Justia Constitutional Law Opinion Summaries

Robert Miller died at his home in Cape Cod in 2019 following an encounter with Barnstable police officers Sean Roycroft and Spencer Jackson. The officers responded to a 911 call from Miller’s girlfriend, who requested a psychiatric evaluation but did not report any crime. Upon arrival, a struggle ensued as the officers attempted to handcuff Miller, who ended up face-down on the floor with Roycroft’s arm pinned beneath him. During the struggle, Jackson delivered two punches to Miller in an effort to facilitate handcuffing. Miller’s girlfriend witnessed one of the officers drive a knee into Miller’s back and heard Miller say, “I can’t breathe” and “Amy, help me.” After Miller was handcuffed, he became unresponsive and was later pronounced dead. The medical examiner attributed the death to cardiac dysrhythmia in the setting of excited delirium, while the plaintiff’s expert opined that Miller died from prone restraint cardiac arrest due to pressure on his back.The plaintiff, Miller’s son, brought a federal excessive force claim under 42 U.S.C. § 1983 against the officers in the United States District Court for the District of Massachusetts. After discovery, the officers moved for summary judgment on qualified immunity grounds. The district judge denied summary judgment, finding that there were genuine disputes of material fact regarding whether the officers used excessive force, particularly after Roycroft freed his arm and Miller was restrained. The judge concluded that clearly established law prohibited kneeling on a restrained person’s back and that a reasonable jury could find the officers’ conduct violated Miller’s constitutional rights.On appeal, the United States Court of Appeals for the First Circuit reversed the denial of qualified immunity for the officers’ conduct while Roycroft’s arm was pinned (Phase One), affirmed the denial for conduct after Miller was restrained and a knee was placed on his back (Phase Two), and dismissed the appeal in part for fact-based arguments not suitable for interlocutory review. The case was remanded for further proceedings. View "Miller v. Roycroft" on Justia Law

The defendant pleaded guilty in 2013 to possessing child pornography, after sharing videos of minors being sexually abused and attempting to arrange sex with a minor. He was sentenced to ten years in prison and 25 years of supervised release, with conditions restricting his access to internet-capable devices. After completing his prison term, he began supervised release in December 2019. His release was revoked three times for violations, including unauthorized internet access and failure to comply with monitoring requirements. The conditions at issue required him to use only devices with court-approved monitoring software and to contribute to the cost of monitoring based on his ability to pay.Following the first revocation, the United States District Court for the District of Puerto Rico imposed new, stricter internet monitoring conditions. After further violations, including possessing unauthorized devices and failing to report employment changes, the court again revoked his supervised release (the “Second Revocation”), sentencing him to time served and a renewed term of supervised release with the same conditions. The defendant objected, arguing that the court improperly relied on ex parte communications from his probation officer and that the internet monitoring conditions were unconstitutional and unlawfully delegated judicial authority to the Probation Office.The United States Court of Appeals for the First Circuit reviewed the appeal. The court held that, although the district court erred by relying on new, significant facts from ex parte communications regarding the defendant’s employment, the error was harmless because other uncontested violations supported the revocation and sentence. The court also held that the challenged internet monitoring conditions were not facially unconstitutional or an unlawful delegation of judicial authority. The court found the defendant’s as-applied constitutional challenges unripe, as they depended on future enforcement. The judgment and sentence from the Second Revocation were affirmed. View "United States v. Negron-Cruz" on Justia Law

A police officer with the Cambridge Police Department, who had served in both patrol and special investigations roles, posted a comment on his personal Facebook page criticizing the naming of a federal police reform bill after George Floyd. In his post, he referred to Floyd as a "career criminal, a thief and druggie," and expressed pessimism about the country's future. The post was made from home, visible only to his Facebook friends, but was quickly screenshotted and shared with community members, including the local NAACP. The police commissioner was alerted, and the department initiated an internal investigation. The officer was placed on administrative leave and, after the investigation concluded that his post violated department policies on courtesy and professionalism, he was suspended without pay for four days.The officer filed suit in the United States District Court for the District of Massachusetts, alleging that his suspension was unconstitutional retaliation for exercising his First Amendment rights. Both parties moved for summary judgment. The district court granted summary judgment in favor of the department, finding that the department’s interest in maintaining public trust and effective service outweighed the officer’s and the public’s interest in his speech, particularly given the context of heightened scrutiny and protest following George Floyd’s death.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s decision de novo. The First Circuit held that, while the officer’s speech addressed a matter of public concern, its mocking and disparaging nature diminished its First Amendment value. The court further held that the department’s prediction that the post could undermine public trust was reasonable, especially in the context of ongoing public unrest and the department’s need to maintain community confidence. The court found no evidence of impermissible viewpoint discrimination. The First Circuit affirmed the district court’s grant of summary judgment for the department. View "Hussey v. City of Cambridge" on Justia Law

