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

The defendant, John Volungus, a convicted pedophile, was conditionally released from civil commitment under the Adam Walsh Child Protection and Safety Act of 2006. The Act allows for the involuntary civil commitment of sexually dangerous persons in federal custody. Volungus, who had been in federal prison for child-sex crimes, was civilly committed in 2012. In 2022, the facility's warden certified that Volungus would not be sexually dangerous if released under a prescribed regimen of care. The district court ordered his conditional release with specific conditions and a prescribed regimen of treatment.The district court's conditional-release order included numerous conditions, some of which Volungus objected to, arguing that the court exceeded its authority by imposing conditions beyond the prescribed treatment regimen and requiring him to pay for certain costs. The district court denied his objections and his motion to dismiss the government's motion to revoke his conditional release for alleged violations of the conditions.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the Adam Walsh Act allows judges to impose conditions beyond the prescribed regimen of treatment, provided they are related to the individual's mental illness and the safety of the public. The court also rejected Volungus's argument that the district court lacked authority to require him to pay for certain costs associated with his release conditions. The court affirmed the district court's conditional-release order, finding that the additional conditions and cost requirements were within the court's authority and aligned with the Act's purpose of protecting the public from sexually dangerous individuals. View "US v. Volungus" on Justia Law

Kalel Martínez-Bristol was indicted on June 24, 2021, for being a felon in possession of a firearm and ammunition, and for possession of a machinegun. At the time, he was on federal supervised release for a 2011 drug conspiracy conviction. He pled guilty to the felon-in-possession charge on September 9, 2022. The presentence report identified the firearm as a pistol with a machinegun conversion device. Martínez did not object to the report. On February 6, 2023, he was sentenced to 46 months' imprisonment for the felon-in-possession conviction.The District Court for the District of Puerto Rico also addressed the supervised release violation. The government argued it was a Grade A violation due to the machinegun, while Martínez argued for a Grade B violation. The court initially granted a continuance for further evidence. At the continued hearing, the government presented evidence that the firearm was a machinegun, which Martínez did not cross-examine. The court determined it was a Grade A violation and sentenced Martínez to 15 months' imprisonment, consecutive to his other sentence.The United States Court of Appeals for the First Circuit reviewed the case. Martínez waived any appeal regarding his felon-in-possession conviction and sentence by not briefing those issues. He argued that his due process and confrontation rights were violated in the revocation hearing, but the court found no error. The court noted that Martínez had the evidence months before the hearing and did not object. The court affirmed the judgments, finding the government's evidence sufficient to establish the firearm as a machinegun. View "United States v. Martinez-Bristol" on Justia Law

Plaintiff Samantha Pike, a licensed alcohol and drug treatment counselor employed by Wellspring, Inc., worked at Maine's Adult Treatment and Recovery Court (TRC) in Penobscot County. Charles Budd, Jr., the presiding judge overseeing TRC, made unwelcome sexual advances towards Pike during an out-of-state conference and continued this behavior upon returning to Maine. Pike filed a § 1983 action against Budd, alleging a violation of the Equal Protection Clause due to a hostile work environment.The United States District Court for the District of Maine dismissed Pike's claim, granting Budd qualified immunity. The court reasoned that case law did not clearly establish that Budd's conduct would violate the Equal Protection Clause in this context, particularly given Pike's status as a private employee rather than a state employee. The district court also noted that Budd likely was not acting under color of state law during the conference.The United States Court of Appeals for the First Circuit reviewed the case and concluded that Pike plausibly alleged a violation of her equal protection right to be free from a hostile work environment. The court determined that Budd's conduct, both at the conference and in his chambers, was sufficiently severe and pervasive to alter the conditions of Pike's employment. The court also found that it was clearly established that a state actor creating a hostile work environment violates the Equal Protection Clause, regardless of the plaintiff's employment status. Consequently, the First Circuit vacated the district court's dismissal and remanded the case for further proceedings. View "Pike v. Budd" on Justia Law

