Justia Constitutional Law Opinion Summaries

This matter began in a New Hampshire family court (“Family Court”) in 2006 and involved Plaintiff’s support obligations to his former wife and son. Due to Plaintiff’s financial evasiveness, the Family Court appointed a commissioner (“Commissioner”) to investigate and report Plaintiff’s gross income from 2006 forward. The Commissioner found Plaintiff’s income was higher than what Plaintiff had previously represented to the court. Consequently, the Family Court held Plaintiff in contempt for failure to pay past-due child support obligations and entered judgment in favor of Plaintiff’s ex-wife. The New Hampshire Supreme Court (NHSC) denied Plaintiff’s discretionary appeal. Plaintiff subsequently filed a complaint in the U.S. District Court seeking to enjoin the orders of the Family Court on constitutional grounds and to reverse the NHSC’s denial of his discretionary appeal. Plaintiff also asserted various claims against the Commissioner. The district court’s dismissed all of Plaintiff’s claims. The First Circuit Court of Appeals affirmed, holding (1) N.H. Sup. Ct. R. 3, which classifies appeals from child support orders as discretionary, does not violate the due process and equal protection clauses of the U.S. Constitution; and (2) the Commissioner was immune to suit for his acts as Commissioner in the matter. View "D'Angelo v. N.H. Supreme Court" on Justia Law

Plaintiff, the former captain of a village fire department, filed this action against the department, its fire chief, and the board of fire commissioners (collectively, Defendants) after the board chose to terminate Plaintiff’s employment. Plaintiff alleged political discrimination in violation of the First Amendment and 42 U.S.C. 1983, retaliation in violation of the Massachusetts Whistleblower Act, and tortious interference with contractual relations. The district court granted summary judgment for Defendants on all counts. The First Circuit Court of Appeals affirmed, holding that Defendants presented legitimate, business-related grounds for their employment decisions, and Plaintiff failed to demonstrate that the proffered explanations were pretextual. View "Pierce v. Cotuit Fire Dist." on Justia Law

Appellant filed an action against her former employer, The Children Place (TCP) and the TCP district manager (collectively, Appellees), alleging that she was fired, harassed, and not rehired on the basis of race. The district court granted summary judgment in favor of Appellees. The First Circuit Court of Appeals affirmed, holding (1) the district court did not abuse its discretion when it denied three of Appellant’s discovery-related motions; and (2) the district court did not err by granting Appellees’ motion for summary judgment as to (i) Appellant’s claims of race discrimination where Appellant was unable to rebut Appellees’ legitimate, nondiscriminatory basis for her termination with evidence of pretext and discriminatory motive, and (ii) Appellant’s retaliation claim in light of her failure to establish a prima facie case. View "Pina v. Children's Place" on Justia Law

Sixty-four-year-old Plaintiff was born anatomically male but suffered from severe gender identity disorder. In 1992, Plaintiff was convicted of murder and sentenced to life imprisonment. In 2000, Plaintiff filed a complaint against the Massachusetts Department of Correction (DOC), alleging that the DOC was denying her adequate medical care by not providing her with sex reassignment surgery. The district court subsequently issued an order requiring the Commissioner of the DOC to provide Plaintiff was sex reassignment surgery, finding that the DOC’s failure to provide the surgery violated Plaintiff’s Eighth Amendment rights. The DOC appealed. The First Circuit Court of Appeals affirmed, holding that the district court did not err in finding that Plaintiff had a serious medical need for sex reassignment surgery and that the DOC refused to meet that need for pretextual reasons unsupported by legitimate penological considerations in violation of Plaintiff’s Eighth Amendment rights. View "Kosilek v. Spencer" on Justia Law

Defendant was convicted on charges of conspiracy and tax evasion. Defendant appealed, arguing that the district court erred in (1) denying his motion to suppress because the premises search conducted by armed agents of the Internal Revenue Service was unlawful, and (2) instructing the jury. The First Circuit Court of Appeals affirmed the district court’s judgment, holding (1) the district court did not err in refusing to grant Defendant’s motion to suppress, as the performance of the search by armed agents did not constitute an unreasonable intrusion into Defendant’s dwelling where the agents entered the home and conducted the search pursuant to a warrant; and (2) the district court properly instructed the jury. View "United States v. Adams" on Justia Law

