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

This case involves a child with significant developmental disabilities, B.D., who attended Georgetown Public Schools. B.D.'s parents, Rachel and Michael Doucette, sued the school district and various personnel, alleging that the school's failure to properly implement B.D.'s individualized education program (IEP) and health and safety plan led to a series of five severe seizures that B.D. experienced at school in 2012. The Doucettes claimed that the school district violated B.D.'s constitutional rights under 42 U.S.C. § 1983 and Massachusetts tort law.The district court granted the school district's motion for summary judgment, finding that a reasonable jury could not conclude that the school district engaged in the conscience-shocking conduct necessary to sustain the constitutional claim, nor that the school district was liable under the state-law claims.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court found that the school district's conduct, while flawed, did not rise to the level of "conscience-shocking" behavior necessary to establish a violation of B.D.'s substantive due process rights. The court also found that the Doucettes failed to establish that the school district's conduct was the but-for cause of B.D.'s seizures, a necessary element of their state-law claims. View "Doucette v. Jacobs" on Justia Law

A defamation lawsuit was filed by Dana Cheng, a New York resident and political commentator, against Dan Neumann and Beacon, a Maine news outlet, for characterizing Cheng as "far-right" and a "conspiracy theorist" in an article. Neumann and Beacon sought dismissal of the case under both federal law and a New York anti-SLAPP law, which applies to meritless defamation lawsuits. The district court conducted a choice-of-law analysis, decided that New York law applied, and granted the motion to dismiss under New York's anti-SLAPP statute.The district court's decision was appealed to the United States Court of Appeals for the First Circuit. The appellate court agreed with the district court's ruling but for a different reason: it decided that Cheng's lawsuit had to be dismissed under binding First Amendment principles protecting free speech by the press. Back at the district court, Neumann requested attorneys' fees under the fee-shifting provision of New York's anti-SLAPP law. The district court denied Neumann's request after determining that Maine, not New York, law applied to the specific issue of attorneys' fees.Neumann appealed again, arguing that the district court erred in its choice-of-law analysis. The appellate court, noting the lack of clear controlling precedent on the issue, certified to the Supreme Judicial Court of Maine the question of which state's law applies to the attorneys' fees issue. View "Cheng v. Neumann" on Justia Law

The plaintiff, John Deaton, was arrested and charged with assault, battery, and disorderly conduct following an altercation at a youth football game. Although the charges were later dismissed, Deaton filed state and federal claims against the Town of Barrington and several individuals, including police officers and the town manager. The case was removed from state court to the United States District Court for the District of Rhode Island. The district court granted summary judgment in favor of the defendants on most counts and remanded three counts to the state court for resolution. Deaton appealed, arguing that the district court improperly found that probable cause to arrest him existed, improperly denied his post-judgment motion, and should have abstained and remanded to state court to allow the state claims to be resolved.The district court had granted summary judgment in favor of the defendants, finding that there was probable cause for Deaton's arrest. The court also denied Deaton's post-judgment motion for relief. Deaton appealed these decisions, arguing that the district court had improperly found probable cause for his arrest, improperly denied his post-judgment motion, and should have abstained from hearing the case and remanded it to state court.The United States Court of Appeals for the First Circuit affirmed the district court's decisions. The court found that the district court had correctly determined that there was probable cause for Deaton's arrest. The court also found that the district court had not erred in denying Deaton's post-judgment motion for relief. Finally, the court determined that abstention was not appropriate in this case, as resolution of the state law question would not avoid the need to resolve a significant federal constitutional question. View "Deaton v. Town of Barrington" on Justia Law

In the summer of 2020, amid pandemic mask mandates and nationwide racial justice protests, Whole Foods Market, Inc. began disciplining employees who wore facemasks to work supporting the Black Lives Matter movement, citing its dress code. The three plaintiff-appellants, Savannah Kinzer, Haley Evans, and Christopher Michno, persisted in wearing these masks, among taking other actions, until the company terminated them, ostensibly for repeated violations of the dress code or attendance policy. The Employees sued under Title VII, alleging retaliation. The district court granted Whole Foods' motion for summary judgment against all three.The United States Court of Appeals for the First Circuit held that summary judgment was improper against one of the Employees, Savannah Kinzer, an outspoken critic of Whole Foods whose termination arguably deviated from the company's disciplinary process, but affirmed the court's holding as to both Haley Evans and Christopher Michno. The Employees also asked the court to review a discovery order compelling the production of communications whose confidentiality they argue is protected by the National Labor Relations Act. The court declined to reach the merits of that issue. View "Kinzer v. Whole Foods Market, Inc." on Justia Law