A coastal town in Maine, known for its small population and proximity to a national park, experienced a significant increase in cruise ship tourism, with large vessels bringing thousands of passengers daily. In response to concerns about congestion, public safety, and the impact on local amenities, residents approved an ordinance capping the number of cruise ship passengers who could disembark in the town to 1,000 per day. The ordinance imposed fines for violations and was intended to address issues primarily at the waterfront and, to a lesser extent, in the downtown area.Several local businesses, a business association, and a pilots’ association challenged the ordinance in the United States District Court for the District of Maine. They argued that the ordinance was preempted by federal and state law, violated the Commerce Clause (including its dormant aspect), and infringed on due process rights. After a bench trial, the District Court largely ruled in favor of the town and an intervening resident, rejecting most claims but finding that the ordinance was preempted by federal regulations only to the extent it restricted crew members’ shore access. The court declined to enjoin the ordinance, noting the town’s intent to address this issue through further rulemaking.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s rejection of the state law preemption, federal preemption (except for the now-moot crew access issue), and due process claims. The First Circuit also affirmed the dismissal of discrimination-based Dormant Commerce Clause claims, finding no similarly situated in-state and out-of-state competitors. However, the court vacated and remanded the District Court’s dismissal of the Pike balancing Dormant Commerce Clause claim, instructing further analysis of whether the ordinance’s burdens on interstate commerce are clearly excessive in relation to its local benefits. The court dismissed as moot the appeals related to the crew access issue. View "Ass'n to Preserve and Protect Local Livelihoods v. Town of Bar Harbor" on Justia Law

While serving a ten-year sentence in Rhode Island Department of Corrections (RIDOC) custody, Jerry Cintron, who suffers from opioid use disorder, relapsed and overdosed on a fentanyl-laced pill. After the incident, RIDOC officials sanctioned him with a total of 450 days in solitary confinement for various infractions related to the overdose and alleged trafficking. During this period, Cintron experienced severe mental and physical deterioration, including significant weight loss, self-injurious behavior, and psychiatric symptoms. He repeatedly informed RIDOC officials of his worsening condition and requested relief, but his pleas were denied or ignored, and his conditions remained unchanged.Cintron filed a lawsuit in the United States District Court for the District of Rhode Island under 42 U.S.C. § 1983, alleging violations of his Eighth Amendment rights due to deliberate indifference by RIDOC officials. The defendants moved for judgment on the pleadings, arguing that Cintron’s claims failed on the merits and that they were entitled to qualified immunity. The district court denied the motion as to the Eighth Amendment claim, allowing it to proceed against all defendants, and the defendants appealed.The United States Court of Appeals for the First Circuit reviewed the case and held that Cintron’s complaint plausibly alleged an Eighth Amendment violation by three RIDOC officials—Aceto, Corry, and Kettle—who were aware of his deterioration and had authority to intervene but failed to do so. The court found that, as of 2019, it was clearly established that prolonged social, sensory, and sleep deprivation in solitary confinement could constitute cruel and unusual punishment, and that officials could not respond with deliberate indifference. The court affirmed the district court’s denial of qualified immunity for these three officials, reversed as to the other defendants, and remanded for further proceedings on declaratory and injunctive relief. View "Cintron v. Bibeault" on Justia Law

Amber Lavigne filed a lawsuit against the Great Salt Bay Community School Board and various school staff members, alleging that they infringed on her constitutional right to parent by providing her child, A.B., with a chest binder and referring to A.B. by a different name and pronouns without informing her. Lavigne claimed that these actions were part of a school-wide policy of withholding such information from parents.The United States District Court for the District of Maine dismissed the claims against the individual defendants and later granted the Board's motion to dismiss, concluding that Lavigne had not plausibly alleged that the Board had a custom or policy of withholding information. The court found that Lavigne's allegations were based on conclusions unsupported by factual allegations and that the Board's statements did not constitute active approval of the individual defendants' actions.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that Lavigne had not plausibly alleged the existence of an unwritten policy or custom of withholding information from parents. The court noted that the Board's written policies encouraged parental involvement and that the statements made by the Board and school officials did not support the inference of an unwritten policy of withholding. The court also found that the Board's decision to renew the contract of the social worker involved did not amount to ratification of the alleged conduct. Thus, the appellate court concluded that Lavigne had failed to show that the Board was responsible for any constitutional violation. View "Lavigne v. Great Salt Bay Community School Board" on Justia Law

A graduate student and resident advisor (RA) at the University of Massachusetts, John Doe, was found responsible for sexual misconduct by the University in 2023. The University sanctioned him based on complaints from four female RAs about his interactions with them. Doe filed a federal lawsuit against the University, its trustees, and the members of the hearing panel, alleging that the University violated his First Amendment rights by punishing him for protected speech and expressive conduct. He sought a preliminary injunction, which the district court considered on a "case stated" basis, consolidating the preliminary injunction hearing with the trial on the merits.The district court ruled against Doe, finding that his First Amendment rights had not been violated. The court applied the Tinker standard, determining that the University's actions were justified because Doe's conduct caused or would cause a substantial disruption and invaded the rights of others. The court also held that the Individual Defendants were entitled to qualified immunity for monetary damages. Doe appealed the decision.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the record lacked evidence of substantial disruption to the academic environment or the complainants' jobs. The court also concluded that Doe's conduct did not constitute a pervasive pattern of unwelcome conduct. Therefore, the court held that the University's actions were not justified under the Tinker standard. However, the court affirmed the district court's ruling that the Individual Defendants were entitled to qualified immunity, as the law was not clearly established that their actions violated Doe's First Amendment rights. The judgment was reversed in part and affirmed in part. View "Doe v. University of Massachusetts" on Justia Law

