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

In this civil rights action alleging violations of 42 U.S.C. 1981, 1983, and 1985, the First Circuit affirmed the judgment of the district court dismissing with prejudice Plaintiff's claims against Stanley Spiegel and later granting summary judgment in favor of the remaining defendants, holding that the allegations against Spiegel failed to state a claim upon which relief can be granted.Defendant's second amended complaint named as defendants the Town of Brookline, Massachusetts, the Brookline Board of Selectmen, certain members of the Board, Spiegel (a town meeting member), and others. Plaintiff alleged that Defendants discriminated against him on the basis of race, retaliated against him for exercising his First Amendment rights, and conspired to enforce the Town's policy of opposing racial equality. After the district court disposed of Defendant's claims he appealed, arguing that the district court erred by dismissing his claims against Spiegel. The First Circuit affirmed, holding that there were no facts pleaded in the complaint sufficient to ground a reasonable inference that Spiegel was liable to Defendant for any of the causes of action he brought. View "Alston v. Town of Brookline, Massachusetts" on Justia Law

The First Circuit affirmed the judgment of the district court revoking Defendant's supervised release and sentencing him to six months of imprisonment and an additional eight years of supervised release, holding that Defendant's constitutional rights were not violated.On appeal, Defendant argued that the revocation of his release violated his privilege against self-incrimination under the Fifth Amendment and that his suspension from treatment violated his Fifth Amendment due process right. The First Circuit disagreed, holding (1) a court in this circuit can impose mandatory periodic polygraph examinations in connection with sex offender treatment programs as a condition of supervised release, where the condition prohibits basing revocation in any way on the defendant's assertion of his Fifth Amendment privilege against self-incrimination; (2) in this case, no penalty was attached to Defendant's potential invocation of the Fifth Amendment privilege, and therefore, his privilege was not violated; and (3) Defendant's suspension from sex offender treatment did not violate his Fifth Amendment right to due process. View "United States v. Rogers" on Justia Law

The First Circuit affirmed Defendant's conviction for possession of a controlled substance with intent to distribute, holding that the district court did not err in concluding that the police officers had reasonable suspicion to approach the vehicle in which Defendant was a passenger and direct its occupants to exit.Defendant filed a motion to suppress evidence of cash and drugs that were recovered from him and the other occupant of the car after officers instigated an investigatory motor vehicle stop. The district court denied the motion, holding that reasonable suspicion existed to support the traffic stop. The First Circuit affirmed, holding that the police officers had reasonable suspicion that the vehicle's occupants were involved in illegal drug activity, and therefore, the officers' decision to approach the car and search Defendant did not violate the Fourth Amendment. View "United States v. Tom" on Justia Law

In this appeal arising from a lawsuit brought under the Americans with Disabilities Act (ADA) and the Puerto Rico Civil Rights Act the First Circuit affirmed the decision of the district court denying Plaintiffs' post-judgment motion for attorney's fees and motion to reopen, holding that the district court did not abuse its discretion.In their complaint, Plaintiffs alleged that they encountered barriers to their equal access and full enjoyment of Defendants' facilities, services, goods, and amenities. Plaintiffs later moved for final judgment on their ADA claims, claiming that they obtained the requested relief under federal law because Defendants had agreed to make challenges or adjustments to the design of the locale. The district court dismissed the claims without prejudice, stating that Plaintiffs may file a motion to reopen if Defendants failed to comply with the agreed-upon deadlines. Plaintiffs then moved for attorney's fees, arguing that they were the prevailing parties under the ADA's fee-shifting provision, 42 U.S.C. 12205. The district court denied the motion. The First Circuit affirmed, holding (1) Plaintiffs failed to demonstrate the requisite judicial imprimatur on the outcome to make them prevailing parties; and (2) the district court did not abuse its discretion in declining to reopen the case based on Appellants' allegations. View "Suarez-Torres v. Panaderia y Reposteria Espana, Inc." on Justia Law

