Justia Constitutional Law Opinion Summaries

In 2014, four residents of the City of Cranston, Rhode Island, and the American Civil Liberties Union of Rhode Island filed a complaint against the City under 42 U.S.C. 1983 for declaratory and injunctive relief, alleging that Cranston’s 2012 Redistricting Plan violated the Equal Protection Clause. The district court entered an injunction prohibiting Cranston from holding elections, concluding that the inclusion in the Redistricting Plan of 3,433 inmates of the Adult Correctional Institutions (ACI) in the population count of Cranston’s Ward Six diluted the votes of voters in the City’s other five wards. The First Circuit reversed and instructed the district court to enter summary judgment in favor of Cranston, holding that the United States Constitution does not require Cranston to exclude the ACI inmates from its apportionment process and gives no power to the federal courts to interfere with Cranston’s decision to include them. View "Davidson v. City of Cranston, R.I." on Justia Law

Plaintiff filed a complaint against Defendants - both FBI special agents - alleging that Defendants violated his Fourth Amendment right to be protected against seizure but upon probable cause. Defendants moved to dismiss the case on the grounds of qualified immunity. The district court denied Defendants' motion. The First Circuit affirmed and remanded the case to the district court. After a trial, the district court granted Defendants’ motion for judgment as a matter of law and dismissed the case. The First Circuit affirmed, holding (1) the record was insufficient to permit a jury to find for Plaintiff; and (2) there was no other prejudicial error in the district court’s decision. View "Hernandez-Cuevas v. Taylor" on Justia Law

After a jury trial in the Commonwealth of Massachusetts, Petitioner was convicted of first-degree murder, armed home invasion, and unlawful possession of a firearm. The Supreme Judicial Court (SJC) reversed Petitioner’s conviction for armed home invasion and upheld the remaining conditions. Thereafter, Petitioner sought federal habeas corpus relief in a federal court, asserting three claims. The district court denied the petition. The First Circuit affirmed, holding (1) Defendant’s trial counsel did not provide constitutionally deficient representation; (2) Petitioner’s waiver of his right to testify was not invalid based on erroneous legal advice or Petitioner’s misunderstanding of counsel’s advice; and (3) the SJC did not act contrary to clearly established federal law when it imposed on Petitioner the obligation to show that his waiver was invalid. View "Smith v. Dickhaut" on Justia Law

After a jury trial, Defendant was convicted of possessing drugs with intent to distribute and possessing a firearm in furtherance of a drug trafficking crime. Defendant appealed his conviction and sentence, asserting that judicial misconduct, inadequate preparation time, and ineffective assistance of counsel denied him a fair proceeding. The First Circuit affirmed Defendant’s conviction but remanded the action for further proceedings, holding (1) the trial judge’s conduct of the trial did not prejudice Defendant; (2) the district court did not abuse its discretion in denying Defendant’s motion to continue the trial date; and (3) there were sufficient signs of attorney ineffectiveness to remand for an evidentiary hearing. View "United States v. Marquez-Perez" on Justia Law

In an effort to raise more tax revenue, the Puerto Rico legislature amended the corporate alternative minimum tax (AMT) in 2015. Wal-Mart Puerto Rico, Inc., the largest private employer in Puerto Rico, brought this action seeking an injunction against the continued enforcement of the AMT against it and a declaration that the AMT was unlawful. The district court permanently enjoined and declared invalid the enforcement of the AMT, concluding that the AMT violates the dormant Commerce Clause, the Federal Relations Act, and the Equal Protection Clause. The First Circuit affirmed, holding (1) the federal district court had jurisdiction over the suit; and (2) the AMT is a facially discriminatory law that does not survive the heightened level of scrutiny under the dormant Commerce Clause. View "Wal-Mart Puerto Rico, Inc. v. Zaragoza-Gomez" on Justia Law

Plaintiffs filed a class action suit on behalf of approximately 1.5 million Puerto Rican residents who are customers of Autoridad de Energia Electrica de Puerto Rico (PREPA), alleging that PREPA used a portion of its overall revenue to subsidize municipalities’ energy use. Plaintiffs claimed violations of the Takings Clause and their procedural due process rights because PREPA deprived them of their property interest in electricity and/or the funds they paid for electricity. The district court granted summary judgment for PREPA,concluding that Plaintiffs had not identified a valid property interest, that no taking had occurred, and that no valid procedural due process claim existed. The First Circuit affirmed on other grounds, holding that because Plaintiffs did not identify a valid property interest, they did not have standing to bring the takings and due process claims. View "Santiago-Ramos v. Autoridad de Energia Electrica de P.R." on Justia Law

Defendant entered a conditional guilty plea to conspiracy to distribute and possess with intent to distribute twenty-eight grams or more of cocaine base and possession of a firearm in furtherance of a drug trafficking crime. Defendant appealed, arguing that the district court erred in denying his motion to suppress evidence obtained by law enforcement officers while executing a warrant for his arrest. The First Circuit agreed with Defendant and reversed the denial of his motion to suppress, holding that the officers had insufficient grounds to justify entering Defendant’s girlfriend’s apartment without consent to execute the arrest warrant. Remanded. View "United States v. Young" on Justia Law

After a jury trial, Defendant was convicted of one count of possession of cocaine with intent to distribute. The district court sentenced Defendant to a term of imprisonment of forty-one months. The First Circuit affirmed, holding (1) the district court did not err in denying Defendant’s pre-trial motion to suppress evidence obtained upon the seizure of the car Defendant was driving; (2) the district court did not abuse its discretion in permitting the prosecution to use in its rebuttal a piece of evidence that the government delayed in disclosing, and the government did not act in bad faith in disclosing the evidence when it did; (3) the prosecutor did not commit plain error by questioning Defendant about facts not in evidence; and (4) Defendant’s challenges to his sentence were without merit. View "United States v. Mercer" on Justia Law

After a joint jury trial, Alexis Candelario-Santana (Candelario) and David Oquendo-Rivas (Oquendo) (together, Defendants) were found guilty of numerous crimes stemming from a drug-related mass shooting carried out in furtherance of a Racketeer Influenced and Corrupt Organizations Act. Both defendants received life sentences. The First Circuit affirmed Oquendo’s convictions but vacated and remanded as to Candelario, holding (1) the district court’s closure of the courtroom to facilitate a reluctant witness’s testimony constituted a constitutionally impermissible closure, effecting structural error; (2) there was no prejudicial error related to Oquendo’s case; and (3) the evidence was sufficient to support Oquendo’s convictions. View "United States v. Candelario-Santana" on Justia Law

When Plaintiff observed that a company named 110, Inc. was operating a substance abuse treatment facility next door to his residence, he argued that the Town of Wenham’s unilateral, non-public approval of 110, Inc.’s use was unlawful. Plaintiff filed a complaint in state court, alleging four causes of action. The Town removed the case to federal court. The district court subsequently granted the Town’s motion to dismiss some of Plaintiff’s claims. The court concluded that the complaint failed to state a claim under 42 U.S.C. 1983 for the deprivation of property without due process and that Plaintiff’s declaratory judgment claim had been rendered moot. The First Circuit (1) affirmed the dismissal of Plaintiff’s federal claim, holding that Plaintiff was not deprived of any constitutionally protected property interest without due process of law; (2) vacated the district court’s determination that one state law claim was moot; and (3) otherwise affirmed the remand of the remaining state law claim to state court. View "Miller v. Town of Wenham, Mass." on Justia Law