Justia Constitutional Law Opinion Summaries

Petitioner pleaded guilty to two counts of carjacking resulting in death. The jury sentenced Petitioner to death under the Federal Death Penalty Act (FDPA). Due to jury taint, Petitioner’s sentence was vacated and his case remanded for further proceedings. The government subsequently filed an amended notice of intent to seek the death penalty, as required by the FDPA. The amended notice listed the factors that the government believed justified the death penalty, largely tracking the original notice. Petitioner filed a motion in limine to dismiss or strike two non-statutory aggravating factors the prosecutor intended to present in a second penalty-phase proceeding under the FDPA. The district court denied the motion. Petitioner appealed, arguing that because the jury in his first penalty-phase proceeding did not find unanimously that the government proved these two aggravating factors beyond a reasonable doubt, their introduction at the new penalty-phase proceeding was barred by double jeopardy principles. The First Circuit affirmed, holding that the Double Jeopardy Clause did not bar the government from alleging those non-statutory aggravating factors again at Petitioner’s new penalty-phase proceeding. View "Sampson v. United States" on Justia Law

At issue in this case was whether one of the Commonwealth of Puerto Rico’s special-purpose public corporations, the Puerto Rico Ports Authority (PRPA), is an arm of the Commonwealth that enjoys sovereign immunity under the Eleventh Amendment. Daniel Grajales and his family alleged that PRPA subjected Daniel to political discrimination and unlawfully terminated his employment for reasons related to political discrimination and retaliation. After many procedural “twists and turns,” the district court granted PRPA’s motion to dismiss, concluding that PRPA was an arm of the Commonwealth and thus immune from suit under Eleventh Amendment immunity principles. The First Circuit reversed, holding that PRPA was not entitled to claim the Commonwealth’s immunity as an arm of the Commonwealth. Remanded. View "Grajales v. P.R. Ports Auth." on Justia Law

Plaintiff, a Puerto Rico Police Department law enforcement officer, filed a complaint alleging that Defendants, his superior officers, violated the Establishment Clause by holding a group prayer while on duty and punishing Plaintiff for his non-conformance. Defendants moved to dismiss the complaint on the grounds that the complaint failed to allege plausibly a constitutional violation, and invoking qualified immunity. The district court denied the motion on both grounds. Appellants filed this interlocutory appeal to challenge the court’s denial of qualified immunity. The First Circuit affirmed, holding that the district court did not err in rejecting Defendants’ qualified immunity defense. View "Marrero-Mendez v. Calixto-Rodriguez" on Justia Law

Defendant pleaded guilty to possessing child pornography. The district court sentenced Defendant to 135 months in prison. At a second change-of-plea hearing, Defendant acknowledged that the indictment charged “pornography involving prepubescent minors.” Defendants was sentenced to fifteen years of supervised release. Defendant appealed, arguing, inter alia, that the district court violated the Double Jeopardy Clause by permitting the prosecution to continue via a second change-of-plea hearing because his “first plea was to possession of child pornography and not to possession of prepubescent child pornography.” The First Circuit affirmed Defendant’s conviction and prison sentence but vacated one of the conditions of Defendant’s supervised release, holding (1) the Double Jeopardy Clause did not bar the government from “continuing its prosecution” of Defendant on the greater offense, even assuming that Defendant’s initial plea was to a lesser-included offense; (2) the district court did not commit clear or obvious error in “vacat[ing]” Defendant’s first plea and accepting the second after the presentence report had issued; (3) Defendant’s ineffective assistance of counsel claim is not reviewable on direct appeal; (4) the prosecutor did not breach the plea agreement at the sentencing hearing; and (5) the district court did not err in sentencing Defendant. View "United States v. Gall" on Justia Law

Defendant pleaded guilty to a federal indictment charging him with possession of a firearm and ammunition by an unlawful user of a controlled substance and possession of a machine-gun. Before sentencing, the probation department prepared a presentence investigation report (the PSI report) that contained information about Defendant’s participation in a musical group that recorded songs that promote violence and drugs. Defendant objected to the PSI report on the ground that consideration of his performances with the musical group would violate his First Amendment rights. The sentencing court ruled that it could consider Defendant’s musical pursuits in deciding the sentence and then sentenced Defendant to a ninety-six-month term of immurement, which was more than three times the top of the Guidelines Sentencing Range. The First Circuit vacated Defendant’s sentence and remanded for resentencing, holding that the sentencing court’s sentencing rationale was implausible because the court heavily relied on protected conduct that was not tied through extrinsic evidence to any relevant sentencing factor. View "United States v. Alvarez-Nunez" on Justia Law

