Justia Constitutional Law Opinion Summaries

A federal grand jury indicted Defendant of being a felon in possession of a firearm. Defendant moved to suppress the gun on the ground that the search that resulted in the discovery of the gun derived from an unlawful seizure. The district court granted the motion to suppress, finding that Defendant's encounter with law enforcement officers was at first consensual, but by the time it became a Terry stop, the officers lacked reasonable suspicion to permit the detention. The First Circuit Court of Appeals affirmed, holding that the district court did not err in concluding that the totality of the circumstances did not provide a reasonable suspicion to support Defendant's continuing detention at the time of the search that produced the firearm. View "United States v. Dapolito" on Justia Law

After exhausting her administrative remedies, Plaintiff, together with her husband and their conjugal partnership, sued Employer under Title VII, alleging sex discrimination in the form of hostile-work-environment harassment, and retaliation for challenging the harassment. A magistrate judge entered summary judgment for Employer on all claims. The Supreme Court affirmed, holding (1) ultimately, Plaintiff had no sex discrimination claim against Employer and so summary judgment was appropriate on that claim; (2) the evidence did not show that Employer infracted Title VII by retaliating against Employee for alleging that Employer discriminated against her on the basis of sex; and (3) Plaintiff could not prevail on her claim that the federal court judge was "bound" by Puerto Rico's summary-judgment policy. View "Medina-Rivera v. MVM, Inc." on Justia Law

Defendant, who had a 1994 conviction for criminal sexual assault, failed to register as required under the Sex Offender Registration and Notification Act (SORNA) when he moved to Puerto Rico in 2010. Defendant also had two prior failures to register as a sex offender in New Jersey and Florida, and he had an extensive criminal record, including a recent assault on an adult female. Defendant pled guilty to the federal charge of failure to register in this case. In sentencing Defendant, the district court imposed a particular condition of supervised release: that Defendant participate in a sex offender treatment and/or mental health treatment program arranged by the probation officer. The First Circuit Court of Appeals affirmed, holding that the district court did not abuse its discretion in imposing the sex-offender treatment, which was reasonably related to Defendant's present offense as well as to his criminal history. View "United States v. Morales-Cruz" on Justia Law

Defendant purchased a stolen handgun. Two days later, Defendant returned the gun in exchange for the money he paid. Based on the time he possessed the weapon, Defendant was indicted and convicted of one count of possession of a stolen firearm and was sentenced to a $100 special assessment, a one-month jail term, and a two-year term of supervised release. The First Circuit Court of Appeals vacated Defendant's conviction and remanded the case for a new trial, holding that the district court erred when it declined to instruct the jury on "innocent possession," which would have allowed Defendant to make out a defense of innocent possession of the stolen weapon. View "United States v. Baird" on Justia Law

Plaintiff, the former proprietor of a now-defunct bar and restaurant in Wrentham, Massachusetts, sued the Town of Wrentham and several town officials, alleging that Defendants maliciously imposed excessive regulatory requirements on his restaurant in retaliation for his opposition to certain town policies. Defendant filed causes of action for federal civil rights violations and violations of the state unfair trade practices law. The district court dismissed Defendant's complaint for failure to state a claim, concluding (1) the 42 U.S.C. 1983 claims were vague, failed to connect any of the alleged harms to any particular defendant, and did not establish a basis for municipal liability; and (2) the state law claim did not suggest any business contest or allege any unfair act or deceptive practice. The First Circuit Court of Appeals affirmed, holding that the district court did not err in its judgment. View "Gianfrancesco v. Town of Wrentham" on Justia Law

Defendants, both Chinese nationals, shipped tens of millions of dollars worth of sophisticated electronic components from the United States to China with little regard for whether the parts they sold were export-controlled. In 2008, Defendants were arrested and later indicted for thirty-four counts of export-related offenses. The two were ultimately convicted of, among other things, exporting without a license items designated as defense articles on the U.S. Munitions List and items controlled under the Commerce Control List, conspiracy to violate the Munitions List and Commerce Control List restrictions, and conspiracy to file materially false Shipper's Export Declarations (SED) with the Commerce Department. On appeal, Defendants argued that the federal government's arms export control system constituted a regulatory scheme that violated the Due Process Clause. The First Circuit Court of Appeals (1) affirmed the Commerce Control List convictions and SED convictions, holding that the federal government's arms export control system does not violate the Fifth Amendment's Due Process Clause; and (2) vacated the Munitions List convictions, holding that the district court erred by not submitting to the jury an element of the offense, and the error was not harmless. Remanded. View "United States v. Wu" on Justia Law

