Justia Constitutional Law Opinion Summaries

The First Circuit affirmed the judgment of the district court convicting Defendant of three drug trafficking offenses after law enforcement officers discovered cocaine and heroin inside of his vehicle, holding that the district court did not err in denying Defendant's motion to suppress.In his motion to suppress, Defendant argued that the officers stopped his vehicle without reasonable suspicion, in violation of the Fourth Amendment, and therefore, the drugs found inside of the vehicle were inadmissible as evidence. The district court denied Defendant's motion to suppress. The First Circuit affirmed, holding that the officers had probable cause to arrest Defendant when they conducted the vehicle containment in this case. View "United States v. Gonzalez" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellants' request for a preliminary injunction to prevent enforcement of a regulation promulgated by Maine's Center for Disease Control requiring all workers in licensed healthcare facilities to be vaccinated against COVID-19, holding that the district court did not err.Under Maine law, a healthcare worker may claim an exemption from the vaccination requirement only if a medical practitioner certifies that vaccination "may be medically inadvisable." Appellants - several Maine healthcare workers and a healthcare provider - brought this action alleging that the vaccination requirement violated their rights under 42 U.S.C. 1985 and the Free Exercise Clause, Supremacy Clause, and Equal Protection Clause of the United States Constitution. The district court denied Appellants' motion for a preliminary injunction. The First Circuit affirmed, holding that the district court did not err in concluding that Appellants were unlikely to succeed on the merits of their claims. View "Does v. Mills" on Justia Law

The First Circuit affirmed the district court's entry of summary judgment on Count I of Plaintiff's complaint seeking damages under 42 U.S.C. 1983 but reversed the entry of summary judgment on Count IX, holding that unconstitutional conduct of police officers violated the clearly established law of the Supreme Court, as set forth in Florida v. Jardines, 569 U.S. 1, 6 (2013).Plaintiff brought this complaint against the Town of Orono, the chief of the Orono Police Department, and four police officers with whom he interacted during two encounters in 2016 - one in February and one in September - both of which resulted in his being arrested without a warrant on charges that were subsequently dropped. The district court granted summary judgment in favor of Defendants. The First Circuit affirmed in part and reversed in part, holding that the district court (1) correctly granted summary judgment on Count I relating to the February incident; but (2) erred in granting summary judgment on Count IX relating to the September incident. View "French v. Merrill" on Justia Law

The First Circuit affirmed the district court's denial of Francis Lang's petition seeking a writ of habeas corpus to vacate his Massachusetts conviction for murder in the first degree, holding that the district court did not err in denying the petition.Lang was convicted in a Massachusetts court for murder in the first degree. In this action, filed pursuant to 28 U.S.C. 2254, Lang sought to vacate his conviction, arguing that his trial counsel provided ineffective assistance by failing to investigate Lang's mental health history. The district court denied the petition. The First Circuit affirmed, holding that Defendant failed to establish prejudice under Strickland v. Washington, 466 U.S. 668 (1984). View "Lang v. DeMoura" on Justia Law

The First Circuit affirmed Defendants' convictions connected with the murder of Steven DiSarro, holding that Defendants were not entitled to relief on their allegations of error.Defendants, Francis Salemme and Paul Weadick, were convicted of the 1993 murder of DiSarro. At the time of the murder, Salemme was the boss of a criminal organization known as the New England La Cosa Nostra. Defendants murdered DiSarro to prevent him from talking with federal agents about his activities with Salemme, Weadick and Salemme's son. On appeal, Defendants challenged the trial court's admission of a significant amount of evidence concerning the prior criminal activities of Salemme and several witnesses. The First Circuit affirmed, holding that the district court did not err in admitting the evidence. View "United States v. Weadick" on Justia Law

