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

The First Circuit affirmed the judgment of the district court denying Defendant's motion to suppress approximately twenty pounds of methamphetamine that a postal inspector delivered in two United States Postal Service Priority Mail Express packages, as well as the fruits of the packages' search, holding that the warrant authorizing one package's search was valid and that the warrantless search of the other package was constitutional.The district court assumed arguendo that Defendant held a reasonable expectation of privacy in the searched packages then concluded that neither search was unconstitutional. The First Circuit affirmed, holding (1) the warrant authorizing the search of one package was not facially invalid despite the government's attachment of the incorrect attachment because the error was a mere technical error and the package was described with sufficient particularity and there was no reasonable probability of another package being searched; and (2) the warrantless search of the second package was justified by both the private search doctrine and the consent of the package's addressee. View "United States v. Moss" on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment in favor of Defendant on Plaintiff's Age Discrimination in Employment Act (ADEA) claim regarding the termination of Plaintiff's employment, holding that the totality of the circumstances showed a lack of foundation for Plaintiff's pretextual argument.In granting Defendant's motion for summary judgment, the district court determined that the evidence did not support Plaintiff's argument that Defendant's articulated reason for terminating Plaintiff's employment was pretextual, let alone a pretext for age discrimination. The First Circuit affirmed, holding the district court did not misapply the summary judgment standard or err in holding that no reasonable fact-finder could determine that Defendant's reasons for terminating Plaintiff were pretextual. View "Rodriguez-Cardi v. MMM Holdings, Inc." on Justia Law

In this action brought by parents of a severely disabled student against the school district alleging federal and statement claims the First Circuit vacated the district court's entry of judgment for the school district on Plaintiffs' federal claims on the basis that they were subject to the exhaustion requirement set forth in the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400-1491o, holding that no further administrative pursuit was required for the claims.Plaintiffs' federal claims claims included a Rehabilitation Act claim and a substantive due process claim under 42 U.S.C. 1983. The district court granted the school district's motion for judgment on the pleadings as to Plaintiffs' federal claims and remanded the state law claims to state court, concluding that the federal claims were subject to the IDEA's exhaustion requirement. The First Circuit vacated that decision, holding (1) the gravamen of Plaintiffs' Rehabilitation Act claim did not involve the denial of a free appropriate public education, and therefore, that claim was not subject to the exhaustion requirement of the IDEA; and (2) Plaintiffs' section 1983 claim was either exhausted or continued engagement with the IDEA's administrative scheme would have been futile. View "Doucette v. Georgetown Public Schools" on Justia Law

The First Circuit vacated the district court's dismissal of Appellant's sexual harassment claims based on a hostile work environment, holding that the district court erred in concluding that alleged incidents of harassment that occurred earlier than 2014 were time-barred and that the error contributed to other flaws in the court's analysis.Appellant brought this action claiming sexual harassment and retaliation under both Title VII of the Civil Rights Act and Puerto Rico Commonwealth law. Defendant asserted that he was sexually harassed for more than a decade and thus subjected to a hostile work environment and that managers at his workplace retaliated against him for complaining about this treatment. The district court granted summary judgment for Defendant on all claims. The First Circuit remanded the case, holding (1) the district court did not err in dismissing the retaliation claims; but (2) a jury could reasonably find that incidents that allegedly occurred in 2014 were instances within the limitations period of a claimed pattern of sexually charged interactions, and the court's statute-of-limitations error necessarily impacted its assessment of the hostile work environment claim. View "Nieves-Borges v. El Conquistador Partnership, L.P." on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Plaintiff's complaint against three Maine prison officials and denying Plaintiff's motion for leave to amend, holding that the district court did not abuse its discretion in rejecting as futile Plaintiff's motion for leave to file her amended complaint.Plaintiff's complaint alleged federal constitutional violations, a civil rights conspiracy, and supplementary state law claims. The district court dismissed the complaint, concluding that the complaint did not state any plausible claims against the defendants. Plaintiff then moved for reconsideration and for leave to amend. The district court denied both motions and entered a final judgment in favor of Defendants, concluding that allowing the motion to amend would be futile because the proposed amended complaint failed to state any plausible claims for relief. The First Circuit affirmed, holding that the facts alleged in Plaintiff's proposed amended complaint were insufficient to make out plausible claims of either supervisory liability or civil rights conspiracy against Defendants. View "Parker v. Landry" on Justia Law

