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 dismissing Plaintiff's complaint alleging that Defendants, his former employer along with its administrators, conspired to deprive him of his First, Fourth, Fifth, and Fourteenth Amendment rights, holding that the district court correctly dismissed the claims but erred in dismissing the Puerto Rico law claims with prejudice. In his complaint, Plaintiff alleged that several adverse employment actions taken against him by his employer were done in retaliation for his whistleblowing activities. The First Circuit (1) summarily affirmed the district court's dismissal of four of Plaintiff's claims, holding that Plaintiff failed to "seriously develop" argument in their favor on appeal; (2) affirmed the district court's dismissal of the remaining claims; and (3) vacated the district court's dismissal of the Puerto Rico claims with prejudice, holding that those claims should have been dismissed without prejudice. View "Borras-Borrero v. Corporacion del Fondo del Seguro del Estado" on Justia Law

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In these cases against four defendants - Manuel De Jesus Rosario-Perez (Rosario), Jorge Gomez-Gonzalez (Gomez), Bryant Setiawan-Ramos (Setiawan), and Santiago Hernandez-Rosa (Hernandez) - the First Circuit affirmed the various drug and weapons charges as to Rosario, Gomez, and Hernandez but vacated Setiawan's convictions and remanded his case for a new trial, holding that Setiawan's convictions must be set aside on a cumulative error theory. Each defendant was indicted for conspiracy to distribute drugs within 1,000 feet of a school and possession with intent to distribute heroin, cocaine, and marijuana. The indictment also charged everyone but Rosario with carrying and using firearms in relation to drug trafficking. Each defendant was convicted of one or more counts. The First Circuit affirmed, holding (1) most of Defendants' claims were without merit; but (2) the district court's decision to admit evidence that Setiawan killed "Teton," a drug seller, while excluding evidence that a witness named "Cascote" killed Teton was improper, and the cumulative effect of the decision warranted a new trial. View "United States v. Rosario-Perez" on Justia Law

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The First Circuit affirmed the district court's grant of summary judgment against Appellant and dismissing his race discrimination and retaliation claims against the Maine Department of Corrections (MDOC), holding that Appellant lacked the proof needed to reach trial. Appellant left his job with MDOC as a state corrections officer to apply for a position in the federal prison system. Appellant met the minimum qualification and interviewed for each open spot but was turned down each time. Appellant subsequently reapplied for his former job, but MDOC refused to rehire him. Appellant sued MDOC in federal court for race discrimination and retaliation. The district court judge granted summary judgment for MDOC. The First Circuit affirmed, holding that a reasonable jury could not find that MDOC's rejection of Appellant's application for reinstatement was a product of unlawful discrimination or made in retaliation for his complaint to the Maine Human Rights Commission. View "Brandt v. Fitzpatrick" on Justia Law

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The First Circuit affirmed the decision of the district court granting summary judgment in favor of Employer in this disability discrimination case brought by Plaintiff, a former employee, holding that the district court did not err in entering summary judgment against Plaintiff on her claims. Plaintiff was a military veteran who suffers from post-traumatic stress disorder (PTSD). After she was discharged from her employment, Plaintiff sued Employer for disability discrimination under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213, and the Maine Human Rights Act, Me. Stat. tit. 5 4551-4634, alleging that she was wrongfully discharged based on her PTSD. Plaintiff also claimed that Employer unlawfully failed to accommodate her disability. The district court granted summary judgment for Employer. The First Circuit affirmed, holding that the district court properly granted summary judgment for Employer on Plaintiff's discriminatory discharge claim and failure to accommodate claim. View "Trahan v. Wayfair Maine LLC" on Justia Law

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In this lawsuit brought against three Boston police officers who were involved in breaking up a party and arresting Plaintiffs, the First Circuit reversed the judgment for Plaintiffs, holding that the officers were entitled to qualified immunity for entering through the open door of a house under the community care taking exception to the Fourth Amendment's warrant requirement. Plaintiffs brought civil rights claims under 42 U.S.C. 1983 and Mass. Gen. Laws ch. 12, 11H and 11I, as well as state tort claims for, among other things, false imprisonment. The jury reached a unanimous verdict in favor of Defendants on all counts. The district court, however, granted Plaintiffs' motion for a new trial, finding that the verdict was against the law as to the officers' warrantless entry into the home and that the warrantless entry on the facts as presented in the trial was not protected by qualified immunity. The court then amended its judgment so that it reflected a judgment in favor of Plaintiffs as to the section 1983 unlawful entry claim. The First Circuit reversed, holding that the officers were entitled to qualified immunity because, under the community caretaking exception, their entry through the home's open door did not violate Plaintiffs' constitutional rights. View "Castagna v. Jean" on Justia Law

