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

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

In 2002, Natale Cosenza was convicted by a Massachusetts state court jury of assault and battery with a dangerous weapon and armed burglary. The prosecution's case heavily relied on the victim, Melissa Horgan, identifying Cosenza from a photo array administered by Worcester police. In 2016, state courts granted Cosenza a new trial, and in 2017, they suppressed the photo array evidence, leading the Commonwealth to drop the charges.Cosenza then filed a federal civil rights lawsuit in 2018 against the City of Worcester, alleging that the City had a policy of not properly training its officers on photo arrays and other investigative techniques, which he claimed violated his constitutional rights. The U.S. District Court for the District of Massachusetts granted summary judgment in favor of the City, finding no evidence of deliberate indifference to Cosenza's constitutional rights.The United States Court of Appeals for the First Circuit reviewed the case. The court found that there was no evidence Worcester had a policy of not training its officers on photo arrays. The court noted that officers received training at a police academy and on-the-job training, and that the law at the time did not clearly establish the procedures Cosenza argued were required. The court also found no evidence that the City had a policy of fabricating or suppressing evidence. Consequently, the First Circuit affirmed the district court's summary judgment in favor of the City of Worcester. View "Cosenza v. City of Worcester, MA" on Justia Law

In this case, the petitioner was convicted by a jury in New Hampshire state court for the first-degree murder of Larry Lemieux. The petitioner admitted to shooting Lemieux but claimed he acted in self-defense or in defense of another, arguing he did not act with premeditation. After his conviction, the prosecution disclosed a proffer letter recommending a suspended sentence for drug charges against Jose Gomez, a key prosecution witness. The petitioner argued that the failure to disclose this letter violated his due process rights under Brady v. Maryland.The state trial court denied the petitioner's motion for a new trial, finding that the nondisclosure of the proffer letter did not prejudice the petitioner. The New Hampshire Supreme Court affirmed this decision, holding that the petitioner was not prejudiced under New Hampshire law, which sets stricter standards than Brady. The court found that the undisclosed evidence would not have altered the defense strategy or the trial's outcome, given the overwhelming additional evidence of premeditation presented by other witnesses.The United States Court of Appeals for the First Circuit reviewed the case, focusing on whether the New Hampshire Supreme Court's decision involved an unreasonable application of clearly established federal law under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). The First Circuit affirmed the denial of habeas relief, concluding that the New Hampshire Supreme Court reasonably determined that the petitioner was not prejudiced by the nondisclosure of the proffer letter. The court noted the overwhelming evidence of premeditation from multiple witnesses, which supported the jury's verdict independent of Gomez's testimony. View "Etienne v. Edmark" on Justia Law

Brian Watson was convicted in 2017 by a jury for the felony sale of a controlled drug (fentanyl) resulting in death. The prosecution's evidence included testimony from Dr. Daniel Isenschmid, a forensic toxicologist, who discussed toxicology tests conducted by his colleagues, revealing fentanyl and its metabolites in the victim's blood. Watson appealed, arguing that the trial court erred by allowing Dr. Isenschmid to testify about tests he did not perform. The New Hampshire Supreme Court affirmed the conviction, finding that Dr. Isenschmid's involvement in the case was sufficient to satisfy the Confrontation Clause.Watson then filed a habeas corpus petition under 28 U.S.C. § 2254 in the United States District Court for the District of New Hampshire, claiming that his Confrontation Clause rights were violated by Dr. Isenschmid's testimony. The warden moved for summary judgment, which the district court granted, concluding that the state court's decision was neither contrary to nor an unreasonable application of Supreme Court precedent.The United States Court of Appeals for the First Circuit reviewed the case and upheld the district court's decision. The court found that Watson did not provide clear and convincing evidence to show that the state court's factual findings were incorrect. The court also determined that the state court's decision was not contrary to or an unreasonable application of clearly established federal law. The First Circuit noted that Dr. Isenschmid had personally reviewed all relevant documentation, data, and test results, and had issued and signed the toxicology report, making his testimony permissible under the Confrontation Clause. The court affirmed the district court's grant of summary judgment in favor of the warden. View "Watson v. Edmark" on Justia Law

Joseph Segrain, an inmate at Rhode Island's Adult Correctional Institutions, filed a civil lawsuit against the Rhode Island Department of Corrections and several correctional officers, alleging violations of his Eighth Amendment rights and various state laws. Segrain claimed that on June 28, 2018, officers used excessive force by executing a leg-sweep maneuver, spraying him with pepper spray, and delaying his decontamination. The district court granted summary judgment in favor of the officers on all claims, leading Segrain to appeal.The United States District Court for the District of Rhode Island initially reviewed the case. The court found that no reasonable jury could conclude that the officers' conduct constituted an Eighth Amendment violation. It granted summary judgment on the basis that the force used was minimal and necessary to maintain order. The court also dismissed the state law claims, concluding that the officers' actions did not meet the legal standards for battery, intentional infliction of emotional distress, or excessive force under Rhode Island law.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed the district court's judgment regarding the 42 U.S.C. § 1983 claim that Officer Walter Duffy's use of pepper spray violated Segrain's Eighth Amendment rights. It found that a reasonable jury could conclude that Duffy's use of pepper spray was excessive and not in good faith. The court vacated the district court's judgment on the Rhode Island Constitution Article I, Section 8 claim regarding Duffy's use of pepper spray and remanded for further proceedings. However, the court affirmed the district court's judgment on all other claims, including the leg-sweep maneuver and the delayed decontamination, granting qualified immunity to the officers on those issues. View "Segrain v. Duffy" on Justia Law