A drug interdiction in Caribbean waters by the United States Coast Guard ended with the arrest and indictment of multiple defendants, including Appellant. The Coast Guard determined that the vessel was "without nationality" and subject to the jurisdiction of the United States under the Maritime Drug Law Enforcement Act (MDLEA). Appellant was convicted of possession with the intent to distribute more than 1140 pounds of cocaine and heroin while on board a vessel in violation of the MDLEA. On appeal, Appellant argued that Congress lacked the authority under the Piracies and Felonies Clause to criminalize drug trafficking on board a vessel in international waters under the MDLEA without requiring a nexus between the conduct and the United States. The First Circuit Court of Appeals affirmed, holding that any jurisdictional error under the MDLEA related to Appellant's conviction did not constitute plain error in this case. View "United States v. Nueci-Pena" on Justia Law

James "Whitey" Bulger was the leader of a criminal organization in Boston from 1972 to 1999. An indictment returned by a federal grand jury charged Bulger with a number of federal offenses, including violations of the Racketeer Influenced and Corrupt Organizations (RICO) Act, and the indictment alleged that Bulger committed nineteen murders ancillary to the RICO conspiracy. Bulger's case was assigned to U.S. District Court Judge Richard Stearns. Bulger moved that Judge Stearns recuse himself, arguing that the judge's prior employment as head of the U.S. Attorney's Criminal Division in Boston and his close friendship with FBI Director Robert Mueller created an appearance of impropriety necessitating recusal. Judge Stearns denied the motion. Bulger subsequently petitioned the First Circuit Court of Appeals for a writ of mandamus requiring reversal of the judge's order denying the motion for recusal. The First Circuit granted the petition and ordered the case to be reassigned to a different judge "because it is clear that a reasonable person would question the capacity for impartiality of any judicial officer with the judge's particular background in the federal prosecutorial apparatus in Boston during the period covered by the accusations." View "In re Bulger" on Justia Law

Defendant pled guilty to one count of importing codone. The guilty plea was based on an incident in which, based on tips from three confidential informants (CIs), federal agents apprehended Defendant at the Canadian border, handcuffed him to a hospital bed, and monitored Defendant's bowel movement, in which Defendant passed a condom containing 104 eighty-milligram and five forty-milligram oxycodone pills. The district court assigned Defendant a drug quantity equivalent to 2,637 eighty-milligram oxycodone pills based in part on uncharged conduct described by the CIs and sentenced Defendant to 108 months in prison. The First Circuit Court of Appeals affirmed, holding that the district court did not err in (1) denying Defendant's motion to force the government to disclose the CIs' names, as the court correctly weighed the correct factors in finding that the government's interest in preserving the CIs' anonymity tipped the scale against disclosure; and (2) calculating the drug quantity attributable to Defendant, as the CIs' statements were sufficiently reliable. View "United States v. Mills" on Justia Law

Defendant entered a plea of guilty to distributing cocaine base pursuant to a binding plea agreement. More than seven months later, Defendant filed a motion to vacate his guilty plea, which the district court denied. The court subsequently sentenced Defendant to serve ninety months in prison. Defendant appealed, arguing that his plea was neither voluntary nor knowing because he did not realize at the time he entered it that the sentencing guidelines were merely advisory. The First Circuit Court of Appeals affirmed, holding that the district court did not err in denying Defendant's motion to vacate his guilty plea, as (1) the proffered reason for revoking the plea was implausible; and (2) the waiver of appeal provision contained in the plea agreement was valid, and enforcement of the waiver would not result in a miscarriage of justice. View "United States v. Chambers" on Justia Law