Justia Constitutional Law Opinion Summaries

In this case, the United States Court of Appeals for the First Circuit examined an appeal against a district court's refusal to issue a preliminary injunction against the enforcement of a Rhode Island law banning certain large-capacity ammunition magazines. The plaintiffs, a group of gun owners and a registered firearms dealer, argued that the law infringed upon their Second Amendment rights, as well as their rights under the Fifth and Fourteenth Amendments.The Court of Appeals, however, upheld the district court's decision. It noted that the law did not impose a significant burden on the right of armed self-defense, as it did not prevent gun owners from owning other forms of weaponry or ammunition, and the banned magazines were rarely used in self-defense situations. Furthermore, the court found that the law was consistent with a longstanding tradition of regulating firearms in the interest of public safety.The court also rejected the plaintiffs' arguments that the law was retroactive and vague, violating their Fourteenth Amendment rights. It concluded that the law was not retroactive as it did not impose new liability on past actions, and it was not unconstitutionally vague as individuals of ordinary intelligence could understand what it prohibited. The court also found that the plaintiffs were unlikely to succeed on their Fifth Amendment claims, as the law did not effect a physical or regulatory taking of their property. View "Ocean State Tactical, LLC v. Rhode Island" on Justia Law

In Rhode Island Truck Center, LLC v. Daimler Trucks North America, LLC, the United States Court of Appeals for the First Circuit was asked to determine whether a Rhode Island truck dealer could challenge a ruling by a Rhode Island state agency that it lacked jurisdiction to grant relief for alleged violations of a Rhode Island law regulating motor-vehicle dealers and manufacturers. The violations in question were committed by an out-of-state truck manufacturer. The plaintiff, Rhode Island Truck Center, LLC ("RITC"), argued that the manufacturer's establishment of a dealership outside of Rhode Island violated the law and harmed RITC's business. The District Court granted summary judgment to the manufacturer, Daimler Trucks North America, LLC, arguing that the state agency lacked authority to apply Rhode Island law extraterritorially.The Court of Appeals concluded that it had subject-matter jurisdiction over the case under the federal-question jurisdiction. The court then certified a question of state law to the Rhode Island Supreme Court concerning whether a "relevant market area" specified in Rhode Island law could extend beyond Rhode Island's borders. The court affirmed the District Court's grant of summary judgment on another claim, where RITC challenged the Board's dismissal of a claim related to Daimler's denial of a Western Star franchise to RITC. The court held that the District Court did not err in concluding that the relief requested would have an extraterritorial effect that violated the Dormant Commerce Clause. View "Rhode Island Truck Ctr v. Daimler Trucks North America" on Justia Law

In the case before the United States Court of Appeals for the First Circuit, plaintiff Shawn McBreairty claimed that a local school-board policy violated his First Amendment rights by restricting what he could say at the board's public meetings. McBreairty sought a temporary restraining order and preliminary injunction against the policy. The defendants were the School Board of Regional School Unit 22 in Maine and Heath Miller, the Board's chair. The policy in question prohibited public complaints or allegations against any school system employee or student during board meetings. It also allowed the Chair to terminate any presentation that violated these guidelines or the privacy rights of others.McBreairty had been stopped from criticizing school employees during two separate board meetings. Each time, after he mentioned a teacher's name and criticized their practices, the Chair warned him to stop, the video feed was cut, and the police were contacted to remove him from the premises. He was not arrested or charged with any crime on either occasion.The District Court denied McBreairty's request for a temporary restraining order and preliminary injunction. He then appealed this decision. While this appeal was pending, the School Board amended the policy in question.The Court of Appeals vacated the decision of the District Court, not on the merits of McBreairty's First Amendment claims, but on the grounds that he lacked standing to seek the injunctive relief at issue. The Court reasoned that McBreairty did not sufficiently demonstrate an intention to engage in the allegedly restricted speech at future board meetings, which is necessary to establish a concrete, live dispute rather than a hypothetical one. The Court thus concluded that it did not have jurisdiction to hear the case under Article III of the Constitution. The case was remanded to the District Court for further proceedings. View "McBreairty v. Miller" on Justia Law

