Justia U.S. 1st Circuit Court of Appeals Opinion Summaries

Articles Posted in Civil Rights
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The First Circuit affirmed Defendant's conviction of interstate transportation of a minor with intent to engage in criminal sexual activity, holding that the district court did not err in denying Defendant's motion to suppress the confession he made during the second phase of his custodial interrogation. In support of his motion to suppress Defendant argued that the interrogation violated his Fifth Amendment rights as set forth in Miranda v. Arizona, 384 U.S. 436 (1966), and Edwards v. Arizona, 451 U.S. 477 (1981). The district court denied the motion, finding that Defendant initiated the second phase of the interview, that Defendant did not thereafter reinvade his right to counsel, and that Defendant knowingly and voluntarily waived his Miranda rights before confessing. The First Circuit affirmed, holding that Defendant's confession was admissible at trial for all of the reasons determined by the district court. View "United States v. Carpentino" on Justia Law

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The First Circuit reversed Defendant's conviction, holding that the district court erred in denying Defendant's motion to suppress seized evidence because law enforcement officers' warrantless entry into the house where Defendant was living, on the grounds that exigent circumstances existed, was unconstitutional, and there was no evidence demonstrating a different exception to the warrant requirement applied. Defendant was convicted of sixteen counts of production of child pornography and one count of possession of child pornography involving prepubescent minors. Defendant appealed the denial of his motion to suppress, arguing that the warrantless entry into his mother's house, where he was living, was presumptively unreasonable and that no exception to the warrant requirement existed. The First Circuit agreed and remanded the case to the district court to determine whether consent to the entry was given, holding that entry into the home on the basis of exigency was unconstitutional and could not serve as justification for the search and seizure that followed. View "United States v. Rodriguez-Pacheco" on Justia Law

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The First Circuit affirmed the district court's order dismissing Plaintiff's disability discrimination and failure to accommodate claims on summary judgment, holding that the district court did not abuse its discretion in partially striking Plaintiff's affidavit submitted in support of his opposition to Defendant's motion for summary judgment and that Plaintiff failed to establish a prima facie case of disability discrimination or a claim for failure to accommodate. Specifically, the Court held (1) the district court did not clearly abuse its discretion in striking Plaintiff's inconsistent statements in his affidavit; and (2) the district court properly granted summary judgment because Plaintiff failed to establish a prima facie case of disability discrimination and that Plaintiff's failure to accommodate claims failed on the merits. View "Flaherty v. Entergy Nuclear Operations, Inc." on Justia Law

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The First Circuit affirmed Defendant's convictions and dismissed without prejudice Defendant's claim of ineffective assistance of counsel, holding that Defendant was not entitled to relief on her allegations of error. Defendant was convicted of twelve counts of making a materially false statement to a federal agency. On appeal, Defendant argued, among other things, that she received ineffective assistance of trial counsel. The First Circuit affirmed, holding (1) Defendant's convictions were supported by sufficient evidence; (2) Defendant was not denied her federal constitutional right to be present at any stage of the criminal proceeding; (3) the district court did not abuse its discretion in providing a so-called "nullification instruction" to the jury; (4) Defendant waived a duplicity challenge to certain counts; and (5) the record was not sufficiently developed to permit appellate consideration of Defendant's ineffective assistance of counsel claim. View "United States v. Brown" on Justia Law

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The First Circuit affirmed Defendant's conviction of drug trafficking charges, including conspiracy to distribute one kilogram or more of heroin, and Defendant's sentence of 136 months in prison, holding that no reversible error occurred in the proceedings below. Pursuant to a search warrant, federal agents searched Defendant's apartment and found a stolen gun, more than $30,000 in cash, more than a kilo of heroin, and other narcotics and drug paraphernalia. Defendant pleaded guilty to several drug trafficking charges. The First Circuit affirmed, holding that the trial judge did not err by (1) denying Defendant's motion to suppress the evidence from his apartment; (2) denying Defendant's motion to withdraw his guilty plea; (3) deciding not to appoint new counsel and to let Defendant handle his sentencing pro se; and (4) failing to set a lower guideline sentencing range. View "United States v. Gonzalez-Arias" on Justia Law

