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

The First Circuit dismissed this appeal arising in connection with a lawsuit alleging that the Equal Rights Amendment (ERA) is now part of the United States Constitution, holding that none of the plaintiffs met their burden at the pleading stage with respect to federal constitutional requirements.Plaintiffs were Equal Means Equal, a national nonprofit organization, The Yellow Roses, a student organization based in Massachusetts, and Katherine Weitbrecht, a resident of Massachusetts. Plaintiffs brought this action against David Ferriero, in his official capacity as Archivist of the United States, alleging that, after Virginia ratified the ERA in 2020, the Archivist violated 1 U.S.C. 106b when he refused to publish it and certify its adoption. The district court dismissed the claims for lack of subject matter jurisdiction. The First Circuit affirmed, holding that Plaintiffs failed to plead sufficient facts to establish standing under Article III of the United States Constitution to bring this action in federal court. View "Equal Means Equal v. Ferriero" on Justia Law

The First Circuit affirmed Defendant's conviction of possession with intent to distribute cocaine, fentanyl, and methamphetamines, holding that Defendant's challenges on appeal were unavailing.During a probation compliance check in Defendant's apartment state probation officers discovered a black case containing illegal narcotics. The police then obtained and executed a warrant to search Defendant's apartment and his two cellphones for evidence of drug dealing. On appeal, Defendant argued, among other things, that there was no probable cause to search his cellphones and that the warrant did not adequately specify which files on the phones would be searched. The First Circuit affirmed, holding (1) the trial court did not err in denying Defendant's motion to suppress evidence recovered from the cellphones; (2) there was sufficient evidence to support the convictions; and (3) Defendant was not entitled to relief on his remaining allegations of error. View "United States v. Lindsey" on Justia Law

The First Circuit affirmed Defendant's conviction of possession of a firearm in furtherance of a drug trafficking crime and possession of a controlled substance with intent to distribute entered after Defendant pled guilty pursuant to a plea agreement, holding that Defendant's argument that his plea was invalid was without merit.On appeal, Defendant argued that his plea was invalid because he entered it without knowing that he was waiving his right to appeal the trial court's denial of his motion to suppress the drugs, gun, and statements he had made following his arrest. The First Circuit affirmed, holding that, even if there was error, it was not clear or obvious. View "United States v. Casiano-Santana" on Justia Law

The First Circuit affirmed the judgment of the district court holding that the Federal National Mortgage Association (Fannie Mae) and the Federal Housing Finance Agency (FHFA) were not subject to Appellants' Fifth Amendment claims, holding that there was no error.Appellants obtained loans secured by mortgages on their real property in Rhode Island. The loans and mortgages were later sold to Fannie Mae while the FHFA was acting as Fannie Mae's conservator. Consistent with Rhode Island law, when Appellants defaulted on their loans Fannie Mae conducted nonjudicial foreclosure sales of the mortgaged properties. Appellants brought suit in a federal district court, arguing that the nonjudicial foreclosure sales violated their procedural due process rights under the Fifth Amendment. The district court dismissed those claims. The First Circuit affirmed, holding that FHFA and Fannie Mae were not government actors subject to Appellants' due process claims. View "Montilla v. Federal National Mortgage Ass'n" on Justia Law

The First Circuit vacated the judgment of the district court granting summary judgment in favor of Defendant in this case alleging a violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., holding that genuine issues of material fact precluded summary judgment.Plaintiff, who was Black, sued Bridgewater State university's Board of Trustees and Office of Equal Opportunity and a University administrator (collectively, Defendants) alleging that she was not hired for a University position because of her race. The district court granted summary judgment in favor of Defendants. The First Circuit reversed, holding that Plaintiff's aggregate package of proof sufficed to survive Defendants' motion for summary judgment. View "Taite v. Bridgewater State University" on Justia Law