A high school student, Adrianna Wadsworth, filed a lawsuit against her principal, Andrew Cavanaugh, a school social worker, Chuck Nguyen, and the school district, MSAD 40/RSU 40, alleging constitutional violations and a Title IX claim. Wadsworth claimed that Cavanaugh sexually harassed her, Nguyen failed to protect her, and the school district was indifferent to the harassment.The United States District Court for the District of Maine dismissed some of Wadsworth's claims and granted summary judgment in favor of the defendants on others. The court dismissed the supervisor-liability claim against Nguyen, finding no control over Cavanaugh. It also granted summary judgment to Cavanaugh on the substantive due process claim, concluding that non-physical harassment did not violate Wadsworth's right to bodily integrity. The court found that Wadsworth's equal protection claim against Cavanaugh was valid but granted him qualified immunity. Nguyen was granted summary judgment on the state-created-danger claim, as his conduct did not shock the conscience. The court also granted summary judgment to MSAD on the § 1983 municipal liability claim, finding no deliberate indifference, and on the Title IX claim, concluding that the assistant principals did not have actual knowledge of the harassment.The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court's decision on the substantive due process claim against Cavanaugh but reversed the summary judgment on the equal protection claim, finding that a reasonable jury could conclude that Cavanaugh's conduct was severe and pervasive enough to constitute sexual harassment. The court also affirmed the dismissal of the supervisor-liability claim against Nguyen and the summary judgment on the state-created-danger claim. However, it reversed the summary judgment on the Title IX claim against MSAD, concluding that a reasonable jury could find that the assistant principals had actual knowledge of the harassment. The case was remanded for further proceedings consistent with the opinion. View "Wadsworth v. MSAD 40/RSU 40" on Justia Law

A registered nurse, Alexandra Melino, sued her former employer, Boston Medical Center (BMC), alleging violations of Title VII of the Civil Rights Act and Massachusetts General Laws by denying her request for a religious exemption from BMC's COVID-19 vaccination mandate. Melino's primary duties involved direct patient care in critical units. During the pandemic, BMC converted several units to COVID-19 units and faced significant staffing challenges due to the virus. BMC implemented a vaccination policy based on CDC recommendations to mitigate the risk of COVID-19 transmission among staff and patients.The United States District Court for the District of Massachusetts granted summary judgment to BMC, holding that Melino's requested exemption would impose undue hardship on the hospital. The court found that Melino could not work remotely, could not work in-person unvaccinated without risking patient safety, and that any feasible accommodation would impose substantial costs on BMC. Melino's motion to strike portions of an affidavit submitted by BMC was also denied due to her failure to comply with local procedural rules.The United States Court of Appeals for the First Circuit reviewed the case de novo. The court affirmed the district court's decision, agreeing that BMC had demonstrated undue hardship by showing that allowing Melino to work unvaccinated would increase the risk of COVID-19 transmission. The court noted that Melino did not provide any medical evidence to contradict BMC's reliance on CDC recommendations. Additionally, Melino's argument that BMC should have considered alternative accommodations was waived as it was not raised in the lower court. The court upheld the district court's rulings, affirming the grant of summary judgment in favor of BMC. View "Melino v. Boston Medical Center" on Justia Law

George Rodrique, II, a photographer for WCVB-TV, sued his employer, Hearst Stations, Inc. ("Hearst"), after it denied his request for a religious exemption from the company's COVID-19 vaccination requirement and subsequently terminated him for refusing to receive the vaccine. Rodrique claimed that Hearst's actions violated Title VII of the Civil Rights Act of 1964, which prohibits religious discrimination in employment.The United States District Court for the District of Massachusetts granted Hearst's motion for summary judgment, concluding that Rodrique's objections to the vaccine were not religious in nature. The court did not address whether accommodating Rodrique's request would have imposed an undue hardship on Hearst.Rodrique appealed to the United States Court of Appeals for the First Circuit, arguing that his objections were indeed religious and that granting the exemption would not have caused undue hardship. He contended that Hearst provided insufficient evidence that the COVID-19 vaccine reduces virus transmission.The First Circuit assumed, without deciding, that Rodrique's objections were religious. However, it affirmed the district court's summary judgment on different grounds, holding that Hearst reasonably relied on objective medical evidence, including public health guidance, to conclude that the vaccine reduces the likelihood of transmitting COVID-19. The court found that Hearst's reliance on such evidence was reasonable and that accommodating Rodrique's request would have imposed an undue hardship on the company. Thus, the First Circuit affirmed the district court's order granting summary judgment to Hearst. View "Rodrique v. Hearst Communications, Inc." on Justia Law

Justin and Jared Brackett own and operate two restaurants in Harwich, Massachusetts: Ember Pizza, Inc. and The Port Restaurant and Bar, Inc. Both establishments held liquor and entertainment licenses issued by the town. Allegedly, they violated Harwich's noise ordinance and Massachusetts COVID-19 restrictions, leading to suspensions and restrictions on their permits. In response, they sued Harwich, several town officials, and other individuals in federal district court, asserting various federal and state claims.The United States District Court for the District of Massachusetts largely granted the defendants' dispositive motions, rejecting all of Ember and The Port's claims. The court also denied their request for leave to amend their complaint, finding that an amendment would be futile. Ember and The Port then appealed the district court's decisions.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's rulings. The appellate court held that Ember and The Port failed to state a plausible claim for relief under federal law, including their First Amendment, Fourteenth Amendment, and procedural due process claims. The court also found that the Massachusetts Civil Rights Act claims and common law claims, including civil conspiracy and defamation, were inadequately pleaded. The court concluded that the district court did not abuse its discretion in denying the request for leave to amend the complaint, as the proposed amendments would not have cured the deficiencies in the original complaint. View "3137, LLC v. Town of Harwich" on Justia Law

