claims of failure to accommodate his disability at work but remitting the jury's punitive damages award, holding that Defendants' claims on appeal failed.Specifically, the First Circuit held (1) the district court did not err in denying Defendants' post-trial motions for judgment as a matter of law because Plaintiff sufficiently proved his case under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101, and Maine Human Rights Act (MHRA), Me. Stat. tit. 5, 4571; (2) the district court's rulings denying Defendants' motion for a new trial were not an abuse of discretion; and (3) the district court did not abuse its discretion in denying Defendants' motion for remittitur because Defendants' arguments in support of the motion were misplaced and unsupported by the record. View "Burnett v. Ocean Properties, Ltd." on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment to the government on all of Plaintiff's claims, holding that summary judgment was properly granted on Plaintiff's sex discrimination and retaliation claims.Plaintiff, an employee of the Drug Enforcement Agency, brought this action claiming that she had been discriminated against because of her national origin, disability, and sex and that she had been subjected to illegal retaliation. The district court granted summary judgment to the government on all claims. Plaintiff appealed, challenging the judgment as to her sex discrimination and retaliation claims. The First Circuit affirmed, holding that Plaintiff's sex discrimination and retaliation claims could not survive summary judgment. View "Hernandez v. Wilkinson" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant of committing, or aiding and abetting others in committing, the crimes of RICO conspiracy, drug conspiracy, and other crimes, holding that Defendant was not entitled to relief on his allegations of error.After Defendant was originally convicted the First Circuit vacated the convictions, concluding that the police lacked probable cause to search Defendant's house, and therefore, the seized evidence should have been suppressed. On remand, a jury again convicted Defendant of the relevant charges. Defendant appealed, claiming trial error and sentencing issues. The First Circuit affirmed, holding (1) Defendant's claims of trial error were without merit; (2) there was sufficient evidence to support the convictions; (3) the trial court did not err in instructing the jury; (4) there was no abuse of discretion in the denial of Defendant's motion for a new trial; and (5) Defendant's sentence was not procedurally unreasonable. View "United States v. Cruz-Ramos" on Justia Law

The First Circuit affirmed the district court's denial of Petitioner's petition under 28 U.S.C. 2255 to vacate his sentence on the basis that he received ineffective assistance of counsel regarding his rejection of a plea offer, holding that Petitioner failed to show prejudice from any deficient performance by counsel.After a jury trial, Petitioner was found guilty of several charges arising out of a drug enterprise operating in a public housing project. Acting pro se, Petitioner filed a timely petition for postconviction relief, claiming that he received ineffective assistance of counsel. The district court denied the petition. The First Circuit affirmed, holding (1) Petitioner's counsel's performance was deficient when counsel failed to give Petitioner sufficient time to consider a plea offer and failed to advise him of the exposure to a life sentence; but (2) Petitioner failed to satisfy the prejudice prong of Strickland v. Washington, 466 U.S. 668 (1984). View "Feliciano-Rodriguez v. United States" on Justia Law

In these consolidated cases, the First Circuit affirmed the decision of the district court rejecting Plaintiffs' suits seeking to enjoin the enforcement of Section 12616 of the Agriculture Improvement Act of 2018, which bans the sponsorship and exhibition of cockfighting matches in Puerto Rico, holding that Section 12616 is a valid exercise of Congress's Commerce Clause power and does not violate Plaintiffs' individual rights.On their complaints, Plaintiffs argued that Section 12616 violated their First Amendment and Due Process rights and that Congress exceeded its powers under the Commerce and Territorial Clauses and further lodged both facial and as-applied pre-enforcement challenges to the statute. The district court granted the government's motion for summary judgment. The First Circuit affirmed, holding (1) Plaintiffs had standing to bring these lawsuits; (2) Section 12616 is a legitimate exercise of the Commerce Clause power; and (3) Section 12616 does not infringe on Plaintiffs' First Amendment freedoms of speech and association. View "Hernandez-Gotay v. United States" on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment against Plaintiff, acting as the personal representative of the estate of Ambrosia Fagre (Amber), on claims related to Amber's death, holding that the district court did not err when it granted Trooper Jeffrey Parks's motion for summary judgment on Plaintiff's 42 U.S.C. 1983 claim.Plaintiff's complaint alleged use of excessive force against Amber in violation of the Fourth and Fourteenth Amendments under section 1983 and use of excessive force against Amber in violation of Me. Const. art. I, 5 under the Maine Civil Rights Act, failure to protect Amber in violation of the Fourteenth Amendment, and negligence and wrongful death under Maine state law. The district court granted Trooper Parks's motion for summary judgment. The First Circuit affirmed, holding (1) summary judgment on Plaintiff's section 1983 claim was warranted, and Trooper Parks was also entitled to qualified immunity; and (2) the district court did not err by granting summary judgment on Plaintiff's state law claims because Trooper Parks was entitled to immunity under the Maine Tort Claims Act, Me. Stat. Tit. 14, 8111(1). View "Fagre v. Parks" on Justia Law

The First Circuit vacated Defendants' convictions for their roles in an expansive drug-trafficking conspiracy, holding that the evidence was sufficient to support the convictions but the trial was rendered unfair due to repeated, one-sided intercessions by the trial judge.The primary challenge of all four defendants on appeal was that they were entitled to a new trial because, throughout the eleven-day jury trial, the district court judge interjected during witness testimony in a manner that signaled an anti-defense bias to the jury and caused Defendants prejudice. The First Circuit agreed, holding that the trial judge's perceptible partiality impaired the integrity and fairness of the trial and that this judicial misconduct infringed upon all Defendants' right to a fair trial. View "United States v. Raymundi-Hernandez" on Justia Law

The First Circuit affirmed the district court's denial of Appellant's petition for a writ of habeas corpus, holding that the the Supreme Judicial Court of Massachusetts (SJC) reasonably applied clearly established law in holding that improper statements by the prosecutor during Appellant's trial did not render the trial fundamentally unfair.After a jury trial in Massachusetts state court Appellant was convicted of murder in the second degree and sentenced to life imprisonment. On appeal, Appellant argued that the prosecutor's closing argument was improper. The SJC affirmed Appellant's conviction, concluding that the prosecutor's "unfortunate" remarks did not warrant a new trial. Appellant later filed a habeas petition, which the district court denied. The First Circuit affirmed, holding that the district court's conclusion that the prosecutor's challenged statements did not render Appellant's trial fundamentally unfair was a reasonable application of clearly established federal law as determined by the Supreme Court. View "Taylor v. Medeiros" on Justia Law

The First Circuit dismissed this appeal without prejudice for lack of appellate jurisdiction, holding that the appeal was premature.In the early weeks of the COVID-19 pandemic, the Governor of Maine responded to the threat of contagion by issuing executive orders limiting all non-essential activities and gatherings. Plaintiff Calvary Chapel of Bangor brought this action arguing that those orders violated the First Amendment's Free Speech, Free Exercise, Assembly, and Establishment protections. The district court refused Plaintiff's request for a temporary restraining order. Plaintiff appealed. The First Circuit dismissed the appeal, holding that this case did not display the criteria this Court has previously identified as characterizing a de facto denial of injunctive relief and that the remaining requirements for appealability were not satisfied. View "Calvary Chapel of Bangor v. Mills" on Justia Law