The First Circuit reversed the order of the district court excluding two documents from the summary judgment record and granting summary judgment for Defendant on all of Plaintiff's claims, holding that the district court erred in excluding the two documents from the summary judgment record.Defendant terminated Defendant's employment after he had been employed for thirty-three years. Plaintiff brought this lawsuit alleging wrongful termination of his employment under state law and age discrimination under federal and state law. Defendant moved to strike two of Plaintiff's documents on the grounds that they had been produced after the discovery cut-off date and that they were not properly authenticated. The district court granted the motion to strike the documents and then granted Defendant's motion for summary judgment. The First Circuit reversed the order excluding the documents and vacated the entry of summary judgment, holding that the court erred in striking the documents and that material issues of fact precluded summary judgment. View "Zampierollo-Rheinfeldt v. Ingersoll-Rand de Puerto Rico, Inc." on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment to Defendants - various prison officials, the Massachusetts Department of Correction (DOC), and Plaintiff's prison physician - and dismissing Plaintiff's complaint for injunctive and declaratory relief and damages, holding that there was no error in the proceedings below.Plaintiff, an inmate at MCI-Concord in Massachusetts, brought this pro se complaint challenging the termination of his access to the prison's first-floor Lexis Nexis terminal and typewriter, where Plaintiff spent more than two years conducting legal research and creating legal documents. The district court granted summary judgment in favor of Defendants. The First Circuit affirmed, holding (1) Plaintiff's speculative arguments as to the summary judgment in favor of his prison doctor were not enough to summary judgment; (2) the district court properly found that the DOC defendants' legitimate explanations were not pretextual; and (3) the district court did not err in determining that there was no triable issue of material fact that Defendants subjected Plaintiff to cruel and unusual punishment by discontinuing Plaintiff's reliance upon the first-floor terminal. View "Snell v. Neville" on Justia Law

The First Circuit resolved a portion of Appellant's appeal in this opinion addressing the district court's grant of summary judgment in favor of the Town of Brookline, Massachusetts, the Brookline Board of Selectmen, the Town's counsel and Human Resources director, and select members of the Board, holding that the summary judgment is affirmed in part, vacated in part and remanded for further proceedings.Plaintiff, black man, brought this suit alleging that during his employment as a firefighter, he had been discriminated against and retaliated against for reporting discriminatory conduct. The district court entered summary judgment in favor of Defendants. The First Circuit affirmed in part and vacated in part the summary judgment granted in favor of Defendants, holding that the district court erred in granting summary judgment as to Plaintiff's retaliation claims under 42 U.S.C. 1983 against the Town, the Board, and certain members of the Board, in their personal and official capacities. The Court then remanded the case for further proceedings. View "Alston v. Town of Brookline, Mass." on Justia Law

The First Circuit vacated the order of the district court requiring immediate payment of a $10,000 settlement sum by Defendant, the Secretary of Corrections to Puerto Rico, and remanded with instructions to stay Plaintiff's effort to recover on the settlement, holding that the automatic stay provision of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA) applied.Plaintiff brought this suit under 42 U.S.C. 1983 against Defendant and others, alleging that the defendants had been deliberately indifferent to his medical needs while he was an inmate at the Baymon Correctional Facility. The parties eventually settled for $50,000. At issue was who was responsible to pay the remaining $10,000 of that sum. The district court ordered Defendant, and not the Commonwealth, to pay the balance of the settlement amount. Defendant appealed, arguing that Plaintiff's effort to collect the $10,000 should have been stayed under the automatic stay provision of PROMESA. The First Circuit agreed, holding that, given the manner in which Plaintiff styled his effort to recover, the automatic stay properly applied. View "Colon-Torres v. Negron-Fernandez" on Justia Law

The First Circuit held that the district court correctly denied the Commonwealth of Puerto Rico's motions for reconsideration at issue in this appeal insofar as they might be construed as motions to apply an automatic stay under the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA) to either dismiss a 42 U.S.C. 1983 action or a settlement agreement that had not yet been enforced, holding that the circuit court did not err.This case stemmed from a settlement following a section 1983 suit against a Commonwealth officer in the officer's individual capacity. After the settlement agreement was filed under seal and the district court had dismissed the case with prejudice, and before the first installment of the agreed settlement payments was due, the Financial Oversight and Management Board filed a petition for bankruptcy relief on behalf of the Commonwealth under Title III of PROMESA. Appellant filed a motion in opposition, arguing that the automatic stay was not applicable in his case. The district court granted the opposition. The Commonwealth filed a motions for reconsideration, which the district court denied. The First Circuit affirmed, holding that the district court did not err in denying the Commonwealth's motions for reconsideration insofar as they may be construed as motions to apply PROMESA's automatic stay to either the dismiss section 1983 action or the settlement agreement. View "Diaz-Morales v. Rubio-Paredes" on Justia Law