Justia Constitutional Law Opinion Summaries

Broc Waltermeyer, an incarcerated federal inmate, alleged that he received inadequate medical treatment for his chronic knee pain while at the Federal Correctional Institute in Berlin, New Hampshire. He claimed that despite receiving various non-surgical treatments, including cortisone injections, pain medication, special shoes, knee braces, access to a low bunk, and a cane, he continued to experience pain. Waltermeyer argued that he should have been provided with knee replacement surgery, which was recommended to be deferred by an outside specialist until he was older.The United States District Court for the District of New Hampshire dismissed Waltermeyer's complaint, holding that his claims failed because he had an alternative administrative remedy. The district court also denied his motion for a preliminary injunction, as he had been transferred to a different facility, making the defendants no longer responsible for his care. Waltermeyer then amended his complaint to seek only money damages, leading to the current appeal.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's dismissal. The court held that Waltermeyer's claims were meaningfully different from those in Carlson v. Green, where the Supreme Court recognized a Bivens-type Eighth Amendment claim against federal prison officials for deliberate indifference to serious medical needs. The court found that Waltermeyer received substantial treatment, albeit not the treatment he preferred, and that the medical procedures administered were in accordance with doctors' recommendations. The court concluded that the differences in the nature of the medical care provided and the absence of gross inadequacy or deliberate indifference made Waltermeyer's case distinct from Carlson, thus precluding the extension of a Bivens remedy. View "Waltermeyer v. Hazlewood" on Justia Law

A Massachusetts law prohibits the sale, transfer, or possession of assault weapons and large capacity feeding devices. Joseph R. Capen, a Massachusetts resident, and the National Association for Gun Rights challenged the law, claiming it violates the Second Amendment. They sought a declaratory judgment and preliminary and permanent injunctions against the law's enforcement.The U.S. District Court for the District of Massachusetts denied the motion for a preliminary injunction, concluding that the plaintiffs could not demonstrate a likelihood of success on the merits of their claims. The court found that the law is consistent with the nation's historical tradition of regulating dangerous and unusual weapons, which are not typically used for self-defense. The court also found that the law's restrictions on large capacity magazines are supported by historical precedents of regulating items that pose a significant public safety threat.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the Massachusetts law's restrictions on assault weapons, specifically the AR-15, are consistent with historical regulations that aimed to protect public safety by restricting particularly dangerous weapons. The court also found that the law's restrictions on large capacity magazines are supported by historical analogues and do not impose a significant burden on the right to self-defense. Therefore, the plaintiffs are unlikely to succeed on the merits of their claims, and the district court did not abuse its discretion in denying the preliminary injunction. View "Capen v. Campbell" on Justia Law

In November 2004, Julio Rodríguez-Méndez participated in a carjacking in Puerto Rico while possessing a firearm. He was first prosecuted in a Puerto Rico Commonwealth court for robbery of a motor vehicle and carrying a weapon without a license, to which he pleaded guilty and was sentenced to twelve years in prison. Subsequently, a federal grand jury indicted him on three counts related to the same carjacking, including unlawful possession of a firearm by a felon. Rodríguez pleaded guilty to the felon-in-possession count, and the other charges were dismissed. He was sentenced to 216 months in prison, partly due to being classified as an armed career criminal under the Armed Career Criminal Act (ACCA).Rodríguez filed a motion under 28 U.S.C. § 2255 seeking to vacate his conviction on double jeopardy grounds and to challenge his ACCA enhancement. The United States District Court for the District of Puerto Rico denied his motion, holding that double jeopardy did not apply and that his prior convictions for motor vehicle robbery qualified as ACCA predicates.The United States Court of Appeals for the First Circuit reviewed the case. The court rejected Rodríguez's double jeopardy claim, stating that the federal felon-in-possession offense and the Commonwealth firearm offense are separate offenses under the Blockburger test, as each requires proof of an element that the other does not. However, the court agreed with Rodríguez that his prior convictions under Article 173B of the Puerto Rico Penal Code did not qualify as ACCA predicates. The court found that the statute's definition of "intimidation" was broader than the ACCA's requirement for violent felonies, as it included threats against property, not just persons.The First Circuit affirmed the district court's denial of Rodríguez's double jeopardy claim but reversed the denial of his § 2255 motion regarding the ACCA enhancement, vacating his sentence and remanding for resentencing. View "Rodriguez-Mendez v. United States" on Justia Law

