Justia Constitutional Law Opinion Summaries

The First Circuit affirmed the order of the district court dismissing Plaintiff's federal claims seeking to hold private parties liable as state actors under 42 U.S.C. 1983, holding that the district court did not err in granting Defendants' Fed. R. Civ. P. 12(b)(6) motion to dismiss.In this case arising from eviction proceedings, Plaintiff brought this suit against Management Administration Services Corporation and its administrator, alleging violations of the Fourth and Fourteenth Amendments related to a search of her apartment, violations of due process related to rent-adjustment negotiations and eviction proceedings, and pendant claims for emotional distress. In response to Defendants' motion to dismiss Plaintiff argued that Defendants were performing a function traditionally and exclusively reserved to the state. The district court dismissed the complaint. The First Circuit affirmed, holding that the complaint failed to allege sufficient facts to ground a plausible conclusion that the function Defendants performed was, by tradition, an exclusive prerogative of the state. View "Cruz-Arce v. Management Administration Services Corp." on Justia Law

The First Circuit affirmed the judgment of the district court rejecting the claims of Plaintiffs John Doe and Ben Bloggs that their high school discipline was unconstitutional, holding that the district court properly entered judgment in favor of Hopkinton Public Schools on all counts.Following an investigation, Hopkinton High School determined that eight students on the school hockey team, including Plaintiffs, had bullied their fellow hockey team member, and suspended each hockey player for a number of days. In this appeal from the dismissal of their complaint, Plaintiffs argued that the discipline violated their First Amendment rights, the "emotional harm" prong of Mass. Gen. Laws ch. 71, 370 is unconstitutional, and that the punishment violated their student speech rights under Mass. Gen. Laws ch. 71, 82. The First Circuit affirmed the dismissal of the complaint, holding (1) the school did not violate Plaintiffs' First Amendment rights; (2) Plaintiffs' challenges to the "emotional harm" prong of the Massachusetts statute and school policy were moot; and (3) the school did not violate Plaintiffs' rights under the Massachusetts student speech statute. View "Doe v. Hopkinton Public Schools" on Justia Law

The First Circuit affirmed the judgment of the district court denying Petitioner's petition for a writ of habeas corpus seeking to overturn his 2010 New Hampshire conviction for aggravated felonious sexual assault, holding that the district court properly rejected Petitioner's Sixth Amendment claim.In his habeas petition, Petitioner asserted that his Sixth Amendment right to autonomy to determine the objectives of his defense when his counsel took certain actions to present a defense at trial, despite Petitioner's instructions not to do so. The district court denied the petition. The First Circuit affirmed, holding that Petitioner was not denied autonomy to direct the objectives of his defense when his trial counsel presented an active defense contrary to Petitioner's express wishes. View "Kellogg-Roe v. Gerry" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's motion to suppress evidence recovered during a traffic stop, holding that the district court did not err when it denied the motion to suppress.Appellant entered a conditional guilty plea to possession of a controlled substance with the intent to distribute, reserving the right to appeal the district court's denial of his motion to suppress both statements he made at the scene of his traffic stop and the physical evidence obtained during the stop. In denying the motion to suppress, the district court concluded that the law enforcement officer had reasonable suspicion to stop Defendant's car. The First Circuit affirmed, holding that the officer had a reasonable basis to believe Appellant had committed a traffic infraction and thus to perform a traffic stop. View "United States v. Miles" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendants' joint motion to dismiss the charges against them on retrial, holding that the district court did not err.Defendants - Raymond Garraway and Cordwell Bennett - were convicted for possession with intent to distribute marijuana. Defendants moved for a mistrial. The district court granted the motion on the basis of the prosecution's improper arguments made at closing. When the prosecution began to retry them, Defendants filed a joint motion to dismiss for violation of the Double Jeopardy Clause. The district court denied the motion, finding that the prosecution did not intend to provoke a mistrial. The First Circuit affirmed, holding that the record amply supported the district court's decision. View "United States v. Garraway" on Justia Law