The First Circuit affirmed Defendant's conviction and sentence imposed after he pled guilty to six counts stemming from a robbery of a federal confidential informant during a guns-for-cash deal, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the First Circuit held (1) Defendant's challenge based on Rehaif v. United States, 139 S. Ct. 2191 (2019), to his conviction for possession of a firearm by a felon, in violation of 18 U.S.C. 922(g), was without merit; (2) Defendant's challenge to the plea colloquy failed; (3) Defendant's challenge based upon United States v. Davis, 139 S. Ct. 2319 (2019), to the acceptance of his plea to aiding and abetting the use of a firearm during and in relation to a crime of violence, in violation of 18 U.S.C. 2, 924(c), failed on plain error review; (4) the prosecutor did not breach plea agreement; and (5) Defendant's sentence of 198 months' imprisonment was neither procedurally nor substantively unreasonable. View "United States v. Farmer" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Employer and dismissing Employee's claims for retaliation in violation of the Family and Medical Leave Act (FMLA), 29 U.S.C. 2612, and disability discrimination in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213, and the Rhode Island Fair Employment Practices Act, R.I. Gen. Laws 28-5-7, holding that the district court did not err.Employee took leave from Employer under the FMLA to undergo preventive surgery and then took a second leave for a related surgery that same year. The following year, Employer eliminated Employee's position. As an alternative to termination, Employer offered Employee a newly created, lower level position with a lower salary. Employee declined the position, and Employer terminated her employment. Plaintiff then brought this action. The district court granted summary judgment in favor of Employer. The First Circuit affirmed, holding that summary judgment was properly granted. View "O'Rourke v. Tiffany & Co." on Justia Law

In this civil action brought by plaintiffs seeking to enjoin policies governing searches of electronic devices at the United States' borders, the First Circuit found no violations of either the Fourth Amendment or the First Amendment.The border search policies challenged her allow border agents to perform basic searches of electronic devices without reasonable suspicion and advanced searches with reasonable suspicion. The First Circuit joined the Eleventh Circuit in holding that advanced searches of electronic devices at the border do not require a warrant or probable cause and joined the Ninth and Eleventh Circuits in holding that basic border searches of electronic devices are routine searches that may be performed without reasonable suspicion. The Court then affirmed in part, reversed in part and vacated in part the judgment of the district court, holding that the court erred in narrowing the scope of permissible searches of electronic devices at the border. View "Alasaad v. Wolf" on Justia Law

The First Circuit affirmed the judgment of the district court upholding the jury verdict awarding Plaintiff compensatory on his claims of failure to accommodate his disability at work but remitting the jury's punitive damages award, holding that Defendants' claims on appeal failed.Specifically, the First Circuit held (1) the district court did not err in denying Defendants' post-trial motions for judgment as a matter of law because Plaintiff sufficiently proved his case under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101, and Maine Human Rights Act (MHRA), Me. Stat. tit. 5, 4571; (2) the district court's rulings denying Defendants' motion for a new trial were not an abuse of discretion; and (3) the district court did not abuse its discretion in denying Defendants' motion for remittitur because Defendants' arguments in support of the motion were misplaced and unsupported by the record. View "Burnett v. Ocean Properties, Ltd." on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment to the government on all of Plaintiff's claims, holding that summary judgment was properly granted on Plaintiff's sex discrimination and retaliation claims.Plaintiff, an employee of the Drug Enforcement Agency, brought this action claiming that she had been discriminated against because of her national origin, disability, and sex and that she had been subjected to illegal retaliation. The district court granted summary judgment to the government on all claims. Plaintiff appealed, challenging the judgment as to her sex discrimination and retaliation claims. The First Circuit affirmed, holding that Plaintiff's sex discrimination and retaliation claims could not survive summary judgment. View "Hernandez v. Wilkinson" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant of committing, or aiding and abetting others in committing, the crimes of RICO conspiracy, drug conspiracy, and other crimes, holding that Defendant was not entitled to relief on his allegations of error.After Defendant was originally convicted the First Circuit vacated the convictions, concluding that the police lacked probable cause to search Defendant's house, and therefore, the seized evidence should have been suppressed. On remand, a jury again convicted Defendant of the relevant charges. Defendant appealed, claiming trial error and sentencing issues. The First Circuit affirmed, holding (1) Defendant's claims of trial error were without merit; (2) there was sufficient evidence to support the convictions; (3) the trial court did not err in instructing the jury; (4) there was no abuse of discretion in the denial of Defendant's motion for a new trial; and (5) Defendant's sentence was not procedurally unreasonable. View "United States v. Cruz-Ramos" on Justia Law