The case involves a challenge by eighteen states and other plaintiffs against the enforcement of Executive Order No. 14,160, which limits the recognition of U.S. citizenship for certain individuals born in the United States. The Executive Order specifies that individuals born to mothers unlawfully present in the U.S. or temporarily present mothers, where the father is not a U.S. citizen or lawful permanent resident, will not be recognized as U.S. citizens. The plaintiffs argue that this order violates the Citizenship Clause of the Fourteenth Amendment and 8 U.S.C. § 1401.The United States District Court for the District of Massachusetts granted a preliminary injunction preventing the enforcement of the Executive Order. The court found that the plaintiffs were likely to succeed on the merits of their claims, would suffer irreparable harm without the injunction, and that the balance of harms and public interest favored the injunction. The court issued a "universal" preliminary injunction, applying nationwide, to prevent the enforcement of the Executive Order.The United States Court of Appeals for the First Circuit reviewed the government's motion for a stay pending appeal of the preliminary injunction. The court denied the stay, concluding that the government failed to make a "strong showing" that it was likely to succeed on the merits of its appeal, particularly regarding the plaintiffs' standing and the lawfulness of the Executive Order. The court also found that the government did not meet its burden on the other factors required for a stay, including irreparable harm and public interest. The court upheld the nationwide scope of the preliminary injunction, noting that the government did not adequately address the necessity of such broad relief to prevent harm to the plaintiffs. View "State of New Jersey v. Trump" on Justia Law

In this case, José M. Rojas-Tapia appealed the denial of his 28 U.S.C. § 2255 petitions for post-conviction relief, which he filed in the District of Puerto Rico. Rojas's convictions and sentences stem from his October 2000 guilty pleas to charges related to two separate post office robberies. The first indictment involved the Levittown Post Office, and the second involved the Sabana Seca Post Office. Both indictments included charges under 18 U.S.C. § 2114(a) for assaulting postal employees with intent to rob, and under 18 U.S.C. § 924(c) for using a firearm during a crime of violence. Additionally, Rojas was charged under 18 U.S.C. § 922(g) for being a felon in possession of a firearm.Rojas did not challenge his convictions or sentences on direct appeal. However, in 2017, he filed two habeas petitions challenging his § 924(c) convictions and the application of the Armed Career Criminal Act (ACCA) to his § 922(g) convictions. He argued that his § 924(c) convictions could not stand under Johnson v. United States (2015) and United States v. Davis (2019), as his underlying offenses did not qualify as crimes of violence. He also contended that his ACCA-enhanced sentences were improper because his prior convictions did not qualify as violent felonies or serious drug offenses.The United States District Court for the District of Puerto Rico denied both petitions. The court concluded that Rojas's federal mail robbery convictions under § 2114(a) qualified as crimes of violence under the force clause of § 924(c). Additionally, the court found that Rojas's prior convictions for attempted murder, second-degree murder, and armed carjacking under Puerto Rico law qualified as violent felonies under the ACCA.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court held that Rojas's convictions for aggravated mail robbery under § 2114(a) qualified as crimes of violence under § 924(c)'s force clause. The court also rejected Rojas's argument that his aiding and abetting convictions did not qualify as crimes of violence, reaffirming that aiding and abetting liability under 18 U.S.C. § 2 does not alter the application of the categorical approach. The court did not address Rojas's ACCA-related arguments, as his request for a Certificate of Appealability on those claims had been denied. View "Rojas-Tapia v. United States" on Justia Law

A high school student, Adrianna Wadsworth, filed a lawsuit against her principal, Andrew Cavanaugh, a school social worker, Chuck Nguyen, and the school district, MSAD 40/RSU 40, alleging constitutional violations and a Title IX claim. Wadsworth claimed that Cavanaugh sexually harassed her, Nguyen failed to protect her, and the school district was indifferent to the harassment.The United States District Court for the District of Maine dismissed some of Wadsworth's claims and granted summary judgment in favor of the defendants on others. The court dismissed the supervisor-liability claim against Nguyen, finding no control over Cavanaugh. It also granted summary judgment to Cavanaugh on the substantive due process claim, concluding that non-physical harassment did not violate Wadsworth's right to bodily integrity. The court found that Wadsworth's equal protection claim against Cavanaugh was valid but granted him qualified immunity. Nguyen was granted summary judgment on the state-created-danger claim, as his conduct did not shock the conscience. The court also granted summary judgment to MSAD on the § 1983 municipal liability claim, finding no deliberate indifference, and on the Title IX claim, concluding that the assistant principals did not have actual knowledge of the harassment.The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court's decision on the substantive due process claim against Cavanaugh but reversed the summary judgment on the equal protection claim, finding that a reasonable jury could conclude that Cavanaugh's conduct was severe and pervasive enough to constitute sexual harassment. The court also affirmed the dismissal of the supervisor-liability claim against Nguyen and the summary judgment on the state-created-danger claim. However, it reversed the summary judgment on the Title IX claim against MSAD, concluding that a reasonable jury could find that the assistant principals had actual knowledge of the harassment. The case was remanded for further proceedings consistent with the opinion. View "Wadsworth v. MSAD 40/RSU 40" on Justia Law