The case involves Jennifer Root Bannon, who sued six law enforcement officers and the City of Boston on behalf of her brother's estate. Her brother, Juston Root, was fatally shot by the officers after a series of events that began with him pointing a gun at a hospital security guard and a responding police officer, leading the officers on a high-speed chase, and disregarding police instructions to drop his weapon. Bannon claimed that the officers used excessive force in violation of the Fourth Amendment. The district court granted summary judgment to the defendants.The United States Court of Appeals for the First Circuit agreed with the district court's conclusion that the officers acted reasonably under the circumstances during the fatal shooting and did not violate the Fourth Amendment. The court also held that the officers were entitled to qualified immunity and affirmed the grant of summary judgment on Bannon's other claims. The court found that no reasonable jury could conclude that the officers acted unreasonably in employing deadly force against Root in violation of the Fourth Amendment. The court also independently concluded that the officers were entitled to summary judgment on Bannon's § 1983 and MCRA claims based on qualified immunity. View "Bannon v. Godin" on Justia Law

The case involves Caitlin Corrigan, a graduate student at Boston University (BU), who sued the university under the Americans with Disabilities Act (ADA) for implementing a mandatory COVID-19 testing program. Corrigan claimed that due to a chronic medical condition, she could not comply with the program and that requiring her compliance would violate the ADA. BU rejected her proposed exemption, leading to her suspension for the fall semester. However, before the district court could reach the merits of Corrigan's claims, BU ended its mandatory testing program, leading the court to dismiss Corrigan's suit for lack of subject-matter jurisdiction, arguing that it had become moot.BU moved to dismiss Corrigan's suit for lack of subject-matter jurisdiction, and the district court granted the motion, applying mootness principles. The court determined that since BU had ended its mandatory testing program, an order requiring BU to provide Corrigan with a reasonable accommodation to the program would have no effect. The court also found that Corrigan's claim was not inherently transitory and that BU was unlikely to subject Corrigan to mandatory testing again. The court held that the monetary relief that Corrigan sought was legally insufficient to support a claim of jurisdiction.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court concluded that the district court appropriately applied mootness principles to dismiss Corrigan's suit and that Corrigan had not shown that her case comes within an applicable exception to those mootness principles. The court rejected Corrigan's arguments that the district court misread the mootness exceptions, misconstrued the facts, and ignored the import of the ADA's scheme for providing prospective relief. View "Corrigan v. Boston University" on Justia Law

The case involves Joseph A. Jakuttis, a former officer and detective in the Dracut Police Department, who also served as a Task Force Officer for the federal Drug Enforcement Administration's Cross Borders Initiative. Jakuttis brought multiple federal and state claims against the Town of Dracut, certain Dracut police officers, and members of the federal law-enforcement task force. He alleged that he was demoted and faced retaliation after reporting serious criminal activities implicating two Dracut police officers, which he learned from a confidential drug informant.The United States Court of Appeals for the First Circuit affirmed the dismissal of Jakuttis's Bivens claims against Michael V. O'Hanlon and Richard P. Poirier, Jr., and his §1983 claim against the Town of Dracut, David J. Chartrand Jr., and Demetri Mellonakos. The court ruled that the defendants are entitled to qualified immunity, as they could have reasonably thought that Jakuttis was speaking as part of his official duties rather than as a private citizen when he reported the misconduct, thus not clearly violating his First Amendment rights.The court also affirmed the dismissal of Jakuttis's state-law tort claims against Poirier, as Poirier was deemed to be acting within the scope of his federal employment during the relevant times. However, the court remanded the Massachusetts Whistleblower Act claim against the Town of Dracut and the Intentional Interference with Advantageous Economic Relationship claim against Chartrand and Mellonakos to the District Court. The court reasoned that these state-law claims should be resolved by a state court due to reasons of comity. View "Jakuttis v. Town of Dracut" on Justia Law

