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

The First Circuit affirmed the decision of the district court denying Defendant's motion to suppress drug evidence that was seized without a warrant after an automobile stop and drug evidence from a subsequent visual body cavity search, holding that the police had reasonable suspicion to perform the automobile stop and particularized reasonable suspicion to perform the visual body cavity search.On appeal, Defendant argued that his rights under the Fourth and Fourteenth Amendments were violated because the law enforcement officers lacked reasonable suspicion to perform the initial stop of his vehicle and the requisite level of suspicion to perform the visual body cavity search of his person at the police station. The First Circuit disagreed, holding that the officers (1) had reasonable suspicion to stop Defendant's vehicle; and (2) had particularized reasonable suspicion to conduct the visual body cavity search. View "United States v. Perez" on Justia Law

The First Circuit affirmed the district court's grant of summary judgment on Plaintiff's racial discrimination and retaliation claims against the Massachusetts Bay Transportation Authority (MBTA), holding that both challenges were meritless.Plaintiff brought claims of racial discrimination, unlawful retaliation, and negligent infliction of emotional distress against the MBTA. The district court granted summary judgment to the MBTA on all claims. The First Circuit affirmed, holding (1) Plaintiff did not produce sufficient evidence to get to a jury on his claim that he was denied a promotion based on his race; and (2) Plaintiff did not establish a prima facie case of retaliation. View "Henderson v. Massachusetts Bay Transportation Authority" on Justia Law

The First Circuit vacated the decision of the district court granting summary judgment for Defendants and dismissing Plaintiff's 42 U.S.C. 1983 action on the grounds that Plaintiff's claims were time barred, holding that there was no basis for summary judgment on the record.Plaintiff filed suit against the City of Biddeford, Captain Norman Gaudette with the Biddeford Police Department (BPD), and Chief of Police Roger Beaupre, alleging that Gaudette sexually abused him as a teenager in the later 1980s and that the City and Baupre were deliberately indifferent to Gaudette's violation of his constitutional rights when Plaintiff reported the abuse. Defendants argued that the suit was barred by the statute of limitations. In response, Plaintiff asserted that his claims did not accrue until 2015, when he learned that the BPD and Baupre allegedly knew of at least one other report of Gaudette sexually abusing a minor that pre-dated Plaintiff's experience. The district court granted summary judgment for Defendants. The First Circuit reversed, holding (1) a reasonable jury could find that Plaintiff had no duty to diligently investigate his claims against Defendants before 2015; and (2) therefore, the district court erred in concluding as a matter of law that Plaintiff's claims accrued at the time of his injury in the late 1980s. View "Ouellette v. Beaupre" on Justia Law

The First Circuit affirmed the judgment of district court dismissing Plaintiff's case against the City of Boston and several of its police officers, holding that the district court did not abuse its discretion in dismissing the case with prejudice.Plaintiff filed suit in superior court under 42 U.S.C. 1983 and the Massachusetts Tort Claims Act, alleging, among other things, false arrest and imprisonment, excessive force, and intentional infliction of emotional distress. After a lengthy history of delay, the district court gave Plaintiff fourteen days to serve an amended complaint on two defendants. Plaintiff never properly served one of the defendants. The district court dismissed the defendant not properly served. The court then dismissed the other defendant, concluding that Plaintiff's failure to meet a deadline for service did not constitute excusable neglect. The First Circuit affirmed, holding that the district court acted within its discretion in dismissing the case with prejudice. View "Tubens v. Doe" on Justia Law

The First Circuit vacated the judgment of the district court in favor of Defendant on Plaintiff's claim that Defendant failed properly to accommodate his disability under the Americans with Disabilities Act (ADA), 42 U.S.C. 1210 et seq., and the Maine Humans Rights Act (MHRA), Me. Rev. Stat. 5, 4551 et seq., holding that the district court committed prejudicial error in instructing the jury.On appeal, Plaintiff argued that the district court erred in instructing the jury that to succeed on a claim that an employer failed to provide a reasonable accommodation, a plaintiff must prove that he needed an accommodation to perform the essential functions of his job. The First Circuit agreed, holding (1) by instructing the jury that an employee must demonstrate that he needed an accommodation to perform the essential functions of his job, the district court wrongly limited Plaintiff's potential liability; and (2) the error was prejudicial. View "Bell v. O'Reilly Auto Enterprises, LLC" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendants' motions for judgment as a matter of law or, in the alternative, for a new trial or remittitur, holding that the trial court properly found Defendants liable for conspiracy to violate Plaintiff's civil rights.Plaintiff suffered a head injury at the Andover, Massachusetts State Police Barracks. Plaintiff filed this action against the three officers involved in his booking, including Trooper James J. Foley, alleging several federal and state causes of action. After a trial, the jury found Foley liable on six claims, including the use of excessive force, and all three officers liable for conspiracy to violate Plaintiff's civil rights. On appeal, Defendants argued that the district court erred in denying their motions for judgment as a matter of law or, in the alternative, for a new trial or remittitur. The First Circuit affirmed, holding that the district court (1) correctly denied Defendants' post-verdict motions for judgment as a matter of law on each of the counts for which they were found liable; (2) did not abuse its discretion in declining to order a new trial; and (3) did not err in denying Foley's motion for remittitur. View "Sanchez v. Foley" on Justia Law

