Justia Constitutional Law Opinion Summaries
Articles Posted in U.S. 1st Circuit Court of Appeals
Scoggins v. Hall
After a jury trial in 1998, Petitioner was convicted iof first-degree murder and sentenced to life imprisonment. This appeal concerned Petitioner’s petition for habeas relief in which Petitioner sought to invalidate his conviction on the ground that his court-appointed attorney’s failure to interview a certain prosecution witness, Barbara Holbrook, before trial and counsel’s failure to interview or to call at trial several witnesses who allegedly could have rebutted Holbrook’s testimony constituted ineffective assistance. The district court denied the petition. The First Circuit affirmed, holding that Petitioner’s ineffective assistance of counsel claim failed on the merits. View "Scoggins v. Hall" on Justia Law
United States v. Arthur
A Boston police officer spotted two men, including Appellant, matching the general description of culprits who had recently robbed a cell phone store. The officer stopped the men and questioned them. During the conversation, the officer received information from other officers that supported his suspicions. Appellant was brought to the scene of the crime, where he was identified in a “show-up” procedure. Appellant was charged with robbery and firearms offenses. Appellant filed a motion to suppress. The district court denied the motion, determining that the stop was justified by reasonable suspicion and that, although the show-up procedure was impermissibly suggestive, the store clerk’s identification was reliable and therefore admissible. Appellant entered a conditional guilty plea to the charged counts and then appealed the denial of his motions to suppress. The First Circuit affirmed, holding that the district court (1) did not err in finding that the stop effectuated by the officer was accompanied by reasonable suspicion; and (2) did not err in refusing to suppress the store clerk’s eyewitness identification testimony. View "United States v. Arthur" on Justia Law
Penn v. Escorsio
Defendants worked as corrections officers at a jail where Matthew Lalli was being held as a pre-trial detainee. Defendants were involved in a series of troubling events that led to Lalli’s attempted, and almost completed, suicide. Plaintiff, Lalli’s guardian, sued Defendants, claiming deliberate indifference in violation of Lalli’s Fourteenth Amendment rights. Defendants filed a motion for summary judgment, asserting that they were not deliberately indifferent and were entitled to qualified immunity. The district court denied the motion, determining that a reasonable jury could find Defendants acted with deliberate indifference toward Lalli and that Defendants were not entitled to qualified immunity on the claim of deliberate indifference at the summary judgment stage. The First Circuit affirmed, holding that Defendants could not show they were entitled to qualified immunity at the summary judgment phase of this litigation. View "Penn v. Escorsio" on Justia Law
United States v. Vizcarrondo-Casanova
The three defendants in this appeal - Jose Vizcarrondo-Casanova, Carlos Aponte-Sobrado, and Erik Diaz-Colon - were convicted of crimes related to the kidnapping, robbery, and homicide of Elis Manuel Andrades-Telleria, a drug dealer and rival to Diaz-Colon. The defendants were among twelve people charged in a single indictment in connection with the crimes committed against Andrades-Telleria. The First Circuit affirmed all three defendants’ convictions, holding (1) the admission of evidence of prior shared criminal conduct among groups of the defendants charged in this case were permissible under Fed. R. Evid. 404(b) and 403; (2) certain remarks by the prosecutor during closing argument were not clearly and obviously improper; (3) although certain counts of Diaz-Colon’s indictment were constructively amended, the error did not prejudice Diaz-Colon; (4) the government was permitted to withdraw its plea offer made to Diaz-Colon before trial; and (5) the fact that the jury rendered inconsistent verdicts on two counts for which Diaz-Colon was convicted was not grounds for reversing Diaz-Colon’s convictions. View "United States v. Vizcarrondo-Casanova" on Justia Law
Millay v. State of Maine Dep’t of Labor
Plaintiff, who was blind, requested transportation subsidies from a Maine state agency. The agency refused the request. After an unsuccessful appeal to an administrative hearing officer, Plaintiff brought suit in the federal district court. A magistrate judge recommended dismissal but suggested that Plaintiff reframe his action as one for judicial review under Title I of the Rehabilitation Act. Plaintiff subsequently sought leave to amend his complaint to assert a claim for judicial review. The agency objected, arguing that Plaintiff’s proposed claim was barred by Maine’s general thirty-day statute of limitations for judicial review of administrative decisions. The district court allowed Plaintiff to file his proposed amended complaint and concluded that the hearing officer should have granted Plaintiff relief. The agency appealed, arguing that Plaintiff’s action for judicial review was time-barred. The First Circuit affirmed, holding (1) Plaintiff’s judicial review action under 29 U.S.C. 722(c)(5)(J) arises out of a post-1990 congressional enactment within the meaning of 29 U.S.C. 1658, which enactment does not explicitly incorporate any specific limitations period; and (2) accordingly, the right to judicial review that the statute creates is subject to the general catch-all limitations period contained in section 1658(a). View "Millay v. State of Maine Dep't of Labor" on Justia Law