In this case, Grace Katana appealed his conviction for conspiracy to interfere with interstate commerce by robbery in violation of the Hobbs Act. He argued that the indictment accused him of conspiring to rob Joseph Wilson, while the government only proved at trial that he had planned a break-in at Wilson's home. Katana claimed that this constituted a constructive amendment to the indictment in violation of his constitutional rights, that there was a prejudicial variance from the charge in the indictment, and that there was insufficient evidence to support his conviction.The United States Court of Appeals for the First Circuit rejected Katana's arguments and affirmed his conviction. The court found that the offense charged in the indictment was the same offense on which the court instructed the jury and on which the government presented evidence. The court also held that the identity of the robbery target was not an element of a robbery or conspiracy to commit robbery under the Hobbs Act, so focusing on Wilson's home business as the target at trial did not amount to a constructive amendment. The court further concluded that Katana failed to demonstrate that any variance from the indictment was prejudicial, as the record showed he had sufficient notice of, and was able to defend himself against, the government's theory at trial. Finally, the court ruled that a rational jury could have concluded that Katana and his co-conspirators planned to rob Wilson's home business, so there was sufficient evidence to support his conviction. View "US v. Katana" on Justia Law

In the case before the United States Court of Appeals for the First Circuit, the defendant, Randall Crater, was convicted of wire fraud, unlawful monetary transactions, and operating an unlicensed money transmitting business based on his involvement in a cryptocurrency scheme. The trial lasted eight days and was based on Crater's management of My Big Coin (MBC), a cryptocurrency company that allegedly misrepresented itself as a gold-backed digital currency and claimed a partnership with MasterCard. The defendant appealed two of the district court's rulings.Firstly, Crater argued that the district court violated his Sixth Amendment right to compulsory process by refusing to enforce subpoenas against three federal agency witnesses due to Crater's non-compliance with the agencies' Touhy regulations. Secondly, Crater contended that the district court did not perform its gatekeeping duty by admitting testimony from the government's cryptocurrency expert without holding a Daubert hearing.However, the Court of Appeals affirmed the district court's decision, stating that Crater's arguments could not be reconciled with controlling precedent or the record in the case. The court found that Crater's failure to show how the excluded testimony of the federal agents would have been both material and favorable to his defense invalidated his Sixth Amendment claim. Furthermore, the court held that Crater's objections to the expert witness's qualifications and methodology were insufficient to necessitate a Daubert hearing. View "US v. Crater" on Justia Law

The case concerns the appeal of Gilbert Perez, who sought to have his federal drug conviction overturned on the basis that the United States District Court for the District of Maine had incorrectly denied his motion to suppress the outcomes of a warrantless search of his backpack. Perez argued that the search was not justified under the search-incident-to-arrest exception to the warrant requirement of the Fourth Amendment to the U.S. Constitution. The District Court, relying on a previous case (United States v. Eatherton), had upheld the search. Perez contended that subsequent Supreme Court decisions had undermined the validity of Eatherton.On the night of his arrest, Perez had been seen acting suspiciously in a McDonald’s parking lot in Lawrence, Massachusetts. When he left the lot, carrying a backpack, he was monitored by state troopers. He was seen exiting a taxi, and large quantities of cash were found in the vehicle, arousing suspicion that he had been involved in a drug transaction. When Perez returned to the McDonald’s lot, he was approached by Trooper Jason Conant, who identified himself as a state trooper. Perez ran but was caught, and the backpack was removed from him and searched. The search revealed it contained fentanyl and cocaine. Perez was subsequently indicted on a federal drug-related charge.In his appeal, Perez maintained that the backpack's search was a violation of the Fourth Amendment. The United States Court of Appeals for the First Circuit disagreed, affirming the judgement of conviction. It concluded that neither of the Supreme Court cases cited by Perez had invalidated the Eatherton ruling. The panel also rejected the notion that Perez's backpack could be considered separate from his person at the time of arrest. As such, it fell within the search-incident-to-arrest exception to the Fourth Amendment's warrant requirement. View "US v. Perez" on Justia Law

