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

The First Circuit affirmed in part and vacated in part the judgment of the district court entered judgment for the pleadings on all of Plaintiff's claims, holding that Plaintiff's state certiorari claim did not fail to state a claim on the pleadings.Plaintiff, a former City of Haverhill police officer, brought this action against the city's chief of police and the city's mayor after Plaintiff was denied his request for an identification card to allow him to carry a concealed firearm across state lines under the Law Enforcement Officers Safety Act. Defendants removed the case to federal district court, which entered judgment on the pleadings for Defendants on all four of Plaintiff's claims. The First Circuit directed the dismissal of Plaintiff's state certiorari claim without prejudice for lack of jurisdiction and otherwise affirmed, holding (1) Massachusetts has, in its state certiorari procedure, provided a constitutionally adequate remedy precluding assertion of a federal procedural due process claim in this case; (2) Plaintiff failed to plead facts sufficient to support his federal substantive due process claim; (3) the district court properly dismissed Plaintiff's 42 U.S.C. 1983 due process claim; and (4) Plaintiff's negligence claim and purported equity claim plainly failed to assert a claim under state law. View "Lambert v. Fiorentini" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment to the Administrator of the United States General Services Administration (GSA) and dismissing the discrimination and retaliation claim brought by Plaintiff, a former employee of that agency, holding that summary judgment was properly granted on Plaintiff's claims.Specifically, the Court held (1) the district court did not err in granting summary judgment to the GSA on Plaintiff's sex discrimination claims under Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq.; (2) the district court did not err in granting summary judgment to the GSA on Plaintiff's age discrimination claims under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq.; and (3) Plaintiff's retaliation claims under Title VII and the ADEA also lacked merit. View "Paul v. Murphy" on Justia Law

The First Circuit affirmed Defendant's conviction of conspiracy to possess with intent to distribute and to distribute oxycodone, holding that the district court did not err in denying Defendant's motion to suppress.The motion to suppress centered around a series of five search warrants federal law enforcement officers executed as part of an investigation into an oxycodone-distribution conspiracy involving Defendant. The officers obtained location data for Defendant's cell phones and recovered a significant amount of cash stored in a hidden compartment in Defendant's vehicle. This information led to charges that Defendant was the New York-based oxycodone supplier for his co-conspirators' Massachusetts operation. Defendant filed, without success, a motion to suppress, arguing that the first warrant for cellular location data, which served as the foundation for the subsequent warrants, was not supported by probable cause. Defendant was subsequently convicted. The First Circuit affirmed, holding that the warrant for Defendant's vehicle was properly issued, and therefore, the evidence seized from the vehicle was properly admitted at trial. View "United States v. Bregu" on Justia Law

The First Circuit affirmed Defendant's conviction of interstate transportation of a minor with intent to engage in criminal sexual activity, holding that the district court did not err in denying Defendant's motion to suppress the confession he made during the second phase of his custodial interrogation.In support of his motion to suppress Defendant argued that the interrogation violated his Fifth Amendment rights as set forth in Miranda v. Arizona, 384 U.S. 436 (1966), and Edwards v. Arizona, 451 U.S. 477 (1981). The district court denied the motion, finding that Defendant initiated the second phase of the interview, that Defendant did not thereafter reinvade his right to counsel, and that Defendant knowingly and voluntarily waived his Miranda rights before confessing. The First Circuit affirmed, holding that Defendant's confession was admissible at trial for all of the reasons determined by the district court. View "United States v. Carpentino" on Justia Law

The First Circuit reversed Defendant's conviction, holding that the district court erred in denying Defendant's motion to suppress seized evidence because law enforcement officers' warrantless entry into the house where Defendant was living, on the grounds that exigent circumstances existed, was unconstitutional, and there was no evidence demonstrating a different exception to the warrant requirement applied.Defendant was convicted of sixteen counts of production of child pornography and one count of possession of child pornography involving prepubescent minors. Defendant appealed the denial of his motion to suppress, arguing that the warrantless entry into his mother's house, where he was living, was presumptively unreasonable and that no exception to the warrant requirement existed. The First Circuit agreed and remanded the case to the district court to determine whether consent to the entry was given, holding that entry into the home on the basis of exigency was unconstitutional and could not serve as justification for the search and seizure that followed. View "United States v. Rodriguez-Pacheco" on Justia Law

