Justia Constitutional Law Opinion Summaries

Three foreign nationals, crewmembers aboard the vessel MARGUERITA, were detained in the United States after the vessel was held in port in Maine due to alleged improper disposal of bilge water and inaccurate record-keeping. The plaintiffs were ordered to remain in the U.S. as potential material witnesses. They were later allowed to leave but returned for trial and were awarded for their contributions to the conviction of the vessel's operator.The plaintiffs filed a lawsuit under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics and the Federal Tort Claims Act (FTCA) against various U.S. government entities and officials, alleging violations of their constitutional rights and various tort claims. The U.S. District Court for the District of Maine dismissed the Bivens claim and granted summary judgment for the defendants on the FTCA claims. The court found that the plaintiffs' detention and the revocation of their landing permits were authorized and that the plaintiffs did not show that the actions taken by the government officials were unlawful or unreasonable.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the requirement for ships to maintain an Oil Record Book under 33 C.F.R. § 151.25 is valid and that the plaintiffs' detention was justified under the circumstances. The court also found that the plaintiffs failed to establish their claims for false arrest, false imprisonment, abuse of process, and intentional infliction of emotional distress under the FTCA. Additionally, the court concluded that the Bivens claim presented a new context and that special factors counseled hesitation in extending a Bivens remedy, particularly given the availability of alternative remedies and the implications for government policy and international relations. View "Hornof v. United States" on Justia Law

In this case, a citizen-journalist named Inge Berge recorded a video in the Gloucester school superintendent's office, questioning COVID-19 policies. He openly filmed the interactions and later posted the video on Facebook. The school district's human resources director, Roberta Eason, sent Berge a letter demanding he remove the video, citing a violation of Massachusetts's wiretap act, which prohibits secret recordings. However, Berge's recording was not secret, and he did not remove the video. Instead, he filed a lawsuit against the Gloucester School Committee and individual officials, alleging First Amendment retaliation and seeking declaratory relief.The United States District Court for the District of Massachusetts dismissed Berge's complaint. The court granted the individual defendants qualified immunity on the First Amendment retaliation claim, ruling that Berge had not shown a clearly established right to publish the video. The court also dismissed the declaratory relief claims as moot, noting that the school district had revoked the demand letter and assured no further action would be taken against Berge. Additionally, the court denied Berge's motion for a temporary restraining order and preliminary injunction as moot.The United States Court of Appeals for the First Circuit reviewed the case. The court vacated the district court's dismissal of the First Amendment retaliation claim against the individual defendants, holding that Berge plausibly alleged a violation of a clearly established right to publish on a matter of public concern. The court affirmed the dismissal of the declaratory relief claims as moot, given the school district's retraction of the demand letter and assurances. The court also affirmed the denial of the motion for a temporary restraining order and preliminary injunction as moot. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Berge v. School Committee of Gloucester" on Justia Law

A former teacher at Hanover High School in Massachusetts, Kari MacRae, was terminated from her position due to controversial memes she posted on her personal TikTok account. The memes, which were posted before she was hired, touched on sensitive topics such as gender identity, racism, and immigration. After her posts became public knowledge, the school district decided to terminate her employment, citing concerns about potential disruption to the learning environment.In the lower courts, MacRae filed a lawsuit against the school district, the school's principal, and the superintendent, alleging that they had unconstitutionally retaliated against her for exercising her First Amendment rights. The district court granted the defendants' motion for summary judgment, concluding that the school district's interest in preventing disruption outweighed MacRae's First Amendment rights.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court applied the Garcetti framework, which balances the interests of a public employee in commenting on matters of public concern against the interest of the state in promoting the efficiency of public services. The court found that while MacRae's posts did touch on matters of public concern, the school district's interest in preventing disruption to the learning environment was reasonable and outweighed MacRae's First Amendment interest. The court also noted that the timing of the posts, the media attention they received, and the controversy they stirred in the community all supported the school district's prediction of disruption. View "MacRae v. Mattos" on Justia Law

