Justia Constitutional Law Opinion Summaries

The First Circuit reversed the decision of the district court denying Defendant's motion to suppress evidence obtained through a search and seizure of his vehicle, holding that the warrantless seizure of Defendant's vehicle was unlawful.Defendant was convicted of possession of marijuana and unlawful possession of a firearm by a prohibited person. On appeal, Defendant argued that law enforcement officers had no right to seize and tow his car, thereby setting it up for the inventory search that produced the evidence leading to his conviction. The First Circuit agreed, holding (1) the community caretaking exception to the warrant requirement did not apply in this case; (2) the government did not have probable cause to seize the vehicle pursuant to the Puerto Rico Uniform Forfeiture Act; and (3) the doctrine of inevitable discovery did not apply to justify the warrantless seizure of Defendant's vehicle. View "United States v. Del Rosario-Acosta" on Justia Law

In this case involving the bombing at the 2013 Boston Marathon, the First Circuit vacated Dzhokhar Tsarnaev's death sentences and reversed his three convictions for carrying a firearm during crimes of violence, holding that the judge did not meet the standard set by Patriarca v. United States, 402 F.2d 314, 318 (1st Cir. 1968), and erred in denying Tsarnaev's post-trial motion for judgments of acquittal.A jury convicted Tsarnaev of all charges for which he was indicted arising from the Boston Marathon bombing. The district judge imposed a sentence of death on six of the death-eligible counts. On appeal, Tsarnaev argued, among other things, that the judge erred in the way he handled Tsarnaev's venue-change motions and the jury-selection process. The First Circuit held (1) the trial judge in this high-profile case did not fully comply with Patriarca by running a voir dire sufficient to identify prejudice, which provided a sufficient ground to vacate Tsarnaev's death sentences; and (2) because not each of the underlying offenses constituted a crime of violence, three of Defendant's convictions for carrying a firearm for crimes of violence are reversed. View "United States v. Tsarnaev" on Justia Law

The First Circuit affirmed Defendant's plea-based conviction for conspiracy to possess with intent to distribute, holding that Defendant's prosecution did not violate constitutional double jeopardy protections.In 2011, Defendant pleaded guilty in the United States District Court of the District of Puerto Rico to conspiracy to possess with intent to distribute. In 2016, Defendant pleaded guilty in the United States District Court of the District of Puerto Rico to a drug trafficking conspiracy charge. Defendant appealed, arguing that his double jeopardy rights were violated because the two conspiracy prosecutions concerned conduct at the same "places" and charged him with violations of "the same statutory provision." The First Circuit affirmed, holding that there was a rational basis to conduct that the two conspiracies were distinct. View "United States v. Perez-Gonzalez" on Justia Law

The First Circuit vacated the judgment of the district court dismissing Plaintiff's complaint seeking to recoup assets purportedly gifted to a charitable institution for less than adequate consideration by Plaintiff's ex-husband, holding that the district court erred by dismissing Plaintiff's claims on the basis that she lacked standing.Janet and Robert Foisie entered into a divorce settlement agreement in which each party agreed to a mutually acceptable split of assets. When Janet discovered that Robert had fraudulent transferred several million dollars to the Worcester Polytechnic Institute (WPI), Janet brought a civil action against WPI asserting claims of actual and constructive fraudulent transfers under both the common law and Connecticut's version of the Uniform Fraudulent Transfer Act (UFTA). The district court dismissed the complaint. The First Circuit vacated the judgment, holding (1) Janet easily satisfied the three elements of Article III standing, and her claims were ripe; (2) a choice-of-law analysis would be better performed on a more fully developed factual record; (3) the district court erred by dismissing Janet's UFTA claims on the basis that she lacked standing as a creditor; (4) the dismissal of Janet's common law claims on preemption grounds cannot stand; and (5) Janet's UFTA and common law claims were adequately pleaded. View "Foisie v. Worcester Polytechnic Institute" on Justia Law

The First Circuit reversed the judgment of the district court granting Defendants' motions to suppress all evidence obtained directly by a pole camera, holding that the doctrine of stare decisis controlled this case and required reversal of the district court.At issue was whether the Supreme Court's opinion in Carpenter v. United States, 138 S. Ct. 2206 (2018), a cell phone location automatic tracking technology case, provided a basis for departing from otherwise binding First Circuit precedent in United States v. Bucci, 582 F.3d 108 (1st Cir. 2009) and Supreme Court precedent on which Bucci was based. The First Circuit held that, by departing from that precedent in granting Defendants' motions to suppress, the district court violated the vertical rule of stare decisis. The Court thus remanded with instruction to deny the motions to suppress. View "United States v. Moore-Bush" on Justia Law

