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

The First Circuit affirmed the district court's grant of summary judgment for Defendant's and dismissing Plaintiffs' claim that the City of Fitchburg's refusal to exempt four sober houses Plaintiffs operated for recovering addicts from a legal requirement to install sprinklers in the sober houses violated the Americans with Disabilities Act (ADA) and the Fair Housing Act, holding that the district court did not err in concluding that the requested accommodation was not reasonable.Plaintiffs brought this suit under the ADA, 42 U.S.C. 12101-12213, and the Fair Housing Act, 42 U.S.C. 3601-3631, as amended by the Fair Housing Amendments Act (FHAA). The district court dismissed the suit on summary judgment, concluding that Plaintiffs failed to show that an exemption from the sprinkler requirement was either reasonable or necessary to allow recovering addicts to live in and benefit from the sober houses. The First Circuit affirmed, holding that the district court did not err in entering summary judgment on Plaintiffs' ADA and FHAA reasonable accommodation claims. View "Summers v. City of Fitchburg" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant for disclosure of social security numbers and aggravated identity theft, holding that the district court did not commit clear or obvious error in refusing to ask prospective jurors about racial bias.On appeal, Defendant argued that there was a reasonable possibility that racial bias might have affected the jury because she requested that the district court ask the prospective jurors as a group a question during voir dire about whether any of them harbored racial bias and the district court denied that request. The First Circuit affirmed, holding (1) Defendant objection to the district court's failure to ask a question about racial bias during voir dire was at least forfeited; and (2) it was not clear or obvious error for the district court to refuse to ask such a question. View "United States v. Cezaire" on Justia Law

The First Circuit reversed the order of the district court dismissing the indictment against Defendants after a first trial ended in a mistrial, holding that the district court erred in concluding that Defendants were protected from a retrial by double jeopardy principles.Four defendant were charged with multiple counts of wire fraud, honest-services wire fraud, and conspiracy to commit both species of wire fraud. After trial began, one juror was diagnosed with a brain tumor requiring immediately surgery. The government was unwilling to consent to a reduced jury, and the court subsequently declared a mistrial. Defendants moved to preclude retail and to dismiss the indictment under the Double Jeopardy Clause on the ground that the government could not establish manifest necessity for its decision to force the mistrial. The court granted the motion to dismiss the indictment. The First Circuit reversed as to three of the four defendants, holding that the district court's decision to declare a mistrial rested on manifest necessity, and because the mistrial was not the produce of any purposeful instigation or other government misconduct, double jeopardy principles did not prohibit the government from retrying the defendants. View "United States v. Garske" on Justia Law

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