Justia Constitutional Law Opinion Summaries

Eurie Stamps, Sr., an innocent, elderly, African-American man, was shot by Paul Duncan, a local police officer, during a SWAT team raid executing a search warrant for drugs and drug-related paraphernalia belonging to two drug dealers thought to reside in Stamps’s home. The co-administrators of Stamps’s estate sued the Town of Framingham and Duncan, arguing that Duncan violated Stamps’s constitutional right against unreasonable seizure when he pointed a loaded semi-automatic rifle at Stamps’s head, with the safety off and a finger on the trigger, even though Stamps was compliant and posed no known threat to the officers. Duncan filed a motion for summary judgment, arguing that he was entitled to qualified immunity because the shooting was an accident and not a violation of clearly established law. The district court denied the motion, ruling that a reasonable jury could find that Duncan had violated Stamps’s Fourth Amendment rights and that the law was sufficiently clearly established to put Duncan on notice that his actions were not constitutionally permissible. The First Circuit affirmed, holding that Duncan, in the situation at issue, was on notice that his actions could be violative of Stamps’s Fourth Amendment right to be free from excessive force. View "Stamps v. Town of Framingham" on Justia Law

In 2012, Plaintiffs brought this action arguing that they were unlawfully removed from the Commonwealth’s active voter registry for having failed to vote in the 2008 election for Resident Commissioner. On interlocutory appeal, the First Circuit held that the Help America Vote Act (HAVA) bars Puerto Rico from removing voters from the registry for the office of Resident Commissioners unless they fail to participate in the preceding two general federal elections. On remand, the district court found in favor of Plaintiffs and issued injunctive and declaratory relief from removing otherwise eligible voters from the active election registry unless HAVA's requirements are met. The First Circuit affirmed, holding (1) the National Voter Registration Act does not apply to Puerto Rico and thus does not supersede the Commonwealth’s voter deactivation procedures; (2) HAVA invalidates the deactivation procedures of Article 6.021 of Puerto Rico Act No. 2011 insofar as it applies to voter eligibility for federal elections; and (3) Plaintiffs may bring a private cause of action seeking relief under HAVA pursuant to 42 U.S.C. 1983. View "Colon-Marrero v. Garcia-Velez" on Justia Law

After Plaintiff was terminated from her employment with Puerto Rico’s Vocational Rehabilitation Administration, she filed a federal-court suit alleging that Defendants discriminated against her because of her disability, age, and politics. Plaintiff’s complaint alleged various violations of federal and local law. The district court dismissed Plaintiff’s 42 U.S.C. 1983 claim for failure to exhaust administrative remedies and then dismissed the remaining claims without explanation. The First Circuit affirmed the district court’s judgment in every respect, except that the Court reversed the dismissal of Plaintiff’s Americans with Disabilities Act (ADA) claim, holding (1) the district judge erred in concluding that Plaintiff’s section 1983 claim was barred for failure to exhaust administrative remedies, but Plaintiff’s section 1983 was time-barred; (2) because Defendants agreed that Plaintiff’s ADA claim should not have been dismissed on failure-to-exhaust grounds, the reversal is dismissed; (3) Plaintiff’s age discrimination claim was correctly dismissed for failure to exhaust; and (4) because the dismissal of the ADA claim is reversed, the judge on remand must reinstate the local-law claims as well. View "Martinez-Rivera v. Commonwealth of P.R." on Justia Law

Plaintiff sued the City of Waltham, Massachusetts and several of its officials alleging that Defendants conspired to deprive Plaintiff of his federal constitutional rights and alleging various violations of Massachusetts state law. Defendants moved for summary judgment on each of Plaintiff’s claims. The district court rejected the immunity defenses of two municipal officials in ruling on this motion. On interlocutory appeal, the First Circuit ruled that the two individual defendants were immune to suit under 42 U.S.C. 1983 because Plaintiff’s Equal Protection claim - the only preserved federal claim in the case - failed. After the Court’s decision, the district court granted Defendants’ motion for summary judgment on the remaining claims. The First Circuit affirmed the district court’s dismissal of Plaintiff’s remaining claims and the court’s denial of Plaintiff’s motion for leave to amend, holding that Plaintiff’s arguments were unavailing. View "Snyder v. Collura" on Justia Law

Plaintiff filed this action alleging that she was stripped of various job duties and eventually terminated from her job at the Puerto Rico Highway and Transportation Authority due to her affiliation with the Popular Democratic Party. The district court granted summary judgment in favor of Defendants on Plaintiff’s First Amendment political discrimination claims, concluding that there was insufficient evidence that the stripping of Plaintiff’s job functions constituted adverse employment actions, and absent any political discrimination, Plaintiff would have in any event been terminated for nondiscriminatory reasons. The First Circuit reversed, holding (1) Plaintiff made out a prima facie case of political discrimination; and (2) a genuine dispute existed as to whether Defendants would have fired Plaintiff regardless of her political affiliation. Remanded. View "Reyes-Orta v. P. R. Highway and Transp. Auth." on Justia Law

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