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The First Circuit dismissed this interlocutory appeal for lack of appellate jurisdiction and remanded the matter to the district court, holding that Appellant's challenge to the district court's denial of summary judgment was not a final, appealable order. Plaintiff, an inmate at Souza Baranowski Correctional Center (SBCC), brought this lawsuit alleging that Appellant, an SBCC prison official, and other SBCC officials failed to protect him from a substantial risk of serious harm in violation of his constitutional rights. Appellant and the remaining defendants filed for summary judgment on grounds of qualified immunity. The district court granted summary judgment to all SBCC officials except Appellant. Appellant filed a timely interlocutory appeal, alleging that the district court erred because the undisputed material facts showed Appellant was not deliberately indifferent to a substantial risk of harm to Plaintiff. The First Circuit dismissed the appeal, holding that Appellant's challenge rested on factual, rather than legal, grounds, and therefore, this Court lacked appellate jurisdiction. View "Norton v. Rodrigues" on Justia Law

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The First Circuit affirmed the order of the district court granting summary judgment in favor of the United States and the Director of the United States Citizenship and Immigration Services (collectively, the Government) on Plaintiff's claims that the inclusion of the phrase "so help me God" at the end of the both of allegiance administered at United States naturalization ceremonies is unlawful and unconstitutional, holding that the district court correctly denied Plaintiff's claims. In her complaint, Plaintiff argued that the inclusion of "so help me God" as a means of completing the naturalization oath violates the First and Fifth Amendments and the Religious Freedom Restoration Act, 42 U.S.C. 2000bb-2000bb-4 (RFRA). The district court granted summary judgment on all claims. The First Circuit affirmed, holding that the phrase "so help me God" in the oath does not violate the Establishment Clause, the Free Exercise Clause, the RFRA, Equal Protection, or the Due Process Clause. View "Perrier-Bilbo v. United States" on Justia Law

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The First Circuit affirmed Defendant's convictions for one count of conspiracy and one count of structuring the export of monetary transactions, holding that there was no error in the proceedings below. Defendant's convictions arose from his role in assisting the leader of conspiracy in smuggling cash through the Logan International Airport in Boston and onto a plane headed to Portuguese islands in the Atlantic Ocean. The First Circuit affirmed the convictions, holding (1) the district court did not err in denying Defendant's motion to suppress certain evidence against him; (2) the district court did not err by admitting into evidence certain statements that the leader made to undercover agents and to admit records of Defendant's phone contacts with the leader; (3) there was no merit to Defendant's argument that the district court erred by refusing to issue certain jury instructions that Defendant argued he requested; and (4) Defendant's remaining allegations of error were without merit. View "United States v. Melo" on Justia Law

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The First Circuit affirmed the judgment of the district court granting Defendants' motion to dismiss Plaintiffs' complaint alleging that Defendants knew that Mount Ida College was on the brink of insolvency but concealed this information, holding that Plaintiffs' claims were properly dismissed. Mount Ida, a higher education institution in Massachusetts, permanently closed after providing its students six weeks' notice that it was closing. Plaintiffs, current and prospective students, brought a putative class action against Mount Ida, its board of trustees, and five Mount Ida administrators (collectively, Defendants), alleging seven Massachusetts state law claims. The district court dismissed the complaint. The First Circuit affirmed, holding (1) Plaintiffs' breach of fiduciary duty claim failed; (2) the district court did not err in dismissing Plaintiffs' violation of privacy claim; (3) no claims were stated for fraud, negligent misrepresentation, or fraud in the inducement; (4) Plaintiffs' allegations did not plausibly allege a breach of implied contract; and (5) the district court properly dismissed Plaintiffs' Mass. Gen. Laws ch. 93A claim. View "Squeri v. Mount Ida College" on Justia Law

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The First Circuit vacated the district court's decision granting summary judgment to the City of Somerville, Massachusetts and dismissing Plaintiff's claim that the City unlawfully forced him to retire as a police officer when it discovered that he had basically no vision in one eye, holding that Plaintiff raised a triable issue of fact precluding summary judgment. Plaintiff brought this lawsuit alleging violations of the Americans with Disabilities Act, the Rehabilitation Act, and Massachusetts discrimination law. In granting summary judgment to the City, the district court ruled in part that no reasonable jury could find that Plaintiff could perform high-speed pursuit driving, which the court concluded was an essential function of his job. The First Circuit vacated the summary judgment, holding that Plaintiff raised a triable issue of fact as to whether his monocular vision rendered him unqualified to perform the essential job functions of an incumbent officer in the City's police department. View "Melo v. City of Somerville" on Justia Law