The First Circuit affirmed the ruling of the district court rejecting Defendant's request for a Franks hearing before Defendant entered a conditional guilty plea to one count of possession of a firearm by a prohibited person, holding that the district court did not err in denying Defendant a Franks hearing.Defendant was charged with one count of possession of a firearm by a prohibited person and one count of possession with the intent to distribute cocaine. Prior to trial, Defendant filed a motion to suppress evidence seized pursuant to search warrants and sought a Franks hearing on the basis of two alleged material omissions from the warrant affidavit. The district court denied both Defendant's Franks motion and his motion to suppress. The First Circuit affirmed, holding that the district court did not err in ruling that Defendant had failed to make the threshold showing necessary to obtain a Franks hearing. View "United States v. Leonard" on Justia Law

The First Circuit vacated the federal convictions challenged on appeal by the two defendants in this case - Noel de Leon-De la Rosa and Juan Batista Johnson-Debel - holding that vacatur was required of Defendants' challenged convictions for different reasons.Defendants were both convicted of destruction of a controlleded substance while on a vessel and conspiracy to destroy a controlled substance while on a vessel (counts five and six). The First Circuit vacated Defendants' of counts five and six, holding (1) the evidence was sufficient to support the convictions; (2) the admission of Johnson's statement in the defendants' joint trial violated De Leon's rights under the Confrontation Clause to the Federal Constitution; and (3) as to Johnson's convictions, the district court constructively amended the indictment through its instructions to the jury. View "United States v. De Leon-De la Rosa" on Justia Law

The First Circuit reversed the judgment of the district court denying Defendant's motion to vacate her federal conviction and sentence on the grounds that her appellate counsel was constitutionally ineffective under Strickland v. Washington, 466 U.S. 668 (1984), for failing to raise a claim on direct appeal under Brady v. Maryland, 373 U.S. 83 (1963), holding that the district court erred.Defendant and her co-defendants were convicted of various drug-trafficking offenses. In their direct appeals, Defendant's co-defendants successfully argued that the government's failure to produce several clearly relevant documents that plainly called into question the credibility of the government's key witnesses against Defendant and her co-defendants violated their due process rights under Brady. The First Circuit vacated the co-defendants' convictions and remanded for a new trial. Because Defendant did not raise the Brady violation on her simultaneous appeal, she was denied relief. Thereafter, Defendant brought this action pursuant to 28 U.S.C. 2255. The First Circuit reversed, holding (1) Defendant established prejudice under Strickland; and (2) the failure to raise the Brady claim was the result of deficient performance by appellate counsel. View "Flores-Rivera v. United States" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's motion to dismiss the criminal proceedings against him, holding that Appellant was statutorily barred under 8 U.S.C. 1326(d) from bringing a collateral attack in his criminal proceeding.Defendant was charged with violating 8 U.S.C. 1326, which makes it a felony to unlawfully enter the United States while an order of removal is outstanding. Defendant filed a motion to dismiss the indictment against him, arguing that the government may not use his prior removal order to prove the "outstanding order of removal" element of the crime. Defendant thus sought to dismiss his indictment based on a due process-based collateral attack on the order of removal, arguing that the entry of the order was fundamentally unfair. The district court denied the motion. The First Circuit affirmed, holding (1) Defendant's first argument had already been rejected by this Court since the district's ruling; and (2) because the removal proceeding was not fundamentally unfair Defendant did not satisfy the conditions under 8 U.S.C. 1326(d) that would permit him to collaterally attack his prior removal. View "United States v. Castillo-Martinez" on Justia Law

The First Circuit affirmed the rulings of the district court denying the Commission of the New Hampshire Department of Health and Human Services' motion to dismiss Plaintiffs' complaints against her, holding that Plaintiffs' allegations of error were without merit.Plaintiffs were (1) a class of individuals who claimed to have been held against their will without due process on the basis of a certification of their need for emergency mental health treatment, and (2) a group of hospitals who claimed to have been forced to retain persons certified to be in need of such treatment. The Commissioner moved to dismiss the claims based on Eleventh Amendment immunity and Plaintiffs' asserted lack of standing. The district court denied the motion to dismiss. The First Circuit affirmed, holding that there was no merit to the Commissioner's challenges to the district court's standing and Eleventh Amendment immunity rulings. View "Doe v. Shibinette" on Justia Law