Justia Constitutional Law Opinion Summaries

Articles Posted in U.S. 1st Circuit Court of Appeals

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A civilian was shot without justification by an on-duty police officer, Javier Pagan-Cruz. Plaintiffs, the victim’s family, filed suit under 42 U.S.C. 1983 against Pagan, his two on-scene colleagues, and five supervisors for violating the victim’s Fourth Amendment rights by causing his wrongful death. The supervisory defendants filed a motion to dismiss under Fed. R. Civ. P. 12(c). The motion was granted in part and denied in part. The district court subsequently granted summary judgment to the supervisory defendants on the remaining claims against them. After a trial, the jury reached a verdict in favor of Plaintiffs against the remaining defendants. The First Circuit affirmed the grant of summary judgment against Plaintiffs’ supervisory liability claims against each of the supervisory defendants, holding that these defendants were not liable in this case under section 1983. View "Ramirez-Lluveras v. Rivera-Merced" on Justia Law

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After a jury trial, Appellant was convicted of distributing cocaine. On appeal, Appellant argued that two instances of prosecutorial misconduct deprived him of a fair trial. The First Circuit affirmed the conviction, holding (1) the prosecutor erred during closing argument rebuttal by offering “overzealous and inappropriate” statements regarding the credibility of the government’s witnesses, thus improperly vouching for the prosecution’s investigation and witnesses; (2) the prosecutor erred during closing arguments by playing an audio recording for the jury that had not been entered into evidence; but (3) neither of the errors affected Appellant’s conviction. View "United States v. Rojas" on Justia Law

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The Maine State Prison has a longstanding practice of issuing footlockers with padlocks to most inmates. Appellants, inmates in the Prison, were each seriously injured in assaults by other inmates who used prison-issued padlocks as weapons. Appellants filed complaints in federal district court alleging that the failure of Appellees, officials in the Maine Department of Corrections, to take adequate measures to protect inmates from padlock assaults violated Appellants’ Eighth Amendment rights. The district court dismissed the complaints on summary judgment, concluding that there existed no genuine dispute of material fact as to whether providing inmates with padlocks subjected Appellants to conditions posing a substantial risk of serious harm in violation of the Eighth Amendment. The First Circuit affirmed, holding that the small number of assaults involving the use of prison-issued padlocks, without more, was not sufficient to sustain the conclusion that providing the padlocks to inmates rose to the level of constitutional violation. View "Lakin v. Barnhart" on Justia Law

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In 2011, agents intercepted a call between James Brichetto and a potential customer, Michael Leavitt, in which Leavitt sought to purchase approximately 100 oxycodone pills. Brichetto asked whether Leavitt was with someone else, and Leavitt responded affirmatively. As the conversation wound down, Brichetto and Leavitt agreed to meet in the parking lot of a Walmart store in Scarborough, Maine. Defendant Paul Arnott was a passenger in Leavitt's car. The issues this case presented for the First Circuit's review centered on a court order issued in November 2011, which authorized a wiretap on a cellular telephone in the possession of Brichetto (a suspected drug dealer). Agents pulled Leavitt's car over, and asked the occupants to get out. Agents searched the car and found drugs in the compartment. Defendant would ultimately be arrested on drug charges. After the district court denied his motion for suppression, defendant entered a conditional guilty plea, reserving his right to challenge the suppression ruling. Following the imposition of sentence, defendant acted upon this reservation and appealed. Finding no reversible error, the First Circuit affirmed. View "US v. Arnott" on Justia Law

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In 2011, the Maine Legislature made certain amendments to Maine’s public employee retirement system. In general, the retired Maine employees stood to be paid significantly less cost-of-living adjustments as a result of the amendments. Plaintiffs - retired Maine employees, public school teachers, and members of the Maine Association of Retirees and the Maine State Employees Association - filed suit, arguing that the amendments violated the Contract Clause and Taking Clause of the United States Constitution. The district court granted summary judgment against Plaintiffs. The First Circuit affirmed, holding that the 2011 amendments did not violate the Contract Clause. View "Me. Ass'n of Retirees v. Bd. of Trustees" on Justia Law