The First Circuit affirmed Defendant's convictions and sentence for possession of firearms in furtherance of drug trafficking crimes and of possession with intent to distribute heroin and cocaine base, holding that Defendant was not entitled to reversal on any of his claims.Specifically, the First Circuit held (1) the evidence of Defendant's guilt was sufficient to support the jury's verdict; (2) the district court did not err in denying Defendant's motion to suppress the statements he provided to law enforcement or the evidence seized from the residence; (3) the district court did not clearly err in imposing the sentencing enhancement for obstruction of justice because Defendant perjured himself; and (4) the district court did not err in rejecting Defendant's request for a reduction in his offense level based on his claimed minimal participation in the offenses. View "United States v. Mendoza-Maisonet" on Justia Law

The First Circuit affirmed Defendant's conviction for production of child pornography, holding that the district court did not err in denying Defendant's motion to suppress a video on his cellphone under the private search doctrine.When Defendant's wife was looking through pictures on Defendant's cellphone she discovered a video of the couple's daughter masturbating Defendant. The wife brought the cellphone to law enforcement authorities and directed their attention to the video. Defendant was subsequently indicted on a charge of production of child pornography. Defendant moved to suppress the video and his ensuing confession, arguing that the officers violated the Fourth Amendment by accessing the video without a warrant and prior to obtaining his consent. The district court denied the motion to suppress. Defendant was subsequently convicted and sentenced to a 360-month term of immurement. The First Circuit affirmed, holding (1) under the circumstances, the officers initially could not be said to have conducted a "search" of Defendant's cellphone, and two reexaminations of the video fell within the protections of the private search doctrine; and (2) there was no procedural error at Defendant's sentencing, and the sentence was substantively reasonable. View "United States v. Rivera-Morales" on Justia Law

In this case concerning arbitration agreements, nursing homes, and wrongful death claims under Massachusetts law, the First Circuit affirmed the judgment of the district court compelling arbitration after first certifying two questions to the Massachusetts Supreme Judicial Court (SJC), holding that the SJC's decision compelled the First Circuit to affirmed the judgment compelling arbitration.The personal representative of a deceased former nursing home resident brought a state wrongful death action against a set of organizations that oversaw the nursing home (collectively, nursing home). The nursing home sued to compel arbitration. The federal court compelled arbitration. On appeal, the personal representative argued that she was not bound by the decedent’s agreement to arbitrate with the nursing home because her wrongful death right of recovery was independent of the decedent’s wrongful death claim. The First Circuit certified questions of law to the SJC. After the SJC answered that claims of statutory beneficiaries under the state's wrongful death statute are derivative of the decedent's own cause of action, the First Circuit affirmed the district court's judgment, holding that the SJC's decision required this Court to affirm the judgment compelling arbitration. View "GGNSC Chestnut Hill LLC v. Schrader" on Justia Law

The First Circuit affirmed Defendant's conviction of possessing with intent to distribute controlled substances in a protected area and conspiring to distribute controlled substances in a protected area, holding that the district court did not plainly err with respect to any of Defendant's challenges.Specifically, the First Circuit held (1) the district court did not commit plain error in admitting evidence of the conspiracy's activities occurring after he withdrew from the conspiracy or, alternatively, in not instructing the jury to ignore such evidence; (2) the district court did not plainly err in admitting evidence of a drug trafficking organization's violent acts; and (3) the delay between Defendant's indictment and arrest did not violate his Sixth Amendment right to a speedy trial. View "United States v. Perez-Couvertier" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's petition for a writ of habeas corpus, holding that, under the highly deferential standard prescribed by the Antiterrorism and Effective Death Penalty Act for federal habeas review of state criminal convictions, Appellant's claims to habeas relief failed.Appellant was convicted in a Massachusetts superior court of murder in the first degree and related crimes. The Supreme Judicial Court (SJC) affirmed the convictions. Appellant subsequently petitioned the District Court for the District of Massachusetts for a writ of habeas corpus. The district court denied the petition but granted a certificate of appealability. The First Circuit affirmed, holding (1) sufficient evidence supported Appellant's conviction for first-degree murder as a joint venturer, and the SJC's sufficiency determination was not unreasonable; and (2) the SJC reasonably determined that the trial court's admission into evidence of certain items did not constitute error. View "Gomes v. Silva" on Justia Law