Justia Constitutional Law Opinion Summaries

The First Circuit affirmed Defendant's convictions for receipt and possession of child pornography, holding that the district court did not err in denying Defendant's pre-trial motion to suppress evidence obtained pursuant to a search warrant and did not abuse its discretion in excluding certain text-message evidence as inadmissible hearsay.On appeal, Defendant argued that the district court erred in denying his motion to suppress because the affidavit filed in support of the search warrant failed sufficiently to describe ether pornographic images to be found and that the court erred in excluding from his trial the text message evidence at issue. The First Circuit affirmed, holding (1) there was no error in the district court's denial of Defendant's motion to suppress; and (2) the district court did not err in barring the text messages from Defendant's trial. View "United States v. Chiu" on Justia Law

The First Circuit reversed the decision of the district court that the prosecutor in the underlying Rhode Island case transgressed the Batson rule in the course of jury selection but that Petitioner was not entitled to habeas corpus relief, holding that the decision of the Rhode Island Supreme Court could not withstand habeas review.Petitioner, a Rhode Island state prisoner and an African-American man who was convicted of murder and other crimes, claimed in his petition for writ of habeas corpus that the prosecutor violated Batson during jury selection. The federal district court concluded that Petitioner's rights under Batson were violated but that the Rhode Island Supreme Court did not abuse its discretion in finding sufficient race-neutral reasons for a peremptory challenge against the juror in question. The First Circuit reversed, holding (1) the prosecutor's explanation for his peremptory strike was not race-neutral on its face and thus violated Batson; and (2) the Rhode Island Supreme Court's decision rested on either an unreasonable application of clearly established federal law, an unreasonable determination of the facts, or both. View "Porter v. Coyne-Fague" on Justia Law

The First Circuit vacated the judgment of the district court granting summary judgment to Defendants and dismissing Plaintiff's claims challenging the termination of his employment on free speech grounds, holding that summary judgment was improper in this case.Plaintiff, a former bus driver for the Worcester Regional Transit Authority (WRTA), brought this action under 42 U.S.C. 1983 claiming that Defendants violated his right to free speech under the First Amendment to the federal constitution and the Massachusetts Civil Rights Act (MCRA) when they terminated his employment following public comments that he made to a television network about proposed budget cuts to the WRTA. The district court granted summary judgment for Defendants. The First Circuit remanded the case, holding (1) the district court erred in concluding that, as a matter of law, Plaintiff was not speaking "as a citizen" during the television interview; and (2) Defendants did not have an adequate justification for treating Plaintiff differently from other members of the general public by terminating him for his protected speech. View "Bruce v. Worcester Regional Transit Authority" on Justia Law

In this interlocutory appeal, the First Circuit affirmed the judgment of the district court denying Defendant's motion to dismiss this suit pursuant to both the Eleventh Amendment and the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA), 48 U.S.C. 2101 et seq., holding that the district court did not err.The plaintiff in this case was the Centro de Periodismo Investigativo (CPI), a non-profit media organization based in Puerto Rico. Plaintiff sued the Financial Oversight and Management Board for Puerto Rico, alleging that the Board improperly ignored their requests for documents or provided less than complete responses in violation of P.R. Const. 4. The Board moved to dismiss the claim for lack of subject-matter jurisdiction and for failure to state a claim. The district court denied the motion. The First Circuit affirmed, holding that Defendants were not entitled to Eleventh Amendment sovereign immunity. View "Centro de Periodismo Investigativo, Inc. v. Financial Oversight & Management Board for Puerto Rico" on Justia Law

The First Circuit reversed the judgment of the district court denying Defendants' motion for entry of an automatic stay under 11 U.S.C. 922, incorporated into Title III of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA), 48 U.S.C. 2101-2241, through 48 U.S.C. 2161(a), holding that Defendants were entitled to an automatic stay.Plaintiffs, who owned an operated the Integrand Assurance Company, sued Defendants, Puerto Rico government officials whose defense was assumed by the Commonwealth of Puerto Rico pursuant to the Commonwealth's legal representation and indemnification statute, alleging, among other claims, that the government officials violated their First Amendment rights, the Equal Protection Clause, and the Due Process Clause. Defendants, who were granted legal representation under Law 9, filed a notice of automatic stay. The district court denied the motion, concluding that PROMESA did not stay the litigation. The First Circuit reversed, holding that the automatic stay provision in Title III of PROMESA applied to this action. View "Victor J. Salgado & Associates v. Cestero-Lopategui" on Justia Law