In this case, the petitioner, a state prisoner, challenged the dismissal of his federal habeas petition, which alleged violations of his constitutional rights under the Fifth, Sixth, and Fourteenth Amendments. The petitioner, along with two accomplices, planned and executed a robbery that resulted in the murder of a pizza delivery driver. The petitioner was convicted of first-degree murder, armed robbery, and breaking and entering, and was sentenced to life in prison without parole.The Massachusetts Supreme Judicial Court (SJC) affirmed the petitioner's conviction, rejecting his claims of insufficient evidence, improper admission of redacted statements from a co-defendant, and errors in jury instructions. The SJC found that the evidence was sufficient to support the petitioner's conviction under theories of felony-murder and extreme atrocity or cruelty. It also held that the redacted statements did not violate the petitioner's Confrontation Clause rights and that the trial court's jury instructions were appropriate.The United States Court of Appeals for the First Circuit reviewed the district court's denial of the habeas petition de novo. The court applied the standards set forth in the Antiterrorism and Effective Death Penalty Act (AEDPA), which requires deference to state court decisions unless they are contrary to or involve an unreasonable application of clearly established federal law, or are based on an unreasonable determination of the facts.The First Circuit affirmed the district court's decision, holding that the SJC's rulings were not unreasonable. The court found that the evidence was sufficient to support the petitioner's conviction, the redacted statements did not violate the Confrontation Clause, and the jury instructions were proper. The court also concluded that any errors in the trial court's rulings were harmless and did not prejudice the petitioner. View "St. Jean v. Marchilli" on Justia Law

The appellants, Meredith O'Neil, Jessica Svedine, Deanna Corby, and Roberto Silva, sued various officials from the Canton Police Department and the Town of Canton, Massachusetts, seeking declaratory and injunctive relief to prevent the enforcement of Massachusetts witness intimidation statutes, Mass. Gen. Laws ch. 268 §§ 13A and 13B. They claimed that these statutes violated their First Amendment rights, fearing prosecution for their actions during a November 5, 2023 protest and alleging that their speech would be chilled for a planned protest on November 12, 2023. The appellants moved for emergency relief to enjoin the enforcement of these statutes.The United States District Court for the District of Massachusetts denied the emergency motion on November 10, 2023. The court assumed the plaintiffs had standing but found they did not demonstrate a reasonable likelihood of success on the merits of their claims. The court held that the statutes served compelling interests in protecting the administration of justice and were narrowly tailored. The court also found that the plaintiffs had not shown they faced a risk of irreparable harm, noting that the plaintiffs had other public forums to express their views. The balance of harms and public interest considerations also weighed against granting the injunction.The United States Court of Appeals for the First Circuit reviewed the case and dismissed the appeal as moot. The court noted that the state court had dismissed the charges against the appellants for lack of probable cause, and no ongoing conduct remained for the court to enjoin. The court also found that the appellants' general allegations of future protests did not show a credible threat of prosecution, failing to establish standing for their pre-enforcement challenges. The case was remanded to the district court for further proceedings as appropriate. View "O'Neil v. Canton Police Department" on Justia Law

Jaden Brown, a pregnant inmate at Cumberland County Jail, was transported to Maine Medical Center for childbirth. During her hospital stay, correction officers Daniel Haskell and Sam Dickey were present in her room. Brown alleged that Haskell and Dickey observed her naked body during medical procedures and the delivery of her baby, which she claimed violated her Fourth Amendment rights.The United States District Court for the District of Maine denied Haskell and Dickey's motion for summary judgment based on qualified immunity. The court found that there were genuine issues of material fact regarding whether the officers' observations of Brown's naked body were more than inadvertent, occasional, casual, or restricted. The court also ruled that such observations, if they occurred, would constitute a search under the Fourth Amendment.The United States Court of Appeals for the First Circuit reviewed the case. The court dismissed the appeal in part, stating it lacked jurisdiction to consider the officers' argument that they did not observe Brown's naked body, as this was a factual dispute. The court affirmed the district court's denial of summary judgment, holding that if the officers did observe Brown's naked body, it would constitute a search under the Fourth Amendment. The court emphasized that a search does not require deliberate intent to inspect a naked body and that such observations could violate clearly established law. View "Brown v. Dickey" on Justia Law

Xiomara Santiago was hired as the Deputy Director for the Head Start Program in Utuado, Puerto Rico. Following a mayoral election, the new mayor, Jorge Pérez, terminated her employment. Santiago claimed her dismissal violated her Fourteenth Amendment due process rights and was politically motivated, violating her First Amendment rights. She sought a preliminary injunction to be reinstated.The United States District Court for the District of Puerto Rico held hearings and ultimately denied Santiago's request for a preliminary injunction. The court concluded that Santiago had not shown a likelihood of success on the merits of either her due process or political discrimination claims. The magistrate judge's Report & Recommendation, which the district judge adopted, found that Santiago's initial hire was contrary to Puerto Rico law, meaning she did not have a property interest in her employment. Additionally, the court found insufficient evidence to support her claim of political discrimination.The United States Court of Appeals for the First Circuit reviewed the district court's decision. The appellate court affirmed the lower court's ruling, agreeing that Santiago had not demonstrated a likelihood of success on the merits of her claims. The court noted that Santiago's argument regarding the incorrect application of Puerto Rico law was waived because it was raised for the first time on appeal. Furthermore, the court found no clear error in the district court's assessment that Santiago's political affiliation was not a substantial factor in her termination. The court concluded that the district court did not abuse its discretion in denying the preliminary injunction. View "Santiago v. Municipality of Utuado" on Justia Law