The case involves parents (the "Parents") of a student at Baird Middle School in Ludlow, Massachusetts, who challenged the school's protocol regarding the use of a student's requested name and gender pronouns without notifying the parents unless the student consents. The Parents argued that this practice interfered with their parental rights under the U.S. Constitution. The school, represented by the Ludlow School Committee and various school officials, defended the protocol as necessary to ensure a safe and inclusive environment for students.In the United States District Court for the District of Massachusetts, the Parents' complaint was dismissed. The court held that the Parents failed to state a plausible claim that the school's protocol violated their fundamental right to direct the upbringing of their child. Specifically, the court found that the Parents did not adequately allege that the school's actions constituted medical treatment or that the conduct was so egregious as to shock the conscience, which is required to establish a substantive due process violation.The United States Court of Appeals for the First Circuit reviewed the case. The court concluded that the protocol is a form of legislative conduct, not executive conduct, and thus did not require the shock-the-conscience test. The court determined that the Parents had identified a fundamental right but failed to plausibly allege that the school's conduct restricted that right. The court found that the school's actions, including the use of the student's chosen name and pronouns, did not constitute medical treatment and that the protocol did not restrict the Parents' rights to direct their child's upbringing.The First Circuit held that the protocol was rationally related to the legitimate state interest of creating a safe and inclusive educational environment for students. Therefore, the court affirmed the district court's dismissal of the Parents' complaint. View "Foote v. Ludlow School Committee" on Justia Law

A developer purchased a historical property in Newton, Massachusetts, and began restoration work. The Newton Historical Commission issued a stop-work order, claiming the developer violated the permit by demolishing large portions of the building. The developer, 29 Greenwood, LLC, disagreed but complied with the order and submitted revised proposals, all of which were denied. The developer then filed a lawsuit, alleging a violation of the Takings Clause of the U.S. Constitution and state law.The case was initially filed in state court but was removed to the U.S. District Court for the District of Massachusetts. The district court dismissed the complaint, ruling that the dispute was a typical zoning issue not rising to the level of a constitutional taking. The developer appealed the dismissal, arguing that the Commission acted in bad faith and would never permit the reconstruction.The United States Court of Appeals for the First Circuit reviewed the case. The court noted that two related actions were pending in state court, which could potentially resolve or narrow the federal constitutional issues. The court decided to abstain from ruling on the federal issues until the state court proceedings concluded, invoking the Pullman abstention doctrine. The court vacated the district court's dismissal and remanded the case with instructions to stay the federal proceedings pending the outcome of the state court cases. Each party was ordered to bear its own costs. View "29 Greenwood, LLC v. City of Newton" on Justia Law

Two state forensic chemists in Massachusetts tampered with drug evidence and falsified test results, affecting tens of thousands of drug cases. The Massachusetts Supreme Judicial Court (SJC) vacated over 30,000 criminal cases due to this misconduct. The SJC ruled that under the Fourteenth Amendment, affected individuals were entitled to the repayment of most funds collected due to their vacated convictions but not the automatic return of forfeited property. Instead, individuals had to file motions for relief from judgment under Rule 60(b) of the Massachusetts Rules of Civil Procedure.The plaintiffs, whose criminal convictions were vacated, sought a federal court order for the automatic return of their forfeited property and related relief. The Commonwealth defendants moved to dismiss the complaint, arguing that the claims were barred by the Eleventh Amendment, which prohibits suits in federal court against a state by its own citizens. The United States District Court for the District of Massachusetts dismissed the complaint in part, ruling that it could not order the automatic return of forfeited property but allowed other claims to proceed under the Ex parte Young exception to the Eleventh Amendment.The United States Court of Appeals for the First Circuit reviewed the case and concluded that the Eleventh Amendment bars all the relief sought by the plaintiffs. The court held that the plaintiffs' claims focused on a past wrong, and the Ex parte Young exception applies only to prospective relief against ongoing violations of federal law. Additionally, the state officials sued lacked the authority to enforce or change the state court procedures. The court reversed the district court's partial denial of the motion to dismiss and remanded with instructions to dismiss the case in full. View "Cotto v. Campbell" on Justia Law

The case involves Maine healthcare workers who were terminated from their employment for refusing to comply with a COVID-19 vaccine mandate based on their religious beliefs. The mandate, initially promulgated by emergency rule on August 12, 2021, was no longer enforced as of July 12, 2023, and was repealed effective September 5, 2023. The plaintiffs filed suit in the United States District Court for the District of Maine, asserting that the mandate's lack of religious exemptions violated the First and Fourteenth Amendments. Their motion for a temporary restraining order and preliminary injunction was denied, and the denial was affirmed by the First Circuit. The Supreme Court also denied their application for emergency injunctive relief.The defendants moved to dismiss the complaint for failure to state a claim, which was granted. The First Circuit affirmed in part and reversed in part, reinstating the First Amendment Free Exercise and Fourteenth Amendment Equal Protection Clause claims for declaratory and injunctive relief against state health officials. Following the repeal of the mandate, the defendants moved to dismiss the remaining claims as moot, and the district court granted the motion, also denying the plaintiffs leave to amend the complaint.The United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the district court's determinations. The court held that the challenge was moot because the COVID-19 vaccine mandate had been repealed and was no longer in effect. The court also found that no exceptions to mootness, such as voluntary cessation or capable of repetition yet evading review, applied. The court further affirmed the denial of the plaintiffs' request to amend their complaint, concluding that justice did not require permitting further amendments to broaden the scope of their claims. View "Lowe v. Gagne-Holmes" on Justia Law