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

Articles Posted in Civil Rights

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The First Circuit affirmed the district court's grant of summary judgment to the Puerto Rico Ports Authority (the PRPA) on Plaintiffs' suit alleging that the PRPA violated the First Amendmen and Puerto Rico law by terminating Plaintiff's employment, holding that Plaintiffs' claims were barred by res judicata. Daniel Grajales, his wife, their children brought this suit under 42 U.S.C. 1983 and Puerto Rico law against the PRPA alleging that Grajales was transferred to a new job location and subsequently terminated from his employment because of both his political affiliation and his reporting of alleged safety violations by PRPA employees. Just before Grajales filed his federal complaint, the Secretary of Labor and Human Resources of Puerto Rico filed a civil complaint against the PRPA in the Puerto Rico Court of First Instance, which entered judgment for the PRPA. The PRPA moved for summary judgment in the federal case on res judicata grounds in light of the Court of First Instance's ruling. The district court ruled in favor of the PRPA. The First Circuit affirmed, holding (1) the district court properly found that the two actions shared a "common nucleus of operative fact"; (2) Grajales's claims were barred by res judicata; and (3) the derivative claims of Grajales's family members necessarily failed. View "Grajales v. Puerto Rico Ports Authority" on Justia Law

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The First Circuit affirmed the district court's grant of summary judgment in favor of Defendants in this case involving a constitutional challenge to a Massachusetts law proscribing the sale, transfer, and possession of certain semiautomatic assault weapons and large-capacity magazines (LCMs), Mass. Gen. Laws ch. 140, 121, 131M (the Act), holding that the Act withstands intermediate scrutiny. In their constitutional challenge to the Act, Plaintiffs claimed that they had an "unfettered" Second Amendment right to possess the proscribed LCMs and assault weapons in their homes for purposes of self-defense. The district court granted summary judgment for Defendants. The First Circuit affirmed, holding (1) even if the proscribed weapons have some degree of protection under the Second Amendment, and even if the Act implicates the core Second Amendment right of individuals to bear arms in self-defense, the Act minimally burdens that right; and (2) the Act withstands intermediate scrutiny. View "Worman v. Healey" on Justia Law

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The First Circuit affirmed the district court's grant of summary judgment in favor of Employer on this action brought by Employee under the Americans with Disabilities Act (ADA), 42 U.S.C. 1210 et seq., and under various Rhode Island laws, holding that the district court properly granted summary judgment on all of Employee's claims. After Employer terminated Employee's employment on the basis of job abandonment Plaintiff filed this suit claiming that Employer terminated her on the basis of her disabilities, failed to provide her with reasonable accommodations, and retaliated against her. The district court granted Employer's motion for summary judgment, concluding that Employee had not met the requirements of Cleveland v. Policy Management Systems Corp., 526 U.S. 795 (1999). The First Circuit affirmed, holding that the district court properly granted Employer summary judgment as to all of Plaintiff's claims. View "Pena v. Honeywell International, Inc." on Justia Law

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The First Circuit affirmed the judgment of the district court granting summary judgment for two prison officers on an inmate's claims under 42 U.S.C. 1983 alleging violations of his federal constitutional rights, holding that the officers were entitled to qualified immunity. In his complaint, the inmate alleged (1) one of the officers pushed him against a pillar, allegedly causing him to hit his head on it, in violation of the Eighth Amendment; and (2) the other officer sprayed pepper spray into his cell, in violation of both the First Amendment and the Eighth Amendment. The district court granted Defendants' motion for summary judgment on qualified immunity grounds. The First Circuit affirmed, holding that no genuine dispute of material fact existed as to whether the officers violated either the First or the Eighth Amendment. View "Staples v. Gerry" on Justia Law

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The First Circuit affirmed the judgment of the district court denying Defendant's motions to suppress evidence and to dismiss his indictment for outrageous government conduct, holding that the district court did not err in its judgment. Defendant was identified as a user of Playpen, an online forum that allowed users to upload, download, and distribute child pornography, and indicted for possession and receipt of child pornography. Defendant moved to suppress evidence resulting from an Network Investigative Technique warrant and also sought to dismiss the indictment on the grounds that the government engaged in outrageous conduct by running Playpen for two weeks after seizing its control. The district court denied the two motions. Defendant subsequently pled guilty to both charges. The First Circuit affirmed, holding (1) the district court correctly denied Defendant's motion to suppress for lack of probable cause; and (2) under the totality of the circumstances, there were no grounds to reverse the district court's denial of Defendant's motion to dismiss the indictment. View "United States v. Anzalone" on Justia Law