Three appellants, Anthony Rivera-Rivera, Victor M. Hernández-Carrasquillo, and Jimmy Ríos-Alvarez, were convicted of armed carjacking and using a firearm in a crime of violence. They were part of a group that committed a violent home invasion targeting a family. During the invasion, the group assaulted the family members, causing serious injuries, and stole valuables. Two members of the group took the family's car to withdraw money from an ATM, while the appellants stayed behind to guard the family.The United States District Court for the District of Puerto Rico held a joint trial for the appellants. The jury found them guilty on both counts. The appellants filed motions for judgment of acquittal, which the court denied, concluding that the government had presented sufficient evidence for a rational factfinder to find each appellant guilty beyond a reasonable doubt. Rivera and Hernández also filed motions to dismiss the indictment due to delayed Brady disclosures, which the court denied. Additionally, Rivera and Hernández sought severance from Ríos to call him as a witness, but the court denied this motion as well.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the convictions, finding sufficient evidence to support the jury's verdicts. The court held that the appellants had knowledge of the carjacking and took affirmative acts to further the crime. The court also found no abuse of discretion in the district court's denial of the motions to dismiss the indictment and for severance. The court rejected Rivera's Confrontation Clause claims and upheld the sentences for Rivera and Hernández, finding them procedurally and substantively reasonable. View "United States v. Rivera-Rivera" on Justia Law

Between February 2014 and December 2015, United States Postal Inspection Service (USPIS) agents in Puerto Rico identified a pattern of suspicious packages being sent between Puerto Rico and New York. Upon inspection, these packages were found to contain cocaine and large sums of money concealed in household items. The investigation led to Miguel A. Reyes-Ballista (Reyes) and two co-conspirators. Reyes was indicted and, after a six-day trial, a jury convicted him of participating in two conspiracies to possess with intent to distribute cocaine and three counts of possession with intent to distribute cocaine.Reyes was sentenced to 170 months in prison with four years of supervised release. He appealed his convictions, arguing that the government provided insufficient evidence to support the jury's verdict. Reyes also sought a new trial, claiming ineffective assistance of counsel due to inadequate communication with his attorney and poor performance at trial, which he argued violated his Sixth Amendment right to counsel.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the evidence presented at trial, including testimony from co-conspirators, surveillance footage, and fingerprint evidence, was sufficient to support Reyes's convictions for conspiracy. The court noted that Reyes's arguments regarding the credibility of witnesses and the lack of direct evidence placing him inside the post office did not undermine the jury's verdict. The court also dismissed Reyes's Sixth Amendment claim as premature, indicating that such claims are typically better suited for collateral proceedings where a more developed record can be established.The First Circuit affirmed Reyes's convictions and dismissed his Sixth Amendment claim without prejudice, allowing him the opportunity to raise the issue in a future collateral proceeding. View "United States v. Reyes-Ballista" on Justia Law

In early 2025, the National Institutes of Health (NIH) and the Department of Health and Human Services (HHS) implemented a new policy prohibiting NIH from funding certain categories of scientific research grants. Two groups of plaintiffs, including private research organizations, individual researchers, and several states, sued, alleging that the new policy and the resulting grant terminations violated the Administrative Procedure Act (APA) and the U.S. Constitution. They argued that the policy was arbitrary and capricious, as the prohibited research categories were undefined and the rationale for discontinuing the research was circular.The United States District Court for the District of Massachusetts held a trial on the merits and ruled in favor of the plaintiffs, finding the agencies' actions to be "breathtakingly arbitrary and capricious." The court set aside the new policy and related grant terminations as illegal under the APA. The court found that the decisions were based on circular reasoning, lacked a rational connection to the facts, and ignored significant reliance interests. The government then moved for a stay of the district court's order pending appeal, which the district court denied.The United States Court of Appeals for the First Circuit reviewed the case. The court concluded that the district court had jurisdiction to review the agency action under the APA and to grant declaratory relief. The court found that the district court's orders did not enforce a contractual obligation to pay money but rather provided declaratory relief that set aside agency actions as arbitrary and capricious. The court also determined that the grant terminations were reviewable under the APA and that the Department had failed to show a likelihood of success on the merits. The court denied the Department's motion for a stay, concluding that the balance of equities and the public interest favored the plaintiffs. View "American Public Health Assn v. National Institutes of Health" on Justia Law