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

A group of eleven current and former employees of the Woods Hole, Martha’s Vineyard and Nantucket Steamship Authority challenged the Authority’s COVID-19 vaccine mandate, which required all employees to be fully vaccinated unless they qualified for a medical or religious exemption. The policy allowed for exemptions if an employee provided sufficient medical documentation or demonstrated a sincerely held religious belief, provided that reasonable accommodations could be made without undue burden to the Authority. Thirteen employees applied for religious exemptions, but only the request of one fully remote employee was granted. One employee received a temporary medical exemption but was ultimately terminated after refusing vaccination once that exemption expired. Four appellants later became vaccinated and remained employed; the remaining seven were fired for noncompliance.After the Authority enacted its policy, the plaintiffs filed suit, alleging violations of their rights under the Massachusetts Declaration of Rights, the First and Fourteenth Amendments, and Massachusetts anti-discrimination law. The state court initially granted a temporary restraining order, but after removal to the United States District Court for the District of Massachusetts, the district court denied their preliminary injunction request. On a prior appeal, the United States Court of Appeals for the First Circuit affirmed the denial as to most claims but remanded for further consideration of the First Amendment claim, instructing the district court to address the relevance of the granted medical exemption and to determine the appropriate level of scrutiny.On remand, the district court again denied a preliminary injunction, finding the policy to be generally applicable and thus subject to rational basis review, which it held the policy satisfied. The United States Court of Appeals for the First Circuit affirmed, holding that the policy’s medical and religious exemptions were not comparable for Free Exercise purposes, the policy was generally applicable, and the Authority’s interests justified the mandate under rational basis review. View "Brox v. Woods Hole, Martha's Vineyard & Nantucket Steamship Authority" on Justia Law

Marilyn Besosa-Noceda moved from Puerto Rico to Texas with her daughter, whose biological father, Emmanuel Santiago-Melendez, objected to the relocation and subsequently filed criminal charges against Besosa, alleging she deprived him of access to his child. Santiago’s complaint led to Besosa’s arrest in Texas and extradition to Puerto Rico. Ultimately, the criminal charges were dismissed after Besosa demonstrated a lack of probable cause.After the dismissal, Besosa filed suit in the United States District Court for the District of Puerto Rico against the police officer who received Santiago’s complaint, the prosecutor who authorized the criminal charges, and the prosecutor’s supervisor. She alleged malicious prosecution under 42 U.S.C. § 1983 and Commonwealth law, claiming her constitutional rights were violated by the initiation of legal process unsupported by probable cause. The defendants moved for summary judgment, which the district court granted. The court found the arrest warrant was issued by a judge based on probable cause and was not obtained through false statements or omissions. The district court also rejected Besosa’s claim that her absence from the probable cause hearings violated her rights, finding no entitlement under Commonwealth law to be present at such hearings.On appeal, the United States Court of Appeals for the First Circuit reviewed Besosa’s arguments, including a challenge to an unresolved discovery dispute and the merits of the summary judgment ruling. The First Circuit held that Besosa failed to invoke the proper procedural mechanism to delay summary judgment pending discovery and that she did not present evidence showing the defendants knowingly provided false information or recklessly disregarded the truth when seeking the arrest warrant. The First Circuit affirmed the district court’s grant of summary judgment for the defendants. View "Besosa-Noceda v. Capo-Rivera" on Justia Law

Two long-time residents of Nashua, New Hampshire, sought to fly various flags on a designated "Citizen Flag Pole" located at City Hall Plaza. The City had previously allowed private citizens and groups to fly flags representing diverse causes and cultural events on this pole, with minimal oversight and no substantive review of flag content. After one of the plaintiffs flew a "Save Women's Sports" flag, the City received complaints, revoked permission, and removed the flag, stating that it was discriminatory toward the transgender community. Subsequently, the City adopted a written policy in 2022 asserting that the flagpole’s use constituted government speech and reserving the right to deny flags not aligned with City policies.The plaintiffs filed suit in the United States District Court for the District of New Hampshire, alleging violations of the First and Fourteenth Amendments and seeking a preliminary injunction to prevent viewpoint-based denials of flag applications. Before the City filed its opposition, it enacted a new policy to exercise exclusive government control over the flagpoles. The magistrate judge recommended denying the injunction, finding the flag program to be government speech, and the district court adopted that recommendation and denied relief. The plaintiffs then appealed to the United States Court of Appeals for the First Circuit.The First Circuit reviewed the district court’s denial for abuse of discretion and legal conclusions de novo. Applying the government speech test from Shurtleff v. City of Boston, the court held that Nashua’s Citizen Flag Pole program was not government speech, but rather operated as a forum for private expression. Because Nashua conceded that, absent a government speech determination, its actions constituted impermissible viewpoint discrimination, the First Circuit reversed the district court. The case was remanded with instructions to enter interim declaratory relief in favor of the plaintiffs. View "Scaer v. City of Nashua" on Justia Law

