Justia Constitutional Law Opinion Summaries

A jury convicted Appellant on nine counts growing out of a conspiracy to commit armed robbery and the unlawful killing of a guard during a robbery. In an earlier multi-defendant appeal, the First Circuit Court of Appeals affirmed Appellant's convictions and sentences on eight of the nine counts. As to the remaining count, however, the First Circuit affirmed Appellant's conviction but vacated his sentence in order to afford him an opportunity to allocute. At resentencing on that count, the district court heard Appellant's allocution and proceeded to reinstate the original sentence of life imprisonment without the possibility of release. On appeal, the First Circuit affirmed, holding (1) the district court's failure to fully explain its reason for imposing its sentence on count eight was not plain error, and Appellant's sentence on count eight was substantively reasonable; and (2) Appellant's conviction and sentence on count nine did not violate the Double Jeopardy Clause. View "United States v. Medina-Villegas" on Justia Law

This insurance coverage dispute arose from charges of sexual harassment brought by a one-time employee against Appellant, the former president of Jasmine Company, Inc. Appellant sought a defense to and indemnity for the harassment claims from Appellee, Jasmine's liability insurance provider. The district court ruled that Appellant was not entitled to coverage from Appellee because, under the doctrine of issue preclusion, a prior arbitration between Appellant and the purchaser of his business conclusively established that Appellant's conduct fell within an exclusion to Appellee's insurance policy. The First Circuit Court of Appeals affirmed, holding (1) the arbitration presented Appellant with the full and fair opportunity for adjudication on the issue at hand; and (2) therefore, the district court was correct to bar Appellant from disputing the applicability of the exclusion based on the doctrine of issue preclusion. View "Manganella v. Evanston Ins. Co." on Justia Law

Appellant served several prison terms for sex-related crimes. Before Appellant was released from custody in the Bureau of Prisons (BOP), the federal government commenced the effort to have him certified as a sexually dangerous person and to commit him civilly under the Adam Walsh Act. The federal district court determined that Appellant met the conditions for certification as a sexually dangerous person and ordered him civilly committed. The First Circuit Court of Appeals affirmed, holding (1) Appellant was legitimately in BOP custody when the commitment proceeding began, as required by statute; and (2) the district court correctly found that Appellant suffered from the requisite mental disorder and that he satisfied the statutory dangerousness test. View "United States v. Wetmore" on Justia Law

Appellant appealed a judgment of the U.S. district court sentencing him to thirty-three months' imprisonment for failing to register as a sex offender. In calculating a range for his sentence under the sentencing guidelines, the district court included two additional criminal history points because Appellant was under a criminal justice sentence when he failed to register. Appellant contended that he was not under a criminal justice sentence at that time. The First Circuit Court of Appeals affirmed, holding that Appellant was under a criminal justice sentence when he failed to register, and therefore, the district court's sentencing calculation was sound. View "United States v. Peters" on Justia Law

Plaintiff appealed a grant of summary judgment to her former employer in this suit for discrimination, retaliation, and hostile work environment under the Age Discrimination in Employment Act, arguing that the district judge slipped by premising dismissal on disputed facts. The First Circuit Court of Appeals dismissed Plaintiff's appeal with prejudice after discussing the circumstances under which appeals will be dismissed for failure to adhere to appellate rules, holding that Plaintiff's substantial noncompliance with important appellate rules were major violations in that they crippled any attempt to review the issues intelligently and constituted sufficient cause to dismiss the appeal. View "Rodriguez-Machado v. Shinseki" on Justia Law

A jury convicted Defendant of being a felon in possession of a firearm. Defendant was sentenced under the Armed Career Criminal Act (ACCA) to 216 months in prison. The First Circuit Court of Appeals affirmed the district court's rulings, holding that the district court did not err in (1) refusing to suppress Defendant's statement regarding a bag containing firearms, as Defendant was not in custody for Miranda purposes when he made the statement; (2) admitting an audio recording of a telephone call to a police chief where the court properly authenticated the evidence; and (3) determining Defendant was convicted of two predicate offenses in Virginia and Florida and sentencing Defendant under the ACCA. View "United States v. Murdock" on Justia Law

This case required the First Circuit Court of Appeals to explore the parameters of the doctrine of quasi-judicial immunity. The underlying litigation was a will contest turned conspiracy case. The plaintiff prevailed in probate court after two and a half years of legal wrangling. By the time Plaintiff was found to be the sole lawful heir of the decedent, the estate's assets were depleted. Seeking retribution, the plaintiff sued several persons involved in the will contest, alleging a wide-ranging conspiracy. In a preliminary ruling, the district court concluded that two of the defendants, a lawyer who had served as a court-appointed discovery master and the lawyer's firm, were immune from suit by reason of quasi-judicial immunity. The court certified this ruling as a partial final judgment. The First Circuit affirmed, holding (1) the district court did not err in certifying the ruling; and (2) the court-appointed discovery master was entitled to share in the judge's immunity from suit, and the law firm whose partner enjoyed quasi-judicial immunity was entitled to share in that immunity for helping the partner to perform his judicial tasks. View "Nystedt v. Nigro" on Justia Law

Defendant was arrested and ordered to be detained on criminal charges. An initial indictment and several superseding indictments followed charging Defendant with several drug offenses. The last indictment was filed in October 2011. Defendant filed motions seeking dismissal of the fourth superseding indictment and release from custody under the section 3164 of the Speedy Trial Act. The district court ordered Defendant's discharge. Fifteen minutes later, Defendant was re-arrested on a new criminal complaint for drug possession. Defendant was re-indicted on four counts virtually identical to the counts charged in the October 2011 indictment and again pled not guilty. Pursuant to the Ninth Circuit's decision in United States v. Tirasso, the district court found that re-indictment on the same offense does not restart section 3164's ninety-day clock and granted Defendant's motion for release. The First Circuit Court of Appeals reversed, holding that when an indictment is dismissed upon the motion of a defendant, the dismissal is without prejudice and that defendant is again detained awaiting trial, section 3164's ninety-day clock restarts at the moment that Defendant is re-arrested, regardless of the nature of the charges in the new complaint. View "United States v. Worthy" on Justia Law

An undercover United States Customs Task Force operation involving efforts on land, at sea, and in the air ended with the arrests of Defendants, Saturnino Tatis-Nunez, Cesar Hernandez-De la Rosa, Carols Espinal-Almeida, and Jacobo Peguero-Carela. Each defendant was indicted on, and ultimately convicted of, one count of conspiracy to possess with intent to distribute, and one count of conspiracy to import, 418 kilograms of cocaine. All Defendants appealed, raising a myriad of challenges that spanned jury voir dire to sentencing. After considering each claimed error, the First Circuit Court of Appeals affirmed Defendants' convictions and sentences, holding that none of Defendant's claims of error had merit. View "United States v. Espinal-Almeida" on Justia Law

Following a bench trial, Appellant was convicted of thirteen counts for crimes involving child pornography. Appellant appealed, challenging various rulings rulings by the district court before and after the trial. This case presented complex questions of first impression in the First Circuit regarding the admissibility of evidence in the wake of the Supreme Court's recent Confrontation Clause jurisprudence. After careful review, the First Circuit Court of Appeals concluded that the admission of certain evidence violated Appellant's Confrontation Clause rights, and the admission of this evidence was harmless as to some counts of conviction but not as to others. The Court thus reversed Appellant's convictions on certain counts and remanded for resentencing or a new trial. View "United States v. Cameron" on Justia Law