Justia Constitutional Law Opinion Summaries

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

In 2013, Plaintiff, a participant in the Section 8 Federal Housing Choice Voucher Program, listed among her assets a trust that had been established in 2010 to hold Plaintiff's proceeds from a series of tort settlements. The Brookline Housing Authority (BHA) subsequently determined that Plaintiff was “over-income” for continued participation in the Program, as locally administered by the BHA. Plaintiff appealed, requesting that the BHA exclude at least some of these trust disbursements from its income calculation in reasonable accommodation of her disability. The BHA reaffirmed its determination. Thereafter, Plaintiff sued, alleging that the BHA had violated state and federal law by incorrectly calculating her income under the relevant federal regulations and by engaging in disability-based discrimination. The district court ruled in favor of BHA. The First Circuit (1) reversed the district court’s ruling on Plaintiff’s 42 U.S.C. 1983 claim brought under the Housing Act, holding that the BHA misconstrued federal regulations in calculating Plaintiff’s income; (2) vacated the district court’s ruling on Plaintiff’s state and federal discrimination claims and remanded with instructions to dismiss those claims as moot; and (3) affirmed the district court’s denial of Plaintiff’s remaining claims. Remanded. View "DeCambre v. Brookline Housing Auth." on Justia Law

Officers sought to execute a warrant for Bey's arrest, stemming from a domestic violence dispute involving a firearm. They determined that Bey was likely at the Summons home. Bey was barred from that residence by an abuse prevention order. Five officers arrived at Summons's apartment, Summons answered her door, repeated aloud, "Is Paul Bey here?" and stated that she was not sure. Summons then put her finger to her lips in a hushing gesture and backed into the apartment while opening the door. The officers entered and found Bey in a bedroom. Concerned for his own safety, Officer Stallbaum moved a backpack away from Bey's reach and noticed its weight. Bey stated the bag belonged to Summons. After Bey's removal, Officer McCabe asked Summons about her four-year-old son and mentioned contacting the Massachusetts Department of Children and Families. McCabe did not mention removing the child. Stallbaum returned to the apartment and asked Summons to sign a consent-to-search form, stating that she was free to withhold consent. Summons signed. She stated that the backpack was hers, but that she was lending it to Bey. A search of the backpack yielded a loaded semi-automatic pistol and ammunition, 15.31 grams of marijuana, 22.5 15-milligram oxycodone pills, and an electronic scale with cocaine and marijuana residue. Bey was charged with drug and firearm offenses. Bey pleaded guilty and was sentenced to 60 months’ imprisonment. The First Circuit affirmed denial of a motion to suppress and rejected a challenge to the sentence as waived. Summons's decisions to admit the officers and to allow a search of the backpack were knowing and intelligent. View "United States v. Bey" on Justia Law

In 2005, Puerto Rico Police Agent Lizardi was undercover, investigating Casey. Lizardi went missing on the day of a scheduled drug buy. Casey was arrested, signed a Miranda waiver, and at some point, told officers he was no longer interested in talking. While Casey was in custody, Casey's grandparents, with whom he lived, permitted officers to search his bedroom without a warrant. The FBI discovered a loaded firearm, Lizardi's cell phone, and a pair of blood-stained flip flops. Confronted with this evidence, Casey requested an attorney. His common-law wife visited him in custody. Casey's statements to her during their exchange were overheard by officers. Lizardi's body was found. Casey was charged with carjacking with the intent to cause death or serious bodily injury (18 U.S.C. 2119(3)); possession, use, discharge, carrying of firearms during a crime of violence resulting in another's death (18 U.S.C. 924(j)); and being a felon in possession of a firearm (21 U.S.C. 922(g)(1)). Pretrial proceedings took six years and included unsuccessful motions to suppress evidence from the bedroom search, a photo array identification that connected him to the crime, statements elicited from him allegedly in violation of his Miranda rights, words exchanged with his wife while in custody, and photos of Lizardi's decomposing body. The FIrst Circuit affirmed Casey’s convictions and the sentence of life in prison, rejecting challenges concerning voir dire, the motions to suppress, and the judge’s refusal to recuse himself. View "United States v. Casey" on Justia Law