Former executives of medical device manufacturer Acclarent, Inc., William Facteau and Patrick Fabian, were found guilty of multiple misdemeanor violations of the Federal Food, Drug, and Cosmetic Act (FDCA) for commercially distributing an adulterated and misbranded medical device. They appealed their convictions, claiming First Amendment violations, due process violations, and insufficiency of evidence. The United States Court of Appeals for the First Circuit rejected all of these claims and affirmed the convictions. The court held that the use of promotional speech as evidence of a device's intended use did not implicate the First Amendment. The court also found that the term "intended use" was not unconstitutionally vague and that Facteau and Fabian had fair warning of the conduct prohibited under the FDCA. Finally, the court found that the evidence was sufficient to support the convictions and that Fabian's fine did not violate the Eighth Amendment. View "United States v. Facteau" on Justia Law

In a drug trafficking case, the defendant, Amanda Cowette, appealed the district court's denial of her motion to suppress statements she made to law enforcement officers on July 16 and 17, 2018. Cowette argued that she unequivocally invoked her Fifth Amendment right to counsel and any subsequent questioning by law enforcement officers was in violation of that right. She contended that the district court's ruling to the contrary was in error. The United States Court of Appeals for the First Circuit agreed with Cowette and held that she properly invoked her Fifth Amendment right to counsel. The court found that the phrase "I guess" used by Cowette did not create any ambiguity in her clear invocation of her right to counsel. The court vacated the decision of the district court in part, affirmed in part, and remanded for proceedings consistent with this opinion. View "US v. Cowette" on Justia Law

The United States Court of Appeals for the First Circuit affirmed the convictions of Rafael Cardona Sr. and Isaac Cardona for conspiracy to distribute and possess with intent to distribute cocaine and heroin. Isaac Cardona was also convicted of conspiracy to commit money laundering with intent to promote the carrying on of unlawful activity. The defendants raised several arguments on appeal.Rafael Cardona Sr. argued that his two convictions were multiplicitous in violation of the Double Jeopardy Clause. The court concluded that this argument was not reviewable because it was raised for the first time on appeal and not supported by good cause, as required under Federal Rules of Criminal Procedure 12(b)(3) and 12(c)(3).Isaac Cardona argued that the money laundering statute under which he was charged is unconstitutionally vague. The court determined that this argument was not reviewable because it was not raised before trial, as required by Rule 12(b)(3). Isaac Cardona also argued that there was insufficient evidence to support his money laundering conviction and that the court gave erroneous jury instructions on this charge. The court found sufficient evidence to support the conviction and concluded that the erroneous instructions did not affect his substantial rights.The case arose from surveillance footage, recorded communications between the defendants and other co-conspirators, and other evidence showing that the defendants conspired to distribute cocaine and heroin and that Isaac Cardona conspired to commit money laundering by using the proceeds of cocaine distribution to procure and resell heroin. View "US v. Cardona" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment to Defendants, several city officials of the City of Gloucester, Massachusetts, in this First Amendment action brought by Plaintiff, the Harbormaster of the city, holding that Defendants were entitled to qualified immunity.In his complaint, Plaintiff claimed that Defendants violated his rights under the First Amendment by retaliating against him for his giving expert testimony in a maritime tort dispute. The district court granted summary judgment for Defendants, concluding that they were entitled to qualified immunity. The First Circuit affirmed, holding that, at the time of the alleged retaliation, the law did not clearly establish that the value of Plaintiff's speech outweighed the city's interest in the efficient provision of public services by the Harbormaster's office. View "Ciarametaro v. City of Gloucester" on Justia Law