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

The First Circuit affirmed the decision of the district court granting summary judgment in favor of Defendants on Plaintiffs’ claims that the Massachusetts firearms licensing statute, as implemented in the communities of Boston and Brookline, violates the Second Amendment, holding that the statute bears a substantial relationship to important governmental interests.Plaintiffs sought and received licenses to carry firearms in public, but the licenses allowed Plaintiffs to carry firearms only in relation to certain specified activities, denying them the right to carry firearms more generally. Plaintiff argued that the Massachusetts firearms licensing statute violates the Second Amendment. The First Circuit disagreed, holding that the statute bears a substantial relationship to important governmental interests in promoting public safety and crime prevention without offending Plaintiffs’ Second Amendment rights. View "Gould v. Morgan" on Justia Law

The First Circuit affirmed the district court’s decision granting Defendants’ motion for summary judgment on Plaintiff’s 42 U.S.C. 1983 claim and dismissing Plaintiff’s Massachusetts state law negligence claim without prejudice, holding that the district court’s judgment was without error.Plaintiff, a pretrial detainee at the Massachusetts Correctional Institute-Framingham, sued Dr. Thomas Groblewski and the Massachusetts Partnership for Correctional Healthcare in federal district court, bringing a state law claim for common law negligence and a federal law claim under section 1983 for a violation of her Eighth Amendment right to be free from cruel and unusual punishment. The district court concluded that no reasonable jury could find that Groblewski acted with deliberate indifference to Plaintiff’s medical needs. The First Circuit affirmed, holding that the district court did not err in granting Defendants summary judgment on Plaintiff’s Eighth Amendment claim. View "Zingg v. Groblewski" on Justia Law

The First Circuit vacated the decision of the district court and remanded this case for entry of judgment in favor of Plaintiff and for remedial proceedings, holding that the district court erred in finding that Rhode Island does not discriminate against students with disabilities by failing to provide free appropriate public education (FAPE) to qualifying students of the same age.Plaintiff, through her parent and on behalf of a certified class of those similarly situated, brought this action claiming that Rhode Island violated the Individuals with Disabilities Education Act (IDEA) by providing “public education” to individuals without disabilities between the ages of twenty-one and twenty-two but does not provide special education services to individuals with disabilities of the same age. The district court concluded that the adult education programs provided to non-disabled Rhode Island students beyond the age of twenty-one do not constitute “public education” within the meaning of the IDEA. The First Circuit disagreed, holding that the adult education services in Rhode Island qualify as “public education” within the meaning of the IDEA. View "K.L. v. Rhode Island Board of Education" on Justia Law

The First Circuit affirmed Defendant’s conviction of one counts of stalking in violation 18 U.S.C. 2216A, holding that Defendant’s constitutional challenge was unsuccessful, there was no error in the district court’s jury instructions, and sufficient evidence supported the conviction.On appeal, Defendant brought a First Amendment challenge to the federal anti-stalking statute, arguing that section 2261A(2)(B) is facially overbroad and a content-based restriction on speech that does not survive strict scrutiny. The First Circuit disagreed as to this issue and the remaining issues Defendant raised on appeal, holding (1) Defendant’s First Amendment challenge to the statute was unavailing; (2) the district court did not err in denying Defendant’s request for a unanimity instruction or in giving jury instructions that precisely tracked the statute’s wording; and (3) there was sufficient evidence to support Defendant’s conviction. View "United States v. Ackell" on Justia Law

The First Circuit affirmed the district court’s decision upholding the determination of the Massachusetts Bureau of Special Education Appeals (BSEA) ruling against all of Plaintiff’s claims seeking placement for her minor child in a school outside of the Boston Public Schools (BPS) system, holding that there was no basis in which to reverse the district court’s decision.Plaintiff, on behalf of her minor child, initiated this proceeding pursuant to the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. A hearing officer denied relief. The district court affirmed the BSEA’s decision. On appeal, Plaintiff raised a number of claimed errors during the hearing. The First Circuit affirmed, holding (1) the district court applied the proper standard in evaluating the minor child’s education progress; and (2) Plaintiff’s challenges to the conduct of the hearing itself did not warrant reversal of the district court’s decision. View "Johnson v. Boston Public Schools" on Justia Law