The First Circuit affirmed the judgment of the district court denying class certification in this suit alleging violations of Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12131-12134, and the court's grant of judgment on the pleadings as to Parent/Professional Advocacy League (PPAL) and Disability Law Center (DLC), holding that PPAL and DLC lacked standing to pursue the claims in the complaint.S.S., a student at the Springfield Public Day School (SPDS), brought this suit on his own behalf and on behalf of a class of all student with a mental health disability who were or had been enrolled at SPDS, alleging that the City of Springfield, Massachusetts, and Springfield Public Schools violated Title II by segregating students with mental health disabilities in SPDS, a separate and inferior school. Associations PPAL and DLC joined S.S. as plaintiffs. The district court denied class certification. The court then ruled that the associations had standing but dismissed their claims for failure to exhaust. The First Circuit held (1) class certification was correctly denied; and (2) the associations lacked standing to bring this suit. View "Parent/Professional Advocacy League v. City of Springfield" on Justia Law

The First Circuit affirmed the district court's dismissal of Plaintiff's complaint in part and otherwise vacated the judgment, holding that the University of Massachusetts at Amherst violated Plaintiff's federal constitutional right to due process in suspending him for five months without prior notice or a fair hearing but did not violate his rights in expelling him after providing a fair expulsion hearing.After the university suspended and then expelled Plaintiff, Plaintiff brought this action seeking compensatory damages, declaratory relief, and an injunction preventing the university from enforcing the expulsion. The district court entered summary judgment in favor of Defendants. The First Circuit (1) affirmed the district court's dismissal of Plaintiff's 42 U.S.C. 1983 claims challenging the adequacy of his expulsion hearing, Plaintiff's section 1983 claims for money damages against the university officials acting in their official capacities, and Plaintiff's Title IX claim; but (2) vacated for the entry of nominal monetary damages the dismissal of Plaintiff's section 1983 claims challenging the constitutionality of the manner in which the university suspended Plaintiff without prior notice or an adequate hearing. The Court then remanded the case for further proceedings. View "Haidak v. University of Massachusetts-Amherst" on Justia Law

The First Circuit affirmed Defendants' convictions of conspiring to violate the Racketeer Influenced and Corrupt Organizations Act; aiding and abetting violent crimes in aid of racketeering, namely murder or attempted murder under Puerto Rico law; conspiring to engage in drug trafficking; and other offenses, holding that Defendant's challenges to their convictions were unavailing.The three defendants in this case were members of a vicious Puerto Rican gang called La ONU. Defendants appealed their convictions, bringing a variety of claims. The First Circuit affirmed, holding (1) the district court did not err in denying a motion to suppress a cache of guns and drugs seized during a warrantless search of a house; (2) the judge did not err in finding that no courtroom closure occurred during the proceedings; (3) the judge did not err in denying Defendants' motion for a mistrial; and (4) the remainder of Defendants' arguments on appeal did not entitle them to reversal of their convictions. View "United States v. Lanza-Vazquez" on Justia Law

The First Circuit affirmed in part and vacated in part the district court's partial denial of Defendant's motion to suppress evidence seized from Defendant's home on the day of his arrest on drug and money laundering charges, holding that the district court properly determined that certain items were lawfully seized but that it could not be determined on the record that other items were lawfully seized.The district court concluded that federal law enforcement agents validly relied on exceptions to the warrant requirement when they searched Defendant's home, a cargo van inside Defendant's garage, and a minivan parked in Defendant's driveway. The First Circuit held (1) the district court correctly determined that certain items were lawfully seized from the first floor; (2) it could not be determined whether items on the second floor and in the cargo van were lawfully seized, and therefore, remand was required for further findings concerning the duration and scope of the purported protective sweep; (3) remand was required for reconsideration of the issue of application of the automobile exception to the cargo van based on the court's conclusions regarding the sweep; and (4) as to items seized from the minivan, remand was necessary for a determination whether the minivan was within the curtilage of Defendant's home. View "United States v. Hernandez-Mieses" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Defendants, the Town of Duxbury, Massachusetts and the Town's chief of police, and dismissing Plaintiff's complaint filed under 42 U.S.C. 1983, holding that Plaintiff could not reasonably have expected privacy in his phone service provider's cell and home phone records.In 2015, the chief of police opened an internal investigation concerning Plaintiff, a police officer with the Town. In 2017, Plaintiff filed an amended complaint alleging that Defendants compelled Plaintiff to turn over his phone records in connection with the investigation and that this constituted an illegal warrantless search in violation of Plaintiff's Fourth Amendment rights. The district court granted summary judgment for Defendants. The First Circuit affirmed, holding that a phone subscriber has no reasonable expectation of privacy in the phone service provider's records of the numbers that the subscriber has dialed and from which the subscriber as received calls, and Defendant did not have a reasonable expectation of privacy in the records simply because he asked for a copy of the records at issue. View "Johnson v. Town of Duxbury, Massachusetts" on Justia Law