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

Articles Posted in Civil Rights
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The First Circuit affirmed the order of the district court granting summary judgment in favor of Defendants on the basis of qualified immunity and dismissing Plaintiff's complaint bringing various constitutional claims under 42 U.S.C. 1983 alleging Fourth and Fourteenth Amendment violations and state law tort claims under the Maine Civil Rights Act (MCRA), Me. Stat. tit. 5, 4682, holding that there was no error.Plaintiff brought this action against the City of Portland and six city police officers alleging that the officers used excessive force and otherwise violated his constitutional rights when they were investigating a domestic violence incident in which he was involved and left him standing outside in his socks in freezing temperatures for several minutes. The district court granted summary judgment in favor of Defendants on the grounds of qualified immunity. The First Circuit affirmed, holding (1) Defendant was entitled to qualified immunity under the circumstances of this case; and (2) the district court properly concluded that Plaintiff's tort claims had been waived and granted summary judgment in Defendants' favor. View "Punsky v. City of Portland" on Justia Law

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The First Circuit affirmed the district court's decision granting summary judgment to Defendants, Norman Sylvester and the Town of Bourne, Massachusetts and dismissing Plaintiff's lawsuit alleging that the discipline he faced as a firefighter violated his constitutional rights, holding that the district court did not err.In his complaint, Plaintiff claimed that he refused to sit for a "promotional" photograph in violation of his religious beliefs and that he was disciplined as a result of his refusal. Plaintiff brought this complaint against Sylvester, in his role as Fire Chief of the Bourne Fire Department, under 42 U.S.C. 1983, for violation of his rights under the Free Exercise Clause, and against the Town and Sylvester under the Massachusetts Wage Act, Mass. Gen. Laws ch,. 149, 148. The district court granted summary judgment to Sylvester on qualified immunity grounds on the section 1983 claim and declined to exercise supplemental jurisdiction over the state law claim. The First Circuit affirmed, holding (1) the district court correctly concluded that Sylvester did not violate Plaintiff's constitutional rights, as required by the first prong of the qualified immunity analysis; and (2) there was no abuse of discretion in the district court's decision declining to exercise supplemental jurisdiction over the remaining state law claim. View "Swartz v. Sylvester" on Justia Law

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The First Circuit vacated Defendant's convictions for nine counts of wire fraud and six counts of aggravated identity theft for his participation in an alleged health insurance fraud scheme, holding that the verdict form that was submitted to the jury violated Defendant's federal constitutional right to a jury trial, and the error was not harmless beyond a reasonable doubt.Specifically, the First Circuit held (1) the district court invaded the jury's over fact-finding by overemphasizing certain of the government's evidence in a manner that was contrary to Appellant's interests, in violation of Appellant's Sixth Amendment right; and (2) there was a reasonable possibility that the constitutional violation at issue influenced the jury in reaching its verdicts in this case, and therefore, the verdicts could not stand, and remand was required. View "United States v. Moffett" on Justia Law

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The First Circuit affirmed the judgment of the district court dismissing Appellant's complaint asserting that New Hampshire's criminal defamation statute was unconstitutionally vague in violation of the Fourteenth Amendment and violated the First Amendment by criminalizing defamatory speech, holding that Appellant's allegations did not assert viable constitutional claims.At issue was N.H. Rev. Stat. 644:11(I), which provides that a person is guilty of a misdemeanor if he "purposely communicates to any person, orally or in writing, any information he knows to be false and knows will tend to expose any other living person to public hatred, contempt or ridicule." Appellant was twice charged under the statute. Appellant later brought this complaint. The district court dismissed the complaint for failure to state a claim. The First Circuit affirmed, holding (1) Garrison v. Louisiana, 379 U.S. 64 (1964), precluded Appellant's First Amendment attack on section 644:11; and (2) the New Hampshire statute was not unconstitutionally vague. View "Frese v. Formella" on Justia Law

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The First Circuit reversed the judgment of the district court denying Appellants' denial of their pre-discovery motions for summary judgment on grounds of qualified immunity, holding that Appellants were entitled to qualified immunity as a matter of law.Appellants - two members of the FBI's joint terrorism task force - shot and killed a suspected terrorist. Plaintiff, the representative of the decedent's estate, brought this action alleging that Appellants' actions violated the decedent's Fourth Amendment rights and asserting state law tort claims. The district court denied Appellants' motions for summary judgment on the grounds of qualified immunity. The First Circuit reversed, holding that the officers were entitled to qualified immunity under each aspect of the "clearly established" prong of the defense. View "Estate of Rahim v. Doe 1" on Justia Law

