Justia Constitutional Law Opinion Summaries

The First Circuit affirmed the drug conspiracy and distribution convictions of five members of a drug trafficking organization, holding that none of the issues raised by the five defendants translated into reversible error warranting vacatur of their convictions or sentences.Fifty-five individuals were indicted on charges of conspiracy to distribute heroin, cocaine, cocaine base, marijuana, and prescription pills. By the time a jury trial began most of the defendants had pleaded guilty. Five of the defendants who were ultimately convicted appealed their convictions, and some of them appealed their sentences. The defendants were Joel Rivera-Alejandro, Carlos Rivera-Alejandro, Juan Rivera-George, Suanette Ramos- Gonzalez, and Idalia Maldonado-Pena. The First Circuit affirmed the judgments in their entirety, holding that there was no reversible error in this case. View "United States v. Maldonado-Pena" on Justia Law

The First Circuit dismissed this appeal arising in connection with a lawsuit alleging that the Equal Rights Amendment (ERA) is now part of the United States Constitution, holding that none of the plaintiffs met their burden at the pleading stage with respect to federal constitutional requirements.Plaintiffs were Equal Means Equal, a national nonprofit organization, The Yellow Roses, a student organization based in Massachusetts, and Katherine Weitbrecht, a resident of Massachusetts. Plaintiffs brought this action against David Ferriero, in his official capacity as Archivist of the United States, alleging that, after Virginia ratified the ERA in 2020, the Archivist violated 1 U.S.C. 106b when he refused to publish it and certify its adoption. The district court dismissed the claims for lack of subject matter jurisdiction. The First Circuit affirmed, holding that Plaintiffs failed to plead sufficient facts to establish standing under Article III of the United States Constitution to bring this action in federal court. View "Equal Means Equal v. Ferriero" on Justia Law

The First Circuit affirmed Defendant's conviction of possession with intent to distribute cocaine, fentanyl, and methamphetamines, holding that Defendant's challenges on appeal were unavailing.During a probation compliance check in Defendant's apartment state probation officers discovered a black case containing illegal narcotics. The police then obtained and executed a warrant to search Defendant's apartment and his two cellphones for evidence of drug dealing. On appeal, Defendant argued, among other things, that there was no probable cause to search his cellphones and that the warrant did not adequately specify which files on the phones would be searched. The First Circuit affirmed, holding (1) the trial court did not err in denying Defendant's motion to suppress evidence recovered from the cellphones; (2) there was sufficient evidence to support the convictions; and (3) Defendant was not entitled to relief on his remaining allegations of error. View "United States v. Lindsey" on Justia Law

The First Circuit affirmed Defendant's conviction of possession of a firearm in furtherance of a drug trafficking crime and possession of a controlled substance with intent to distribute entered after Defendant pled guilty pursuant to a plea agreement, holding that Defendant's argument that his plea was invalid was without merit.On appeal, Defendant argued that his plea was invalid because he entered it without knowing that he was waiving his right to appeal the trial court's denial of his motion to suppress the drugs, gun, and statements he had made following his arrest. The First Circuit affirmed, holding that, even if there was error, it was not clear or obvious. View "United States v. Casiano-Santana" on Justia Law

The First Circuit affirmed the judgment of the district court holding that the Federal National Mortgage Association (Fannie Mae) and the Federal Housing Finance Agency (FHFA) were not subject to Appellants' Fifth Amendment claims, holding that there was no error.Appellants obtained loans secured by mortgages on their real property in Rhode Island. The loans and mortgages were later sold to Fannie Mae while the FHFA was acting as Fannie Mae's conservator. Consistent with Rhode Island law, when Appellants defaulted on their loans Fannie Mae conducted nonjudicial foreclosure sales of the mortgaged properties. Appellants brought suit in a federal district court, arguing that the nonjudicial foreclosure sales violated their procedural due process rights under the Fifth Amendment. The district court dismissed those claims. The First Circuit affirmed, holding that FHFA and Fannie Mae were not government actors subject to Appellants' due process claims. View "Montilla v. Federal National Mortgage Ass'n" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment to Defendants - various prison officials, the Massachusetts Department of Correction (DOC), and Plaintiff's prison physician - and dismissing Plaintiff's complaint for injunctive and declaratory relief and damages, holding that there was no error in the proceedings below.Plaintiff, an inmate at MCI-Concord in Massachusetts, brought this pro se complaint challenging the termination of his access to the prison's first-floor Lexis Nexis terminal and typewriter, where Plaintiff spent more than two years conducting legal research and creating legal documents. The district court granted summary judgment in favor of Defendants. The First Circuit affirmed, holding (1) Plaintiff's speculative arguments as to the summary judgment in favor of his prison doctor were not enough to summary judgment; (2) the district court properly found that the DOC defendants' legitimate explanations were not pretextual; and (3) the district court did not err in determining that there was no triable issue of material fact that Defendants subjected Plaintiff to cruel and unusual punishment by discontinuing Plaintiff's reliance upon the first-floor terminal. View "Snell v. Neville" on Justia Law