The First Circuit affirmed the district court's order dismissing Plaintiff's disability discrimination and failure to accommodate claims on summary judgment, holding that the district court did not abuse its discretion in partially striking Plaintiff's affidavit submitted in support of his opposition to Defendant's motion for summary judgment and that Plaintiff failed to establish a prima facie case of disability discrimination or a claim for failure to accommodate.Specifically, the Court held (1) the district court did not clearly abuse its discretion in striking Plaintiff's inconsistent statements in his affidavit; and (2) the district court properly granted summary judgment because Plaintiff failed to establish a prima facie case of disability discrimination and that Plaintiff's failure to accommodate claims failed on the merits. View "Flaherty v. Entergy Nuclear Operations, Inc." on Justia Law

The First Circuit affirmed Defendant's convictions and dismissed without prejudice Defendant's claim of ineffective assistance of counsel, holding that Defendant was not entitled to relief on her allegations of error.Defendant was convicted of twelve counts of making a materially false statement to a federal agency. On appeal, Defendant argued, among other things, that she received ineffective assistance of trial counsel. The First Circuit affirmed, holding (1) Defendant's convictions were supported by sufficient evidence; (2) Defendant was not denied her federal constitutional right to be present at any stage of the criminal proceeding; (3) the district court did not abuse its discretion in providing a so-called "nullification instruction" to the jury; (4) Defendant waived a duplicity challenge to certain counts; and (5) the record was not sufficiently developed to permit appellate consideration of Defendant's ineffective assistance of counsel claim. View "United States v. Brown" on Justia Law

The First Circuit affirmed Defendant's conviction of drug trafficking charges, including conspiracy to distribute one kilogram or more of heroin, and Defendant's sentence of 136 months in prison, holding that no reversible error occurred in the proceedings below.Pursuant to a search warrant, federal agents searched Defendant's apartment and found a stolen gun, more than $30,000 in cash, more than a kilo of heroin, and other narcotics and drug paraphernalia. Defendant pleaded guilty to several drug trafficking charges. The First Circuit affirmed, holding that the trial judge did not err by (1) denying Defendant's motion to suppress the evidence from his apartment; (2) denying Defendant's motion to withdraw his guilty plea; (3) deciding not to appoint new counsel and to let Defendant handle his sentencing pro se; and (4) failing to set a lower guideline sentencing range. View "United States v. Gonzalez-Arias" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motion to suppress his booking fingerprints as the fruit of what he argued was an unlawful arrest, holding that because the fingerprints were obtained for routine booking purposes there was no basis in the record for suppression of the fingerprint evidence.During a law enforcement scheme targeting a stolen identity refund fraud scheme, Defendant was administratively arrested for unlawful presence in the United States. Defendant was fingerprinted during a routine booking and later charged with multiple counts related to his involvement in the scheme. Defendant moved to suppress his booking fingerprints. The district court denied the motion, concluding that Defendant was arrested without probable cause but that the fingerprint evidence was admissible under the doctrine of inevitable discovery. The First Circuit affirmed, albeit on different grounds, holding that where the fingerprints were not obtained for any purpose other than routine booking the evidence could not be suppressed under the exclusionary rule. View "United States v. Cruz-Mercedes" on Justia Law

The First Circuit reversed the judgment of the magistrate judge concluding that Defendant, a state drug lab supervisor, was not entitled to qualified immunity from a claim brought under 42 U.S.C. 1983 and vacated the denial of Defendant's motion to dismiss an intentional infliction of emotional distress state law claim, holding that Defendant was entitled to qualified immunity from the section 1983 claim.Plaintiff's conviction was vacated after the discovery of the drug abuse of Sonja Farak, a chemist at the Amherst Drug Lab on the campus of the University of Massachusetts. Plaintiff brought this complaint alleged that Defendant's inadequate supervision Farak constituted deliberate indifference to Defendant's constitutional rights. Defendant also claimed intentional infliction of emotional distress. The magistrate judge denied Defendant's motion to dismiss the section 1983 claim and held that Defendant's behavior showing a disregard for "repeated red flags" was enough to state a claim for intentional infliction of emotional distress under state law. The First Circuit reversed in part and vacated in part, holding (1) Defendant was entitled to qualified immunity from the section 1983 claim; and (2) because the sole basis for federal jurisdiction was dismissed the judgment on the intentional infliction of emotional distress state law claim is remanded to state court. View "Penate v. Hanchett" on Justia Law