The First Circuit reversed the decision of the district court refusing to quash subpoenas seeking discovery from Rhode Island public officials and a state consultant, holding that Petitioners were entitled to a writ of advisory mandamus reversing the decision to allow the discovery sought from Rhode Island's former governor, the former speaker of Rhode Island's legislature, and former state representative.In these consolidated cases Petitioners sought to reverse the district court's decision refusing to quash subpoenas seeking discovery from Rhode Island public officials and a state consultant. Proponents of the discovery - trucking interests - asserted that the discovery was reasonably calculated to provide evidence that Rhode Island elected officials intended to discriminate against interstate commerce in charging bridge tolls. The First Circuit issued a writ of advisory mandamus reversing the decision to allow the discovery sought from certain Rhode Island public officials, holding that the district court erred in determining that the proponents' interest in obtaining evidence of the state officials' subject motives outweighed the comity considerations implicated by the subpoenas. View "American Trucking Associations, Inc. v. Raimondo" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motion to suppress his federal New Hampshire prosecution on double jeopardy grounds, holding that Defendant's double jeopardy rights did not attach in earlier Maine criminal proceedings.In 2018, Defendant was indicted in the District of Maine with criminal offenses. On January 31, 2020, the United States filed a motion to dismiss the indictment without prejudice. Defendant filed a motion for a judgment of acquittal or dismissal with prejudice, arguing that, given the government's accompanying admission that it could not prove its case and his lengthy pretrial detention, due process required an acquittal or dismissal with prejudice. The district court denied the motion and dismissed the case without prejudice. Also on January 31, 2020, the United States filed a criminal complaint in the New Hampshire district court. A grand jury issued an indictment. Defendant moved to dismiss count two on double jeopardy grounds. The district court denied the motion. The First Circuit affirmed, holding that jeopardy did not attach to Defendant's Maine criminal proceedings. View "United States v. Suazo" on Justia Law

The First Circuit affirmed Defendants' convictions of one count each of conspiracy to possess with intent to distribute and to distribute one hundred grams or more of heroin and one count each of possession with intent to distribute and distribution of heroin, holding that there was no error.Specifically, the First Circuit held (1) the district court did not err in denying Defendants' pre-trial rulings denying their motions to suppress evidence that resulted from the search of their vehicle, including their statements made during the stop; (2) the district court did not impermissibly limit the questioning of Gutierrez in violation of the Confrontation Clause; (3) the prosecutor improperly made a statement during closing argument that referred to facts not in evidence, but the statement was harmless; (4) the district court properly instructed the jury in response to a question asked during deliberations; and (5) the district court did not err in applying the mandatory minimum sentence under 21 U.S.C. 841(b)(1)(B)(i). View "United States v. Cruz-Rivera" on Justia Law

The First Circuit affirmed the decision of the district court rejecting Appellants' facial challenge to the Rhode Island comprehensive statutory scheme designed to increase transparency in regard to election-related spending, holding that there was no error.The law at issue required limited disclosure of funding sources responsible for certain independent expenditures and electioneering communications. Appellants challenged the disclosure an disclaimer provisions, arguing that the provisions did not withstand the required degree of scrutiny and infringed on constitutionally protected free-speech, privacy, and associational rights. The trial court dismissed the complaint. The First Circuit affirmed, holding that the challenged aspects of Rhode Island's disclosure and disclaimer regime were constitutional. View "Gaspee Project v. Mederos" on Justia Law

The First Circuit affirmed Defendants' cross-motions for summary judgment in this action challenging the denial of Plaintiff's application for a "permit to purchase" a firearm, holding that Defendant provided no basis on appeal for overturning the district court's grant of summary judgment to Defendants.William Lyver, the chief of police for Northborough, Massachusetts, denied Plaintiff a permit to purchase based on Plaintiff's criminal history - specifically, his two out-of-state firearms-related convictions. Plaintiff subsequently brought this action pursuant to 42 U.S.C. 1983 seeking a declaratory judgment that Mass. Gen. Laws ch. 140, 131(d)(ii)(D) violated the Second and Fourteenth Amendments to the United States Constitution. The district court upheld the provisions on the ground that they were substantially related to an important governmental interest. The First Circuit affirmed, holding that Plaintiff provided no ground for overturning the district court's grant of summary judgment to Defendants. View "Morin v. Lyver" on Justia Law