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

Petitioner, a Nigerian citizen by birth, pleaded guilty to making a material false statement in a matter within the jurisdiction of the United States government. Because of his conviction, Petitioner was permanently barred from obtaining lawful permanent resident status and was subject to deportation at any moment. Nearly a decade after his probationary sentence ended, Petitioner sought a writ of error coram nobis that vacates or allows him to revise the factual basis of his conviction. As grounds for the writ, Petitioner alleged that the performance of his attorney was constitutionally deficient under Sixth Amendment standards, and therefore, his conviction arose from fundamental error. The district court denied a writ of error coram nobis. The First Circuit affirmed, holding that Petitioner’s counsel was not constitutionally ineffective in any way. View "Williams v. United States" on Justia Law

Defendant was charged with conspiracy to possess with intent to distribute and to distribute more than 1,000 grams of marijuana, among other charges. Defendant moved to suppress evidence taken from a warrantless search of his truck. The district judge denied the motion. Defendant later conditionally pled guilty, reserving his right to challenge the denial of his suppression motion. The First Circuit affirmed, holding (1) the questioning of Defendant was within the permissible scope of a traffic stop, and the questions did not impermissibly extend the duration of the stop; (2) the initial search of the truck was permissible in light of Defendant’s voluntary consent; (3) the continuation of the search after Defendant withdrew his consent was permissible because probable cause existed; and (4) there were no constitutional violations during the traffic stop. View "United States v. Dion" on Justia Law

The First Circuit affirmed the district court’s rejection of Appellant’s claims that she, among other things, suffered discrimination in violation of the Americans with Disabilities Act (ADA) and its Massachusetts state-law corollary when Defendants failed to accommodate her request for transfer to another position in the Plymouth Police Department after she suffered an on-the-job injury. The district court concluded that Appellant failed to raise a genuine issues of material fact regarding her discrimination claims. The First Circuit affirmed, holding (1) the district court correctly entered summary judgment on Appellant’s handicap discrimination claims and gender discrimination claim; and (2) even if the court were able to glean an ADA retaliation claim from Appellant’s complaint, Appellant waived it during summary judgment proceedings. View "Audette v. Town of Plymouth, Mass." on Justia Law

The First Circuit affirmed Defendant’s conviction for conspiracy to commit access-device fraud. Before trial, Defendant and his co-defendant filed motions to suppress evidence and statements that had been obtained in the previous months in connection with three traffic stops. The district court denied the motions to suppress. The First Circuit affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress concerning a traffic stop in Kittery, Maine because the police had reasonable suspicion to justify the investigative stop as of 1:55 a.m. and the seizure was not unreasonably long; and (2) the district court did not err in denying the motion to suppress evidence obtained from a traffic stop in Ohio because there was reasonable suspicion to justify the detention. View "United States v. Ramdihall" on Justia Law

The First Circuit affirmed Defendant’s conviction for conspiracy to commit access-device fraud. Before trial, Defendant and his co-defendant filed motions to suppress evidence and statements that had been obtained in the previous months in connection with three traffic stops. The district court denied the motions to suppress. The First Circuit affirmed, holding (1) the district court did not err in denying the motion to suppress evidence obtained from a traffic stop in Ohio because there was no unlawful seizure, and therefore, the evidence Defendant sought to suppress did not constitute the fruits of an unlawful seizure; and (2) the district court did not err in concluding that the warrantless swiping of credit cards from in the trunk of a rental car through a card reader was constitutional. View "United States v. Hillaire" on Justia Law

First Circuit rejects civil rights claims relating to retention of property in car towed for an evidentiary search.Chelmsford police located Denault’s 2000 Nissan parked in Testa’s Lowell driveway. Denault, the suspect in a crime, was in custody. Testa was the mother of Denault's children. The officers had Denault's car towed and secured a warrant. Days later, they executed the warrant; having determined that the car did not contain evidence, they released it to Christopher's Towing. The officers had no contact with Denault. They did not supply, and Christopher's Towing did not request, Denault’s contact information. Testa repeatedly tried to recover the car and her belongings, particularly child booster seats. Testa claims that officers refused to discuss returning the car or its contents unless Testa agreed to be questioned in connection with the Denault investigation; they never informed her that they had released the car. Three months later, Denault's mother showed Tesla a Notice of Abandoned Vehicle sent to Denault's last known address, indicating a lien of $4797.82 for towing, storage, and processing. Neither Testa nor Denault could pay. They sued under 42 U.S.C. 1983 and the Massachusetts Civil Rights Act. They ultimately prevailed on a common-law conversion claim against one officer for $2225. The First Circuit affirmed, noting the “confusing” record and that the plaintiffs had waived claims relating to the initial seizure. View "Denault v. Ahern" on Justia Law

A plaintiff may not bring claims for damages under 42 U.S.C. 1981 against state actors, including defendants sued in their official capacities as government officials.The First Circuit affirmed the district court’s dismissal of Plaintiff's section 1981 claims against employees of the City of Boston. Plaintiff, who represented the estate of her late father, challenged her father’s termination from his employment with the Department of Public Works. The district court dismissed the section 1981 claims, concluding that section 1981 provides no implied private right of action for damages against state actors. The First Circuit affirmed, holding that Jett v. Dallas Independent School District compelled the result reached by the district court. View "Buntin v. City of Boston" on Justia Law

While they were investigating a suspected drug-trafficking operation, federal DEA agents made a warrantless entry into an apartment that, as it turned out, served as a stash house for a second, more substantial, drug-trafficking operation. Defendant, a participant in the second drug-trafficking operation, was charged with conspiring to possess with intent to distribute and to distribute one kilogram or more of heroin. Defendant moved to suppress the evidence gathered from the apartment. The district court denied the motion, concluding that probable cause and exigent circumstances justified the warrantless entry. The First Circuit affirmed, holding that the record supported the district court’s determination that the combination of probable cause and exigent circumstances justified the DEA agents’ warrantless entry into the apartment. View "United States v. Almonte-Baez" on Justia Law

Plaintiff appealed the district court’s grant of summary judgment in favor of her former employer, AstraZeneca Pharmaceutical LP, on Plaintiff’s claims that AstraZeneca violated the Americans with Disabilities Act (ADA) and several provisions of Puerto Rico law. Plaintiff attempted to persuade the First Circuit that there existed several material factual disputes in this case. The First Circuit affirmed the summary judgment, holding (1) AstraZeneca was entitled to summary judgment on both Plaintiff’s ADA disability discrimination claim and her ADA retaliation claim; and (2) Plaintiff failed to shoulder her burden to proceed to trial on her claims sounding in Puerto Rico law. View "Delgado-Echevarria v. AstraZeneca Pharmaceutical LP" on Justia Law

The First Circuit affirmed the district court’s grant of summary judgment to the City of Portland on Plaintiff’s claim that the City unconstitutionally denied him the opportunity to apply for a permit for his taxi to pick up passengers at the Portland International Jetport on the basis of his race and national origin. The district court ruled that Plaintiff did not have standing to bring his constitutional challenge because Plaintiff had not established a likelihood that he was “ready and able” to apply for the permit. The First Circuit affirmed, holding that there was no genuine issue of material fact regarding the likelihood that Plaintiff would seek the permit. View "McDonough v. City of Portland" on Justia Law