Justia Constitutional Law Opinion Summaries

Plaintiffs brought two citizen enforcement actions under the Clean Water Act (CWA) against Defendants pursuant to 33 U.S.C. 1365(a). The suits were dismissed without prejudice due to defects in the service or contents of earlier pre-suit notices. Plaintiffs then brought their most recent citizen suit, which the district court dismissed without prejudice, finding that Plaintiffs had failed to allege or establish several mandatory prerequisites to a citizen suit under the CWA in their pre-suit notice. The First Circuit Court of Appeals reversed in part, holding that the district court erred in dismissing the case, as (1) Plaintiffs' pre-suit notice satisfied the requirement that the notice identify the potential plaintiffs, provide basic contact information, and allow the putative defendants to identify and remedy the alleged violations; and (2) therefore, the enforcement action may proceed. View "Paolino v. JF Realty, LLC" on Justia Law

Defendant bought a custom-made yacht with the help of a loan from Barclays Bank. When Defendant stopped making payments on the loan, Barclays repossessed the yacht and sold it pursuant to the Florida UCC. Barclays got less than what Defendant owed on the yacht, and therefore, Barclays sued Defendant for the deficiency. Defendant moved for summary judgment, arguing that Barclays was barred from recovering the deficiency because, in violation of the mortgage's terms, it did not provide Defendant with proper notice of the sale. The district court denied Defendant's motion and sua sponte granted summary judgment in favor of Barclays. The First Circuit Court of Appeals affirmed, holding that the notice Barclays provided to Defendant was sufficient. View "Barclays Bank PLC v. Poynter" on Justia Law

After a jury trial, Defendant was found guilty of bank burglary. In sentencing Defendant, the district court applied a sentencing guideline intended for cases of robbery, rather than the burglary guideline Defendant proposed. The resulting sentence was roughly twice what it would have been under the burglary guideline. Defendant appealed, challenging the constitutionality of the district court's decision to sentence him under a guideline intended for robbery. Without reaching Defendant's constitutional claim, the First Circuit Court of Appeals remanded for resentencing because, under the sentencing guidelines and the introduction to the guidelines' statutory appendix, where the guidelines specify more than one offense guideline for a particular statutory offense and no plea agreement stipulates to a more serious offense, the district court must select the most appropriate guideline based only on conduct charged in the indictment. View "United States v. Almeida" on Justia Law

Plaintiff, an international affairs specialist at the Puerto Rico State Department, filed a complaint against the Department, ten of its employees, the Commonwealth (collectively, the State Department defendants), and the Puerto Rico Ports Authority. Plaintiff alleged that the State Department defendants had discriminated against her due to her political views and that they had denied her the rights and benefits to which she was entitled under federal and local law. As against the Ports Authority, Plaintiff alleged it slandered her by publishing false information regarding an arrest for marijuana, which prevented her from fulfilling her work duties. The district court found that Plaintiff's complaint failed to state a claim upon which relief could be granted and dismissed the complaint. Plaintiff appealed, requesting a reversal of the district court's refusal to grant leave to amend the complaint based upon its finding that amendment would be futile. The First Circuit Court of Appeals affirmed, holding that the district court did not abuse its discretion in denying the requested amendment. View "Flores-Silva v. McClintock-Hernandez" on Justia Law

Defendant was indicted for drug-trafficking charges. Through a succession of court-appointed attorneys, Defendant filed motions to suppress certain evidence and to dismiss the indictment on speedy trial grounds. The district court denied the motions, and Defendant entered a conditional guilty plea to the charges. Prior to sentencing, Defendant moved pro se to withdraw his guilty plea and requested a new court-appointed attorney, which the district court appointed. The court then rejected Defendant's motion and sentenced Defendant to 240 months in prison. The First Circuit Court of Appeals affirmed, holding that the district court (1) did not err in denying Defendant's motion to suppress; (2) did not err in refusing to dismiss the indictment on speedy trial grounds; (3) did not abuse its discretion in concluding Defendant had not shown a fair and just reason for withdrawing his guilty plea; and (4) did not err in sentencing Defendant. View "United States v. Gates" on Justia Law

