Justia Constitutional Law Opinion Summaries

The First Circuit affirmed the district court’s denial of Appellant’s motion to dismiss the indictment against him on double jeopardy and issue preclusion grounds, holding that the Double Jeopardy Clause had no application and that Appellant’s issue preclusion claim would fail on the merits even if it were not waived.In preliminary hearings, Puerto Rico courts concluded that Commonwealth weapons charges against Appellant were not supported by probable cause. Thereafter, Appellant plead guilty to equivalent federal charges based on the same conduct. Appellant later moved the district court to dismiss his indictment as a violation of the Double Jeopardy Clause. After a magistrate judge made a report and recommendation, Appellant raised for the first time his issue preclusion claim. The district court denied Appellant’s motion. The First Circuit affirmed, holding that Appellant was not entitled to relief on his claims. View "United States v. Rosado-Cancel" on Justia Law

The First Circuit reversed an vacated the order of the district court granting Defendant’s motion to suppress identification evidence and giving preclusive effect to a Puerto Rico Court of Appeals’ order suppressing the same evidence in a local proceeding for different offenses, holding that the district court deviated from this Court’s precedent in so ruling.The district court concluded that because Puerto Rico and the United States are a single sovereign for purposes of the Double Jeopardy Clause, the court was bound by the local court’s judgment suppressing identification evidence, even where federal prosecutors did not participate in the proceedings. The First Circuit reversed, holding (1) the district court deviated from the holding in United States v. Bonilla Romero, 836 F.2d 39, 43-44 (1st Cir. 1987), that suppression of evidence by a Puerto Rico court does not require a federal court to suppress that same evidence unless federal prosecutors were a party, or were in privity with a party, to the suppression hearing in the Puerto Rico court; and (2) because there was no privity between the two prosecuting authorities in this case, collateral estoppel was inapplicable. View "United States v. Santiago-Colon" on Justia Law

The First Circuit affirmed Defendant’s conviction of interstate domestic violence and discharge of a firearm during and in relation to a crime of violence and sentence of life imprisonment, holding that there was no reason to vacate Defendant’s convictions or sentence on the grounds that he presented on appeal.Specifically, the First Circuit held (1) the district court did not err in denying Defendant’s motion to suppress evidence; (2) the evidence was sufficient to support Defendant’s convictions; (3) Defendant’s sentence was both procedurally and substantively reasonable; and (4) the district court did not err in denying Defendant’s motion to dismiss the indictment on double jeopardy grounds. View "United States v. Owens" on Justia Law

The First Circuit affirmed the district court’s dismissal of Plaintiffs’ complaint against the Financial Oversight and Management Board for Puerto Rico (Board) and its members and executive director alleging that the Board had exceeded its power under the Puerto Rico Oversight, Management and Economic Stability Act (PROMESA) during the 2019 fiscal plan and territory budget development and certification processes, holding that the complaint was properly dismissed.The district court granted Defendants’ motion to dismiss for lack of subject matter jurisdiction and for failure to state a claim to relief. The First Circuit affirmed, holding (1) the federal courts lacked jurisdiction the portion of the complaint seeking declaratory and injunctive relief; (2) the district court properly found that it lacked jurisdiction over the claims challenging the Board’s budget certification decisions; and (3) the district court properly dismissed for failure to state a claim for relief the claims that the Board exceeded its authority under PROMESA. View "Mendez-Nunez v. Financial Oversight & Management Board for Puerto Rico" on Justia Law

The First Circuit affirmed the district court’s entry of summary judgment for Defendants in this case, holding that an objectively reasonable police officer in May 2013 could have concluded that a single use of a Taser to quell a nonviolent, mentally ill person who was resisting arrest did not violate the Fourth amendment and that, in any case, the officer here was shielded by qualified immunity.Plaintiff, a mentally ill person who was tased after absconding from the hospital to which she had been involuntarily committed, sued the officer and the Town of Athol, Massachusetts asserting causes of action under 42 U.S.C. 1983 and Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12131-65, along with supplemental state-law claims for, inter alia, assault and battery and malicious prosecution. The magistrate judge found no violation of the Fourth Amendment under section 1983 and no viable state-law claims, that the officer was entitled to qualified immunity, and that there was no violation of the ADA. The First Circuit affirmed, holding (1) Plaintiff presented sufficient evidence to make out a jury question as to whether the officer used excessive force, but the officer was entitled to qualified immunity; and (2) Plaintiff was not entitled to relief on any of her remaining claims. View "Gray v. Cummings" on Justia Law

