Justia Constitutional Law Opinion Summaries

The First Circuit affirmed Defendant’s conviction for being a felon in possession of ammunition but vacated his sentence. On appeal, Defendant argued that the district court erred in denying his motion to suppress evidence obtained from a warrantless search of the vehicle he was driving and that the district court erred in finding that he qualified for a mandatory minimum sentence under the Armed Career Criminal Act (ACCA). The First Circuit held (1) under the circumstances of this case, the automobile exception to the Fourth Amendment’s warrant requirement applied, and the search of the vehicle Defendant was driving was reasonable; and (2) Defendant was improperly sentenced as an armed career criminal. The court remanded the case for resentencing with the ACCA enhancement. View "United States v. Kennedy" on Justia Law

The First Circuit affirmed the decision of the district court granting the Rhode Island State Board of Election's motion for judgment on the pleadings with respect to Plaintiff's claims that his constitutional rights were violated by the manner in which his employment was brought to an end. The district court concluded that Plaintiff, a quondam employee of the Board, had not shown a deprivation of any constitutionally protected interest. The First Circuit affirmed, holding (1) Plaintiff failed to allege facts sufficient to show a constitutionally protected property interest in his job, and therefore, Plaintiff's loss-of-employment claim failed; and (2) Plaintiff failed to allege sufficient facts to make his claim that the Board stigmatized him plausible. View "Kando v. Rhode Island Board of Elections" on Justia Law

The First Circuit affirmed the district court's dismissal of a complaint filed by unions representing the firefighters and police officers employed by the City of Cranston. The Unions filed a complaint claiming that legislation modifying various state-run pension plans for government employees, including a plan that covered municipal firefighters and police officers, unconstitutionally repudiated contractual obligations owed to the City employees. The district court dismissed the complaint. The First Circuit affirmed, holding (1) the complaint failed to allege that the legislation at issue unconstitutionally impaired any contractual rights of the Unions' members; (2) federal court was not the proper forum to litigate the Unions' undeveloped claims that the City was failing to abide by the terms of its ordinances or collective bargaining agreements; and (3) this lawsuit provided no opportunity to challenge the terms of a settlement by other parties in another lawsuit. View "Cranston Firefighters, IAFF v. Raimondo" on Justia Law

The First Circuit reversed the trial judge’s dismissal of counts in an indictment that charged Defendants with dispensing misbranded drugs in violation of the Federal Food, Drug, and Cosmetic Act (FFDCA).Defendants, Massachusetts-licensed pharmacists, were charged with multiple crimes, including the allegation that Defendants dispensed drugs in violation of the FFDCA. The trial judge granted Defendants’ motions to dismiss the FFDCA charges, ruling that the indictment did not provide fair notice. The First Circuit reversed, holding that the indictment passed muster because it gave Defendants enough information to prepare a defense and to invoke double-jeopardy protections to forestall a later trial on the same charges. View "United States v. Stepanets" on Justia Law

The First Circuit reversed the district court's denial of Appellant’s petition for a writ of habeas corpus challenging his convictions for armed assault with intent to murder and other offenses, holding that trial counsel’s failure to move to suppress Appellant’s statements to a police officer while in custody constituted ineffective assistance of counsel under clearly established law.In his petition for a writ of habeas corpus, Appellant argued, inter alia, that he was deprived of effective assistance of counsel because trial counsel failed to move to suppress his statements to the police officer. The district court denied the writ. The First Circuit reversed, holding that trial counsel’s deficient performance was sufficiently prejudicial to constitute a violation of Appellant’s Sixth Amendment right to counsel. View "Rivera v. Thompson" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant’s motion to suppress drug evidence found on his person during a traffic stop.A law enforcement officer stopped a vehicle in which Defendant was a passenger for a traffic violation. On appeal from the denial of his motion to suppress, Defendant argued that the officer violated Defendant’s Fourth Amendment rights by unreasonably extending the duration of the traffic stop and that the district court erred in ruling that the inevitable discovery exception to the exclusionary rule applied to the drug evidence found during the resulting patdown search, which the government conceded was unlawful. The First Circuit affirmed, holding (1) the officer did not unlawfully prolong the traffic stop; and (2) the proper scope of a patdown search was exceeded in this case, but the district court properly applied the inevitable discovery rule. View "United States v. Clark" on Justia Law

The First Circuit reversed the district court’s judgment ruling that Defendant had a reasonable expectation of privacy under the Fourth Amendment in the motel room where he was at the time of a police search of the premises, holding that Defendant, a guest of a guest in the motel room, did not have a reasonable expectation of privacy in the motel room.Defendant was charged with possession with intent to distribute a mixture or substance containing cocaine based and aiding and abetting such conduct. Defendant moved to suppress the evidence seized as a result of the search of the motel room where he had been staying. The district court ruled that the search violated the Fourth Amendment and suppressed the evidence. The First Circuit reversed and remanded, holding (1) the district court properly found that Defendant was the guest of a guest; but (2) Defendant failed to demonstrate an objectively reasonable expectation of privacy in the motel room. View "United States v. Aiken" on Justia Law

In this case alleging violations of 42 U.S.C. 1983 and tort claims, the First Circuit affirmed the district court’s grant of summary judgment in favor of Defendants following Plaintiffs’ failure to oppose the motion with the timeframe set by the court. Almost one month after Plaintiffs’ opposition to Defendants’ summary judgment motion was due, the district court granted Defendants’ unopposed motion for summary judgment. Two days later, Plaintiff filed a motion for relief from judgment pursuant to Fed. R. Civ. P. 60(b)(1) on the ground of excusable neglect. The district court denied relief, determining that Plaintiffs’ failure to oppose the summary judgment motion was not excusable. The First Circuit affirmed, holding that the district court acted within its discretion in concluding that Plaintiff failed to demonstrate excusable neglect. View "Skrabec v. Town of North Attleboro" on Justia Law

The First Circuit affirmed Appellant’s federal convictions and resulting sentence for five counts of bank robbery. The court held that, contrary to the arguments raised by Appellant on appeal, the district court did not err in denying Appellant’s motions for (1) a hearing pursuant to Franks v. Delaware, 438 U.S. 154 (1978), based on Appellant’s failure to make the requisite preliminary showing, regarding warrants that were issued to install Global Positions System (GPS) tracking devices; (2) the suppression of evidence obtained from the GPS tracking devices installed pursuant to those warrants where the supporting affidavit provided probable cause for the warrants and for the installation of the GPS tracking devices; and (3) the suppression of evidence obtained as the result of Appellant’s arrest where the probable cause standard was met. View "United States v. Patterson" on Justia Law

The First Circuit affirmed the district court’s dismissal of Plaintiffs’ suit challenging the Social Security Administration’s (SSA) termination of tier disability benefits for lack of subject matter jurisdiction based on Plaintiffs’ failure to have exhausted their administrative remedies.After the SSA terminated the disability benefits that Plaintiffs had been receiving, Plaintiffs challenged that decision administratively. Before they had exhausted the administrative review process, however, Plaintiffs filed suit in federal court seeking various kinds of relief based presumably on the same grounds as the claims that had presented to the SSA in seeking to continue to receive their benefits. The district court granted the government’s motion to dismiss for lack of subject matter jurisdiction, concluding that Plaintiffs failed to exhaust their administrative remedies. The First Circuit affirmed, holding that Plaintiffs failed to show that they could not obtain a restoration of their benefits through the administrative review process, despite evidence suggesting that they would have a substantial chance of doing so. View "Justiniano v. Social Security Administration" on Justia Law