In the early hours of May 11, 2018, Chasrick Heredia, while celebrating his birthday, had a violent encounter with Manchester Police officers, including Officer Michael Roscoe. Heredia filed a complaint alleging excessive force and other constitutional violations. At trial, the jury found Roscoe liable for excessive force and awarded Heredia nominal and punitive damages. The district court denied Roscoe's motions for judgment as a matter of law (JMOL) and for remittitur of the punitive damages award.The United States District Court for the District of New Hampshire presided over the initial trial. The jury found in favor of Heredia on the excessive force claim against Roscoe but in favor of the defendants on all other claims. Roscoe's post-trial motions for JMOL and remittitur were denied by the district court, which concluded that a reasonable juror could find that Roscoe violated Heredia's constitutional rights and that qualified immunity did not apply.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's denial of Roscoe's motions. The appellate court held that a reasonable jury could find that Roscoe used excessive force when he performed a takedown on Heredia after Heredia had submitted to arrest by raising his hands. The court also held that Roscoe was not entitled to qualified immunity because it was clearly established that increasing the use of force after an arrestee had submitted was unconstitutional. Additionally, the court found that the punitive damages awarded were justified based on Roscoe's reckless indifference to Heredia's constitutional rights. View "Heredia v. Roscoe" on Justia Law

Plaintiff-appellant Kimberly A. Ripoli, a decorated veteran, claimed she experienced gender-based discrimination when terminated from her role as Associate Director of the Rhode Island Office of Veterans Affairs (OVA). She sued the State of Rhode Island, Department of Human Services, Office of Veterans Affairs under Title VII of the Civil Rights Act of 1964 and various Rhode Island statutes. The district court granted summary judgment in favor of the State on all claims.The United States District Court for the District of Rhode Island granted summary judgment for the State, dismissing Ripoli's claims of gender-based discrimination, retaliation, and hostile work environment. Ripoli did not address the district court's adverse rulings on her retaliation or hostile work environment claims in her appeal, leaving those rulings intact.The United States Court of Appeals for the First Circuit reviewed the case. The court vacated the district court's order on Ripoli's disparate treatment claims, finding that she had established a prima facie case of discrimination and raised genuine issues of material fact regarding whether the State's reasons for her termination were pretextual. The court noted that Ripoli presented evidence suggesting her role was not redundant, that the reorganization was not driven by budgetary constraints, and that she was replaced by a less-qualified heterosexual male. The court affirmed the district court's summary judgment on Ripoli's retaliation and hostile work environment claims, as she did not pursue these on appeal. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Ripoli v. Rhode Island Department of Human Services" on Justia Law

Plaintiffs Luther C. Parente and Eric L. Stewart sued the Rhode Island Department of Corrections (RIDOC) and its staff for failing to properly treat their preexisting medical conditions. They alleged various federal and state constitutional, statutory, and common law bases for relief, including a claim under the Rhode Island Civil Rights Act of 1990 (RICRA). The plaintiffs claimed that RIDOC's medical and correctional staff failed to meet their medical needs, resulting in harm and discrimination.The United States District Court for the District of Rhode Island denied RIDOC's motion for summary judgment on Eleventh Amendment grounds as to the RICRA claim. The district court held that Rhode Island's general waiver of sovereign immunity under the State Tort Claims Act applied to RICRA claims, reasoning that discrimination actions under RICRA sounded in tort. RIDOC appealed this decision, arguing that the district court erred in holding that violations of civil rights under RICRA were subject to the general waiver of Eleventh Amendment immunity.The United States Court of Appeals for the First Circuit reviewed the case and determined that there was a "special reason" to certify the underlying state-law issue to the Rhode Island Supreme Court. The appellate court noted that the question of whether RICRA claims are "actions of tort" under the State Tort Claims Act is a matter of state law that has not been definitively resolved by the Rhode Island Supreme Court. Therefore, the First Circuit certified the question to the Rhode Island Supreme Court to determine whether discrimination claims under RICRA are covered by the general waiver of sovereign immunity under the State Tort Claims Act. The First Circuit retained jurisdiction over the issue pending resolution of the certified question. View "Parente v. Lefebvre" on Justia Law