The First Circuit vacated the judgment of the district court dismissing this complaint alleging a First Amendment claim and seeking a preliminary injunction, holding that Plaintiffs plausibly alleged a First Amendment violation.At issue was the electronic case filing system piloted by the Maine Supreme Judicial Court (SJC) for the state's trial courts, which resulted in delayed access. Plaintiffs, state and federal news agencies, sued Defendants, state court officials, alleging violations of their First Amendment rights. Thereafter, the SJC changed its rules. The district court held that Plaintiffs had failed to state a claim, dismissed the complaint, and denied the motion for a preliminary injunction as moot. The Supreme Court reversed, holding that Plaintiffs plausibly alleged a First Amendment violation. View "Courthouse News Service v. Quinlan, Bangor Publishing Co., Inc." on Justia Law

The First Circuit affirmed Defendant's conviction of possession with intent to distribute forty grams or more of fentanyl, holding that the district court did not err in denying Defendant's motion to suppress evidence seized during a stop and warrantless search of his vehicle.After Defendant was indicted he filed a motion to suppress the evidence obtained a result of the stop and search in this case. The district court denied the motion and found Defendant guilty. On appeal, Defendant argued that the district court abused its discretion in failing to hold an evidentiary hearing on his motion to suppress and that, alternatively, the district court erred in denying his motion to suppress because he was de facto placed under arrest without probable cause. The First Circuit affirmed, holding (1) if there was an arrest it was a lawful one; and (2) no evidentiary hearing was necessary in this case. View "United States v. Batista" on Justia Law

The First Circuit affirmed the judgment of the district court denying Petitioner's petition for a writ of habeas corpus filed pursuant to 28 U.S.C. 2254 alleging that the prosecution violated Batson v. Kentucky, 476 U.S.C. 79 (1986) during his criminal trial, holding that there was no error.Based on an interaction with four white men outside an apartment building Petitioner was convicted in the Maine Superior Court of reckless conduct with a dangerous weapon and criminal threatening with a dangerous weapon. Petitioner later filed his petition for habeas corpus. The superior court denied the petition, concluding that the prosecution's race-neutral explanation for striking the sole person of color from the jury pool was not pretextual and, therefore, that there was no purposeful discrimination. The First Circuit affirmed, holding that there was no error. View "Hollis v. Magnusson" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Defendants, the Town of Marblehead and its buildings commissioner, and dismissing this lawsuit brought under the Religious Land Use and Institutionalized Persons Act (RLUIPA), holding that the district court did not err.St. Paul's Foundation and the Shrine of St. Nicholas the Wonderworker, Patron of Sailors, Brewers and Repentant Thieves (collectively, St. Paul's), brought this action alleging that Defendants substantially burdened St. Paul's religious exercise. Specifically, St. Paul's sought to reinstate a building permit that it had secured for the redevelopment of a site on which the Shrine of St. Nicholas was located but that had been suspended prior to the completion of that construction. The district court granted summary judgment in favor of Defendants. The First Circuit affirmed, holding that St. Paul's did not successfully advance a basis for reversing the summary judgment in this case. View "St. Paul's Foundation v. Ives" on Justia Law

The First Circuit affirmed Appellant's plea of guilty to one count of investment adviser fraud, four counts of wire fraud, and one count of aggravated identity theft, holding that there was no prejudicial error in the proceedings below.On appeal, Appellant argued that her plea was not knowing and voluntary, that the evidence was insufficient to convict her of wire fraud and aggravated identity theft, that several sentencing enhancements were improperly applied, and that her counsel was ineffective. The First Circuit affirmed, holding (1) there was no error in the district court's acceptance of Appellant's guilty plea; (2) Appellant's conduct clearly satisfied the statutory requirements for wire fraud and aggravated identity theft; and (3) Appellant's challenges to several aspects of her sentence were unavailing. View "United States v. Kitts" on Justia Law