Justia Constitutional Law Opinion Summaries

Copia Communications, LLC, a Massachusetts company, brought this action in federal district court in Massachusetts against Seawind Key Investments, Limited, a Jamaican resort operator, and Seawind’s alleged alter-ego, AMResorts, LP, a Pennsylvania limited partnership, alleging breach of contract. The subject contract was proposed and executed in Jamaica, performance on the contract occurred almost exclusively in Jamaica, and the contract was governed by the laws of Jamaica. Both defendants, neither of which operated any business or had any corporate presence in Massachusetts, moved to dismiss, arguing lack of personal jurisdiction and forum non conveniens. The district court dismissed the case without prejudice, finding that it lacked personal jurisdiction over the defendants. The First Circuit affirmed, holding that the exercise of personal jurisdiction over the defendants was barred by the due process clause of the Fifth Amendment. View "Copia Commc’ns, LLC v. AMResorts, LP" on Justia Law

Plaintiff’s late father was formerly employed as a mechanic by the City of Boston. Plaintiff brought this lawsuit on behalf of her father’s estate, alleging that the City and her father’s supervisors discriminated against her father on the basis of race and retaliated against him by terminating his employment. Plaintiff’s federal claims appeared to arise under 42 U.S.C. 1981 and 1983. The district court dismissed Plaintiff’s complaint, concluding that Plaintiff had not pled facts sufficient to support her section 1983 claim and had failed to timely exhaust the administrative prerequisites necessary to bring suit on her section 1981 claim. The First Circuit (1) affirmed the dismissal of the section 1983 claim, holding that this claim was properly dismissed pursuant to Fed. R. Civ. P. 12(b)(6); but (2) reversed the dismissal of the section 1981 claim, holding that the district court erred by imposing an administrative exhaustion requirement where none exists. View "Buntin v. City of Boston" on Justia Law

Plaintiff filed suit against officials at the University of Massachusetts at Dartmouth after the university had commenced termination proceedings against him, alleging, inter alia, claims under 42 U.S.C. 1983 for violations of his First and Fourteenth Amendment rights. Plaintiff then filed a second amended complaint along with an amended motion for preliminary injunction requesting that the termination proceedings be halted and Plaintiff be reinstated to his position. Defendants moved to dismiss the amended complaint. The district court granted in part and denied in part the motion to dismiss and sua sponte combined the motion for preliminary injunction with a trial on the merits. The university subsequently terminated Plaintiff. During the pendency of Plaintiff’s interlocutory appeal of the district court’s order combining the preliminary injunction hearing with the trial, the district court proceeded with the case. The First Circuit dismissed the appeal, holding that the Court had no jurisdiction over the underlying decision to consolidate the motion for preliminary injunction with trial. Therefore, the Court also lacked jurisdiction over the district court’s denials of Plaintiff’s motions to reconsider its order. View "Nwaubani v. Grossman" on Justia Law

After a jury trial, Appellant was convicted of transportation, receipt, and possession of child pornography. The First Circuit affirmed on appeal. Appellant later filed a petition for a writ of habeas corpus under 28 U.S.C. 2255 claiming that the jury selection process for his trial violated his Fifth Amendment right to be present and his Sixth Amendment right to a public trial. Appellant did not raise either the Fifth Amendment or the Sixth Amendment claim at trial or on direct appeal. The district court denied habeas relief. The First Circuit affirmed, holding that Appellant could not overcome his procedural default from not pursuing either his Fifth Amendment or Sixth Amendment claim at trial or on appeal. View "Wilder v. United States" on Justia Law

Appellants, Boston police officers, made a warrantless entry into a dwelling in the Brighton neighborhood of Boston, Massachusetts. Plaintiff, the only person inside, was eventually arrested. Plaintiff was eventually acquitted on criminal charges resulting from his arrest. Thereafter, Plaintiff sued Appellants, alleging that the search of his residence was unreasonable and that the officers violated his civil rights through the use of excessive force. The jury found for Plaintiff on both of his claims and awarded him $50,000 in damages. The district court subsequently awarded Plaintiff attorneys’ fees and costs. The First Circuit affirmed, holding (1) Appellants' actions did not fall within the community caretaking exception, and therefore, qualified immunity was inapplicable; and (2) the attorneys’ fee award fell within the universe of reasonable awards. View "Matalon v. Hynnes" on Justia Law

After a second trial, Defendant was convicted of conspiracy to possess with intent to distribute five kilograms or more of cocaine and possession with intent to distribute five kilograms or more of cocaine. Defendant was sentenced to 196 months of incarceration. The First Circuit affirmed Defendant’s conviction and sentence, holding (1) it was not plain error for the district court to admit an unexecuted draft contract into evidence; (2) the district judge did not err by commenting on the draft contract; (3) there was no violation of the Jones Act, and Defendant suffered no prejudice in the admission of English testimony peppered with Spanish colloquialisms; (4) the prosecutor’s closing and rebuttal arguments did not constitute prosecutorial misconduct; and (5) Defendant’s sentence was neither procedurally nor substantively unreasonable. View "United States v. Carela" on Justia Law

Massachusetts state police confiscated firearms owned by Russell Jarvis and James Jarvis, Massachusetts gun owners, and transferred custody of the confiscated firearms to Village Gun Shop, Inc. (the Gun Shop), which operates a bonded warehouse for the storage of firearms and ammunition. Massachusetts local police confiscated firearms owned by Robert Crampton, a Massachusetts gun owner, and transferred the guns to the Gun Shop for storage. When Crampton and the Jarvises failed to pay storage charges, the Gun Shop sold their firearms at public auction. The Jarvises, Crampton, and Commonwealth Second Amendment, Inc. brought suit in federal district court against the Gun Shop alleging that their Fourteenth Amendment right to due process had been violated. Plaintiffs moved for partial summary judgment against the Gun Shop, arguing that the Gun Shop was a state actor that could be held liable for damages under section 1983. The district court granted summary judgment on the state action issue to the Gun Shop. The court subsequently entered final judgment in favor of the Gun Shop. The First Circuit affirmed, holding that the Gun Shop may not be liable as a state actor under section 1983. View "Jarvis v. Village Gun Shop, Inc." on Justia Law

Defendant’s vehicle was stopped and searched by officers with the Maine Drug Enforcement Agency, the Maine Police, and the Portland Police Department. The search involved the use of a drug-sniffing dog and resulted in the discovery of cocaine and a firearm. Defendant pleaded guilty to one count of possession with intent to distribute 500 grams or more of cocaine and one count of possession of a firearm in furtherance of a drug trafficking crime. Defendant appealed, challenging the district court’s denial of his motion to suppress and the court’s denial of his motion for discovery of records. The First Circuit affirmed, holding that the district court did not err in finding that the warrantless search and seizure of Defendant’s vehicle were justified by the automobile exception. View "United States v. White" on Justia Law

Petitioner, who was serving a 235-month sentence as an armed career criminal under the Armed Career Criminal Act (ACCA), sought certification to file in the district court a second or successive motion to vacate his sentence pursuant to 28 U.S.C. 225. In his application, Petitioner relied upon the United States Supreme Court’s decision in Johnson v. United States, which struck down the “residual clause” of the ACCA as unconstitutionally vague. The First Circuit granted the application, allowing Petitioner to file his petition with the district court, and certified that Petitioner had made the requisite prima facie showing that the new constitutional rule announced in Johnson qualified as a basis for habeas relief on a second or successive petition. View "Pakala v. United States" on Justia Law