Justia Constitutional Law Opinion Summaries

The First Circuit affirmed Defendant's conviction for being a felon in possession of a firearm, holding that the district court did not err in denying Defendant's motion to suppress.Upon executing a no-knock search warrant following reports of discharged shots the police found two shotguns and related paraphernalia in Defendant's bedroom. In his motion to suppress, Defendant argued that the police exceeded the scope of the warrant by searching his bedroom, which was located on the third floor of the building, because the searched warrant was for "88 Foundation St. 2nd floor." The district court denied the motion, concluding that the good-faith exception to the exclusionary rule applied. The First Circuit affirmed, holding that the officers reasonably believed that the warrant permitted the search of Defendant's third-floor bedroom. View "United States v. Pimentel" on Justia Law

The First Circuit affirmed Defendants' convictions for conspiring to distribute twenty-eight grams or more of cocaine base, holding that neither Defendant was entitled to relief on his claims of error.Defendants Juan Pena and Rosnil Ortiz were convicted for conspiring to distribute twenty-eight grams or more of cocaine base. On appeal, Defendants argued that the district court erred in allowing the jury to consider certain video recordings and the "out-of-court" statements captured therein. The First Circuit affirmed, holding that the district court (1) did not commit reversible error in admitting certain portions of two videos and the audio statements therein; (2) did not deny Defendants' constitutional rights to confront witnesses and to present a complete defense by excluding certain statements, as Defendants intended to use them; and (3) did not deprive Defendants of their right to an impartial tribunal by instructing the jury mid-cross-examination that it was proper for law enforcement agents to use confidential informants and to take drug weight into account when directing controlled drug purchases. View "United States v. Pena" on Justia Law

The First Circuit affirmed Defendant's conviction of one count of conspiracy to possess with intent to distribute and to distribute 500 grams or more of cocaine, in violation of 21 U.S.C. 846, and one count of possession with intent to distribute 500 grams or more of cocaine, in violation of 21 U.S.C. 841(a)(1), holding that there was no error.Specifically, the First Circuit held (1) the district court did not err in denying Defendant's motion to suppress evidence obtained during a traffic stop and admitting items seized from the vehicle at trial; (2) the district court did not manifestly abuse its discretion in admitting certain statements of lay witnesses; (3) the proceedings did not contravene Defendant's constitutional right to a speedy trial; and (4) Defendant's absence at certain pre-trial proceedings did not violate his statutory or constitutional presence rights. View "United States v. Reyes" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Appellants' action for declaratory relief against the Governor of Rhode Island and various Rhode Island officials and agencies (collectively, Rhode Island), holding that the district court did not err.On behalf of a putative class of Rhode Island students attending K-12 schools, Appellants brought this action under the Equal Protection, Due Process, and Privileges and Immunities Clauses of the Fourteenth Amendment and the Republican Guarantee Clause of U.S. Const. art. IV, 4, claiming that Rhode Island failed to provide them with an adequate education to function productively in civic activities. The district court dismissed the action. The First Circuit affirmed, holding that the district court properly concluded that an adequate civics education is not a fundamental constitutional right and that Rhode Island's approach to civics education satisfies rational basis review. View "A.C. v. McKee" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's petition for habeas relief, holding that the district court did not err in its treatment of Defendant's claim for habeas relief based on Batson v. Kentucky, 476 U.S. 79 (1986).Defendant was convicted of first-degree murder and sentenced to life in prison. On appeal, Defendant raised a Batson claim of race-based discrimination in jury selection. The state court denied Defendant's appeal. Thereafter, Defendant filed a petition for habeas relief based on Batson. The federal district court denied relief. The First Circuit affirmed, holding that the Massachusetts Supreme Judicial Court did not unreasonably apply clearly established Supreme Court case law in concluding that Defendant did not establish the prima facie case of purposeful race-based discrimination required by Batson. View "Yacouba-Issa v. Calis" on Justia Law

The First Circuit granted Petitioner's petition for review of a decision by the Board of Immigration Appeals (BIA) affirming the denial of Petitioner's claims for asylum, withholding of removal, and protection under the United Nations Convention Against Torture (CAT), holding that the immigration judge's (IJ) credibility judgment was not supported by substantial evidence.The IJ rejected Petitioner's petition for relief based on an adverse credibility determination that primarily drew its support from a gang assessment database. The BIA affirmed. Petitioner then petitioned for review, arguing that the agency's reliance on the flawed gang package undermined the credibility finding and resulted in a due process violation. The First Circuit granted the petition after noting the flaws in the gang assessment database, including the database's reliance on an erratic point system built on unsubstantiated inferences, holding that neither the agency's adverse credibility determination nor its denial of Petitioner's claims was supported by substantial evidence. View "Ortiz v. Garland" on Justia Law

The First Circuit affirmed Defendant's conviction of possession with intent to distribute marijuana and possession of a firearm and ammunition by a convicted felon, holding that the district court did not err by not granting Defendant's motion to suppress.In his motion to suppress, Defendant sought to suppress evidence obtained after the execution of a search warrant at his residence, asserting errors and omissions in the underlying search warrant affidavit. The First Circuit affirmed the district court's denial of Defendant's motion, holding that the various motions that Defendant filed ultimately seeking to suppress the evidence seized from his residence were correctly denied. View "United States v. Maglio" on Justia Law

The First Circuit affirmed the decision of the district court entering summary judgment against the political discrimination claims brought by Plaintiffs, former Automobile Accident Compensation Administration (AACA) employees, against Defendants, the AACA and its former executive director, holding that the district court did not err.Plaintiffs were laid off pursuant to an agency-wide, facially-neutral layoff plan based on seniority. Plaintiffs brought this action under 42 U.S.C. 1983 alleging violations of their rights under the First, Fifth, and Fourteenth Amendments, along with violations of Puerto Rico law. The district court adopted Puerto Rico court decisions concluding that it was the Board of Directors, and not the Executive Director, that was responsible for the layoff plan, and then granted summary judgment for Defendants. The First Circuit affirmed, holding that the district court correctly concluded that Plaintiffs were barred from arguing in this litigation that the executive director was responsible for the layoff plan. View "Diaz-Baez v. Alicea-Vasallo" on Justia Law

The First Circuit affirmed the district court's judgment denying Defendant's motion to suppress evidence obtained during the execution of a no-knock search warrant at the apartment where he and his girlfriend lived, holding that the district court did not err.On appeal, Defendant argued that the district court erred by failing to suppress evidence obtained from the search of his backpack because his backpack was not properly subject to search and erred in failing to find that there was insufficient justification for the no-knock provision of the warrant. The First Circuit affirmed, holding (1) there was nothing improper about the search; and (2) the district court did not commit plain error by not ruling that the no-knock provision was unsupported. View "United States v. Congo" on Justia Law

The First Circuit reversed the judgment of the district court granting Defendant's motion to suppress evidence seized during a protective search of a car, holding that the actual-fear analysis set forth in United States v. Lott, 870 F.2d 778 (1st Cir. 1989), is no longer controlling.In Lott, the First Circuit held that officers cannot do a frisk for weapons where the officers were not actually concerned for their safety. The district judge in this case granted Defendant's motion to suppress after finding that while officers had an objectively reasonable basis to search the car, they had no subjective concerns for their safety. The First Circuit reversed the judge's evidence suppression and remanded the case for further proceedings, holding that Lott is abrogated to the extent that it is inconsistent with the opinion in this case. View "United States v. Guerrero" on Justia Law