Justia Constitutional Law Opinion Summaries

Defendant was charged with structuring financial transactions to evade reporting requirements in violation of 31 U.S.C. 5324(a)(3). After a trial, Defendant was convicted and sentenced. The First Circuit Court of Appeals affirmed Defendant’s conviction and sentence, holding (1) Defendant was not denied his right to a speedy trial under the Speedy Trial Act and the Sixth Amendment; (2) Defendant’s claim that his counsel provided ineffective assistance required further factual development; (3) consistent with due process, Defendant could be convicted of structuring his transactions in a way that demonstrated his intent to evade the reporting requirements, even though he actually failed to evade them; and (4) the district court did not err in its evidentiary rulings, and the court’s sentencing guidelines calculation was not erroneous. View "United States v. Souza" on Justia Law

Defendant was indicted for aiding and abetting in the possession of a firearm with an obliterated serial number. Defendant filed a motion to suppress a series of inculpatory statements. Specifically, Defendant sought to suppress (1) a statement he made to his arresting officer, arguing that he was questioned while in formal custody but prior to being given Miranda warnings, and (2) all statements he made during his formal interrogation, arguing that the questioning resumed impermissibly soon after his initial refusal to make a statement and continued after his unambiguous request for counsel. The district court denied the motion to suppress. The First Circuit Court of Appeals affirmed, holding (1) Defendant waived his argument for suppression of the statement he made to his arresting officer; and (2) there was no violation of Defendant’s right to remain silent during his formal interrogation, and Defendant did not invoke his right to counsel in a manner sufficiently unambiguous and direct as to require the cessation of questioning. View "United States v. Oquendo-Rivas" on Justia Law

In 2002, Appellant was convicted in Massachusetts state court on charges of forcibly raping his nephew, J.B., and J.B.’s friend when both boys were fifteen years old. Appellant appealed his conviction, arguing that his attorney provided ineffective assistance by failing to seek to have admitted evidence that Appellant’s sister had accused J.B. of sexually assaulting three of Appellant’s nieces. The Massachusetts appeals court affirmed. Appellant later filed a petition for habeas corpus in federal district court, arguing that he received ineffective assistance of counsel in his state court trial. The district court denied relief. The First Circuit Court of Appeals affirmed, holding that the Massachusetts appeals court reasonably applied federal law in rejecting Appellant’s claim of ineffective assistance of counsel. View "Collins v. Roden" on Justia Law

In 2011, Immigration and Customs Enforcement (ICE) agents in New Hampshire arrested six aliens who had prior criminal convictions or arrests. The arrests were part of a nationwide enforcement program. The Union Leader, a New Hampshire newspaper, requested the names and addresses of the six individuals arrested in New Hampshire. The ICE provided the Union Leader with I-213 forms from which the aliens’ names, addresses, and other personal information had been redacted. The Union Leader subsequently filed a Freedom of Information Act (FOIA) complaint to compel disclosure of the arrestees’ names and addresses. The district court granted summary judgment in favor of ICE, concluding that FOIA exempted the requested information from disclosure as an unwarranted invasion of the arrestees’ privacy. The First Circuit Court of Appeals reversed in part, holding that the public interest in disclosure outweighed the arrestees’ privacy interests, and therefore, the withheld information subject to this appeal was not exempt from disclosure. Remanded. View "Union Leader Corp. v. U.S. Dep't of Homeland Sec. " on Justia Law

In 2010, Plaintiff, then fifty-eight years old, applied for a job with Defendant. Defendant extended a written offer of employment, which Plaintiff accepted, but before Plaintiff started on the job, Defendant rescinded the offer. Plaintiff filed a complaint against Defendant alleging, among other claims, that the rescission of the employment offer was a by-product of age discrimination. Defendant removed the case to the federal district court. Thereafter, Plaintiff’s attorneys blundered time and again, which led to the district court issuing an order for Plaintiff to show cause why his case should not be dismissed. After the district court received no response from Plaintiff, it dismissed the case. Plaintiff subsequently filed a motion pursuant to Fed. R. Civ. P. 60(b) asking the court to set aside the judgment due to the neglect of one of Plaintiff’s attorneys. The district court denied the motion. The First Circuit Court of Appeals affirmed, holding that, given Plaintiff’s persistent pattern of noncompliance, the district court’s refusal to set aside the order of dismissal was not an abuse of discretion. View "Rivera-Velazquez v. Hartford Steam Boiler Inspection & Ins. Co." on Justia Law