The First Circuit reversed the decision of the district court denying Defendant's motion to dismiss his indictment under the Double Jeopardy Clause of the United States Constitution based on his prior conviction in a Commonwealth court for a local drug offense, holding that Defendant met his burden to make a prima facie case that he had been prosecuted twice for the same conduct under equivalent criminal laws.On March 15, 2016, Defendant pleaded guilty to a violation of Article 406 of the Puerto Rico Controlled Substances Act. About sixteen months later, Defendant was named in a federal indictment charging him with five drug-related federal offenses, including conspiracy to possess with intent to distribute controlled substances, in violation of 21 U.S.c. 846. Defendant moved to dismiss the section 846 conspiracy count on double jeopardy grounds, alleging that his prior Article 406 conviction was for the same criminal conduct that the section 846 count charged him with committing. The district court denied the motion. The First Circuit reversed, holding that Defendant met his burden of presenting evidence to establish a prima facie non frivolous double jeopardy claim, and the government failed to meet its burden to rebut it. View "United States v. Reyes-Correa" on Justia Law

The First Circuit reversed Defendant's conviction for transporting a minor in interstate or foreign commerce or in any commonwealth, territory or possession of the United States with the intent to engage in criminal sexual activity, holding that the trial judge violated Defendant's Sixth Amendment right to in-person confrontation when he allowed the victim to testify by two-way close-circuit television and without making specific on the record findings.Specifically, the First Circuit held (1) 2423(a)'s ban on transporting a minor to commit a sex crime applies to transportation without Puerto Rico, which is a "commonwealth" of the United States under the statute; (2) there was sufficient evidence to support the conviction; (3) the judge properly instructed the jury on the elements of the Puerto Rico crimes the government alleged Defendant had intended to commit at her destination; but (4) the judge violated Defendant's right to confront the victim in person absent a compelling need for remote testimony, and the error was not harmless beyond a reasonable doubt. View "United States v. Cotto-Flores" on Justia Law

The First Circuit held that the district court did not abuse its discretion in granting a preliminary injunction prohibiting Defendants - Maine's Cape Elizabeth School District and officials of Cape Elizabeth High School - from suspending A.M., a student at the high school, holding that the district court did not abuse its discretion in issuing the preliminary injunction.A.M. anonymously posted a sticky note on a mirror at the high school girls' bathroom stating, "There's a rapist in our school and you know who it is." Defendants determined that the note constituted bullying under the school's policies and imposed a three-day suspension on A.M. Through her mother, A.M. filed a complaint requesting that the district court enjoin Defendants from suspending her, arguing, among other things, that the suspension violated her right to free expression under the First Amendment. A.M. also moved for a preliminary injunction. The district court granted a preliminary injunction based on A.M.'s First Amendment claim. The First Circuit affirmed, holding that A.M. showed a likelihood of success in demonstrating that her sticky note was constitutionally protected speech. View "Norris v. Cape Elizabeth School District" on Justia Law

The First Circuit vacated the district court's dismissal of Plaintiff's claim for a violation of Title IX, 20 U.S.C. 1961 et seq., and affirmed the district court's dismissal of the other claims, holding that Plaintiff's allegations told a plausible story of deliberate indifference by school officials to repeated and severe sexual harassment.Plaintiff alleged that she was the victim of several incidents of sexual assault and harassment while she was a student at the Pawtucket Learning Academy in Rhode Island. Plaintiff sued twenty-one defendants under sixteen different counts. The district court dismissed the entire action. The First Circuit vacated the judgment in part, holding that based on the facts set forth in Plaintiff's complaint it was plausible that a fact-finder could find that the conduct of school officials caused Plaintiff's harassment in some way or made Plaintiff liable or vulnerable to harassment. View "Doe v. Pawtucket School Department" on Justia Law