Justia Civil Rights Opinion Summaries

The First Circuit held that Students for Fair Admissions, Inc. (SFFA) had associational standing to bring its claims against the President and Fellows of Harvard College and the Board of Overseers (collectively, Harvard) and that Harvard's race-conscious undergraduate admissions program does not violate Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d et seq.In its suit, SFFA alleged that Harvard's race-conscious admissions processed violated Title VI by discriminating against Asian American applicants in favor of white applicants. SFFA sought a declaratory judgment, injunctive relief, attorneys' fees and costs. The district court denied Harvard's motion to dismiss for lack of standing and then found that Harvard had met its burden of showing its admissions process did not violate Title VI. The First Circuit affirmed, holding (1) SFFA had associational standing to bring its claims; and (2) under governing Supreme Court law, Harvard's admissions program does not violate Title VI. View "Students for Fair Admissions v. President & Fellows of Harvard College" on Justia Law

The First Circuit affirmed the judgment of the district court granting judgment to the Commissioner of the Maine Department of Education in this federal constitutional challenge to the requirement of Maine's tuition assistance program that a private school must be "a nonsectarian school in accordance with the First Amendment" to qualify as "approved" to receive tuition assistance payments, holding that the program's condition violated neither the Free Exercise Clause nor the Establishment Clause.To ensure that Maine's school administrative units (SAUs) make the benefits of a free public education available Maine provides by statute that SAUs that do not operate a public secondary school of their own may either contract with a secondary school for school privileges or pay the tuition at the public school or an approved private school at which the student from their SAU is accepted. Plaintiffs brought this suit against the Commissioner, arguing that the program's requirement that a private school be a nonsectarian school to receive tuition assistance payments infringed various of their federal constitutional rights. The district court granted judgment to the Commissioner. Having twice before rejected similar federal constitutional challenges to the "nonsectarian" requirement and even accounting for fresh United States Supreme Court precedent the First Circuit affirmed, holding that Plaintiffs' constitutional challenges failed. View "Carson v. Makin" on Justia Law

The First Circuit affirmed Defendant's convictions and sentence for three counts related to distribution of heroin and one count of discharging a firearm in furtherance of a drug crime, holding that the district court did not err.On appeal, Defendant argued that the district court erred in denying his motion to suppress certain evidence at trial and erroneously concluded that he was eligible for a two-level role enhancement under the U.S. Sentencing Guidelines. The First Circuit affirmed, holding (1) the district court properly found that law enforcement officers had sufficient probable cause to substantiate a search warrant for Defendant's apartment before a protective sweep began, and Defendant did not establish that the government failed to meet the requirements for applying the inevitable discovery doctrine; and (2) the district court did not clearly err in applying the two-level role enhancement. View "United States v. Soto-Peguero" on Justia Law

The First Circuit affirmed Defendant's conviction of possession with intent to distribute oxycodone, holding that the district court did not err in denying Defendant's motion to suppress.Defendant's vehicle was intercepted by the Maine State Police, and Defendant's vehicle was searched. Defendant entered a conditional guilty plea to possession with intent to distribute oxycodone. On appeal, Defendant argued that the authorities lacked probable cause to search his vehicle and that the district court erred by refusing to suppress statements he made both before and after Miranda warnings were administered. The First Circuit affirmed, holding (1) the authorities had probable cause to search Defendant's car, and therefore, the evidence seized during the vehicle search was admissible; and (2) the district court did not err in denying Defendant's motion to suppress his statements. View "United States v. Simpkins" on Justia Law

The First Circuit affirmed the decision of the district court denying Defendant's motion to suppress drug evidence that was seized without a warrant after an automobile stop and drug evidence from a subsequent visual body cavity search, holding that the police had reasonable suspicion to perform the automobile stop and particularized reasonable suspicion to perform the visual body cavity search.On appeal, Defendant argued that his rights under the Fourth and Fourteenth Amendments were violated because the law enforcement officers lacked reasonable suspicion to perform the initial stop of his vehicle and the requisite level of suspicion to perform the visual body cavity search of his person at the police station. The First Circuit disagreed, holding that the officers (1) had reasonable suspicion to stop Defendant's vehicle; and (2) had particularized reasonable suspicion to conduct the visual body cavity search. View "United States v. Perez" on Justia Law

