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

Articles Posted in Civil Rights
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The First Circuit affirmed the judgment of the district court denying Petitioner's petition for a writ of habeas corpus seeking to overturn his 2010 New Hampshire conviction for aggravated felonious sexual assault, holding that the district court properly rejected Petitioner's Sixth Amendment claim.In his habeas petition, Petitioner asserted that his Sixth Amendment right to autonomy to determine the objectives of his defense when his counsel took certain actions to present a defense at trial, despite Petitioner's instructions not to do so. The district court denied the petition. The First Circuit affirmed, holding that Petitioner was not denied autonomy to direct the objectives of his defense when his trial counsel presented an active defense contrary to Petitioner's express wishes. View "Kellogg-Roe v. Gerry" on Justia Law

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In this vaccination dispute, the First Circuit denied the motion brought by Appellants seeking an injunction pending appeal, holding that Appellants were not entitled to the injunction.Appellants, eight employees of Mass General Brigham, Inc. (MGB), challenged MGB's application of its mandatory vaccination policy to them individually. The policy was issued in June 2021 requiring all MGB employees to be vaccinated against COVID-19 unless they qualified for a medical or religious exemption. After Appellants' requests for exemptions were denied and they still refused to get vaccinated, MGB placed them on unpaid leave. Appellants sued under Title VII of the Civil Rights Act and the Americans with Disabilities Act, arguing that MGB unlawfully denied their individual exemption requests. The district court denied Appellants' motion for a preliminary injunction, which would have required Appellants' reinstatement from unpaid leave status. The First Circuit denied Appellants' motion for injunction pending appeal, holding that adequate legal remedies foreclosed injunctive relief. View "Together Employees v. Mass General Brigham Inc." on Justia Law

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The First Circuit affirmed the judgment of the district court denying Appellant's motion to suppress evidence recovered during a traffic stop, holding that the district court did not err when it denied the motion to suppress.Appellant entered a conditional guilty plea to possession of a controlled substance with the intent to distribute, reserving the right to appeal the district court's denial of his motion to suppress both statements he made at the scene of his traffic stop and the physical evidence obtained during the stop. In denying the motion to suppress, the district court concluded that the law enforcement officer had reasonable suspicion to stop Defendant's car. The First Circuit affirmed, holding that the officer had a reasonable basis to believe Appellant had committed a traffic infraction and thus to perform a traffic stop. View "United States v. Miles" on Justia Law

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The First Circuit affirmed the judgment of the district court denying Defendants' joint motion to dismiss the charges against them on retrial, holding that the district court did not err.Defendants - Raymond Garraway and Cordwell Bennett - were convicted for possession with intent to distribute marijuana. Defendants moved for a mistrial. The district court granted the motion on the basis of the prosecution's improper arguments made at closing. When the prosecution began to retry them, Defendants filed a joint motion to dismiss for violation of the Double Jeopardy Clause. The district court denied the motion, finding that the prosecution did not intend to provoke a mistrial. The First Circuit affirmed, holding that the record amply supported the district court's decision. View "United States v. Garraway" on Justia Law

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The First Circuit affirmed the judgment of the district court ordering that Plaintiff's breach of contract claim be dismissed for failure to state a plausible claim and granting summary judgment for Defendants on all remaining counts, holding that there was no error.Plaintiff sued the City of East Providence, Rhode Island, its School Department, and the School Superintendent, asserting claims arising from what she alleged were unlawful discriminatory employment actions taken against her. The First Circuit resolved all claims in favor of Defendants. The First Circuit affirmed, holding (1) Plaintiff failed to plead even a prima facie case of discrimination; and (2) Plaintiff's claim of retaliatory employment discrimination was not supported by admissible evidence that would warrant putting the case to a jury. View "Lima v. City of East Providence" on Justia Law