A thirteen-year-old student in Brewer, Maine, developed a relationship with a twenty-year-old man, who was a coach associated with her school. Over two years, the man sexually assaulted the student multiple times. During that period, rumors circulated at the local high school about their inappropriate relationship. The student reported these rumors to the principal, denied any truth to them, and the principal took limited follow-up action. Other school staff and a police officer had some interactions with the student and the perpetrator, but no one reported or investigated the abuse at the time. The student, now an adult, later sued various school officials, the school department, a police officer, and others, alleging they failed to protect her from abuse despite being aware of warning signs, and sought relief under federal and Maine law.At the United States District Court for the District of Maine, most claims were dismissed at the pleading stage for failing to state a claim. The remaining claims, including those brought under Title IX and 42 U.S.C. § 1983, were resolved in favor of defendants at summary judgment. The court also dismissed the claims against the unidentified police officer for lack of personal jurisdiction, denied the plaintiff’s request for more time to serve that officer, and later denied leave to amend the complaint to add the officer once identified.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court’s decisions in all respects. The First Circuit held that the plaintiff’s allegations did not plausibly establish municipal liability under § 1983, nor did they show actual knowledge by school officials sufficient to support a Title IX claim. The appellate court also found no abuse of discretion in the district court’s procedural rulings regarding service of process and amendment of the complaint. View "Hewes v. Gardiner" on Justia Law

In the spring of 2020, three veterans residing at the Soldiers’ Home in Chelsea, Massachusetts, died after contracting COVID-19. The personal representatives of the veterans’ estates filed suit against several Massachusetts state officials responsible for the facility, alleging violations of the veterans’ substantive due process rights under the Fourteenth Amendment. The complaint asserted that the officials failed to protect residents from COVID-19 by not implementing adequate safety protocols and maintaining inhumane living conditions, including lack of sanitation, improper restraint of residents, and exposure to illegal drugs.The United States District Court for the District of Massachusetts reviewed the complaint after the defendants moved to dismiss, arguing that the plaintiffs failed to state a claim for a substantive due process violation and that the officials were entitled to qualified immunity. The District Court granted the motion to dismiss. It held that the plaintiffs had not sufficiently alleged individual involvement by any defendant in the purported misconduct regarding COVID-19, and failed to provide details showing how the named veterans were specifically harmed by the living conditions. The court also found no clearly established legal authority placing the officials on notice that their conduct would violate the veterans’ rights, thus concluding qualified immunity applied.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s judgment. The First Circuit held that the complaint did not plausibly allege that the defendants directly caused the harm suffered by the veterans, nor did it sufficiently invoke exceptions to that requirement. The Court also found that the plaintiffs had not demonstrated a violation of clearly established law and thus, the defendants were entitled to qualified immunity. Consequently, the dismissal of the complaint was affirmed. View "Terenzio v. Urena" on Justia Law

In 2018, the plaintiff contacted police to help resolve a dispute at her home involving her adult children. After officers arrived and de-escalated the situation, a third officer arrived, and a disagreement between the plaintiff and this officer led to her arrest. She was charged with resisting arrest, disorderly conduct, and assault and battery on a police officer. Rather than pleading guilty or going to trial, the plaintiff entered into an agreement under Massachusetts law for three months of pretrial probation, with the understanding that the charges would be dismissed upon successful completion. She did not admit to any wrongdoing or facts, and after completing probation, the charges were dismissed.The plaintiff later filed a lawsuit in state court against the City of Springfield and several police officers, alleging civil rights violations under 42 U.S.C. § 1983, including excessive force during her arrest. The defendants removed the case to the United States District Court for the District of Massachusetts and moved for summary judgment, arguing that the plaintiff’s claims were barred by the doctrine established in Heck v. Humphrey, which prevents § 1983 claims that would impugn a valid criminal judgment. The district court denied summary judgment on this ground for two officers, holding that the Heck bar did not apply because the plaintiff was not convicted.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s decision. The court held that the Heck bar does not apply when there is no underlying criminal conviction or sentence. Because the plaintiff’s charges were dismissed after pretrial probation without any admission of guilt or factual findings, her § 1983 claims could proceed. The case was remanded for further proceedings. View "Aprileo v. Clapprood" on Justia Law

While awaiting resentencing on federal charges, an individual was detained at the Donald W. Wyatt Detention Facility in Rhode Island. During his approximately seventeen-month confinement, he, a Sunni Muslim, communicated with facility officials about his religious needs, including requests to hold congregational prayer and access religious programming and property. He alleges that officials responded with harassment, denied his requests for religious services, and ultimately transferred him to another facility in retaliation for his complaints.He filed a pro se complaint in the United States District Court for the District of Rhode Island against the facility’s warden and three unknown officials, seeking damages under 42 U.S.C. § 1983 for alleged violations of his First and Fourteenth Amendment rights. The defendants moved to dismiss, arguing they were not acting under color of state law but rather federal law, and thus were not subject to suit under § 1983. The district court granted the motion, relying on a prior district court decision that held officials at Wyatt act under color of federal law.On appeal, the United States Court of Appeals for the First Circuit reviewed the facility’s statutory creation and governance, noting that the Central Falls Detention Facility Corporation, a municipal entity, owns and operates Wyatt. The court found that, although the facility houses federal detainees under contract, it remains a municipal institution and its employees are municipal actors. The First Circuit held that the complaint plausibly alleged action under color of state law, making the defendants potentially liable under § 1983. The court reversed the district court’s dismissal and remanded for further proceedings. View "Wright v. Martin" on Justia Law

