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

Articles Posted in Civil Rights
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The First Circuit reversed the ruling of the district court suppressing blood alcohol content evidence from a warrantless blood draw because no exigent circumstances were present, holding that the district court misapplied the law to the facts in this case.After a car accident that killed three people, a police officer ordered a warrantless blood of Defendant's blood without Defendant's consent and without exigent circumstances. The government charged Defendant with three counts of manslaughter and other intoxicated-driving crimes. Defendant filed a motion to suppress evidence from the warrantless blood draw, which the district court granted. The First Circuit reversed, holding that the government met its burden to show it was reasonable for the police officer to think exigent circumstances existed when he took the blood draw. View "United States v. Manubolu" on Justia Law

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The First Circuit affirmed Defendants' cross-motions for summary judgment in this action challenging the denial of Plaintiff's application for a "permit to purchase" a firearm, holding that Defendant provided no basis on appeal for overturning the district court's grant of summary judgment to Defendants.William Lyver, the chief of police for Northborough, Massachusetts, denied Plaintiff a permit to purchase based on Plaintiff's criminal history - specifically, his two out-of-state firearms-related convictions. Plaintiff subsequently brought this action pursuant to 42 U.S.C. 1983 seeking a declaratory judgment that Mass. Gen. Laws ch. 140, 131(d)(ii)(D) violated the Second and Fourteenth Amendments to the United States Constitution. The district court upheld the provisions on the ground that they were substantially related to an important governmental interest. The First Circuit affirmed, holding that Plaintiff provided no ground for overturning the district court's grant of summary judgment to Defendants. View "Morin v. Lyver" on Justia Law

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The First Circuit affirmed in part and vacated and remanded in part the decision of the district court granting summary judgment in favor of Defendants and dismissing Plaintiffs' complaint alleging that Defendants had violated their federal constitutional substantive due process rights under the state-created danger doctrine, holding that remand was required.In 2012, Alivia Welch, Susan Johnson, and Derrick Thompson called the Biddeford Maine Police Department and reported that their landlord, James Bak, had made death threats to them. Police Office Edward Dexter responded to the call. Officer Dexter left without ascertaining whether Bak indeed had a gun. Four minutes later, Bak shot and killed Welch and Thompson and injured Johnson. Plaintiffs - Johnson and the estates representing Welch and Thompson - filed suit. The district court granted summary judgment for Defendants. The First Circuit remanded the case in light of this opinion, holding that remand was required to determine whether Officer Dexter was entitled to qualified immunity before addressing whether Officer Dexter violated Plaintiffs' substantive due process rights under the state-created danger doctrine. View "Welch v. City of Biddeford Police Department" on Justia Law

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The First Circuit affirmed the district court's dismissal of this suit challenging Massachusetts Governor Charles Baker's COVID-19 Order No. 43 as unconstitutional, holding that the case was moot.Bit Bar, which owned and ran a restaurant/arcade in the city of Salem, Massachusetts, brought suit under 42 U.S.C. 1983, attacking Governor Baker's order, which temporarily closed the trade part of Bit Bar's business, as unconstitutional. The complaint alleged that the Governor's restriction violated Bit Bar's First and Fourteenth Amendment rights. Just days after Bit Bar filed suit, Governor Baker entered an order allowing arcades to reopen. The Governor then moved to dismiss the complaint as moot. The district court granted the motion to dismiss. The First Circuit affirmed, holding that the case was moot. View "Boston Bit Labs, Inc. v. Baker" on Justia Law

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The First Circuit affirmed the judgment of the district judge ordering a joint retrial of Roger Boncy and Joseph Baptiste in the interest of justice because neither defendant got a fair first trial, holding that Defendants showed deficient performance of counsel and that Defendants were prejudiced.After a jury trial, Defendants were convicted of conspiring to violate the Foreign Corrupt Practices Act and the Travel Act, and Baptiste was convicted of violating the Travel Act and conspiring to violate the Money Laundering Act. Baptist moved for a new trial based on ineffective assistance of counsel. Boncy also requested a separate trial on the grounds that Baptiste's lawyer's ineffectiveness influenced the jury's view of both defendants and thus impaired Boncy's due process right to a fair proceeding. The district judge found that the cumulative effect of counsel's deficiencies prejudiced both Baptiste and Boncy. The First Circuit affirmed, holding that the government's arguments on appeal were unavailing. View "United States v. Baptiste" on Justia Law

