Justia Constitutional Law Opinion Summaries

Defendant was convicted of Hobbs Act extortion, tax fraud, and making false statements to obtain federal worker’s compensation. Defendant appealed, arguing that the district court erred in denying her motion to suppress incriminating statements she made during her interview with two sheriff’s deputies because the statements were obtained through a custodial interrogation without the benefit of a Miranda warning and that her confession was involuntary. The district court denied the motion to suppress. The First Circuit affirmed, holding (1) Defendant was not subjected to a custodial interrogation, and therefore, it was not necessary to provide her with Miranda warnings; and (2) Defendant’s statements were voluntary. View "United States v. Swan" on Justia Law

In 2002, Appellant entered a guilty plea, pursuant to a plea agreement, to four counts of conspiracy to commit, and aiding and abetting, insurance and mail fraud. In 2011, Appellant consulted an immigration attorney to apply for naturalization. The attorney informed Appellant that his guilty plea barred him from becoming a United States citizen and that he was subject to mandatory removal based on his conviction. Appellant brought a petition for a writ of coram nobis, arguing that his attorney provided ineffective assistance by erroneously advising him that a probation sentence from his guilty plea would not affect his immigration status and that the prosecutor provided a similar assurance during plea negotiations. The district court denied the petition, concluding (1) Appellant’s Sixth Amendment claim was barred because its success depended on the retroactive application of Padilla v. Kentucky, and Padilla did not apply retroactively to Appellant’s claim in light of Chaidez v. United States; and (2) Appellant’s claim against the prosecutor lacked merit. The First Circuit vacated and remanded the claim, holding (1) Appellant’s claim against the prosecutor indeed lacked merit; but (2) Appellant’s Sixth Amendment claim was not barred by the retroactivity doctrine. Remanded. View "United States v. Castro-Taveras" on Justia Law

After a jury trial in a Massachusetts state court, Appellant was found guilty of unlawful possession of a firearm, unlawful possession of ammunition, and other offenses. The appeals court affirmed. Appellant later filed a petition for a writ of habeas corpus pursuant to 28 U.S.C. 2254, arguing that the state courts failed to apply the United States Supreme Court’s holding in Snyder v. Massachusetts and violated his due process and equal protection rights in denying his request to be present during the jury view of the crime scene. The First Circuit affirmed, holding that the appeals court’s decision did not contradict, nor was it an unreasonable application of, Snyder. View "Hyatt v. Gelb" on Justia Law

After a jury trial, Defendant was convicted of conspiracy, manufacturing over 100 marijuana plants, maintaining a residence for marijuana manufacturing, and possessing a firearm as a felony. The district court sentenced Defendant to 120 months’ imprisonment followed by eight years of supervised release. The First Circuit affirmed, holding (1) even if the superseding indictment violated the principles outlined in Alleyne v. United States, the error was harmless beyond a reasonable doubt; (2) the district court erred in admitting hearsay testimony under the exception for statements in furtherance of a conspiracy, but this error did not warrant reversal; (3) any error in the admission of other testimony was harmless; and (4) Defendant’s sentence did not violate the Eighth Amendment. View "United States v. Ford" on Justia Law

In 2014, New Hampshire amended a statute by forbidding citizens from photographing their marked ballots and publicizing those photographs (referred to as “ballot selfies”). Three New Hampshire citizens filed suit, arguing that the statute was a content-based restriction of speech that, on its face, violates the First Amendment. The district court ruled in favor of the plaintiffs. On appeal, the New Hampshire Secretary of State argued that the statute was justified to prevent vote buying and voter intimidation. The First Circuit affirmed, holding that the statute as amended is facially unconstitutional even applying only intermediate scrutiny, and the statute’s purposes cannot justify the restrictions it imposes on speech. View "Rideout v. Gardner" on Justia Law

Phillip McCue died after an encounter with five police officers with the City of Bangor. During the encounter, the officers sought to take McCue into protective custody due to his erratic behavior allegedly caused by ingestion of bath salts. In an attempt to restrain McCue, the officers placed him in a face-down position on the ground while two officers exerted significant weight on his neck and shoulders. McCue was declared dead after this intervention. Plaintiff, the father of Phillip, sued the City and the five officers in their individual and official capacities, asserting violations of Phillip’s constitutional rights and various state law tort claims. The district court granted summary judgment in favor of Defendants, on the basis of qualified immunity, with two exceptions. Specifically, the denied Defendants’ claims of qualified immunity as to the alleged use of excessive force after Phillip ceased resisting and as to the assault and battery claim. Defendants appealed, contending that they were entitled to qualified immunity on these remaining claims. The First Circuit dismissed the appeal, holding that material disputed facts yet to be resolved precluded summary judgment, and therefore, the Court lacked appellate jurisdiction to entertain Defendants’ interlocutory appeal at this stage. View "McCue v. City of Bangor, Maine" on Justia Law

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