Justia Constitutional Law Opinion Summaries

Plaintiff sued the Commonwealth of Puerto Rico and three other Puerto Rico governmental entities under Title II of the Americans with Disabilities Act, alleging that, in ordering her committed to a psychiatric hospital, Defendants discriminated against her and denied public services to her because she was “regarded as” having a physical or mental impairment within the meaning of the ADA. The district court dismissed Plaintiff’s suit as time-barred after applying the one-year Puerto Rico statute of limitations. At issue on appeal was whether the limitations period set forth in 28 U.S.C. 1658 applied to Plaintiff’s case. The First Circuit reversed, holding that Plaintiff’s claims are governed by the catch-all limitations period set forth in section 1658. Remanded. View "Mercado v. Commonwealth of P.R." on Justia Law

After a jury trial, Defendant was convicted of being a felon in possession of a firearm. The district court sentenced Defendant to seventy-four months of imprisonment. Defendant appealed, challenging primarily the denial of his pretrial motion to bar a government witness from identifying him at trial. The Supreme Court affirmed the conviction but vacated the sentence, holding (1) the admission of the identification evidence did not violate Defendant’s due process rights, as the existence of the video recording of the witness’s pretrial identification of Defendant in a photo array guarded against the harm that the district court might have otherwise guarded against by excluding the identification; (2) the record is not fully developed to establish Defendant’s claim of ineffective assistance in relation to sentencing, and so Defendant’s sentence must vacated to allow consideration of the Stickland v. Washington issue on remand; and (3) there was no merit to Defendant’s remaining claims. View "United States v. Constant" on Justia Law

While working for Wal-Mart Stores East, L.P., Plaintiff claimed a disability arising from her “pregnancy status.” Plaintiff, however, claimed she could perform the essential functions of her job with a reasonable accommodation. Wal-Mart refused Plaintiff’s accommodation request and later terminated her. Plaintiff brought this action against Wal-Mart claiming violations of the Americans with Disabilities Act (ADA) and the New Hampshire Civil Rights Act. The district court granted summary judgment in favor of Wal-Mart on all claims. The First Circuit affirmed, holding (1) the trial judge correctly granted summary judgment to Wal-Mart on the ADA claim, as Plaintiff failed to create a trial worthy issue as to whether she could have performed an essential function of her job with or without reasonable accommodation; and (2) Plaintiff’s challenges to the dismissal of her state-law claims of unlawful disability discrimination and retaliation were without merit. View "Lang v. Wal-Mart Stores East, L.P." on Justia Law

Defendant was arrested for driving under the influence. Shortly after he was brought by Puerto Rico Police Department officers to the police station, he died in a holding cell. Defendant’s family members and estate filed suit, alleging that Defendants - Officer Perez, Sergeant Rodriguez, and Superintendent Toledo - used excessive force against Defendant and denied him needed medical care in violation of 42 U.S.C. 1983. The district court granted summary judgment in favor of Defendants on the grounds of sovereign immunity and insufficient evidence. Plaintiffs appealed, challenging only the district court’s decisions on the excessive force and denial of medical care claims and supervisory liability. The First Circuit (1) reversed and remanded for trial Plaintiffs’ claims against Perez and Rodriguez, holding (i) Perez and Rodriguez were not entitled to qualified immunity on the excessive force claim or the denial of medical care claim; and (2) affirmed the district court’s grant of summary judgment on Plaintiffs’ claims against Toledo, holding that Plaintiffs did not adequately plead facts going to Toledo’s liability. View "Miranda-Rivera v. Toledo-Davila" on Justia Law

Appellants in this case were family child care providers who were considered public employees for purposes of the statute authorizing employees in public service to organize for collective bargaining. A majority of the class of such providers as Appellants chose Service Employees International Union, Local 509 as their exclusive agent for bargaining collectively with the Department of Early Education and Care. No provider was required to become a Union member or to contribute money to the Union for any purpose. Appellants declined to join the Union. Appellants subsequently brought this action under 42 U.S.C. 1983 challenging the statutory scheme that authorizes the selection of an exclusive bargaining agent to “agree on terms that affect their relationships with their clients and the government.” The district court dismissed the complaint for failure to state a claim. The First Circuit affirmed based on established precedent, holding that Appellants were free from enforced association with the Union. View "D'Agostino v. Baker" on Justia Law