The First Circuit denied Petitioner’s application seeking permission to file a successive motion under 28 U.S.C. 2255 to vacate her conviction and sentence for possessing a destructive device during and in relation to and in furtherance of a crime of violence, holding that Petitioner’s application did not meet the requirements for certification of a successive section 2255 motion.Petitioner sought to file this successive motion in 2016 following the Supreme Court’s decision in Johnson v. United States, 135 S. Ct. 2551 (2015). Petitioner then supplemented her motion after Sessions v. Dimaya, 138 S. Ct. 1204 (2018), was decided. Petitioner hoped to argue in the district court that the rule announced in Johnson and reiterated in Dimaya rendered the definition of “crime of violence” under which she was convicted unconstitutionally void for vagueness. The First Circuit denied the application, holding that Johnson’s rule, reaffirmed in Dimaya, did not extend to Petitioner’s conviction under 924(c)’s residual clause. View "Brown v. United States" on Justia Law

In this case arising from the fatal shooting of an armed civilian by a state trooper, the First Circuit affirmed the district court’s grant of summary judgment to Defendant, holding that Defendant was entitled to qualified immunity.Qualified immunity protects public officials, including police officers such as Defendant, from civil liability while acting under color of state law, with the exception of officials who act incompetently or in disregard of clearly established legal principles. The district court concluded that, under the facts of this case, Defendant was entitled to qualified immunity. The First Circuit affirmed, holding that, under the totality of the circumstances, the district court’s entry of summary judgment in Defendant’s favor on the basis of qualified immunity was correct. View "Conlogue v. Hamilton" on Justia Law

The First Circuit vacated the district court’s denial of Defendants’ motion for a new trial based partly on a claim that one juror lied in filling out the written questionnaire given to prospective jurors prior to trial, holding that the district court’s investigation concerning the answers given by the juror was inadequate.After a jury trial, Defendants were convicted of charges arising out of a large-scale marijuana-farming operation. Defendants moved for a new trial, arguing that one juror lied in filling out a written questionnaire given to prospective jurors prior to trial. The district court denied the motion for a new trial. The First Circuit vacated the denial based on the possible bias of the juror and remanded for an evidentiary hearing, holding that the alleged bias of the juror presented a “colorable or plausible” claim of the type of juror misconduct that could require a new trial, and therefore, the district court was required to do more than it did before ruling on the new trial motion. View "United States v. Russell" on Justia Law

The First Circuit affirmed the district court’s grant of summary judgment to MVM, Inc. as to a former employee’s claims under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000, et seq., and related Puerto Rico laws, holding that the district court did not err in granting summary judgment as to these claims.Plaintiff, a former employee of MVM, Inc., brought a variety of federal and Puerto Rico law claims against MVM and other defendants. After dismissing several of Plaintiff’s claims, the district court granted summary judgment to MVM as to the remainder. The First Circuit affirmed the summary judgment ruling, holding that the district court did not err in granting summary judgment to MVM on Plaintiff’s hostile work environment claim, Plaintiff’s claim under Title VII that MVM had unlawfully subjected her to disparate treatment because of her gender, and Plaintiff’s claim under Title VII for retaliation. View "Bonilla-Ramirez v. MVM, Inc." on Justia Law

In this case alleging several violations of federal and state discrimination laws the First Circuit affirmed the decision of the district court denying Defendant’s motion to stay the proceedings in district court and compel arbitration, holding that the contract to arbitration in between the parties was unenforceable.Plaintiffs - several individuals and the National Federation of the Blind - filed a complaint alleging that Defendant - the Container Store, Inc. - failed to utilize tactile keypads on its point-of-sale devices in its stores that could independently be used by customers who are blind in violation of federal and state discrimination laws. Defendant moved to compel arbitration, citing an arbitration provision in the terms and conditions of a loyalty program of which the individual plaintiffs were members. The district court denied the motion. The First Circuit affirmed, holding (1) based upon the lack of evidence that the in-store plaintiffs had any knowledge that arbitration terms applied to their enrollment in the loyalty program, Defendant failed to establish that an agreement to arbitrate was consummated between it and three of the four individual plaintiffs; and (2) the district court did not err in finding that the loyalty program agreement was illusory and therefore void. View "National Federation of the Blind v. Container Store, Inc." on Justia Law