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The First Circuit affirmed Defendant's conviction of one count of possessing child pornography, holding that the district court did not err in denying Defendant's motions to suppress the evidence. Defendant uploaded child pornography images to a digital album on Imgur, an image hosting website. The National Center for Missing and Exploited Children (NCMEC) received a report about the images from an anonymous tipster and informed law enforcement of the images. In his motions to suppress, Defendant argued that the evidence was obtained pursuant to a warrantless search by Imgur, acting at the instigation of NCMEC, and that the computer was searched pursuant to a warrant that lacked probable cause. The district court denied the motions. The First Circuit affirmed, holding that the district court did not err in determining (1) Defendant had no reasonable expectation of privacy in the images he uploaded to Imgur or in his internet protocol address, and (2) the state's warrant to search Defendant's computer was supported by probable cause. View "United States v. Morel" on Justia Law

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The First Circuit affirmed Defendant's conviction of one count of conspiracy to commit health care fraud, eight counts of health care fraud, six counts of aggravated identity theft, and four counts of furnishing false or fraudulent information in prescriptions for controlled substances, holding that there was no error in the proceedings below. Specifically, the Court held (1) the evidence was sufficient to support Defendant's underlying convictions for aggravated identity theft; (2) the district court did not err in denying Defendant's motion for a new trial; (3) the district court correctly denied Defendant's third motion for a judgment of acquittal as to the charges of furnishing false or fraudulent information for prescriptions in controlled substances; (4) Defendant's sentence was not substantively unreasonable; and (5) Defendant's pro se challenges to the sufficiency of the evidence for his conspiracy and health care fraud convictions and argument that an aspect of the trial violated his Sixth Amendment rights failed. View "United States v. Tull-Abreu" on Justia Law

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The First Circuit affirmed Defendant's sentence for bank robbery, Hobbs Act robbery, and a related firearms offense, holding that Appellant's argument that the district court impermissibly considered Appellant's gender as a factor in the sentencing calculus was without merit. The district court sentenced Appellant to a total of 108 months of incarceration. On appeal, Appellant argued that the district court (1) committed procedural error by failing to appreciate that it had discretion to consider the mandatory sentence on the firearms count when formulating the sentence for the grouped counts, and (2) violated his constitutional right to equal protection by engaging in gender stereotyping when formulating his sentence. The First Circuit disagreed, holding (1) the district court in this case did not commit the same procedural error that the Supreme Court condemned in Dean v. United States, 137 S. Ct. 1170, 1178 (2017); and (2) Appellant failed to make a plausible showing of any violation of his right to equal protection. View "United States v. Blewitt" on Justia Law

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The First Circuit affirmed Defendant's conviction of attempted coercion and enticement of a minor to engage in sexual activity, holding that the district court did not err by denying Defendant's motion to suppress statements obtained from him during an interrogation and that the evidence was sufficient to support the convictions. On appeal, Defendant challenged the district court's refusal to suppress his statements made during the interrogation after he received Miranda warnings, arguing that his mental capacity impeded his ability to waive his rights. The First Circuit affirmed, holding (1) the district court correctly found that Defendant knowingly, intelligently, and voluntarily waived his Miranda rights; and (2) there was sufficient evidence to support the convictions. View "United States v. Rang" on Justia Law

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The First Circuit affirmed the district court's denial of Defendant's motion to dismiss and motion to suppress, which Defendant filed before he was convicted of legal reentry after removal from the United States, holding that the district court did not err in not dismissing Defendant's indictment for delay in presentment or in not suppressing information that law enforcement had gathered about Defendant, including his identity. Defendant was a passenger in a van that was stopped for seatbelt violations. A Maine State Trooper who conducted the stop contacted an Immigration and Customs Enforcement (ICE) officer for help identifying the passengers, several of whom did not appear to speak English. When he was asked for his identification, Defendant produced a consular ID card. ICE officers ran the card through ICE databases and determined that Defendant was suspected of illegal reentry. Defendant was subsequently convicted of illegally entering the United States after removal. The First Circuit affirmed, holding (1) because Defendant made his initial appearance just as the criminal process was initiated, there was no unnecessary delay before his initial appearance and so no violation of Fed. R. Crim. P. 5(a); and (2) the district court properly denied Defendant's motion to suppress. View "United States v. Garcia-Zavala" on Justia Law