Giovanni Irizarry Sierra worked as an Attorney Advisor for the Social Security Administration (SSA) in Puerto Rico and was terminated in March 2019 for unsatisfactory performance. He subsequently filed a complaint with the SSA’s Office of Civil Rights and Equal Opportunity (OCREO), alleging that his termination was the result of discrimination and retaliation. The OCREO reorganized his allegations, dismissing one as untimely and bifurcating the remainder into pre-termination and termination discrimination claims. The termination claim was treated as a “mixed case” because it involved both discrimination and an adverse personnel action.After receiving a report of investigation, Irizarry requested a hearing before an Equal Employment Opportunity Commission (EEOC) Administrative Judge (AJ). The AJ dismissed the termination claim for lack of jurisdiction, explaining that mixed cases must proceed through the Merit Systems Protection Board (MSPB), not the EEOC. Irizarry then appealed his termination claim to the MSPB, which sustained his removal and notified him that he had thirty days from the final decision to seek judicial review in federal district court. Irizarry did not file within that period. Later, the OCREO erroneously issued a Final Agency Decision (FAD) on the termination claim, which was subsequently rescinded.Irizarry filed suit in the United States District Court for the District of Puerto Rico, relying on the rescinded FAD. The SSA moved to dismiss, arguing the complaint was untimely and the FAD was issued in error. The district court granted the motion, finding the claims time-barred and rejecting Irizarry’s arguments for equitable tolling and estoppel.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The court held that Irizarry’s claim was untimely because he failed to file within thirty days of the MSPB’s final decision, and equitable relief was not warranted. View "Irizarry Sierra v. Bisignano" on Justia Law

Residents and the municipality of Morovis, Puerto Rico, brought suit against the Puerto Rico Aqueduct and Sewer Authority (PRASA) and its officials, alleging that for years, Morovis has suffered from a severe water crisis, with many residents lacking water service on most days. The plaintiffs, all PRASA subscribers, claimed that despite repeated notifications and proposed solutions—including a report from the U.S. Army Corps of Engineers—PRASA failed to address the crisis. They alleged that sometimes the outages could be resolved by simply turning on pumps or generators, and that PRASA officials were aware of the situation but did little to provide alternative water sources or adjust billing. The plaintiffs also recounted incidents suggesting deliberate inaction or sabotage by PRASA employees.The United States District Court for the District of Puerto Rico dismissed the case in its entirety at the pleading stage, concluding that the plaintiffs failed to state a claim for a substantive due process violation under the Fourteenth Amendment. The court found that the alleged conduct did not rise to the level of “shocking the conscience,” and also held that the plaintiffs’ contracts with PRASA could not form the basis of a substantive due process claim. The court did not decide whether Puerto Rico law created a protected property interest in water service.On appeal, the United States Court of Appeals for the First Circuit held that the district court erred in dismissing the substantive due process claim. The First Circuit ruled that the plaintiffs plausibly alleged government conduct that could shock the conscience, particularly under a deliberate indifference standard, given the prolonged and severe deprivation of water. The court vacated the district court’s dismissal and remanded for further proceedings, leaving unresolved whether a protected property interest exists and whether qualified immunity applies. View "Maldonado-Gonzalez v. Puerto Rico Aqueduct & Sewer Authority" on Justia Law

A man experiencing a mental health crisis was fatally shot by police officers in his Newton, Massachusetts apartment building after a report of an attempted armed robbery at a nearby candy store. When officers arrived, the man, holding a kitchen knife, fled into his apartment building. Officers pursued him to the third floor, where he threatened self-harm and engaged in erratic behavior. Police attempted to negotiate with him for about twenty minutes, eventually convincing him to drop the knife and a fire extinguisher. As officers prepared to incapacitate him with a beanbag shotgun, the weapon malfunctioned. Some officers reported that the man then picked up the knife and moved toward them, prompting two officers to fire their sidearms, resulting in his death.The decedent’s parents, acting as representatives of his estate, filed suit in the United States District Court for the District of Massachusetts against the City of Newton and several police officers. They alleged excessive force under 42 U.S.C. § 1983, violations of the Americans with Disabilities Act (ADA) and the Rehabilitation Act, and various state law claims. The district court dismissed all claims, finding the officers were entitled to qualified immunity and that the plaintiffs had not sufficiently pleaded municipal liability or viable claims under the ADA or state law.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s dismissal de novo. The First Circuit affirmed the dismissal of all claims except the § 1983 excessive force claim against the officers related to the fatal shooting. The court held that, at the pleading stage, there were disputed material facts regarding whether the decedent was armed and posed an immediate threat when lethal force was used. The judgment was vacated as to this claim and remanded for further proceedings; all other dismissals were affirmed. View "Conlon v. Scaltreto" on Justia Law