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The First Circuit affirmed the judgment of the district court denying Defendant's motion to suppress his booking fingerprints as the fruit of what he argued was an unlawful arrest, holding that because the fingerprints were obtained for routine booking purposes there was no basis in the record for suppression of the fingerprint evidence. During a law enforcement scheme targeting a stolen identity refund fraud scheme, Defendant was administratively arrested for unlawful presence in the United States. Defendant was fingerprinted during a routine booking and later charged with multiple counts related to his involvement in the scheme. Defendant moved to suppress his booking fingerprints. The district court denied the motion, concluding that Defendant was arrested without probable cause but that the fingerprint evidence was admissible under the doctrine of inevitable discovery. The First Circuit affirmed, albeit on different grounds, holding that where the fingerprints were not obtained for any purpose other than routine booking the evidence could not be suppressed under the exclusionary rule. View "United States v. Cruz-Mercedes" on Justia Law

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The First Circuit reversed the judgment of the magistrate judge concluding that Defendant, a state drug lab supervisor, was not entitled to qualified immunity from a claim brought under 42 U.S.C. 1983 and vacated the denial of Defendant's motion to dismiss an intentional infliction of emotional distress state law claim, holding that Defendant was entitled to qualified immunity from the section 1983 claim. Plaintiff's conviction was vacated after the discovery of the drug abuse of Sonja Farak, a chemist at the Amherst Drug Lab on the campus of the University of Massachusetts. Plaintiff brought this complaint alleged that Defendant's inadequate supervision Farak constituted deliberate indifference to Defendant's constitutional rights. Defendant also claimed intentional infliction of emotional distress. The magistrate judge denied Defendant's motion to dismiss the section 1983 claim and held that Defendant's behavior showing a disregard for "repeated red flags" was enough to state a claim for intentional infliction of emotional distress under state law. The First Circuit reversed in part and vacated in part, holding (1) Defendant was entitled to qualified immunity from the section 1983 claim; and (2) because the sole basis for federal jurisdiction was dismissed the judgment on the intentional infliction of emotional distress state law claim is remanded to state court. View "Penate v. Hanchett" on Justia Law

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The First Circuit reversed in part the magistrate judge's grant of summary judgment for Defendants and dismissing Plaintiff's civil rights action, holding that the magistrate judge erred by granted summary judgment on the claims that police officers unlawfully searched Defendant's property and falsely arrested Defendant and that a jury could find that one police officer and the chief of police violated Defendant's Fourth Amendment rights. Defendant was arrested for theft after police officers obtained a warrant to search Defendant's home for certain property. Defendant later brought this action alleging that there was no probable cause for his arrest. A magistrate judge dismissed all of Defendant's claims on summary judgment. The First Circuit reversed in part, holding (1) the magistrate judge erred by granting summary judgment on the claims under the federal and state civil rights acts that the officers unlawfully searched Defendant's property; (2) the magistrate judge erred in granting summary judgment on Defendant's federal and state civil rights claims for false arrest; and (3) Defendant alleged sufficient facts that a jury might reasonably find the chief of police and one police officer liable on the Fourth Amendment claims, and the Court declined to affirm the judgment on qualified immunity grounds. View "Jordan v. Town of Waldoboro" on Justia Law

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The First Circuit reversed the judgment of the district court denying Defendant's motion for reconsideration of the denial of his motion to suppress certain evidence, holding that the district court erred in determining that Defendant's sister had either actual or apparent authority to consent to the search. Defendant filed a motion to suppress fentanyl obtained from within closed black garbage bags that were found in his sister's storage unit during a warrantless search. The district court denied the motion to suppress and denied Defendant's subsequent motion for reconsideration. Specifically, the district court concluded that Defendant's sister, who had apparent authority to consent to the search, gave it even if she did not have actual authority to give consent. The First Circuit reversed, holding that the government failed to meet its burden to show that Defendant's sister had either actual or apparent authority to consent to the search of the evidence at issue. View "United States v. Moran" on Justia Law

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The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Defendants and dismissing Plaintiff's civil rights suit alleging excessive force claims under 42 U.S.C. 1983 and Massachusetts state law, holding that the district court did not err in entering summary judgment against Plaintiff on his excessive force claims. Plaintiff was apprehended by Bellingham police officers in the woods after he was found lying in a shallow ravine with his pants unbuckled. The officers arrested Plaintiff and took him to the Bellingham police station, where Plaintiff became irrational and violent. Plaintiff pleaded guilty to several state criminal charges stemming from these incidents. Thereafter, Plaintiff filed this suit against the police officers that apprehended him in the woods and those who attempted to subdue him at the police station. The district court granted summary judgment for Defendants. The First Circuit affirmed, holding (1) Heck v. Humphrey, 512 U.S. 477 (1994), barred Plaintiff's excessive force claims arising from the events in the woods; and (2) the excessive force claims arising from the incidents at the police station failed as a matter of law because Defendants did not use excessive force against Plaintiff at the police station. View "O'Brien v. Town of Bellingham" on Justia Law

Posted in: Civil Rights