Justia Constitutional Law Opinion Summaries

During his trial for the 1986 shooting death of an acquaintance, defendant unsuccessfully urged the jury to find that someone else could have shot the victim, that the killing was accidental, or that he had been too impaired by alcohol or drugs to form specific intent to kill. He was convicted of murder and sentenced to life without parole. Almost five years later, defendant filed a motion for a new trial, claiming ineffective assistance of counsel, based on trial counsel's failure to present a mental impairment or illness defense. Following an evidentiary hearing, defendant was denied a new trial. The state's highest court determined that defendant was competent to stand trial and that counsel's decision was not unreasonable, in light of defendant's opposition to the mental impairment defense. The district court denied a petition for habeas corpus. The First Circuit affirmed.

Defendant,convicted of 21 counts of aggravated felonious sexual assault against his two stepchildren, four counts of endangering the welfare of a child and one count of indecent exposure and lewdness, exhausted direct appeals in New Hampshire state courts. The federal district court denied his petition for habeas corpus, 28 U.S.C. 2254, rejecting claims that the trial court violated his Confrontation Clause rights by prohibiting him from cross-examining his stepchildren regarding their accusations that he had also abused younger siblings. The First Circuit affirmed. Exclusion of cross-examination did not deprive defendant of a defense; he was able to introduce other evidence that the children "invented" the allegations. Trial courts may place reasonable limits on cross-examination based on concerns about harassment, prejudice, confusion of issues, witness safety, or interrogation that is repetitive or only marginally relevant.

Petitioner is serving a life sentence in a Massachusetts state prison for first-degree murder. The state's highest court affirmed the conviction. A federal district court denied habeas relief. The First Circuit affirmed, rejecting a claim that trial counsel was ineffective in failing to investigate and present a defense that petitioner's Tourette's Syndrome exacerbated the effects of alcohol and Artane, and that he was legally insane at the time of the killing on account of the Tourette's Syndrome and other mental illness.

Having lost his bid for a Maine Senate seat, plaintiff sued Republican party leadership for defamation libel, intentional infliction of emotional distress, and publicly placing him in a false light. The complaint referred to flyers, brochures, and radio and TV ads days before the election that conjured up imaginary wrongs that he had supposedly done as a selectman for the town of Blue Hill, primarily concerning discontinuance of fireworks on the Fourth of July. The complaint referred to "actual malice." The district court dismissed. The First Circuit affirmed, finding that false statements were made negligently, not with actual malice. Defamation law "does not require that combatants for public office act like war-time neutrals, treating everyone evenhandedly and always taking the high road. Quite the contrary. Provided that they do not act with actual malice, they can badmouth their opponents, hammering them with unfair and one-sided attacks"

After being extradited from Columbia, petitioner was convicted in federal court for his part in a drug conspiracy. He twice sought relief under 28 U.S.C. 2255, without success. He then sought relief under 28 U.S.C. 2241 for alleged violations of the extradition treaty. The district court denied relief, deeming the petition an attempt to circumvent the limits on section 2255. The First Circuit affirmed. Relief under section 2255 does cover violations of treaties and petitioner cannot circumvent the limits on multiple section 2255 petitions by resorting to section 2241 to assert a treaty claim that could as easily have been advanced in his original section 2255 petition.

Petitioner, serving two life terms for first degree murder, exhausted state appeals and was denied habeas corpus. His trial counsel had conceded that petitioner committed the shootings, but attempted to establish insanity. The First Circuit affirmed. Any errors committed under state law with respect to establishing competence or intoxication did not create federal constitutional issues.

The Massachusetts Delivery Association claimed that a state law is preempted as to motor carriers under the Federal Aviation Administration Authorization Act of 1994, 108 Stat. 1569, which expressly preempts state attempts to regulate "a price, route, or service of any motor carrier," The challenged state law, part of Mass. Gen. Laws ch. 149, sect. 148B(a)(2), which requires that an individual performing a service for another be classified as an employee unless "the service is performed outside the usual course of the business of the employer." The MDA also claimed that the state statute imposes an undue burden which violates the Commerce Clause. The district court found that Younger abstention was appropriate because, while the Association is not itself a party to relevant state litigation, three of its members are defendants in state civil proceedings brought not by the Attorney General (defendant in this case) but by private parties. The First Circuit remanded for the court to exercise jurisdiction, concluding that any decision will not interfere with pending state cases.

Defendant pled guilty to conspiring to possess with intent to distribute five kilograms or more of cocaine and one kilogram or more of heroin within 1,000 feet of a public housing project, 21 U.S.C. 841, 846, and 860, and conspiring to unlawfully possess, use, or brandish a firearm in furtherance of or during and in relation to a drug trafficking crime, 18 U.S.C. 924(c)(1)(A) and 924(o) and was sentenced to 108 months imprisonment and 8 years supervised release. After the conviction was affirmed, defendant challenged the district court's denial of a petition to vacate, set aside, or correct his sentence on grounds of ineffective assistance of counsel. The First Circuit affirmed, holding that defendant failed to establish prejudice.

Defendant, convicted of second-degree murder for the death of his two-week-old son after admitting to shaking the baby, obtained a reduction to involuntary manslaughter, but the Massachusetts Supreme Judicial Court reinstated the original verdict. The federal district court dismissed a habeas corpus petition. The First Circuit affirmed. The state court's conclusion that admission of the autopsy photographs was proper was not so arbitrary or capricious as to be an unreasonable application of clearly established federal law.

Defendant was apprehended on a boat in the Caribbean by a Coast Guard counter-narcotics patrol and charged under the Maritime Drug Law Enforcement Act, 46 U.S.C. 70501-70508. The boat, carrying cocaine, did not display a flag or numbers. Columbian and Venezuelan authorities could not confirm its registration. A vessel without nationality is subject to U.S. jurisdiction under the Act. The district court denied a motion to dismiss based on the Confrontation Clause. Defendant argued that use of State Department certifications memorializing the inability of Columbia and Venezuela to confirm or refute the boat's master's claim of national registry, without an opportunity to cross-examine their author, constituted a violation of the Sixth Amendment. The First Circuit affirmed, noting that defendant did not claim that the boat was registered in another country or otherwise outside U.S. jurisdiction.