The First Circuit affirmed Defendant's conviction of Hobbs Act robbery, murdering a person through the use of firearm during a crime of violence, possessing a firearm in furtherance of a crime of violence, and being a convicted felon in possession of a firearm, holding that there was no error in the proceedings below.Specifically, the First Circuit held (1) under the circumstances of this case, the district court did not err in denying Defendant's motion to suppress identification evidence; (2) the evidence was sufficient to support Defendant's convictions; and (3) the district court did not err in determining that Hobbs Act robbery qualifies as a "crime of violence" under 18 U.S.C. 924(c). View "United States v. Seary-Colon" on Justia Law

The First Circuit affirmed the the district court's denial of Petitioner's petition filed pursuant to 28 U.S.C. 2255 to vacate, set aside, or correct his sentence, holding that the district court did not err in denying the motion.Petitioner pled guilty to one count of possession of a firearm and entered into a plea agreement with the government that included a sixty-month sentencing recommendation. At sentencing, the district court imposed a 120-month sentence. The First Circuit affirmed. Thereafter, Petitioner filed this petition asserting ineffective assistance of counsel. The district court denied relief. The First Circuit affirmed, holding that Petitioner was not prejudiced by counsel's failure to object to the discrepancy between two versions of events contained in the presentence investigation report. View "Fernandez-Garay v. United States" on Justia Law

The First Circuit denied Plaintiff's motion for an injunction preventing the implementation of a plan promulgated by the Boston Public Schools for admitting students to Boston Latin School, Boston Latin Academy, and John D. O'Bryant School of Mathematics and Science for the 2021-2022 school year, holding that Plaintiff did not show it was not entitled to the injunction.Plaintiff, a corporation acting on behalf of fourteen parents and children residing in Boston, asserted that the 2021-2022 admissions plan violated the Equal Protection Clause of the Fourteenth Amendment and Mass. Gen. Laws ch. 76, 5. The district court entered judgment in Defendants' favor. Plaintiff appealed and moved for an order under Fed. R. Civ. P. 62(d) enjoining Defendants from implementing the plan during the pendency of this appeal. The First Circuit denied the motion, holding that Plaintiff failed to show a strong likelihood that it would prevail on the merits. View "Boston Parent Coalition for Academic Excellence Corp. v. School Committee of City of Boston" on Justia Law

The First Circuit affirmed the decision of the Bankruptcy Appellate Panel for the First Circuit (BAP) affirming the judgment of the bankruptcy court finding that Debtor defaulted on his obligation and refusing to grant him a discharge, holding that Debtor's assignments of error were unavailing.Debtor filed a petition for Chapter 13 bankruptcy in the District of Massachusetts. The case was subsequently converted to a Chapter 7 case. After Debtor failed to file any of the documents mandated by court orders the court entered a further order requiring Debtor to file the overdue documents by a certain date. Debtor did not heed the order. After a show cause hearing, the bankruptcy court denied Debtor a discharge and dismissed his petition for failing to ignore the court's orders. The BAP affirmed. The First Circuit affirmed, holding that Debtor received the constitutional protections to which he was entitled and that, due to Debtor's conduct, the bankruptcy court's denial of a discharge was within its discretion. View "Francis v. Desmond" on Justia Law