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

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 Brookeline 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 affirmed Defendant's conviction of Hobbs Act robbery, murdering a person through the use of firearm during a crime of violence, possessing a firearm in furtherance of a crime of violence, and being a convicted felon in possession of a firearm, holding that there was no error in the proceedings below.Specifically, the First Circuit held (1) under the circumstances of this case, the district court did not err in denying Defendant's motion to suppress identification evidence; (2) the evidence was sufficient to support Defendant's convictions; and (3) the district court did not err in determining that Hobbs Act robbery qualifies as a "crime of violence" under 18 U.S.C. 924(c). View "United States v. Seary-Colon" on Justia Law

The First Circuit affirmed the the district court's denial of Petitioner's petition filed pursuant to 28 U.S.C. 2255 to vacate, set aside, or correct his sentence, holding that the district court did not err in denying the motion.Petitioner pled guilty to one count of possession of a firearm and entered into a plea agreement with the government that included a sixty-month sentencing recommendation. At sentencing, the district court imposed a 120-month sentence. The First Circuit affirmed. Thereafter, Petitioner filed this petition asserting ineffective assistance of counsel. The district court denied relief. The First Circuit affirmed, holding that Petitioner was not prejudiced by counsel's failure to object to the discrepancy between two versions of events contained in the presentence investigation report. View "Fernandez-Garay v. United States" on Justia Law

The First Circuit denied Plaintiff's motion for an injunction preventing the implementation of a plan promulgated by the Boston Public Schools for admitting students to Boston Latin School, Boston Latin Academy, and John D. O'Bryant School of Mathematics and Science for the 2021-2022 school year, holding that Plaintiff did not show it was not entitled to the injunction.Plaintiff, a corporation acting on behalf of fourteen parents and children residing in Boston, asserted that the 2021-2022 admissions plan violated the Equal Protection Clause of the Fourteenth Amendment and Mass. Gen. Laws ch. 76, 5. The district court entered judgment in Defendants' favor. Plaintiff appealed and moved for an order under Fed. R. Civ. P. 62(d) enjoining Defendants from implementing the plan during the pendency of this appeal. The First Circuit denied the motion, holding that Plaintiff failed to show a strong likelihood that it would prevail on the merits. View "Boston Parent Coalition for Academic Excellence Corp. v. School Committee of City of Boston" on Justia Law

The First Circuit affirmed the district court's grant of summary judgment in favor of Defendants - the City of Framingham and Chief of the Framingham Police Department - in this Garcetti speech-retaliation and Massachusetts Whistleblower Act action brought by Plaintiff, an FPD detective, holding that the district court did not err.Plaintiff brought this lawsuit challenging allegedly retaliatory employment actions, including a five-day suspension and his being put on paid administrative leave during an investigation. The district court granted summary judgment for Defendants, concluding that Defendants met their burden to show that the adverse employment decisions would have occurred despite Plaintiff's protected speech. The First Circuit affirmed, holding that Defendants met their burden to prove an independent non-retaliatory basis for Plaintiff's discipline. View "Gutwill v. City of Framingham" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's petition for a writ of habeas corpus, holding that Appellant was not entitled to relief.Appellant was convicted in Massachusetts of murder in the first degree. The Massachusetts Supreme Judicial Court affirmed. In his habeas petition, Appellant argued that testimony was erroneously introduced at trial that he had given to a grand jury without being advised of his privilege against self-incrimination. Appellant presented this same argument in his challenge to his conviction on appeal and in his appeal of the denial of his motion for a new trial, all without success. The district court denied Appellant's habeas petition. The Supreme Judicial Court affirmed, holding that Appellant's Fifth Amendment rights were not violated by the admission of his grand jury testimony. View "Woods v. Medeiros" on Justia Law

The First Circuit affirmed Defendant's conviction of one count of possession with intent to distribute various controlled substance and one count of possession of a firearm in furtherance of a drug-trafficking crime, holding that the district court did not err in denying Defendant's motion to suppress.Defendant sought to suppress drug evidence and a firearm seized pursuant to a search warrant for the car he was driving when he was arrested on an outstanding federal warrant. In his motion, Defendant argued that the search warrant for the car was invalid because it was issued based on an unlawful inventory search. The First Circuit affirmed the denial of Defendant's motion to suppress, holding that the district court did not err in concluding that (1) the officers had an objectively reasonable non-investigatory purpose; and (2) the inventory search of the car was unlawful. View "United States v. Sylvester" on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment in favor of Novo Nordisk Inc. and dismissing Plaintiffs' age discrimination claims, holding that the district court did not err.During a global reorganization, Novo Nordisk terminated Plaintiffs from their jobs based in Puerto Rico and did not select Plaintiffs for post-reorganization positions. Plaintiffs brought this complaint alleging that Novo Nordisk violated Puerto Rico's statutes prohibiting age discrimination in employment and penalizing termination without just cause. The district court granted summary judgment in favor of Novo Nordisk on all of Plaintiffs' claims. The First Circuit affirmed, holding that summary judgment was properly granted. View "Puig Martinez v. Novo Nordisk Inc." on Justia Law

The First Circuit denied Defendant's appeal of his conviction for unlawful possession of a firearm by a prohibited person in violation of 18 U.S.C. 922(g) and 924(a)(2), holding that the district court did not commit plain error by accepting Defendant's guilty plea and in denying his motion to suppress.Following Defendant's plea, the Supreme Court decided Rehaif v. United States, 139 S. Ct. 2191 (2019), under which the government must prove that the defendant knew he had the relevant status prohibiting possession. On appeal, Defendant argued (1) under Rehaif, the district court committed plain error during his plea colloquy by failing to inform him that the government was required to prove that he knew he was prohibited from possessing firearms; and (2) the district court erred by denying his motion to suppress. The First Circuit affirmed, holding (1) the search warrant issued for Defendant's residence was supported by probable cause; and (2) the district court did not plainly err by accepting Defendant's guilty plea. View "United States v. Austin" on Justia Law

The First Circuit affirmed Defendant's eighteen-month sentence imposed for violating the conditions of his supervised release by committing a new crime, holding that Defendant had not suffered any prejudice from the delay in his supervised release revocation hearing.The revocation hearing concluded thirty months after the the United States Probation Office petitioned the district court to revoke supervised release and eight months after Defendant was taken into federal custody. On appeal, Defendant argued that his revocation hearing was unreasonably delayed in violation of his rights under Fed. R. Crim. P. 32.1 and the due process clause of the United States Constitution. The First Circuit affirmed, holding that Defendant's claim failed on the prejudice prong. View "United States v. Torres-Santana" on Justia Law