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The First Circuit affirmed the ruling of the district court rejecting Defendant's request for a Franks hearing before Defendant entered a conditional guilty plea to one count of possession of a firearm by a prohibited person, holding that the district court did not err in denying Defendant a Franks hearing.Defendant was charged with one count of possession of a firearm by a prohibited person and one count of possession with the intent to distribute cocaine. Prior to trial, Defendant filed a motion to suppress evidence seized pursuant to search warrants and sought a Franks hearing on the basis of two alleged material omissions from the warrant affidavit. The district court denied both Defendant's Franks motion and his motion to suppress. The First Circuit affirmed, holding that the district court did not err in ruling that Defendant had failed to make the threshold showing necessary to obtain a Franks hearing. View "United States v. Leonard" on Justia Law

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The First Circuit vacated the federal convictions challenged on appeal by the two defendants in this case - Noel de Leon-De la Rosa and Juan Batista Johnson-Debel - holding that vacatur was required of Defendants' challenged convictions for different reasons.Defendants were both convicted of destruction of a controlleded substance while on a vessel and conspiracy to destroy a controlled substance while on a vessel (counts five and six). The First Circuit vacated Defendants' of counts five and six, holding (1) the evidence was sufficient to support the convictions; (2) the admission of Johnson's statement in the defendants' joint trial violated De Leon's rights under the Confrontation Clause to the Federal Constitution; and (3) as to Johnson's convictions, the district court constructively amended the indictment through its instructions to the jury. View "United States v. De Leon-De la Rosa" on Justia Law

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The First Circuit reversed the judgment of the district court denying Defendant's motion to vacate her federal conviction and sentence on the grounds that her appellate counsel was constitutionally ineffective under Strickland v. Washington, 466 U.S. 668 (1984), for failing to raise a claim on direct appeal under Brady v. Maryland, 373 U.S. 83 (1963), holding that the district court erred.Defendant and her co-defendants were convicted of various drug-trafficking offenses. In their direct appeals, Defendant's co-defendants successfully argued that the government's failure to produce several clearly relevant documents that plainly called into question the credibility of the government's key witnesses against Defendant and her co-defendants violated their due process rights under Brady. The First Circuit vacated the co-defendants' convictions and remanded for a new trial. Because Defendant did not raise the Brady violation on her simultaneous appeal, she was denied relief. Thereafter, Defendant brought this action pursuant to 28 U.S.C. 2255. The First Circuit reversed, holding (1) Defendant established prejudice under Strickland; and (2) the failure to raise the Brady claim was the result of deficient performance by appellate counsel. View "Flores-Rivera v. United States" on Justia Law

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The First Circuit affirmed the judgment of the district court approving an amended settlement agreement in this landmark Title IX case brought by a group of women student-athletes against Brown University claiming gender discrimination with respect to the funding and operation of a variety of varsity athletic programs, holding that there was no error.After a bench trial, the district court found that Brown had violated Title IX. After the First Circuit remanded the case for further proceedings, the parties consummated a settlement, which remained in effect for more than two decades. In 2020, Brown unilaterally decided to eliminate certain varsity sports and to upgrade sailing to varsity status, open to men and women. The parties then revisited the matters embodied in the court-approved settlement and jointly moved for approval of a revised settlement. The district court approved the amended settlement agreement. The First Circuit affirmed, holding that the district court properly concluded that the amended settlement agreement was fair and adequate. View "Cohen v. Walsh" on Justia Law

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The First Circuit affirmed the judgment of the district court denying Appellant's motion to dismiss the criminal proceedings against him, holding that Appellant was statutorily barred under 8 U.S.C. 1326(d) from bringing a collateral attack in his criminal proceeding.Defendant was charged with violating 8 U.S.C. 1326, which makes it a felony to unlawfully enter the United States while an order of removal is outstanding. Defendant filed a motion to dismiss the indictment against him, arguing that the government may not use his prior removal order to prove the "outstanding order of removal" element of the crime. Defendant thus sought to dismiss his indictment based on a due process-based collateral attack on the order of removal, arguing that the entry of the order was fundamentally unfair. The district court denied the motion. The First Circuit affirmed, holding (1) Defendant's first argument had already been rejected by this Court since the district's ruling; and (2) because the removal proceeding was not fundamentally unfair Defendant did not satisfy the conditions under 8 U.S.C. 1326(d) that would permit him to collaterally attack his prior removal. View "United States v. Castillo-Martinez" on Justia Law