Defendant was convicted under a Massachusetts statute of possessing child pornography as a repeat offender. The Massachusetts Appeals Court (MAC) affirmed. Defendant later filed a petition for federal habeas relief under 28 U.S.C. 2254. The district court denied the petition. The First Circuit affirmed, holding (1) Defendant’s claim that possession falls within the protection of the First Amendment when the photograph depicts a merely nude minor but is not an expression of lewdness was unavailing; (2) the MAC did not act contrary to or unreasonably apply clear law as declared by the Supreme Court or apply it to facts and factual inferences not reasonably supported by the evidence; and (3) the certificate of appealability the district court granted Defendant did not extend to a claim that the evidence was inadequate to support a finding beyond a reasonable doubt of every element of the offense. View "Sullivan v. Marchilli" on Justia Law

Appellant was convicted of aiding and abetting an armed robbery affecting interstate commerce in violation of the Hobbs Act, using a firearm in connection with the robbery, and being a felon in possession of a firearm. The First Circuit affirmed on appeal. Thereafter, Appellant filed a petition for postconviction relief under 28 U.S.C. 2255, alleging that his counsel provided ineffective assistance. Appellant argued, inter alia, that counsel was ineffective for failing to move for acquittal on the Hobbs Act charge based on the insufficiency of the evidence to support the conviction. The district court denied the motion. The First Circuit granted a certificate of appealability only on the issue of counsel’s failure to move for acquittal on the Hobbs Act charge. The First Circuit affirmed, holding that, even assuming that counsel’s failure to move for acquittal on the Hobbs Act charge was deficient performance under Strickland v. Washington, Appellant failed to establish that he was prejudiced thereby. View "Rivera-Rivera v. United States" on Justia Law

In 2007, Plaintiff was diagnosed with an eye disease. In 2010, Plaintiff’s contract with her employer expired and was not renewed. Plaintiff filed discrimination and retaliation claims against Defendants. The district court awarded summary judgment to Defendants, concluding (1) Plaintiff was not an Americans with Disabilities Act “qualified individual”; (2) Defendants’ denial of Plaintiff’s request for reasonable accommodations did not constitute discharge; and (3) Defendants’ decision not to rehire Plaintiff was for a non-discriminatory reason. The First Circuit affirmed, holding that Defendants acted for a legitimate, non-discriminatory reason, and therefore, Plaintiffs’ claims against Defendants failed. View "Velez-Ramirez v. Commonwealth of P.R." on Justia Law

Defendant entered a conditional guilty plea to two counts of sexual exploitation of children. Defendant appealed, arguing that the district court erred in determining that he was not entitled to raise a “mistake of age” defense and in denying his motion to suppress evidence found in connection with a search of his motel room. The First Circuit affirmed, holding (1) 18 U.S.C. 2251(a) plainly does not require that a person convicted of violating the statute needs to know the actual age of the minor victim, the limited scienter requirements of section 2251(a) do not violate the over breadth doctrine, and the mandatory minimum sentence of fifteen years for violation of the statute is not grossly disproportionate; and (2) the district court did not err in denying Defendant’s motion to suppress. View "United States v. Henry" on Justia Law

It is a violation of Massachusetts state law for a handgun-purveyor to transfer to customers any handgun “which does not contain a load indicator or magazine safety disconnect.” When the Attorney General (AG) informed firearms dealers and consumers that Glock, Inc.’s third and fourth generations pistols lacked an adequate load indicator, some dealers and consumers, joined by two advocacy groups, challenged the constitutionality of the load indicator requirement of the Massachusetts regulation. The district court granted the AG’s motion to dismiss, concluding that the dealers and consumers failed to state a claim for relief and that the two advocacy groups lacked standing. The First Circuit affirmed, holding (1) the load indicator requirement was not unconstitutionally vague, and dismissal of the due process claim required dismissal of the consumers’ Second Amendment claim; and (2) the advocacy groups lacked standing to sue. View "Draper v. Healey" on Justia Law