Justia Constitutional Law Opinion Summaries

Articles Posted in U.S. Court of Appeals for the First Circuit
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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

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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

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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

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Regina M. Thornton was employed by Ipsen Biopharmaceuticals, Inc. as Associate Director - Patient Safety. In September 2021, Ipsen required employees to receive COVID-19 vaccinations. Thornton requested a religious exemption, which Ipsen denied. After she did not comply with the vaccination requirement, Ipsen terminated her employment. Thornton sued Ipsen in the Superior Court of Massachusetts, alleging violations of Title VII, Massachusetts law (Chapter 151B), the Fourteenth Amendment, and the Massachusetts Declaration of Rights (MDR). Ipsen removed the case to the United States District Court for the District of Massachusetts and moved to dismiss all counts. The Magistrate Judge granted Ipsen's motion, dismissing Thornton's complaint. Thornton appealed.The United States District Court for the District of Massachusetts dismissed Thornton's complaint, finding that she failed to state a plausible claim of religious discrimination under Title VII or Chapter 151B. The court concluded that Thornton did not adequately state her religious beliefs or how they related to vaccines. The court also found that Thornton's federal constitutional claims failed because Ipsen was not a state actor, and her MDR claims failed because the MDR does not provide a private right of action.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed the Magistrate Judge's dismissal of Thornton's religious discrimination claims under Title VII and Chapter 151B, finding that she had plausibly alleged that her religious beliefs conflicted with the vaccination requirement. However, the court affirmed the dismissal of her federal constitutional claims, as the Fourteenth Amendment does not apply to private actors like Ipsen. The court also affirmed the dismissal of her MDR claims, noting that Thornton had waived any argument that her claim should be reimagined under the Massachusetts Civil Rights Act. View "Thornton v. Ipsen Biopharmaceuticals, Inc." on Justia Law

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Dario Giambro was convicted under 18 U.S.C. § 922(g)(1) for being a felon in possession of a firearm. The conviction stemmed from evidence found by police officers who forcibly entered his home in Hebron, Maine, without a warrant. The officers entered the home based on information from Giambro's son, Antonio, who reported that his mother, Arline, had died and was not in the house. Giambro argued that the warrantless entry violated his Fourth Amendment rights and that the evidence should be suppressed. He also challenged the charge on Second Amendment grounds.The United States District Court for the District of Maine denied Giambro's motion to suppress, ruling that the entry fell within the emergency aid exception to the Fourth Amendment's warrant requirement. The court found that the officers had an objectively reasonable basis to believe that Arline might be in need of immediate aid, despite Antonio's report that she had died and was not in the house. The court also denied Giambro's motion to dismiss the charge on Second Amendment grounds.The United States Court of Appeals for the First Circuit reviewed the case and disagreed with the district court's application of the emergency aid exception. The appellate court held that the officers did not have an objectively reasonable basis to believe that Arline was alive and in need of immediate aid, given that Antonio had been in the house that morning and reported that she was not there. The court emphasized that the officers should have spoken to Antonio and Giambro, who were available for questioning, before forcibly entering the home. Consequently, the First Circuit reversed the district court's denial of the motion to suppress, vacated Giambro's conviction and sentence, and remanded the case for further proceedings. The court did not address the Second Amendment claim due to its ruling on the Fourth Amendment issue. View "United States v. Giambro" on Justia Law

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The First Circuit affirmed the district court’s rejection of Appellant’s claims that she, among other things, suffered discrimination in violation of the Americans with Disabilities Act (ADA) and its Massachusetts state-law corollary when Defendants failed to accommodate her request for transfer to another position in the Plymouth Police Department after she suffered an on-the-job injury. The district court concluded that Appellant failed to raise a genuine issues of material fact regarding her discrimination claims. The First Circuit affirmed, holding (1) the district court correctly entered summary judgment on Appellant’s handicap discrimination claims and gender discrimination claim; and (2) even if the court were able to glean an ADA retaliation claim from Appellant’s complaint, Appellant waived it during summary judgment proceedings. View "Audette v. Town of Plymouth, Mass." on Justia Law

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The First Circuit affirmed Defendant’s conviction for conspiracy to commit access-device fraud. Before trial, Defendant and his co-defendant filed motions to suppress evidence and statements that had been obtained in the previous months in connection with three traffic stops. The district court denied the motions to suppress. The First Circuit affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress concerning a traffic stop in Kittery, Maine because the police had reasonable suspicion to justify the investigative stop as of 1:55 a.m. and the seizure was not unreasonably long; and (2) the district court did not err in denying the motion to suppress evidence obtained from a traffic stop in Ohio because there was reasonable suspicion to justify the detention. View "United States v. Ramdihall" on Justia Law

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The First Circuit affirmed Defendant’s conviction for conspiracy to commit access-device fraud. Before trial, Defendant and his co-defendant filed motions to suppress evidence and statements that had been obtained in the previous months in connection with three traffic stops. The district court denied the motions to suppress. The First Circuit affirmed, holding (1) the district court did not err in denying the motion to suppress evidence obtained from a traffic stop in Ohio because there was no unlawful seizure, and therefore, the evidence Defendant sought to suppress did not constitute the fruits of an unlawful seizure; and (2) the district court did not err in concluding that the warrantless swiping of credit cards from in the trunk of a rental car through a card reader was constitutional. View "United States v. Hillaire" on Justia Law

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First Circuit rejects Double Jeopardy challenge to second indictment for cocaine smuggling.On August 15, 2013, Díaz was indicted in the Southern District of Florida for his role in planning and organizing a maritime smuggling operation involving over 1,000 kilograms of cocaine. Five days later, Díaz was indicted in the District of Puerto Rico -- for his role in planning and organizing a maritime smuggling operation involving over 1,000 kilograms of cocaine. The First Circuit rejected his argument that the Double Jeopardy Clause barred his prosecution on the Puerto Rico charges because the Florida charges already encompass the conduct for which he was indicted in Puerto Rico. While the places involved and the two statutory provisions under which Díaz was charged were the same, the lower court concluded that the conspiracies charged in the two indictments were separate ones insofar as the conduct charged in the two indictments involved distinct time periods, personnel, and evidence. View "United States v. Diaz-Rosado" on Justia Law

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First Circuit rejects civil rights claims relating to retention of property in car towed for an evidentiary search.Chelmsford police located Denault’s 2000 Nissan parked in Testa’s Lowell driveway. Denault, the suspect in a crime, was in custody. Testa was the mother of Denault's children. The officers had Denault's car towed and secured a warrant. Days later, they executed the warrant; having determined that the car did not contain evidence, they released it to Christopher's Towing. The officers had no contact with Denault. They did not supply, and Christopher's Towing did not request, Denault’s contact information. Testa repeatedly tried to recover the car and her belongings, particularly child booster seats. Testa claims that officers refused to discuss returning the car or its contents unless Testa agreed to be questioned in connection with the Denault investigation; they never informed her that they had released the car. Three months later, Denault's mother showed Tesla a Notice of Abandoned Vehicle sent to Denault's last known address, indicating a lien of $4797.82 for towing, storage, and processing. Neither Testa nor Denault could pay. They sued under 42 U.S.C. 1983 and the Massachusetts Civil Rights Act. They ultimately prevailed on a common-law conversion claim against one officer for $2225. The First Circuit affirmed, noting the “confusing” record and that the plaintiffs had waived claims relating to the initial seizure. View "Denault v. Ahern" on Justia Law