The First Circuit held that members of the Financial Oversight and Management Board (Board Members) created by the 2016 Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA) are “Officers of the United States” subject to the U.S. Constitution’s Appointments Clause and directed the district court to enter a declaratory judgment to the effect that PROMESA’s protocol for the appointment of Board Members is unconstitutional and must be severed.This matter arose from the restructuring of Puerto Rico’s public debt under PROMESA. May 2017, the Board exercised its authority under Title III of PROMESA to initiate debt adjustment proceedings on behalf of the Puerto Rico government. Appellants sought to dismiss the Title III proceedings, arguing that the Board lacked authority to initiate them because the Board Members were illegally appointed in contravention of the Appointments Clause. The district court rejected Appellants’ motions to dismiss. The First Circuit reversed in part, (1) the Territorial Clause does not displace the Appointments Clause in an unincorporated territory such as Puerto Rico; (2) Board Members are “Principal” “Officers of the United States” subject to the Appointments Clause; and (3) therefore, the process PROMESA provides for the appointment of Board Members is unconstitutional. View "Aurelius Investments, LLC v. Commonwealth of Puerto Rico" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Plaintiff’s claims under 42 U.S.C. 1983 and various state laws, holding that the district court properly dismissed Plaintiff’s claims under Fed. R. Civ. P. 12(b)(6).Plaintiff, a captain in the Chicopee Police Department, brought this action against the City, its police chief and mayor, a fellow police officer, and other defendants, alleging that his First Amendment rights were violated after Defendants improperly targeted him for “speaking out and participating in a government investigation.” The district court dismissed Plaintiff’s claimed under Rule 12(b)(6). The First Circuit affirmed, holding that the district court (1) properly dismissed Plaintiff’s First Amendment claim because al of Plaintiff’s speech was made within the scope of his official duties rather than as a citizen; and (2) did not err in dismissing the state law claims. View "Gilbert v. City of Chicopee" on Justia Law

The First Circuit reversed in part and affirmed in part the district court’s grant of summary judgment to all Defendants on Plaintiff’s claims of discrimination, unlawful retaliation, and violations of the Equal Protection Clause and the First Amendment, holding that summary judgment was properly granted as to Rodney Bouffard and Troy Ross but improperly granted as to Correct Care Solutions, LLC (CCS) and Maine Department of Corrections (MDOC).Plaintiff was employed by CCS at a MDOC prison. After MDOC revoked Plaintiff’s prison security clearance and CCS terminated Plaintiff’s employment, Plaintiff sued CCS, MDOC, and Bouffard, the warden, and Ross, the deputy warden, bringing claims under the Maine Human Rights Act (MHRA) and 42 U.S.C. 1983. The district court granted summary judgment for Defendants on all claims. The First Circuit held (1) a reasonable jury could find that Plaintiff’s work environment was hostile; (2) summary judgment was properly granted in favor of the warden and deputy warden based on qualified immunity; (3) an employer can be liable for a hostile work environment created by non-employees as long as the employer knew of the harassment and failed to take reasonable steps to address it; and (4) summary judgment was improper was to MDOC and CCS. View "Roy v. Correct Care Solutions, LLC" on Justia Law

The First Circuit denied and dismissed Petitioner’s petition challenging the Board of Immigration Appeals’s (BIA) denial of her motion to reopen and the BIA’s decision not to exercise its sua sponte authority to reopen her case to grant her request for an adjustment of status, holding that Petitioner was not entitled to relief.Specifically, the First Circuit held (1) Petitioner’s petition for review was denied as to her challenge to the BIA’s determination that the motion to reopen was untimely; and (2) because Petitioner had no colorable constitutional or legal claim on which the Court might base jurisdiction, the petition was dismissed for lack of jurisdiction as to Petitioner’s challenge to the BIA’s decision not to exercise its authority to reopen sua sponte. View "Gyamfi v. Whitaker" on Justia Law

The First Circuit affirmed Defendant’s convictions of two counts of drug trafficking in international waters while aboard a stateless vessel in violation of the Maritime Drug Law Enforcement Act (MDLEA), 46 U.S.C. 70501-08, holding that Defendant’s challenges to his convictions failed but that the district court erred in denying Defendant a minor participant reduction under section 3B1.2(b) of the Sentencing Guidelines.Specifically, the Court held (1) in light of prior precedent concerning Defendant’s assertion about the content of international law, the Court must reject Defendant’s constitutional contention regarding the scope of Congress’s power to criminalize his conduct that he argued lacked any nexus to the United States; and (2) because Amendment 794 to the Sentencing Guidelines, which added five factors to the application note, applies retroactively, this case must be remanded for resentencing so that the district court can have an opportunity to apply the new factors. View "United States v. Aybar-Ulloa" on Justia Law