Justia Constitutional Law Opinion Summaries

Defendant pled guilty to four counts of arson. On appeal, Defendant argued that the district court erred by denying his motion to suppress evidence that the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) obtained by monitoring his automobile using a global positioning system (GPS) device. The ATF began the GPS tracking, without a warrant, in August 2009 and continued for nearly one year. After Defendant filed his notice of appeal, the First Circuit Court of Appeals decided United States v. Sparks, in which the Court held that the warrantless installation of a GSP device on a defendant’s car and the use of that device to monitor the defendant’s movements for eleven days fell within the good-faith exception to the exclusionary rule because the monitoring had occurred before the U.S. Supreme Court decided United States v. Jones, which held that the installation and use of a GPS tracker on an automobile constitutes a Fourth Amendment search. In the instant case, the First Circuit affirmed the denial of Defendant’s suppression motion, holding that this case fell within the rule laid out in Sparks, although the pre-Jones warrantless GPS tracking was of a significantly longer duration than that in Sparks. View "United States v. Baez" on Justia Law

Harold Evans-Garcia and Eric Joel Carrion-Cruz (together, Defendants) were each convicted of a carjacking resulting in death and sentenced to life imprisonment without the possibility of parole. Both Defendants committed the crimes when they were younger than eighteen years old. Each of them unsuccessfully appealed and petitioned for habeas relief. Subsequently, the U.S. Supreme Court decided Miller v. Alabama, in which the Court held that the Eighth Amendment to the U.S. Constitution forbids a sentencing scheme that mandates life imprisonment without the possibility of parole for juvenile offenders. Thereafter, Defendants sought certification to pursue a new habeas petition to secure a potential reduction in their sentences pursuant to Miller. The First Circuit Court of Appeals granted certification to Evans-Garcia but denied it to Carrion-Cruz, holding (1) Evans-Garcia made a prima facie case showing that the new rule announced in Miller qualified as a basis for habeas relief on a second or successive petition; but (2) Carrion-Cruz’s request must be denied because he was not sentenced pursuant to any statute or guideline that mandated a sentence of life without parole. View "Evans-Garcia v. United States" on Justia Law

After a jury trial in the U.S. District Court, Appellant was convicted of possession of a firearm by a convicted felon and possession of a firearm with an obliterated serial number. Prior to trial, Appellant unsuccessfully moved to suppress incriminating statements he made to police over the course of several encounters, arguing that any waiver of his Miranda right to remain silent was a product of threats and coercion. On appeal, Appellant contended that the district court failed to instruct the jury, under 18 U.S.C. 3501(a), to “give such weight to the confession as the jury feels it deserves under all the circumstances.” The First Circuit Court of Appeals affirmed, holding (1) there was no meaningful difference between the instruction called for by section 3501 and the instruction given at Appellant’s trial; and (2) even if courts should follow more closely the precise language of section 3501, any error on the court’s part to do so in this case went unchallenged and was unlikely to have affected the outcome of Appellant’s trial. View "United States v. Colon" on Justia Law

After a jury trial in state court, Petitioner was found guilty of first-degree murder and sentenced to life imprisonment. After the Supreme Judicial Court affirmed on direct appeal, Petitioner filed a petition for habeas corpus in the federal district court, asserting (1) insufficient evidence supported his conviction; and (2) because the prosecutor argued at Petitioner’s state-court trial that Petitioner had shot and killed the victim but, at an earlier state-court trial, argued that Petitioner’s accomplice had shot and killed the victim, the prosecutor’s inconsistent approaches deprived him of his due process rights. The district court denied the petition. The First Circuit Court of Appeals affirmed, holding (1) the evidence presented in Petitioner’s state-court trial was adequate to support his conviction; and (2) the prosecution of Petitioner and his accomplice in different trials on materially inconsistent theories of guilt did not violate due process, as (i) state law permitted such a course of action, (ii) any potential inconsistency in result between Petitioner’s and his accomplice’s cases had been remedied by the time the Supreme Court heard Petitioner’s appeal, and (iii) the Commonwealth did not unfairly manipulate the evidence. View "Housen v. Gelb" on Justia Law

After Plaintiff applied unsuccessfully to be a firefighter in the Puerto Rico Firefighters Corps of the Commonwealth of Puerto Rico (“the Corps”) Plaintiff sued the Commonwealth, claiming that the Corps refused to hire her because of her gender. The parties eventually signed a settlement agreement pursuant to which the Corps agreed to employ Plaintiff as a transitory firefighter until the next training academy was held and to hire Plaintiff as a firefighter if she graduated from the academy. Thereafter, Plaintiff again sued the Corps, alleging that, during her transitory employment, the Corps subjected her to abuse in retaliation for her earlier suit. The district court dismissed Plaintiff’s complaint for failure to state a claim. Plaintiff appealed the dismissal of her claim for unlawful retaliation. The First Circuit Court of Appeals vacated the district court’s order, holding that Plaintiff’s complaint stated a plausible claim of unlawful retaliation in violation of Title VII of the Civil Rights Act. Remanded. View "Rodriguez-Vives v. P.R. Firefighters Corps" on Justia Law