In this case, the United States Court of Appeals for the First Circuit examined an appeal against a district court's refusal to issue a preliminary injunction against the enforcement of a Rhode Island law banning certain large-capacity ammunition magazines. The plaintiffs, a group of gun owners and a registered firearms dealer, argued that the law infringed upon their Second Amendment rights, as well as their rights under the Fifth and Fourteenth Amendments.The Court of Appeals, however, upheld the district court's decision. It noted that the law did not impose a significant burden on the right of armed self-defense, as it did not prevent gun owners from owning other forms of weaponry or ammunition, and the banned magazines were rarely used in self-defense situations. Furthermore, the court found that the law was consistent with a longstanding tradition of regulating firearms in the interest of public safety.The court also rejected the plaintiffs' arguments that the law was retroactive and vague, violating their Fourteenth Amendment rights. It concluded that the law was not retroactive as it did not impose new liability on past actions, and it was not unconstitutionally vague as individuals of ordinary intelligence could understand what it prohibited. The court also found that the plaintiffs were unlikely to succeed on their Fifth Amendment claims, as the law did not effect a physical or regulatory taking of their property. View "Ocean State Tactical, LLC v. Rhode Island" on Justia Law

This case involves an appeal from plaintiffs Sara Halsey and Susan Kiralis-Vernon against Fedcap Rehabilitation Services, Inc. The plaintiffs were participants in a state program, Additional Support for People in Retraining and Employment - Temporary Assistance for Needy Families (ASPIRE-TANF), for which Fedcap was a contract agency. The plaintiffs allege that Fedcap failed to correctly administer the program and fulfill its obligations, including informing them of available services and support, processing their requests for benefits, and engaging in an interactive process to evaluate their requests for reasonable accommodations. Kiralis-Vernon also alleges that a Fedcap employee verbally assaulted her due, in part, to her race.The U.S. District Court for the District of Maine dismissed the case, reasoning that the plaintiffs were required to first pursue an administrative remedy before the Department of Health and Human Services as required by Maine law. On appeal, the United States Court of Appeals for the First Circuit affirmed the dismissal of the claims related to Fedcap’s administration of the ASPIRE-TANF program, agreeing that under Maine law, the plaintiffs had to first seek administrative review before bringing these claims to court.However, the appellate court vacated the dismissal of Kiralis-Vernon's claim of racial discrimination, ruling that this claim did not fall within the same jurisdiction and expertise of the Department, and thus, was not subject to the same requirement for administrative review. The case was remanded for further proceedings on this claim. View "Halsey v. Fedcap Rehabilitation Services, Inc." on Justia Law

In this case, the plaintiffs, Susan Johnson and Jocelyne Welch, brought an action against the City of Biddeford, Chief of Police Roger P. Beapure, and Officer Edward Dexter of the Biddeford Police Department, alleging a violation of substantive due process rights under the state-created danger test. Johnson and Welch's action stems from a violent incident involving their landlord, James Pak. Pak became agitated about the number of cars parked in the driveway of the property he rented to Johnson and her son, Thompson. During a confrontation, Pak made gun-shaped hand gestures and said "bang." Thompson called the police and Officer Dexter responded.Officer Dexter spoke with both parties separately. During his conversation with Pak, Pak expressed his anger and frustration, making various threatening remarks. Despite these threats, Officer Dexter did not arrest, detain, or initiate a mental health intervention for Pak. After speaking with Pak, Officer Dexter returned to Johnson and Thompson's apartment, informing them that Pak was "obviously extremely upset" but did not relay the specific threats made by Pak. A few minutes after Officer Dexter left, Pak entered Johnson and Thompson's apartment and shot Johnson, Thompson, and Welch.On appeal, the United States Court of Appeals for the First Circuit held that Officer Dexter was entitled to qualified immunity against the plaintiffs' claim of violation of substantive due process rights under the enhancement-of-danger prong of the state-created danger test. The court found that a reasonable officer in Dexter's position would not have understood, based on the facts of the case, that he was violating any such rights by his actions and inactions. View "Johnson v. City of Biddeford" on Justia Law