After a jury trial, Appellant was convicted of conspiracy to possess with intent to distribute controlled substances (Count One), distribution of a controlled substance, and possessing and providing contraband to a prison. Appellant was sentenced to a term of imprisonment of seventy-eight months. Appellant appealed his conviction on Count One, arguing that the evidence was insufficient to establish a single conspiracy as charged in the indictment. The First Circuit Court of Appeals affirmed the judgment of the district court, holding that the evidence in this case would allow a rational jury to determine beyond a reasonable doubt that the single conspiracy charged in the indictment existed. View "United States v. Rios-Ortiz" on Justia Law

An investigation of gang-related drug trafficking by the FBI led to the arrest of Appellant, a key supplier of crack cocaine in his community. Defendant pled guilty to conspiracy to distribute crack cocaine and distribution of crack cocaine and received a thirteen-year sentence. Defendant appealed, claiming that his prior felony conviction did not warrant the career offender enhancement and that the district court erred in denying his request for resentencing and failing adequately to explain the reasons for his sentence. The First Circuit Court of Appeals vacated Appellant's sentence and remanded for clarification, holding (1) the district court did not err in its application of the career offender enhancement, as Appellant's conviction for the burglary of a dwelling qualified as a crime of violence under the sentencing guidelines' residual clause; but (2) the record was insufficient to determine whether the district court applied the sentencing enhancement for knowingly or intentionally using a person who is a minor in violating 21 U.S.C. 841(a)(1), and whether, in so doing, the court miscalculated Appellant's guidelines range. View "United States v. Ramirez" on Justia Law

Plaintiffs were United States citizens injured in a 1997 terrorist attack in Jerusalem that Hamas orchestrated. Plaintiffs sued the Islamic Republic of Iran, alleging that Iran had provided material support to Hamas and was therefore liable for the attack. Plaintiffs obtained a default judgment against Iran in 2003. Seeking to collect on that judgment, Plaintiffs moved to attach, by trustee process action in the District of Massachusetts, certain antiquities they claimed were the property of Iran but that were in the possession of Defendants, the Museum of Fine Arts, Boston (MFA) and Harvard University. The district court granted Defendants' motions to dissolve the attachments, concluding that Defendants could invoke the objects' immunity from attachment under the Foreign Sovereign Immunities Act (FSIA), and that although the Terrorism Risk Insurance Act (TRIA) provided a potential way around that immunity, Plaintiffs had failed to meet their burden of proving that the antiquities were attachable under that statute. The First Circuit Court of Appeals affirmed but on narrower grounds, holding that TRIA in this case did not nullify the antiquities' immunity from execution under the FSIA. View "Rubin v. Harvard Univ." on Justia Law

Defendant was found guilty in a New York court of assaulting his wife Megan and sentenced to time served. At approximately the same time, the court entered a protection order prohibiting Defendant from approaching or communicating with Megan. Defendant later pled guilty to a statute criminalizing interstate travel with the intent to engage in conduct that transgresses a court-imposed protection order. The district court accepted the guideline calculations limned in the presentence investigation (PSI) report and imposed a top-of-the-range sentence of forty-one months. Defendant appealed his sentence, arguing that the sentencing court's two-level upward adjustment for violation of the court protection order constituted impermissible double counting because the violation of a court order was also an element of the offense of conviction. The First Circuit Court of Appeals affirmed, holding that the use in tandem of a base offense level dictated by U.S. Sentencing Guidelines Manual 2A6.2(a) and an upward adjustment under U.S. Sentencing Guidelines Manual 2A6.2(b)(1)(A) did not constitute impermissible double counting. View "United States v. Fiume" on Justia Law

Defendant, an engineer for battery producer Electric Vehicles Worldwide (EVW), was convicted of submitting false invoices and conspiring to defraud the Federal Transit Administration (FTA) in connection with federal grants to develop a battery for electric mass transit. The First Circuit Court of Appeals affirmed Defendant's convictions, holding (1) the government's evidence was sufficient to prove beyond a reasonable doubt that Defendant intentionally submitted false or fraudulent claims or conspired to defraud the FTA; and (2) the trial court did not err in refusing to give Defendant's requested theory-of-defense jury instructions on condonation and reasonable interpretation of regulations. View "United States v. Willson" on Justia Law