Justia Constitutional Law Opinion Summaries

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of the County of York and various County officials in this case alleging violation of Plaintiff's civil right, false arrest, false imprisonment, malicious prosecution, and defamation per se, holding that there was no error.Specifically, the First Circuit held (1) no reasonable jury could find facts that would lead to a determination that the officers lacked probable cause to arrest Plaintiff, and Plaintiff likewise developed no argument that his false imprisonment claims could survive a finding that probable cause existed to arrest him; (2) Plaintiff failed to raise a triable issue as to his federal and state malicious prosecution claims; (3) none of Plaintiff's constitutional claims against the officers could survive summary judgment; and (4) the district court properly rejected Plaintiff's defamation claims. View "Charron v. County of York" on Justia Law

The First Circuit affirmed Defendant's conviction for drug-trafficking and firearms charges, holding that the district court did not err in denying Defendant's motion to suppress or in finding Defendant eligible for a mandatory minimum sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924 (e).Reports of a parking-lot confrontation following a road-rage incident led law enforcement to stop Defendant in his vehicle the next day. The ensuing searches of Defendant's car and motor home led to the discovery of evidence supporting drug-trafficking and firearms charges. Defendant pleaded guilty. The First Circuit affirmed Defendant's conviction and sentence, holding (1) there was no error in the district court's denial of Defendant's motion to suppress; and (2) Defendant's sentence under the ACCA was lawfully imposed. View "United States v. Mulkern" on Justia Law

The First Circuit affirmed the convictions of Appellants Edilio Benjamin-Hernandez (Benjamin) and Johanni Balbuena-Hernandez (Balbuena) on multiple charges stemming from a conspiracy to transport cocaine from the Dominican Republic to Puerto Rico, holding that Appellants were not entitled to relief on their claims of error.On appeal, Appellants challenged the district court's denial of their motion to dismiss and argued that the evidence presented at trial was insufficient to support the convictions. Benjamin also raised two evidentiary challenges. The First Circuit affirmed, holding (1) there was no violation of the Speedy Trial Act's seventy-day limit; (2) no Sixth Amendment violation occurred in this case; and (3) there was sufficient evidence supporting Appellants' convictions. View "United States v. Benjamin-Hernandez" on Justia Law

The First Circuit affirmed the judgment of the district court awarding plaintiff Elba I. Falto De Roman only nominal damages against the Municipal Government of Mayguez and against its mayor, Jose Guillermo Rodriguez, on her complaint filed after was terminated from her position without having been afforded a due process hearing, holding that there was no error.Plaintiff brought this action alleging, among other things, that Defendants violated her Fourteenth Amendment right to due process by terminating her without a hearing. After a trial on the issue of whether Plaintiff was entitled to damages as a result of not receiving a hearing, the jury found Defendants not liable for damages and awarded nominal damages of $1 in favor of Plaintiff. The district court denied Plaintiff's subsequently-filed motion for judgment as a matter of law or, alternatively, for a new trial. The First Circuit affirmed, holding (1) Plaintiff waived her challenge to the district court's denial of her motion for judgment; and (2) Plaintiff did not meet the high bar for a new trial. View "Falto-de Roman v. Municipal Government of Mayaguez" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing this case for lack of subject matter jurisdiction, holding that, as to counts I-IV, Plaintiffs ran afoul of the Rooker-Feldman doctrine and that count V failed due to a lack of standing.Appellants, approximately fifty members of a class of retired Rhode Island public employees, brought this action under 42 U.S.C. 1983 alleging constitutional violations in the changes to Rhode Island's retirement benefits scheme (counts I-IV) and in a class action settlement agreement (count V) reached following litigation in state court, in which each appellant was a party. The district court dismissed the action, holding that Appellants' claims were barred by res judicata, a lack of Article III standing, and the Rooker-Feldman doctrine. The First Circuit affirmed, holding (1) Appellants' due process, takings, and Contracts Clause claims were barred by the Rooker-Feldman doctrine; and (2) Appellants' First Amendment claims were nonjusticiable. View "Efreom v. McKee" on Justia Law