The case involves Irvin Abreu, who pleaded guilty to one count of sexual exploitation of a child. The district court sentenced him to 315 months in prison, applying an enhanced mandatory minimum sentence of 300 months due to his prior state-law conviction for enticement of a child under the age of sixteen. Abreu appealed, arguing that his prior state-law conviction should not trigger the twenty-five-year minimum for his federal crime.Previously, the district court had determined during pre-trial proceedings that Abreu's prior conviction did trigger the twenty-five-year mandatory minimum under § 2251(e). Abreu subsequently changed his plea to guilty, and at sentencing, the district court considered a U.S. Sentencing Guidelines range of 300 to 327 months due to the mandatory minimum sentence.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court agreed with the district court's ruling that the enhancement does apply, concluding that the Massachusetts child-enticement statute is divisible and that Abreu's prior offense is related to the generic crimes listed in § 2251(e). The court also rejected Abreu's argument that § 2251(e) is unconstitutionally vague under the Fifth Amendment's Due Process Clause. View "US v. Abreu" on Justia Law

A minor, L.M., represented by his father and stepmother, sued the Town of Middleborough, Massachusetts, the Middleborough School Committee, and various school officials, alleging that his First Amendment rights were violated when he was prohibited from wearing a t-shirt that read "There Are Only Two Genders" at his public middle school. The United States District Court for the District of Massachusetts denied L.M.'s motion for a preliminary injunction and granted final judgment in favor of the defendants.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court's rulings. The Court of Appeals held that the school officials reasonably interpreted the message on L.M.'s t-shirt as demeaning to the gender identities of other students. The court also found that the school officials reasonably forecasted that the t-shirt's message would negatively affect the psychology of students with the demeaned gender identities and disrupt the learning environment. The court concluded that the school's actions were permissible under the "material disruption" limitation of the Supreme Court's decision in Tinker v. Des Moines Independent Community School District, which allows schools to regulate student speech that materially disrupts classwork or involves substantial disorder.The Court of Appeals also rejected L.M.'s facial challenges to the school's dress code, finding that he lacked standing to challenge one provision and that the other provision was not unconstitutionally vague or overbroad. View "L. M. v. Town of Middleborough, Massachusetts" on Justia Law

The defendant, Ronald Yoel Marte Carmona, was convicted on charges related to multiple fentanyl sales. He appealed, challenging the district court's denial of his motions to suppress the fruits of a Terry stop and arguing that the evidence supporting his six convictions was insufficient.Previously, the defendant had been indicted on one count of conspiracy to distribute and to possess with intent to distribute 400 grams or more of fentanyl, and five counts of distribution and possession with intent to distribute forty grams or more of fentanyl. Each of the distribution counts corresponded with a particular controlled buy. The defendant moved to suppress the fruits of a traffic stop and the fruits of a search of an apartment, arguing that the stop was unconstitutional because it was not supported by probable cause or reasonable suspicion. The district court denied the motions, finding that the agents possessed reasonable suspicion to effectuate the stop.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court found that the Terry stop was reasonable, grounded in articulable suspicion, and that the verdicts were supported by the record evidence. The court also found that the agents who stopped the defendant possessed a reasonable, articulable suspicion that he was involved in past criminal conduct, making the Terry stop permissible. The court further held that the evidence presented at trial established that a rational factfinder could conclude, beyond a reasonable doubt, that the defendant was guilty of the charges. View "US v. Carmona" on Justia Law

A Rhode Island oral and maxillofacial surgeon, Dr. Stephen T. Skoly, refused to comply with a COVID-19 Emergency Regulation issued by the Rhode Island Department of Health (RI DOH) that required all healthcare workers and providers to be vaccinated against COVID-19. Following his public declaration of noncompliance, the RI DOH issued a Notice of Violation and Compliance Order against him. Skoly then filed a lawsuit in federal court against the state and its officials, alleging violations of equal protection, due process, and First Amendment rights. The district court dismissed his complaint under Federal Rule of Civil Procedure 12(b)(6).The district court's decision was based on the fact that the state officials were either entitled to absolute or qualified immunity for their actions. The court held that the RI DOH directors were exercising prosecutorial authority delegated to them by Rhode Island law, thus granting them absolute immunity. As for Governor McKee, the court found that he was protected by qualified immunity as Skoly had no clearly established right to continue practicing while violating the vaccine mandate. The court also rejected Skoly's First Amendment retaliation claim, stating that the posting of the Notice constituted government speech, which could not form the basis of a plausible First Amendment retaliation claim.Upon appeal, the United States Court of Appeals for the First Circuit affirmed the district court's dismissal of Skoly's complaint. The appellate court agreed with the lower court's findings that the state officials were entitled to either absolute or qualified immunity and that Skoly's constitutional claims were without merit. The court also upheld the dismissal of Skoly's First Amendment retaliation claim, stating that Skoly had not sufficiently alleged that he was targeted due to his opposition to the First Emergency Regulation. View "Skoly v. McKee" on Justia Law