United States v. Martinez
Defendant was indicted for being a felon in possession of a firearm that had traveled in interstate commerce. Defendant moved to suppress the firearm, arguing that the officers who frisked him had no reasonable suspicion that he was armed and dangerous. The district court denied the motion. Defendant subsequently entered a conditional guilty plea to possessing a firearm as a convicted felon, reserving his right to appeal the suppression ruling. The district court sentenced Defendant to seventy months in prison after applying a six-level sentence enhancement based on a finding that Defendant’s prior Massachusetts conviction for assault and battery constituted a crime of violence under the Sentencing Guidelines. On appeal, the First Circuit affirmed the denial of Defendant’s suppression motion but vacated Defendant’s sentence, holding (1) the district court did not err in concluding that the search of Defendant was supported by reasonable suspicion; but (2) Defendant’s prior Massachusetts conviction did not constitute a crime of violence under the Sentencing Guidelines, and therefore, the district court improperly calculated Defendant’s base offense level. Remanded. View "United States v. Martinez" on Justia Law
McGrath v. Tavares, et al.
Plaintiff filed suit under 42 U.S.C. 1983, alleging that police officers used excessive force when they shot and killed her sixteen-year-old son (Anthony). The district court granted the police officers' motion for summary judgment and dismissed all claims. The officers responded to an activated burglar alarm at a liquor store, were involved in a car chase with Anthony, and when one of the officers exited his vehicle, Anthony drove towards him. The shots were fired at Anthony when he was driving towards one of the officers. The court concluded that a reasonable officer in the same circumstances would have believed that Anthony posed a threat of serious physical harm to the officer when the officer fired the shots. In any event, the officers were entitled to summary judgment based on qualified immunity because they did not violate clearly established law. Plaintiff failed to point to any case that clearly establishes the unconstitutionality of using deadly force to end a car chase that threatened the physical safety of the officers and others in the area. Accordingly, the court affirmed the judgment of the district court. View "McGrath v. Tavares, et al." on Justia Law
Garcia-Gonzalez v. Puig-Morales
Plaintiff filed suit under 42 U.S.C. 1983, alleging First and Fourteenth Amendment violations concerning the rescission of a bid award for a potential, but unexecuted, insurance brokerage contract with the Puerto Rico government. The court affirmed the district court's grant of summary judgment on plaintiff's Fourteenth Amendment due process claim where he had no constitutionally protected property interest in the initial bid award; reversed the grant of summary judgment on plaintiff's First Amendment claim for political discrimination where there is a genuine issue of material fact as to whether plaintiff's political affiliation was a substantial or motivating factor for the adverse action; and remanded for further proceedings. View "Garcia-Gonzalez v. Puig-Morales" on Justia Law
Dunn v. Trs. of Boston Univ.
Michael Dunn worked for Boston University (BU) from 1992 until 2010, at which time Dunn’s job was allegedly eliminated due to restructuring. Dunn brought suit against BU in Massachusetts superior court, claiming age discrimination in violation of both state and federal law. BU removed the case to federal district court. The district court granted summary judgment in favor of BU, concluding that Dunn had not made out a prima facie case that he was laid off because of his age. The First Circuit affirmed without ruling on the sufficiency of Dunn’s prima facie showing, holding that, even assuming that Dunn made a prima facie showing of age discrimination, Dunn failed to demonstrate a genuine issue of material fact as to whether BU’s stated reasons for discharging him were a pretext for unlawful discrimination. View "Dunn v. Trs. of Boston Univ." on Justia Law
United States v. Rodriguez
After a jury trial, Defendant was convicted on three counts of distributing cocaine base. During trial, the court allowed testimony from a cooperating witness who purchased cocaine base from Defendant on three occasions, plus video and audiotapes of those transactions. The First Circuit affirmed the convictions, holding (1) the district court did not commit plain error in allowing the jury to review previously admitted audiotapes and video in the courtroom and in the presence of alternate jurors, the court, and the parties; (2) the district court did not commit plain error in failing to instruct the jury that it could not draw negative inferences from the fact that law enforcement officers possessed photographic images of Defendant; and (3) Defendant’s sentencing as a career offender did not violate the Sixth Amendment prohibition against judicial fact finding. View "United States v. Rodriguez" on Justia Law