Eurie Stamps, Sr., an innocent, elderly, African-American man, was shot by Paul Duncan, a local police officer, during a SWAT team raid executing a search warrant for drugs and drug-related paraphernalia belonging to two drug dealers thought to reside in Stamps’s home. The co-administrators of Stamps’s estate sued the Town of Framingham and Duncan, arguing that Duncan violated Stamps’s constitutional right against unreasonable seizure when he pointed a loaded semi-automatic rifle at Stamps’s head, with the safety off and a finger on the trigger, even though Stamps was compliant and posed no known threat to the officers. Duncan filed a motion for summary judgment, arguing that he was entitled to qualified immunity because the shooting was an accident and not a violation of clearly established law. The district court denied the motion, ruling that a reasonable jury could find that Duncan had violated Stamps’s Fourth Amendment rights and that the law was sufficiently clearly established to put Duncan on notice that his actions were not constitutionally permissible. The First Circuit affirmed, holding that Duncan, in the situation at issue, was on notice that his actions could be violative of Stamps’s Fourth Amendment right to be free from excessive force. View "Stamps v. Town of Framingham" on Justia Law

In 2012, Plaintiffs brought this action arguing that they were unlawfully removed from the Commonwealth’s active voter registry for having failed to vote in the 2008 election for Resident Commissioner. On interlocutory appeal, the First Circuit held that the Help America Vote Act (HAVA) bars Puerto Rico from removing voters from the registry for the office of Resident Commissioners unless they fail to participate in the preceding two general federal elections. On remand, the district court found in favor of Plaintiffs and issued injunctive and declaratory relief from removing otherwise eligible voters from the active election registry unless HAVA's requirements are met. The First Circuit affirmed, holding (1) the National Voter Registration Act does not apply to Puerto Rico and thus does not supersede the Commonwealth’s voter deactivation procedures; (2) HAVA invalidates the deactivation procedures of Article 6.021 of Puerto Rico Act No. 2011 insofar as it applies to voter eligibility for federal elections; and (3) Plaintiffs may bring a private cause of action seeking relief under HAVA pursuant to 42 U.S.C. 1983. View "Colon-Marrero v. Garcia-Velez" on Justia Law

After Plaintiff was terminated from her employment with Puerto Rico’s Vocational Rehabilitation Administration, she filed a federal-court suit alleging that Defendants discriminated against her because of her disability, age, and politics. Plaintiff’s complaint alleged various violations of federal and local law. The district court dismissed Plaintiff’s 42 U.S.C. 1983 claim for failure to exhaust administrative remedies and then dismissed the remaining claims without explanation. The First Circuit affirmed the district court’s judgment in every respect, except that the Court reversed the dismissal of Plaintiff’s Americans with Disabilities Act (ADA) claim, holding (1) the district judge erred in concluding that Plaintiff’s section 1983 claim was barred for failure to exhaust administrative remedies, but Plaintiff’s section 1983 was time-barred; (2) because Defendants agreed that Plaintiff’s ADA claim should not have been dismissed on failure-to-exhaust grounds, the reversal is dismissed; (3) Plaintiff’s age discrimination claim was correctly dismissed for failure to exhaust; and (4) because the dismissal of the ADA claim is reversed, the judge on remand must reinstate the local-law claims as well. View "Martinez-Rivera v. Commonwealth of P.R." on Justia Law

Plaintiff sued the City of Waltham, Massachusetts and several of its officials alleging that Defendants conspired to deprive Plaintiff of his federal constitutional rights and alleging various violations of Massachusetts state law. Defendants moved for summary judgment on each of Plaintiff’s claims. The district court rejected the immunity defenses of two municipal officials in ruling on this motion. On interlocutory appeal, the First Circuit ruled that the two individual defendants were immune to suit under 42 U.S.C. 1983 because Plaintiff’s Equal Protection claim - the only preserved federal claim in the case - failed. After the Court’s decision, the district court granted Defendants’ motion for summary judgment on the remaining claims. The First Circuit affirmed the district court’s dismissal of Plaintiff’s remaining claims and the court’s denial of Plaintiff’s motion for leave to amend, holding that Plaintiff’s arguments were unavailing. View "Snyder v. Collura" on Justia Law

Plaintiff filed this action alleging that she was stripped of various job duties and eventually terminated from her job at the Puerto Rico Highway and Transportation Authority due to her affiliation with the Popular Democratic Party. The district court granted summary judgment in favor of Defendants on Plaintiff’s First Amendment political discrimination claims, concluding that there was insufficient evidence that the stripping of Plaintiff’s job functions constituted adverse employment actions, and absent any political discrimination, Plaintiff would have in any event been terminated for nondiscriminatory reasons. The First Circuit reversed, holding (1) Plaintiff made out a prima facie case of political discrimination; and (2) a genuine dispute existed as to whether Defendants would have fired Plaintiff regardless of her political affiliation. Remanded. View "Reyes-Orta v. P. R. Highway and Transp. Auth." on Justia Law