In 1997, Jaynes befriended 10-year-old Jeffrey in his Massachusetts neighborhood. Jaynes took Jeffrey for rides in Jaynes's Cadillac without his parents' knowledge. On October 1, Jaynes and Sicari picked Jeffrey up in the Cadillac, bought gasoline, duct tape, a large plastic container, lime, and concrete, and traveled to a New Hampshire apartment that Jaynes rented. The next morning, the Cadillac was seen parked at the Great Works River Bridge in Maine. Jaynes was arrested; an inventory search of the Cadillac yielded a driver's license with a picture of Jaynes under a different name and a Manchester address; duct tape; and receipts for a plastic container, lime, and concrete. Following Sicari’s confession, implicating Jaynes, police conducted a warranted search of Jaynes's New Hampshire apartment and found lime, the plastic container's label, and Jeffrey's jersey smelling of gasoline. Jeffrey's body was discovered in the Great Works River, inside a plastic container sealed with duct tape. An autopsy revealed that a gasoline-soaked rag had been held over his nose and mouth. Jaynes was convicted of kidnapping and second-degree murder. State appeals courts rejected his claims that the Commonwealth was required to prove that harm preceding death (not the separately charged abduction) occurred in Massachusetts, and concerning brief closing of the courtroom to the public, although not to Jaynes or his counsel. On unsuccessful appeal from denial of a second motion for a new trial, Jaynes argued that inflammatory evidence of his sexual preferences was improperly admitted, evidence from the searches should have been excluded, and ineffective assistance. The First Circuit affirmed denial of his federal habeas petition, holding that no state court determination was either contrary to nor an unreasonable application of clearly established federal law. View "Jaynes v. Mitchell" on Justia Law

Jenkins was convicted in Massachusetts state court in 2005 of the first-degree murder of his cousin and was sentenced to life in prison. He did not testify. The state trial court denied Jenkins's motion for a new trial, and the Supreme Judicial Court (SJC) affirmed. The federal district court denied his habeas petition and granted a certificate of appealability only on the issue of Jenkins's waiver of his right to testify in his own defense. Jenkins argued that his attorney unilaterally decided that he would not testify. The First Circuit affirmed the denial, engaging in deferential review under the Antiterrorism and Effective Death Penalty Act of 1996, 28 U.S.C. 2254(d) because the SJC adjudicated Jenkins's claim on the merits . Because there is no Supreme Court precedent clearly establishing the proper standard and burdens for assessing whether a criminal defendant has validly waived his right to testify on facts like these, Jenkins is not entitled to habeas relief. His claim depends on too broad a characterization of waiver of federal constitutional rights, not drawn from cases of like circumstances. View "Jenkins v. Bergeron" on Justia Law

Defendant pleaded guilty to being a felon in possession of a firearm and ammunition. The district court sentenced Defendant to a term of imprisonment of sixty months. Defendant appealed, arguing that the district court erred in denying his motion to suppress the firearm and ammunition and erred in classifying his prior convictions and convictions of a crime of violence for purposes of calculating his base offense level under the United States Sentencing Guidelines. The First Circuit affirmed the district court’s denial of Defendant’s motion to suppress but vacated the remanded for resentencing proceedings, holding (1) there was no unlawful seizure at the time that Defendant contended one occurred, and therefore, the district court did not err in denying Defendant’s motion to suppress; and (2) the district court’s application of the sentencing enhancement set forth in U.S.S.G. 2K2.1(a)(2) was erroneous. View "United States v. Fields" on Justia Law

Michael McLaughlin, James Fitzpatrick, and Bernard Morosco, all of whom worked for a public agency responsible for providing low-income housing, were indicted for knowingly and unlawfully conspiring to defraud the United States and its agency, the Department of Housing and Urban Development. McLaughlin pleaded guilty. After a jury trial, Fitzpatrick and Morosco were found guilty as charged. Fitzpatrick and Morosco appealed, raising a number of arguments. The First Circuit affirmed Fitzpatrick’s conviction and sentence, denied as moot Fitzpatrick’s earlier-filed motion asking the Court to stay his sentence pending appeal, and affirmed Morosco’s conviction, holding that Defendants were not entitled to relief on any of their arguments. View "United States v. Morosco" on Justia Law

Plaintiffs were property owners who privately leased units in Worcester, Massachusetts to students from the College of the Holy Cross. Plaintiffs brought suit alleging that the City of Worcester engaged in a scheme, through its zoning and code enforcement officials and entities, to selectively enforce the Worcester Zoning Ordinance and state Lodging House Act in order to pressure Holy Cross to make voluntary payments in lieu of property taxes to Worcester. The district court granted the City’s motion to dismiss for failure to state a claim. The First Circuit affirmed, holding that the district court properly dismissed Plaintiffs’ claims for the reasons stated in the district court’s opinion. View "College Hill Props., LLC v. City of Worcester" on Justia Law

Plaintiffs purchased a piece of land with plans to develop the property. In response to the opposition Defendants’ mounted to Plaintiffs’ plan, Plaintiffs filed suit, alleging violations of their constitutional rights pursuant to 42 U.S.C. 1983 and state law rights. Plaintiffs also alleged First Amendment retaliation claims, a Fourteenth Amendment equal protection claim, and a Fourteenth Amendment substantive due process claim, all with corresponding state-law claims. The district court granted judgment in favor of Defendants due to Plaintiffs’ failure to state any viable claims. The First Circuit affirmed, holding that the allegations put forth by Plaintiffs were insufficient to survive the pleading stage. View "Najas Realty, LLC v. Seekonk Water Dist." on Justia Law