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

The First Circuit affirmed the judgment of the trial court, entered after a jury trial, ruling in favor of Plaintiff on both her gender-based hostile work environment discrimination and retaliation claims. The court awarded Plaintiff emotional and front pay damages. Defendant, the City of Providence, appealed from the denial of its motion for judgment as a matter of law, making numerous arguments as to why the jury verdict should be set aside or, in the alternative, why the judge’s front pay award should be stricken. The First Circuit affirmed, holding that Defendant’s arguments and assignments of error were unavailing. View "Franchina v. Providence Fire Department" on Justia Law

The First Circuit affirmed Defendant’s conviction for being a felon in possession of ammunition but vacated his sentence. On appeal, Defendant argued that the district court erred in denying his motion to suppress evidence obtained from a warrantless search of the vehicle he was driving and that the district court erred in finding that he qualified for a mandatory minimum sentence under the Armed Career Criminal Act (ACCA). The First Circuit held (1) under the circumstances of this case, the automobile exception to the Fourth Amendment’s warrant requirement applied, and the search of the vehicle Defendant was driving was reasonable; and (2) Defendant was improperly sentenced as an armed career criminal. The court remanded the case for resentencing with the ACCA enhancement. View "United States v. Kennedy" on Justia Law

The First Circuit affirmed Defendant’s conviction for being a felon in possession of ammunition but vacated his sentence. On appeal, Defendant argued that the district court erred in denying his motion to suppress evidence obtained from a warrantless search of the vehicle he was driving and that the district court erred in finding that he qualified for a mandatory minimum sentence under the Armed Career Criminal Act (ACCA). The First Circuit held (1) under the circumstances of this case, the automobile exception to the Fourth Amendment’s warrant requirement applied, and the search of the vehicle Defendant was driving was reasonable; and (2) Defendant was improperly sentenced as an armed career criminal. The court remanded the case for resentencing with the ACCA enhancement. View "United States v. Kennedy" on Justia Law

The First Circuit reversed the trial judge’s dismissal of counts in an indictment that charged Defendants with dispensing misbranded drugs in violation of the Federal Food, Drug, and Cosmetic Act (FFDCA).Defendants, Massachusetts-licensed pharmacists, were charged with multiple crimes, including the allegation that Defendants dispensed drugs in violation of the FFDCA. The trial judge granted Defendants’ motions to dismiss the FFDCA charges, ruling that the indictment did not provide fair notice. The First Circuit reversed, holding that the indictment passed muster because it gave Defendants enough information to prepare a defense and to invoke double-jeopardy protections to forestall a later trial on the same charges. View "United States v. Stepanets" on Justia Law

The First Circuit reversed the district court's denial of Appellant’s petition for a writ of habeas corpus challenging his convictions for armed assault with intent to murder and other offenses, holding that trial counsel’s failure to move to suppress Appellant’s statements to a police officer while in custody constituted ineffective assistance of counsel under clearly established law.In his petition for a writ of habeas corpus, Appellant argued, inter alia, that he was deprived of effective assistance of counsel because trial counsel failed to move to suppress his statements to the police officer. The district court denied the writ. The First Circuit reversed, holding that trial counsel’s deficient performance was sufficiently prejudicial to constitute a violation of Appellant’s Sixth Amendment right to counsel. View "Rivera v. Thompson" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant’s motion to suppress drug evidence found on his person during a traffic stop.A law enforcement officer stopped a vehicle in which Defendant was a passenger for a traffic violation. On appeal from the denial of his motion to suppress, Defendant argued that the officer violated Defendant’s Fourth Amendment rights by unreasonably extending the duration of the traffic stop and that the district court erred in ruling that the inevitable discovery exception to the exclusionary rule applied to the drug evidence found during the resulting patdown search, which the government conceded was unlawful. The First Circuit affirmed, holding (1) the officer did not unlawfully prolong the traffic stop; and (2) the proper scope of a patdown search was exceeded in this case, but the district court properly applied the inevitable discovery rule. View "United States v. Clark" on Justia Law

The First Circuit reversed the district court’s judgment ruling that Defendant had a reasonable expectation of privacy under the Fourth Amendment in the motel room where he was at the time of a police search of the premises, holding that Defendant, a guest of a guest in the motel room, did not have a reasonable expectation of privacy in the motel room.Defendant was charged with possession with intent to distribute a mixture or substance containing cocaine based and aiding and abetting such conduct. Defendant moved to suppress the evidence seized as a result of the search of the motel room where he had been staying. The district court ruled that the search violated the Fourth Amendment and suppressed the evidence. The First Circuit reversed and remanded, holding (1) the district court properly found that Defendant was the guest of a guest; but (2) Defendant failed to demonstrate an objectively reasonable expectation of privacy in the motel room. View "United States v. Aiken" on Justia Law

The First Circuit affirmed Appellant’s federal convictions and resulting sentence for five counts of bank robbery. The court held that, contrary to the arguments raised by Appellant on appeal, the district court did not err in denying Appellant’s motions for (1) a hearing pursuant to Franks v. Delaware, 438 U.S. 154 (1978), based on Appellant’s failure to make the requisite preliminary showing, regarding warrants that were issued to install Global Positions System (GPS) tracking devices; (2) the suppression of evidence obtained from the GPS tracking devices installed pursuant to those warrants where the supporting affidavit provided probable cause for the warrants and for the installation of the GPS tracking devices; and (3) the suppression of evidence obtained as the result of Appellant’s arrest where the probable cause standard was met. View "United States v. Patterson" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Plaintiff’s complaint against the Federal Deposit Insurance Corporation challenging its decision to terminate his employment for lack of subject matter jurisdiction. The district court concluded that Plaintiff did not have a “mixed” case because of his failure to reinstate or prosecute his associational disability discrimination before the Merit Systems Protection Board, despite being given the right to do so, after expressly withdrawing the claim with prejudice. The First Circuit held (1) Plaintiff’s original complaint, which alleged a claim of discrimination that was later withdrawn, was not sufficient to create a mixed case, and therefore, the district court lacked subject matter jurisdiction; and (2) the district court did not err in denying Plaintiff’s motion for reconsideration or, in the alternative, to transfer the case to the Court of Appeals for the Federal Circuit. View "Jonson v. Federal Deposit Insurance Corp." on Justia Law

The First Circuit affirmed the district court’s grant of summary judgment in favor of the City of Quincy, Massachusetts, the former employer of Plaintiff, on Plaintiff’s federal and pendent state claims of employment discrimination, retaliation, and constructive discharge. The First Circuit held (1) because Plaintiff was unable to rebut the City’s proffered legitimate, nondiscriminatory basis for its actions with evidence of pretext and discriminatory motive; (2) the record lacked evidence showing that the City retaliated against Plaintiff; and (3) Plaintiff did not meet her burden to show she was constructively discharged. View "Cherkaoui v. City of Quincy, Massachusetts" on Justia Law