Plaintiffs granted a mortgage on their property in Massachusetts to Ameriquest Mortgage Company, which assigned its interest in the mortgage to Mortgage Electronic Registration System, Inc. (MERS). MERS later purported to assign Plaintiffs’ interest to HSBC Mortgage Services, Inc. (HSBC). HSBC subsequently began foreclosure proceedings on Plaintiffs’ property. Plaintiffs filed an eight-count complaint against HSBC, claiming the assignment was void, and therefore, HSBC never acquired the mortgage to their property and had no right to initiate foreclosure proceedings. The district court dismissed Plaintiffs’ complaint for failure to state a claim, concluding that Plaintiffs did not have standing to challenge the assignment because they were not a party to the assignment, nor were they third-party beneficiaries of the assignment. The First Circuit Court of Appeals affirmed, holding (1) under Massachusetts law, homeowners in Plaintiffs’ position have standing to challenge a prior assignment of their mortgage on the grounds that the assignment was void, but because Plaintiffs did not set forth a colorable claim that the mortgage assignment in question was void, Plaintiffs lacked standing to raise certain claims; and (2) Plaintiffs failed to state a claim for promissory estoppel with respect to a loan modification. View "Wilson v. HSBC Mortgage Servs., Inc." on Justia Law

After a jury trial, Petitioner was found guilty of second-degree murder. Petitioner’s conviction was affirmed on appeal by the state court. Petitioner subsequently sought a writ of habeas corpus in the federal district court, which denied habeas relief but issued a certificate of appealability as to three claims. The First Circuit Court of Appeals affirmed, holding (1) the state court did not abuse its discretion in concluding that the evidence adduced at trial was sufficient to support Petitioner’s conviction for second-degree murder; (2) the state court did not abuse its discretion when it declined to find a due process violation based on the unavailability of the victim’s larynx; and (3) the state court’s determination that certain statements made by the prosecutor did not constitute prosecutorial misconduct sufficient to warrant setting aside Petitioner’s conviction was not an unreasonable application of the law. View "Magraw v. Roden" on Justia Law

Michael Mahon sued the government under the Federal Tort Claims Act (FTCA) after falling from a second-story portico during a wedding reception at the Commandant’s House at the Charlestown Navy Yard in Massachusetts. Mahon later amended his complaint to add claims against Eastern National and Amelia Occasions, which contracted with the interior Department’s National Park Service to manage the House and handle the events. The district judge granted the government’s motion to dismiss for lack of subject-matter jurisdiction, concluding that the discretionary-function exception to the FTCA applied. The district judge subsequently granted Mahon’s motion for reconsideration and allowed discovery to go forward on the issue of whether the government’s relationship with Eastern National and Amelia Occasions was governed by a “concession contract,” which could have led the government to learn about the portico’s “impermissibly low railing,” thus placing the case beyond the discretionary-function exception’s reach. After discovery, the district judge dismissed the complaint for lack of subject-matter jurisdiction, concluding that, ultimately, Mahon’s case was within the ambit of the discretionary-function exception. The First Circuit Court of Appeals affirmed, holding that the FTCA’s discretionary-function exception barred Mahon’s claims against the government. View "Mahon v. United States" on Justia Law

After a jury trial, Appellant was convicted of possessing with intent to defraud counterfeit United States currency. The First Circuit Court of Appeals affirmed the conviction, holding that the district court did not err in (1) admitting evidence seized by police during and after Appellant’s arrest ensuing from the officers’ investigative stop, as the officers had a reasonable suspicion of criminal activity sufficient to justify their actions; (2) denying Appellant’s motion for a judgment of acquittal, as sufficient evidence supported Appellant’s intent to defraud; and (3) issuing a jury instruction on the statutory element of fraudulent intent, as the instructions issued in this case were neither incorrect on the law nor unfairly prejudicial in favor of the government. View "United States v. Silva" on Justia Law

Plaintiff filed an action against her former employer (Employer) for violations of Title VII, 42 U.S.C. 2000e et seq., and Mass. Gen. Laws ch. 151B, alleging that she was subject to sexual harassment while working for Employer and that she was terminated in retaliation for reporting the harassment. The district court granted summary judgment in favor of Employer. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in concluding that no reasonable juror could conclude that Plaintiff was subjected to sexual harassment while an employee for Employer; and (2) even if Plaintiff had made a prima facie case of retaliation, which she did not, Plaintiff did not meet her burden of showing that Employer’s legitimate, non-retaliatory reason for the termination was mere pretext. View "Ponte v. Steelcase Inc." on Justia Law