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Appellant was charged with conspiracy to possess with intent to distribute, conspiracy to commit robbery affecting interstate commerce, and felon in possession of a firearm. Appellant subsequently pleaded guilty to all counts. The First Circuit Court of Appeals affirmed, holding (1) the district court did not abuse its discretion in failing to sua sponte order a hearing on the issue of Appellant’s competency; (2) the district court adequately assessed whether Appellant’s plea was knowing and voluntary within the meaning of Fed. R. Crim. P. 11; (3) Appellant’s counsel did not provide ineffective assistance; and (4) the district court did not err in imposing a ten-year mandatory minimum sentence on the drug conspiracy count. View "United States v. Kenney" on Justia Law

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Robert Snyder operated a business in a building that he owned in the city of Waltham, Massachusetts. After Snyder fired an employee who served as a member of the Waltham city council, the former employee complained to the city building department that Snyder’s use of his building violated a local land use ordinance. Code enforcement officers investigated Snyder’s use of his property and fined him under the ordinance. Snyder contested the fines in the district court, alleging that the city and five individuals violated his rights to equal protection under the Fourteenth Amendment by singling him out for differential treatment for reasons unique to him. The defendants moved for summary judgment on the basis of qualified immunity. The district court denied the motion. The First Circuit Court of Appeals reversed the district court’s denial of the two defendants’ motion for summary judgment, holding that the local government officials did not violate any clearly established federal law, and therefore, the defendants were entitled to qualified immunity. View "Snyder v. Collura" on Justia Law

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After a jury trial in federal district court, Petitioner was convicted of child pornography and sentenced to 180 months’ imprisonment. The First Circuit Court of Appeals affirmed Petitioner’s conviction and sentence. Petitioner subsequently filed a petition under 28 U.S.C. 2255 collaterally attacking his conviction on four grounds. The district court rejected the petition. The First Circuit affirmed the district court’s denial of Petitioner’s petition for collateral relief, holding (1) because Petitioner did not show any prejudice, his ineffective assistance of counsel claim failed; (2) any error that the district court made in excluding certain testimony did not have a substantial and injurious effect on the jury’s verdict; (3) the conduct underlying Petitioner’s conviction was not constitutionally protected; and (4) Petitioner’s argument that he was actually innocent failed. View "Ortiz-Graulau v. United States" on Justia Law

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Plaintiff, an African-American woman who was serving in the United States Coast Guard Housing Office at Air Station Cape Cod, filed an employment discrimination action against the Secretary of Homeland Security, asserting that the Secretary failed to promote her to the position of housing manager because of her race and gender. The district court granted summary judgment in favor of the Secretary, concluding that Plaintiff failed to generate a genuine issue of material fact as to whether the Secretary’s non-discriminatory reason for choosing another candidate was pretextual. The First Circuit Court of Appeals affirmed, holding (1) the district court acted within the bounds of its discretion in denying Plaintiff’s motion to reopen discovery shortly after retaining counsel; and (2) the Secretary was entitled to summary judgment because Plaintiff failed to generate a genuine issue of material fact on the issue of pretext. View "Hicks v. Napolitano" on Justia Law

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After a jury trial in Massachusetts state court, Appellant was convicted of the first-degree murder of his estranged wife under both the theory of deliberate premeditation and extreme atrocity or cruelty. The Massachusetts Supreme Judicial Court (SJC) affirmed on appeal. Appellant subsequently filed a petition for a writ of habeas corpus in the federal district court, alleging (1) his constitutional right to confrontation was violated when the testimony of the chief medical examiner in Massachusetts was admitted, and (2) his attorney provided ineffective assistance by failing to introduce certain mental health related evidence. The district court denied the petition. The First Circuit Court of Appeals affirmed, holding (1) the SJC’s rejection of Appellant’s Confrontation Clause argument was not contrary to governing Supreme Court precedent; and (2) the SJC did not unreasonably apply Strickland or commit clear factual error when it concluded that Appellant’s attorney’s performance was not deficient. View "Hensley v. Roden" on Justia Law