The case involves Jennifer Root Bannon, who sued six law enforcement officers and the City of Boston on behalf of her brother's estate. Her brother, Juston Root, was fatally shot by the officers after a series of events that began with him pointing a gun at a hospital security guard and a responding police officer, leading the officers on a high-speed chase, and disregarding police instructions to drop his weapon. Bannon claimed that the officers used excessive force in violation of the Fourth Amendment. The district court granted summary judgment to the defendants.The United States Court of Appeals for the First Circuit agreed with the district court's conclusion that the officers acted reasonably under the circumstances during the fatal shooting and did not violate the Fourth Amendment. The court also held that the officers were entitled to qualified immunity and affirmed the grant of summary judgment on Bannon's other claims. The court found that no reasonable jury could conclude that the officers acted unreasonably in employing deadly force against Root in violation of the Fourth Amendment. The court also independently concluded that the officers were entitled to summary judgment on Bannon's § 1983 and MCRA claims based on qualified immunity. View "Bannon v. Godin" on Justia Law

The United States Court of Appeals For the First Circuit examined a case where the defendant, Derek Gerrish, challenged the constitutionality of a search of his vehicle during his pretrial release on several state criminal charges. During this period, Gerrish was subjected to at least six different bail conditions, five of which allowed for searches of his person, vehicle, or residence at any time without reasonable suspicion. The search in question led to the discovery of fentanyl and other contraband, resulting in Gerrish pleading guilty to possession with intent to distribute fentanyl.Gerrish argued that the search of his vehicle was unconstitutional, despite the terms of his bail conditions. The district court denied his motion to suppress the evidence, citing two reasons: the officers had reasonable suspicion of criminal activity, and Gerrish's bail conditions permitted such a search.On appeal, the defendant argued that both of the district court's reasons were incorrect. The appeals court, however, only focused on the bail condition rationale, as it found it conclusive. The court noted that Gerrish knowingly agreed to bail conditions authorizing searches without suspicion and did not challenge the reasonableness of these conditions. Furthermore, it emphasized that the issue at hand was not the search itself, but the bail conditions that authorized it.The court rejected Gerrish's argument that such bail conditions could not be imposed pre-trial or pre-guilty plea, referring to precedent which stated that acceptance of such conditions significantly diminishes a defendant's reasonable expectation of privacy. It also dismissed Gerrish's claim of a conflict with a Ninth Circuit decision, stating that Maine law requires "least restrictive" bail conditions tailored to the defendant's individual circumstances, thereby eliminating the Ninth Circuit's concerns about mandatory waiver of rights.The judgment of the district court was thus affirmed. View "United States v. Gerrish" on Justia Law

This appeal, heard by the United States Court of Appeals for the First Circuit, centered on the constitutionality of Massachusetts' Law 80, which retroactively provided immunity to higher education institutions for monetary damages due to actions taken in response to the COVID-19 pandemic. The plaintiffs, students at Boston University (BU), had sued the university for breach of contract and unjust enrichment following BU's transition to remote learning during the Spring 2020 semester. They contended that they had paid for in-person instruction and services, which BU failed to provide.The lower court ruled in favor of BU, holding that the university was entitled to the defense of impossibility as it had to comply with COVID-19 emergency orders. On appeal, the court was required to consider whether the retroactive application of Law 80 to the case violated the Due Process Clause of the United States Constitution.The appellate court found that Law 80 served reasonable public interests related to public health, safety, future compliance, and economic consequences beyond the control of the universities. The court also determined that the plaintiffs' alleged implied contract rights did not constitute vested rights. Furthermore, the court noted that the scope of Law 80 was appropriately limited and did not excessively burden the plaintiffs.Consequently, the court held that Law 80 does not violate due process and affirmed the lower court's judgment, ruling in favor of BU. The court did not need to consider the merits of the lower court's decision to exclude the plaintiffs' expert witness's testimony. View "Dutra v. Trustees of Boston University" on Justia Law