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The First Circuit confirmed the convictions of Carlos Velazquez-Fontanez and Jose D. Resto-Figueroa for various criminal offenses related to La Rompe ONU, a drug trafficking organization that operated in San Juan, Puerto Rico, and vacated the convictions of Ruben Cotto-Andino, holding that, as to Cotto-Andino, the court committed reversible error.Specifically, the First Circuit held (1) the evidence against all three defendants was sufficient to support their RICO conspiracy convictions, their 21 U.S.C. 846 convictions, and their 18 U.S.C. 36(b)(2) convictions; (2) the district court's limitation of Cotto-Andino's rebuttal of the government's uncharged murder evidence exceeded the bounds of the court's discretion, was not harmless, and required that Cotto-Andino's convictions be vacated; (3) the remainder of Cotto-Andino's challenges to the admission of evidence were unavailing; (4) an error in the transcript did not warrant reversal of the district court's denial of a mistrial in favor of Resto-Figueroa; and (5) there was no error in the jury instructions. View "United States v. Velazquez-Fontanez" on Justia Law

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The First Circuit affirmed the judgment of the district court dismissing Appellant's claims for mandamus and relief under the Administrative Procedure Act (APA), vacated the dismissal of Appellant's equal protection and due process claims and held that certain of the challenged rules challenged by Appellant were arbitrary and unenforceable.Appellant, a law firm, sued the Social Security Administration (SSA) challenging "the [SSA]'s byzantine and irrational rules that govern payment pf attorney's fees in Social Security disability cases." The district court dismissed Appellant's mandamus and APA claims on the grounds that sovereign immunity barred the mandamus claim and that the firm's challenges to the agency's fee-paying procedures were statutorily barred. The court later granted summary judgment for the SSA on the remaining three claims. The First Circuit held (1) mandamus relief was unavailable here because Appellant had another avenue for obtaining relief; and (2) the SSA's practice of denying attorneys fees under certain circumstances was arbitrary, and therefore, the rule must be eliminated. View "Marasco & Nesselbush, LLP v. Collins" on Justia Law

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The First Circuit affirmed the sentence Defendant received upon resentencing after he was convicted on two drug-related charges, holding that there was no error in the proceedings.This Court previously vacated Defendant's sentence. On remand, the district court imposed a low-end eighty-four-month term of immurement to be followed by six years of supervised release. Defendant appealed, challenging his six-year mandatory minimum term of supervised release. The First Circuit affirmed, holding (1) the district court did not err by failing to make a necessary finding; and (2) the court did not find facts that should have been reserved for a jury. View "United States v. Rabb" on Justia Law

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The First Circuit affirmed the order of the district court dismissing Plaintiff's suit brought against Defendant, his employer, asserting claims of age-based discrimination under the Age Discrimination in Employment Act (ADEA) and Puerto Rico's statutory analog, holding that this Court will not adopt any version of the single filing rule that would excuse the procedural failings associated with Plaintiff's suit.In moving to dismiss the complaint, Defendant asserted that Plaintiff neglected to first file a complaint with the Equal Employment Opportunity Commission and therefore failed to exhaust his administrative remedies before filing suit. Plaintiff argued in response that the district court should adopt and apply the "single filing rule," otherwise known as the "piggyback rule," which would allow him to vicariously satisfy his exhaustion obligation by relying upon a timely-filed administrative complaint against his employer made by a similarly-situated plaintiff. The district court declined to adopt the single filing rule, dismissed Plaintiff's ADEA claims, and declined to exercise supplemental jurisdiction over his Puerto Rico law claims. The First Circuit affirmed, holding that the district court correctly dismissed the complaint. View "Perez-Abreu v. Metropol Hato Rey LLC" on Justia Law

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The First Circuit affirmed the federal convictions and sentences of Defendants - Herzzon Sandoval, Edwin Guzman, Erick Argueta Larios, and Cesar Martinez - stemming from a federal criminal investigation into La Mara Salvatrucha, a transnational criminal organization, in Massachusetts, holding that there was no prejudicial error.Specifically, the First Circuit held (1) Defendants' sufficiency of the evidence challenges to their respective convictions were without merit; (2) there was no merit to Defendants' claims that the district court erred in denying a motion for a continuance due to pretrial publicity or in denying their motion for a mistrial; (3) Defendants' challenges to the court's evidentiary rulings failed; (4) challenges concerning purported misstatements of the evidence in the government's closing argument and purported instructional errors provided no basis for overturning Defendants' convictions; and (5) Defendants' challenges to their sentences failed. View "United States v. Sandoval" on Justia Law