After a jury trial, Defendants, Catherine Floyd and William Dion, were convicted of conspiracy to defraud the United States of payroll and income taxes and endeavoring to obstruct and impede the Internal Revenue Service (IRS). The First Circuit Court of Appeals affirmed, holding (1) there was sufficient evidence to support the convictions; (2) the district court did not err in failing to suppress certain evidence; (3) the district court did not err in denying Defendants’ motions for severance and in trying Defendants jointly with their coconspirator; (4) Defendants’ claim that the IRS’s failure to comply with the Federal Register Act engendered dismissal of some of the charges was without merit; and (5) the district court did not err in sentencing Dion. View "United States v. Dion" on Justia Law

After a jury trial, Defendant was convicted of producing, possessing, and distributing child pornography. Defendant was sentenced to 340 months of imprisonment followed by fifteen years of supervised release. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in applying the exception to the marital communications privilege for offenses committed against the child of either spouse to certain statements Defendant made to his former wife and in admitting the former wife’s testimony regarding the statements; (2) the district court did not err in admitting file and chat room names that were suggestive of child pornography where no images were recovered; (3) the evidence was sufficient to sustain all three charges; and (4) under the applicable United States Sentencing Guidelines, the sentence imposed in this case was both procedurally and substantively reasonable. View "United States v. Breton" on Justia Law

After a jury trial in a Massachusetts state court, Petitioner was convicted of second-degree murder and sentenced to life imprisonment. The Massachusetts Appeals Court (MAC) affirmed. The federal district court granted Petitioner’s petition for a writ of habeas corpus by reaching the merits of Petitioner’s arguments on its own without deferring to the state court decision as required by the Antiterrorism and Effective Death Penalty Act, concluding (1) the MAC did not adjudicate Petitioner’s due process claims as presented at trial on the merits, and (2) constitutional error on the part of the trial court was not harmless. The First Circuit Court of Appeals reversed the petition for habeas corpus relief, holding (1) although the MAC did not expressly discuss Petitioner’s arguments regarding the admissibility of evidence under Chambers v. Mississippi, the MAC correctly rejected the argument on the merits; and (2) to the extent the MAC found in a footnote that Petitioner asserted on appeal a new third-party culprit theory of admissibility that was never raised in the trial court, review of the third-party culprit theory was procedurally barred. View "Hodge v. Mendonsa" on Justia Law

Defendants pleaded guilty to conspiracy to possess, possession of, and use of counterfeit access devices. Defendants appealed the denial of their motion to suppress evidence obtained in connection with the stop and search of their vehicle, arguing (1) law enforcement officers lacked reasonable suspicion for the stop; (2) the warrantless search of the vehicle and the ensuing search warrant obtained for the vehicle were not based on probable cause; (3) law enforcement violated the Fifth Amendment by failing to inform Defendants of their Miranda rights; and (4) evidence and statements obtained through the stop and interrogation should be suppressed as fruits of the poisonous tree. The First Circuit Court of Appeals affirmed, holding (1) the stop of Defendants' vehicle did not violate the Fourth Amendment, and accordingly, the warrant issued for the search of the vehicle was not tainted by an illegal stop; (2) Defendants could not object to the search or seek suppression of the evidence obtained in the search because they failed to establish they had a reasonable expectation of privacy in the vehicle searched after the stop; and (3) the admission of statements obtained through the questioning of Defendants did not violate the Fifth Amendment. View "United States v. Campbell" on Justia Law

Defendants in this consolidated appeal were gang members who were involved in a deadly drug conspiracy in Puerto Rico. Each Defendant was indicted for conspiring to possess and distribute illegal drugs within 1,000 feet of a public-housing facility, and three of the five defendants were indicted for aiding and abetting the use or carrying of a firearm during and in relation to a drug crime or the possession of a firearm in furtherance of that crime. After a jury trial, each defendant was essentially found guilty as charged. Only one defendant was found not guilty of participating in drug-related conspiracy activities within 1,000 feet of a public-housing project. Defendants' appeals raised numerous issues, which the First Circuit Court of Appeals sorted out person by person. In summary, the First Circuit affirmed the district court's judgment in all respects, holding that Defendants were "lawfully tried, convicted, and sentenced." View "United States v. Acosta-Colon" on Justia Law