Justia Constitutional Law Opinion Summaries

At issue on this appeal was whether a petition for habeas corpus was timely filed within the one-year limitations period provided by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). The district court found that Petitioner filed his petition within the one-year window because the running of the limitations period was tolled by proceedings in Massachusetts state court. However, the court rejected the petition on its merits. The First Circuit Court of Appeals affirmed the district court's judgment, albeit on different grounds, holding that Petitioner's petition was filed well outside of AEDPA's one-year limitations period.

The government charged Defendant with one count of interfering with the operation of an aircraft with reckless disregard for human life and one count of making false statements. After a jury trial, the jury found Defendant guilty as charged. The First Circuit Court of Appeals affirmed Defendant's conviction under 18 U.S.C. 1001, vacated Defendant's conviction under 18 U.S.C. 32(a)(5), and remanded, holding (1) the evidence was sufficient to support Defendant's conviction, as the government proved all the elements of the offense beyond a reasonable doubt; and (2) a jury instruction erroneously diluted the mens rea requirement of section 32(a)(5), and the error was not harmless.

Defendant Jose Romero-Lopez was convicted after a jury trial of money laundering offenses in violation of 18 U.S.C. 1956 and 982. The First Circuit Court of Appeals affirmed Defendant's conviction, holding that there was no error in the district court's scheduling or evidentiary rulings, where (1) Defendant's due process rights were not violated when the district court advanced the scheduled trial date by one day; and (2) the district court did not err in allowing the prosecution to present evidence relating to (i) Defendant's tax returns and (ii) Defendant's activities and detention by federal authorities when traveling through the San Diego airport.

Appellant appealed his conviction of conspiracy to commit a carjacking and aiding and abetting an attempted carjacking resulting in a death. The First Circuit Court of Appeals affirmed, holding (1) the government presented inappropriate overview testimony from a FBI agent at the outset of its case, but the error was harmless; (2) the government engaged in improper vouching in its closing argument, but Appellant failed to show the requisite prejudice, and therefore the error was harmless; (3) the district court did not err in denying Appellant's Fed. R. Crim. P. 29 motion for a judgment of acquittal, as the government presented sufficient evidence to support Appellant's convictions; and (4) the court did not err in applying the United States Sentencing Guidelines Manual 2B3.1(c) "murder cross reference" in determining the guidelines range for Appellant's sentence.

This appeal involved an award of $59,787 in attorney's fees against unsuccessful plaintiffs in a civil rights action against the Municipality of Adjuntas, its mayor, and Plaintiffs' direct supervisors. Plaintiffs argued that their lawsuit was not so frivolous or unreasonable as to justify an award of fees to Defendants. The First Circuit Court of Appeals agreed, except for one plaintiff's inferior working conditions claim and another plaintiff's claim against a supervisory defendant, as there was no reasonable basis for those claims. The Court vacated the fee award and remanded for further proceedings relating to any attorney's fees incurred by the Municipality of Adjuntas in relation to those claims only.

Two physicians who contracted with HMOs refused to accept capitation payments in place of fee-for-service payments, so the HMOs dropped the physicians' contracts. The physicians brought constitutional and antitrust claims against the companies, which the district court rejected on a motion to dismiss. The physicians appealed. The First Circuit Court of Appeals affirmed, holding (1) because the appellees were not governmental actors, Appellants' constitutional claims failed; and (2) because the appellees that Appellants contended violated the Sherman Act were not independent firms and were, rather, wholly owned subsidiaries of the same parent company, the appellees could not have violated the Act's conspiracy prohibition.

Appellant was convicted in the United States district court for his role in a scheme to illegally obtain and distribute prescription drugs. The First Circuit Court of Appeals affirmed, holding (1) the district court erred in allowing testimony about the guilty pleas of Appellant's former co-defendants, but the error was harmless; and (2) in determining the appropriate sentence within the United States Sentencing Guidelines (USSG), or in varying guidelines, a sentencing court has discretion to consider the defendant's cooperation with the government as an 18 U.S.C. 3553(a) factor, even if the government has not made a USSG 5K1.1 motion for a downward departure.

Appellant was convicted of conspiracy to commit kidnapping and conspiracy to use interstate commerce facilities in the commission of murder for hire. Appellant appealed, arguing that the district court erred in denying his motion to dismiss the indictment on the grounds of outrageous government misconduct in manufacturing federal jurisdiction and in refusing to instruct the jury on the defense of jurisdictional entrapment. Both arguments depended on the contention that the government created United States jurisdiction by unlawfully orchestrating a change in location for the crimes that Appellant conspired to commit. The First Circuit Court of Appeals affirmed, holding (1) without evidence that Appellant was coerced or unduly induced, or evidence that the government engaged in some other type of outrageous misconduct, the district court did nor err by denying Appellant's motion to dismiss; and (2) as Appellant plainly failed to satisfy his burden to make a threshold showing of inducement, the district court did not err in refusing to give Appellant's proposed jurisdictional entrapment jury instruction.

Defendant appealed the forty-six-month sentence imposed following his guilty plea conviction for being a felon in possession of a firearm in connection with his shipping an assault rifle and pistol from Florida to Puerto Rico. The First Circuit Court of Appeals affirmed, holding that the district court did not abuse its discretion in imposing the sentence, where (1) the district court's application of an upward departure was reasonable; (2) the district court did not abuse its discretion in choosing how far to enhance the sentence; and (3) the district court did not fail to balance the relevant mitigating factors.

Plaintiff appealed from entry of summary judgment against his claims of race-based disparate treatment and of hostile work environment against Employer. Plaintiff's complaint alleged Employer punished him more harshly for a rules violation, on the basis of his Hispanic heritage, than it did a similarly situated white co-worker and permitted other employees to harass him in violation of Title VII. The First Circuit Court of Appeals affirmed, holding that summary judgment was appropriate on both of Plaintiff's claims, as (1) Employer's reasons for disciplining Plaintiff, on the record, did not allow inferences or pretext or discrimination, and there was no differential treatment; and (2) Employer took reasonable steps to address the alleged co-worker harassment.