In 2011, the then-Governor of Puerto Rico appointed Plaintiff to the position of Advocate for Persons with Disabilities. In 2013, new legislation established an Office of the Ombudsman for Personal with Disabilities. Plaintiff was subsequently informed that an Ombudsman had been appointed and that his position had been abolished by legislative act. Plaintiff sued the Governor and other officials for attempting to oust him from his job as Advocate, claiming that it was unconstitutional for Puerto Rico to abolish the Advocate position without an individualized hearing. The district court issued a preliminary injunction in favor of Plaintiff. The First Circuit Court of Appeals vacated the district court’s order, concluding that the court erred in finding that Plaintiff had demonstrated a likelihood of success on the merits where there was no viable claim that the abolition of the Advocate Office independently violated some constitutional proscription. View "Diaz-Carrasquillo v. Garcia-Padilla" on Justia Law

Marilyn Davidson, an intellectually disabled individual, was in the care of the Massachusetts Department of Developmental Services (DDS) most of her life. In 1985, Marilyn was transferred to the Fernald Developmental Center, an intermediate care facility (ICF). In 2003, the Commonwealth of Massachusetts decided to close Fernald. DDS planned to transfer Marilyn to the Wrentham Developmental Center, another ICF. Plaintiffs, Marilyn’s guardians, filed a complaint in the federal district court, alleging that Marilyn’s transfer violated the federal Medicaid statute and various implementing regulations. Plaintiffs also sought a motion for a preliminary injunction. The district court denied the injunction and held that the statutory and regulatory provisions cited in the complaint did not create a private right of action. Marilyn was subsequently transferred to Wrentham, and Fernald was closed. The First Circuit Court of Appeals remanded the case to the district court with instructions to dismiss Plaintiffs’ complaint, holding (1) Plaintiffs’ claim for damages was barred by the Commonwealth’s Eleventh Amendment immunity from suit for damages in federal court; and (2) Plaintiffs’ claims for declaratory and injunctive relief were moot. View "Davidson v. Howe" on Justia Law

Plaintiff’s employment with Employer was terminated due to what Plaintiff alleged was disability discrimination and retaliation. Plaintiff filed a discrimination complaint against Employer with the Equal Employment Opportunity Commission (EEOC) but did not file a civil action against Employer within ninety days after he received a right-to-sue letter from the EEOC. Plaintiff filed a new administrative charge against Employer two months after the first right-to-sue letter issued adding a second charge for retaliation. Less than a month after the transmittal of the second right-to-sue letter, Plaintiff sued Employer and other defendants in federal district court for discrimination and retaliation under the Americans with Disabilities Act (ADA). The district court dismissed both federal claims on the grounds that they were time barred, as (1) the discrimination claim was not brought within ninety days of Plaintiff’s receipt of the first right-to-sue letter, and (2) the retaliation claim had been filed too late with the EEOC. The First Circuit Court of Appeals affirmed, holding that the district court did not err in dismissing both charges due to Plaintiff’s failure to meet applicable time limits. View "Rivera-Diaz v. Humana Health Plans of P.R." on Justia Law

After a jury trial, Appellant was convicted of possessing counterfeit obligations of the United States and sentenced to fifty-one months’ imprisonment. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress evidence obtained from a search of the truck Appellant was driving when he was initially stopped by law enforcement officers and from the seizure of money in Appellant’s wallet; (2) the evidence was sufficient to sustain the conviction, and therefore, the district court did not err in denying Appellant’s motion for acquittal; and (3) the district court did not abuse its discretion in sentencing Appellant. View "United States v. Almeida, III" on Justia Law

This appeal concerned the decade-long litigation regarding the regulation of Puerto Rico’s milk industry. The district court approved a comprehensive Settlement Agreement reached by the original parties: the government defendants, including the Office of the Milk Industry Regulatory Administration for the Commonwealth of Puerto Rico (Spanish acronym “ORIL”), and the plaintiff milk processors, Vaqueria Tres Monjitas, Inc. and Suiza Dairy, Inc. After the district court approved of the Agreement, ORIL filed a motion to alter or amend the judgment, challenging the portion of the district court order opining that Puerto Rico had waived its Eleventh Amendment immunity by entering into the Agreement. The district court denied ORIL’s motion. The First Circuit Court of Appeals (1) held that the language at issue was merely a statement of dicta and not a judgment, and consistent with this construction, the district court was strongly encouraged to strike the statement; and (2) otherwise dismissed the appeal for want of jurisdiction. View "Vaqueria Tres Monjitas, Inc. v. Comas-Pagan" on Justia Law