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The First Circuit affirmed the judgment of the district court issuing a preliminary injunction preliminarily enjoining enforcement of a state law before it took effect, holding that the district court properly entered the preliminary injunction.The law at issue was enacted by the Maine legislature in 2021 to prevent Canadian truck drivers from hauling logs within the state under the auspices of the federal H-2A visa program. Just a few days before the law was to take effect Plaintiffs jointly filed suit in federal district court against the Director of the Maine Bureau of Forestry and the Attorney General of Maine (collectively, the State). Plaintiffs sought injunctive and declaratory relief, alleging that the law was preempted under federal law. Plaintiffs then moved for a temporary restraining order and a preliminary injunction against enforcement of the law. The district court granted the motion. The First Circuit affirmed, holding (1) Plaintiffs carried their burden of showing that the H-2A restriction imposed by the law was likely preempted by federal law; and (2) therefore, the district court properly entered the preliminary injunction. View "Maine Forest Products Council v. Cormier" on Justia Law

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The First Circuit reversed the judgment of the district court dismissing Plaintiff's claim brought under the Americans with Disabilities Act (ADA) against Defendant, which operated an inn on Maine's southern coast, for lack of subject-matter jurisdiction, holding that Plaintiff had Article III standing to bring her suit.Plaintiff, who was disabled and a self-proclaimed ADA "tester" who brought hundreds of other ADA suits around the country, brought a single claim against Defendant for violation of 42 U.S.C. 12181 and 28 C.F.R. 36.302(e), alleging that Defendant's website didn't identify accessible rooms or provide an option for booking an accessible room. Defendant filed a motion to dismiss, alleging that Plaintiff had no real intention of booking a room at its inn, and therefore, Plaintiff lacked Article III standing to bring her suit. The district court granted the motion to dismiss. The First Circuit reversed, holding that the district court had Article III jurisdiction over this case. View "Laufer v. Acheson Hotels, LLC" on Justia Law

Posted in: Civil Rights
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The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Employer and dismissing Employee's claims alleging age discrimination and retaliation against a protected activity, holding that there was no error or abuse of discretion.After he was terminated, Employee brought this action stating that the grounds for his firing were pretextual. The district court granted summary judgment in favor of Employer, dismissing Employee's complaint in its entirety. The First Circuit affirmed, holding that the district court (1) did not err in granting summary judgment to Employer on Employee's age discrimination and retaliation claims; and (2) did not err in denying Employee's evidentiary motions. View "Dusel v. Factory Mutual Insurance Co." on Justia Law

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The First Circuit affirmed the judgment of the district court dismissing Calvary Chapel of Bangor's (Calvary) complaint against Maine Governor Janet Mills raising several facial and as-applied constitutional and statutory challenges to the Governor's executive orders seeking to slow the spread of the COVID-19 outbreak in early 2020, holding that the complaint was moot and that no mootness exception could save it.Calvary sued the Governor in federal court claiming that the Governor's orders at issue discriminated against Calvary by treating religious gatherings less favorably than other gatherings. Calvary requested a temporary restraining order, a preliminary injunction, a permanent injunction, and a declaratory judgment. The district court denied relief and dismissed the complaint. The First Circuit affirmed, holding that this case was moot and that no exception to mootness applied. View "Calvary Chapel of Bangor v. Mills" on Justia Law

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The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Employer and dismissing all of Employee's claims alleging retaliatory behavior under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-2 et seq., discrimination and retaliation under the Uniformed Services Employment and Reemployment Rights Act, 38 U.S.C. 4301 et seq., and violations of Puerto Rico Law 115, holding that there was no error or abuse of discretion.The district court granted Employer's motion for summary judgment, finding that Employee failed to make a prima facie showing of retaliation and, in the alternative, failed to rebut Employer's explanations for why the behavior in question was non-discriminatory in nature. The First Circuit affirmed, holding (1) there was no abuse of discretion in the district court's conclusion that Employee's statement in opposition to Employer's statement of uncontested material facts was noncompliant with Local Rule 56; (2) the district court properly found that Employee failed to make out a prima facie case for retaliation under Title VII; and (3) the dismissal of Employee's antiretaliation law claims was proper. View "Rodriguez-Severino v. UTC Aerospace Systems" on Justia Law