The First Circuit vacated the judgment of the district court dismissing this complaint after concluding that it lacked subject matter jurisdiction over Appellant's suit under the Anti-Injunction Act of the Internal Revenue Code, 26 U.S.C. 7241, holding that the district court erred in dismissing the complaint.Appellant brought a complaint against the Internal Revenue Service (IRS) and some of the IRS's agents alleging that Defendants violated the Fourth and Fifth Amendments and 26 U.S.C. 7609(f) by acquiring Appellant's personal financial information through a third-party summons process. The district court dismissed Appellant's claims for declaratory and injunctive relief for lack of subject matter jurisdiction, ruling that the Anti-Injunction Act of the Internal Revenue Code, 262 U.S.C. 7421, constituted an exception to the APA's waiver of sovereign immunity. The First Circuit vacated the judgment, holding that the Anti-Injunction Act did not bar Appellant's suit. View "Harper v. Rettig" on Justia Law

The First Circuit affirmed the conclusion of the district court that the Maine Medical Marijuana Act's requirement that officers and directors of medical marijuana dispensaries operating in Maine be Maine residents violates the dormant Commerce Clause of the United States Constitution, holding that that Maine residency requirement violates the dormant Commerce Clause.Plaintiffs brought this suit under 42 U.S.C. 1983 and 28 U.S.C. 2201 alleging that the Act's residence requirement violates the dormant Commerce Clause by permitting only in-staters to serve as officers or directors of dispensaries. The district court granted judgment for Plaintiffs. On appeal, Defendants argued that because the Controlled Substances Act (CSA), 21 U.S.C. 801 et seq., makes marijuana contraband, the residency requirement does not run afoul of the dormant Commerce Clause. The First Circuit disagreed, noting that "a congressional exercise of commerce power can never, merely by being in place, displace the dormant Commerce Clause." The Court then affirmed, holding that "nothing on the face of the CSA purports to bless interstate discrimination in the market for medical marijuana that continues to operate even in the face of the CSA." View "Northeast Patients Group v. United Cannabis Patients & Caregivers of Maine" on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment in favor of the Town of Brookline and its Selectmen and dismissing Plaintiffs' claims of unconstitutional mistreatment by the Town's "deliberate indifference" to complaints of racial discrimination by Brookline police, holding that Plaintiffs' claims on appeal were unavailing.The five named plaintiffs here claimed that Brookline police officers violated their rights under the Equal Protection Clause by treating them differently because they are Hispanic. The district court granted summary judgment for Defendants. The First Circuit affirmed, holding that the record evidence did not support a finding of deliberate indifference. View "Baez v. Town of Brookline, Mass." on Justia Law

The First Circuit dismissed this appeal from the dismissal of a 42 U.S.C. 1983 suit filed by Plaintiffs, two college students, against Defendants, their former universities and university officials, asserting constitutional challenges to the universities' COVID-19 vaccination policies, holding that Plaintiffs' claims are moot.The policies at issue required all students either to be vaccinated or to obtain an exemption to be allowed onto campus. Plaintiffs sought declaratory and injunctive relief seeking exemptions from the policies. The district court denied relief and granted Defendants' motion to dismiss. The First Circuit dismissed Plaintiffs' ensuing appeal, holding that where one student had graduated and the other student was no longer enrolled, Plaintiffs' claims were moot. View "Harris v. University of Massachusetts, Lowell" on Justia Law

The First Circuit dismissed this appeal, in which Appellant sought to override an appeal waiver and to proceed with an appeal based on the alleged ineffective assistance of his counsel, holding that ineffective assistance of counsel claims not raised in the district court and not within an exception to United States v. Mala, 7 F.3d 1058 (1st Cir. 1993), are insufficient to overcome an appeal waiver.Defendant agreed to plead guilty to conspiracy to commit bank fraud and to failure to appear in court pursuant to a plea agreement that contained a waiver-of-appeal provision. After sentencing, Defendant appealed, asserting for the first time that his counsel afforded him ineffective assistance both at the time he entered his plea and at sentencing. The First Circuit dismissed the appeal, holding that Defendant's ineffective assistance of counsel allegations fell within the Mala rule and could not surmount his waiver of appeal. View "United States v. Staveley" on Justia Law