The First Circuit affirmed the district court's grant of summary judgment on Plaintiff's racial discrimination and retaliation claims against the Massachusetts Bay Transportation Authority (MBTA), holding that both challenges were meritless.Plaintiff brought claims of racial discrimination, unlawful retaliation, and negligent infliction of emotional distress against the MBTA. The district court granted summary judgment to the MBTA on all claims. The First Circuit affirmed, holding (1) Plaintiff did not produce sufficient evidence to get to a jury on his claim that he was denied a promotion based on his race; and (2) Plaintiff did not establish a prima facie case of retaliation. View "Henderson v. Massachusetts Bay Transportation Authority" on Justia Law

The First Circuit vacated the decision of the district court granting summary judgment for Defendants and dismissing Plaintiff's 42 U.S.C. 1983 action on the grounds that Plaintiff's claims were time barred, holding that there was no basis for summary judgment on the record.Plaintiff filed suit against the City of Biddeford, Captain Norman Gaudette with the Biddeford Police Department (BPD), and Chief of Police Roger Beaupre, alleging that Gaudette sexually abused him as a teenager in the later 1980s and that the City and Baupre were deliberately indifferent to Gaudette's violation of his constitutional rights when Plaintiff reported the abuse. Defendants argued that the suit was barred by the statute of limitations. In response, Plaintiff asserted that his claims did not accrue until 2015, when he learned that the BPD and Baupre allegedly knew of at least one other report of Gaudette sexually abusing a minor that pre-dated Plaintiff's experience. The district court granted summary judgment for Defendants. The First Circuit reversed, holding (1) a reasonable jury could find that Plaintiff had no duty to diligently investigate his claims against Defendants before 2015; and (2) therefore, the district court erred in concluding as a matter of law that Plaintiff's claims accrued at the time of his injury in the late 1980s. View "Ouellette v. Beaupre" on Justia Law

The First Circuit affirmed the judgment of district court dismissing Plaintiff's case against the City of Boston and several of its police officers, holding that the district court did not abuse its discretion in dismissing the case with prejudice.Plaintiff filed suit in superior court under 42 U.S.C. 1983 and the Massachusetts Tort Claims Act, alleging, among other things, false arrest and imprisonment, excessive force, and intentional infliction of emotional distress. After a lengthy history of delay, the district court gave Plaintiff fourteen days to serve an amended complaint on two defendants. Plaintiff never properly served one of the defendants. The district court dismissed the defendant not properly served. The court then dismissed the other defendant, concluding that Plaintiff's failure to meet a deadline for service did not constitute excusable neglect. The First Circuit affirmed, holding that the district court acted within its discretion in dismissing the case with prejudice. View "Tubens v. Doe" on Justia Law

The First Circuit vacated the judgment of the district court in favor of Defendant on Plaintiff's claim that Defendant failed properly to accommodate his disability under the Americans with Disabilities Act (ADA), 42 U.S.C. 1210 et seq., and the Maine Humans Rights Act (MHRA), Me. Rev. Stat. 5, 4551 et seq., holding that the district court committed prejudicial error in instructing the jury.On appeal, Plaintiff argued that the district court erred in instructing the jury that to succeed on a claim that an employer failed to provide a reasonable accommodation, a plaintiff must prove that he needed an accommodation to perform the essential functions of his job. The First Circuit agreed, holding (1) by instructing the jury that an employee must demonstrate that he needed an accommodation to perform the essential functions of his job, the district court wrongly limited Plaintiff's potential liability; and (2) the error was prejudicial. View "Bell v. O'Reilly Auto Enterprises, LLC" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendants' motions for judgment as a matter of law or, in the alternative, for a new trial or remittitur, holding that the trial court properly found Defendants liable for conspiracy to violate Plaintiff's civil rights.Plaintiff suffered a head injury at the Andover, Massachusetts State Police Barracks. Plaintiff filed this action against the three officers involved in his booking, including Trooper James J. Foley, alleging several federal and state causes of action. After a trial, the jury found Foley liable on six claims, including the use of excessive force, and all three officers liable for conspiracy to violate Plaintiff's civil rights. On appeal, Defendants argued that the district court erred in denying their motions for judgment as a matter of law or, in the alternative, for a new trial or remittitur. The First Circuit affirmed, holding that the district court (1) correctly denied Defendants' post-verdict motions for judgment as a matter of law on each of the counts for which they were found liable; (2) did not abuse its discretion in declining to order a new trial; and (3) did not err in denying Foley's motion for remittitur. View "Sanchez v. Foley" on Justia Law