Justia Constitutional Law Opinion Summaries

Petitioner was convicted in Massachusetts Superior Court of first degree murder by reason of extreme atrocity or cruelty. Defendant filed a motion for a new trial, alleging ineffective assistance of counsel, and requested an evidentiary hearing on his claim. The superior court denied the motion for a new trial without holding an evidentiary hearing. The Massachusetts Supreme Judicial Court affirmed. Petitioner subsequently field a petition for writ of habeas corpus in the U.S. district court, reiterating his ineffective assistance claims and arguing that that Massachusetts court's denial of his request for an evidentiary hearing on these claims violated his due process rights. The district court dismissed the petition, concluding that the state court record was sufficient to resolve the case. The First Circuit Court of Appeals affirmed because Petitioner's claim was adjudicated on the merits by the Supreme Judicial Court, and Petitioner failed to raise a substantial issue that might require an evidentiary hearing. View "Garuti v. Roden" on Justia Law

On August 6, Appellant was arrested in Maine and charged by the State for firearm-related crimes. On August 26, the United States ("government") charged Appellant with possession of a firearm by a convicted felon. On August 29, the State dismissed the related State charges. Appellant remained incarcerated by the State for the next month despite the fact the State had dismissed all charges against him. Finally, on October 3, Appellant was arrested by U.S. Marshals and brought before a federal judge. On October 26, a federal grand jury returned an indictment charging Appellant, and Appellant waived his right to contest the government's motion to detain him pending trial. Appellant subsequently filed a motion to dismiss the federal indictment on speedy-trial grounds. The district court denied the motion. The First Circuit Court of Appeals affirmed, holding (1) because Appellant did not enter federal custody until October 3, his October 26 indictment occurred within thirty days of his arrest on federal charges and, therefore, did not violate the Speedy Trial Act; and (2) the district court did not err by failing to impose sanctions against the government for its purported failure to notify Appellant that it had lodged a federal detainer against him. View "United States v. Lewis" on Justia Law

Mother, an Egyptian citizen, acted in violation of a court order when she, together with her two children, boarded an EgyptAir Airlines Company flight to Cairo, Egypt. The father of the children and Mother's former husband (Father) brought this lawsuit against Mother and EgyptAir. Father claimed EgyptAir was negligent in allowing Mother to board the flight despite "red flags" suggesting she was abducting the children. The district court granted summary judgment for EgyptAir, concluding that the airline did not know of Mother's plan to abduct the children and did not owe Defendant or the children a duty to investigate the red flags. The First Circuit Court of Appeals affirmed the dismissal of Father's claims, holding (1) the district court had jurisdiction over the claims; and (2) the claims, which challenged airline ticketing, check-in, and boarding procedures, were preempted under the Airline Deregulation Act. View "Bower v. El-Nady Bower" on Justia Law

A federal law enforcement officer made a lawful traffic stop of Appellant, but by the time the officer stopped Appellant, he and Appellant were outside the jurisdiction in which the officer was authorized to make arrests. The officer could see that Appellant was intoxicated and arrested Appellant. Appellant was subsequently charged with operating a motor vehicle under the influence, unsafe operation of a motor vehicle, and refusal to submit to a breath test. Appellant moved to suppress the evidence from his arrest on the grounds that the officer lacked the authority to arrest him. The magistrate judge agreed that the officer lacked statutory authority to arrest Appellant but refused to suppress the evidence because the arrest was not an unreasonable seizure. The district judge affirmed the magistrate judge's decision not to suppress the evidence. The First Circuit Court of Appeals affirmed, holding that Appellant's arrest did not constitute the kind of invasion of privacy that the Fourth Amendment prohibits. View "United States v. Ryan" on Justia Law

The City of Providence, Rhode Island enacted two ordinances to reduce tobacco use by young people. The Price Ordinance restricted the City's tobacco and cigarette retailers from reducing prices on tobacco products through coupons and multi-pack discounts. The Flavor Ordinance restricted sales of certain flavored tobacco products other than cigarettes. The National Association of Tobacco Outlets challenged the ordinances, alleging, inter alia, that the ordinances were preempted by federal and state law. The district court upheld the ordinances. The First Circuit Court of Appeals affirmed, holding (1) because the Price Ordinance was an appropriate regulation of price, it fell outside the First Amendment; (2) because the Flavor Ordinance was an appropriate sales regulation, it was not preempted; and (3) neither ordinance conflicted with state law. View "Nat'l Ass'n of Tobacco Outlets, Inc. v. Providence, R.I." on Justia Law

Defendant pleaded guilty to conspiracy to commit promotional money laundering pursuant to a plea agreement. Defendant stipulated to the amount of money laundered and received a prison sentence within the range of the federal sentencing guidelines. Defendant appealed, seeking to vitiate his guilty plea on grounds that the record failed to establish a sufficient factual basis for his plea and asserting a claim of sentencing error. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in accepting Defendant's guilty plea, as sufficient facts supported the plea; and (2) there was no sentencing error where Defendant's stipulation removed any necessity for independent proof of the stipulated facts. View "United States v. Torres-Vazquez" on Justia Law

Defendant stole his older brother's identity to obtain five fraudulent mortgages. Defendant subsequently pleaded guilty to three counts of wire fraud and one count of identity fraud pursuant to a plea agreement. Under to the agreement, Defendant was sentenced to a term of imprisonment and ordered to pay $454,207 in restitution to the two defrauded mortgage companies. The plea agreement also contained an appeal waiver. Defendant appealed, challenging the restitution component of his sentence and arguing that his appeal waiver did not extend to it. The First Circuit Court of Appeals dismissed Defendant's appeal, as the waiver unambiguously encompassed restitution. View "United States v. Okoye" on Justia Law

Appellant was a criminal defense attorney that represented a client in a criminal case relating to the discharge of sewage into public waters. After trial, the First Circuit Court of Appeals vacated the client's convictions and remanded for retrial. Appellant subsequently filed ten motions in limine mostly to exclude or limit certain evidence used in the first trial. The trial court issued an order sanctioning Appellant and his client for having filed the motions in limine over the course of the six days prior to the scheduled start of the trial, "abusively late." The court suggested that the motions were filed late to avoid impacting the client's speedy trial act motion or to force a continuance of the trial. The First Circuit reversed the order, holding that the trial court erred in sanctioning Appellant, as there was no clear deadline for the filing of the motions in limine. View "United States v. Agosto-Vega" on Justia Law

Defendant, a pharmacist, accepted payments from "Internet pharmacy sites" for whose customers Defendant's employer, a mail-order pharmacy, filled orders. Eventually, Defendant was indicted on charges related to these payments and pled guilty to soliciting and accepting kickbacks. Defendant appealed his sentence, arguing that the district court should have sentenced him for accepting an illegal gratuity rather than for demanding a bribe. The First Circuit Court of Appeals affirmed, holding that because Defendant pled guilty to soliciting and receiving a bribe, not a gratuity, and because recent changes in case law did not provide Defendant with assistance on appeal, the district court did not err in its judgment. View "United States v. Gracie" on Justia Law

Defendant pled guilty to an eight-count federal indictment including charges of child pornography and using an interstate facility to attempt to persuade a person under eighteen to engage in a sexual act. After Defendant was released on probation, his supervised release was revoked for violating the terms of his probation. The district court subsequently directed Defendant's civil confinement as a "sexually dangerous person" under the Adam Walsh Child Protection and Safety Act. The First Circuit Court of Appeals affirmed, holding that the district court did not clearly err in determining that Defendant was a sexually dangerous person subject to commitment. View "United States v. Volungus" on Justia Law