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 dismiss the indictment against him on double jeopardy grounds after the district court declared a mistrial based on complications brought about by the pandemic, holding that that there was no error.Defendant was charged with transmitting a threatening communication in interstate commerce. During trial, the government's main witness and a case agent took a test that came back positive for COVID-19. The court ultimately ordered a mistrial and dismissed the jurors. Thereafter, Defendant filed a motion to dismiss on double jeopardy grounds. The district court denied the motion. The Supreme Court affirmed, holding that the steps taken by the district court leading to its declaration of a mistrial were within its discretion. View "United States v. Dennison" on Justia Law

The First Circuit affirmed the judgment of the district court in favor of the Puerto Rico Highways and Transportation Authority (PRHTA) and its executive directors (collectively, Appellees) and dismissing this complaint brought by sixty-nine current and former employees of the PRHTA (collectively, Appellants), holding that the district court did not err or abuse its discretion.Appellants brought this action challenging the PRHTA's decision no longer to give effect to a regulation providing Appellants with additional compensation. Specifically, Appellants claimed that the decision was contrary to P.R. Act No. 66-2014, giving rise to violations of the Contracts Clause and Due Process Clause. The district court granted summary judgment for the PRHTA on the federal constitutional claims and declined to exercise supplemental jurisdiction over Appellants' claims under Puerto Rico law. The First Circuit affirmed, holding that the district court (1) did not err in concluding that Appellants could not establish their federal constitutional claims; and (2) did not abuse its discretion in declining to exercise jurisdiction over Appellants' remaining Puerto Rico law claims. View "Vazquez-Velazquez v. P.R. Highway & Transportation Authority" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment for the City of Worcester and several of its officers and dismissing Plaintiff's constitutional and tort claims, holding that the individual defendants were entitled to qualified immunity and that neither they, nor the City, were liable for the alleged torts.The Worcester police used a SWAT team to execute a warrant at a residential apartment where they expected to find a rape suspect but instead found Plaintiff, who was nineteen years old, thirty-eight weeks pregnant, and not conversant in English. Plaintiff began experiencing contractions shortly after the entry, and gave birth the following day. Plaintiff, who was later diagnosed with post-traumatic stress disorder, brought this lawsuit. The district court granted summary judgment for Defendants, concluding that the officers did not violate Plaintiff's constitutional rights and that, even if they did, they were entitled to qualified immunity. The First Circuit affirmed, holding that Plaintiff's claims failed. View "Penate v. Sullivan" on Justia Law

The First Circuit affirmed Defendant's conviction of fifteen counts of an indictment charging sexual exploitation of children and distribution, receipt, and possession of child pornography and his sentence of 480 months' incarceration, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the First Circuit held (1) the evidence presented at trial was sufficient to support Defendant's convictions on each of the child exploitation counts; (2) the district court did not err in denying Defendant's motion to suppress his statements to law enforcement on the grounds that Defendant was not in custody at the time of his interrogation; and (3) Defendant's challenges to the district court's calculation of his Guidelines sentencing range were without merit. View "United States v. Monson" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence of drugs and entering judgment on Defendant's plea of guilty to possession of cocaine with intent to distribute, holding that there was no error or abuse of discretion.Defendant was pulled over by a New Hampshire police officer, Stephen DiChiara, following a suspected drug buy. DiChiara was asked to conduct the stop by a United States Drug Enforcement Agency (DEA) task force officer, DiChiara stoped and seized the car Defendant was driving. A subsequent search of the car revealed uncovered roughly one kilogram of cocaine. Defendant moved to suppress evidence of the drugs, arguing that DiChiara could not act solely on the DEA officer's probable cause. The Supreme Court affirmed, holding that the directive given to DiChiara was sufficient to attribute the DEA officer's probable cause to DiChiara. View "United States v. Balser" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motion to suppress evidence showing that Defendant was carrying heroin with the intent to distribute it, holding that the district court did not err in denying Defendant's motion to suppress the evidence found during the underlying traffic stop.Defendant was stopped for unsafe operation of a vehicle. The stop resulted in more than an hour of questioning and in Defendant relinquishing thirty-seven grams of heroin that he was carrying on his person. Defendant filed a motion to suppress, arguing that the traffic stop was illegal and that the ensuing questioning violated his Fourth and Fifth Amendment rights. The district court denied the motion, after which Defendant pleaded guilty. The First Circuit affirmed, holding that there was no error in the denial of Defendant's motion to suppress. View "United States v. Fagan" on Justia Law

The First Circuit affirmed in part and reversed in part the judgment of the district court denying Defendant's motion to suppress the seizure of his cell phone and its refusal to suppress evidence of child pornography, holding that the warrant authorizing the search of Defendant's electronic devices containing the child-pornography evidence was unsupported by probable cause.On appeal, Defendant argued that the police exceeded the scope of the first warrant by seizing his phone from his wife and that the application for the second warrant did not contain sufficient detail such that a neutral magistrate could determine whether there was probable cause that the alleged objects of the search were pornographic. The First Circuit remanded the case for further proceedings, holding (1) there was no violation of Defendant's constitutional rights in the seizure of his phone under the first warrant; (2) fatal deficiencies in the second affidavit supporting the second warrant resulted in the second search warrant being issued without the required showing of probable cause; and (3) the good-faith exception did not apply, requiring suppression of the evidence. View "United States v. Sheehan" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Matthew Haney's complaint, brought as the Trustee of the Gooseberry Island Trust, against the Town of Mashpee and its Zoning Board of Appeals, holding that Haney's arguments on appeal were either waived or meritless.Haney brought this action seeking a declaratory judgment that Defendants' actions constituted uncompensated taking of property in violation of the Fifth Amendment of the United States Constitution due to an unconstitutional taking and the Massachusetts Constitution due to inverse condemnation. The district court dismissed the complaint on the grounds that the claims were not ripe for review. The First Circuit affirmed, holding (1) Haney waived his argument relative to whether the government had reached a final decision on the Trust's request for variances; and (2) Haney's remaining arguments were meritless. View "Haney v. Town of Mashpee" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant of possession with intent to distribute a controlled substance, holding that the district court did not err in denying Defendant's motion to suppress drug evidence.Defendant was a passenger in a single-vehicle car accident on the Maine Turnpike. Suspicion that the vehicle and/or its occupants were transporting drugs Maine police officers searched Defendant's bag and discovered narcotics. Defendant filed a motion to suppress, arguing that the evidence was obtain in violation of her Fourth Amendment rights. The district court denied the motion, after which Defendant conditionally pleaded guilty. The First Circuit affirmed, holding that Defendant's arguments for suppression failed. View "United States v. Howard" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's challenge to his sentence under 28 U.S.C. 2255, holding that Appellant did not meet his burden of showing that his counsel's performance during the underlying criminal trial was deficient.Appellant pleaded guilty to two counts of conspiracy to distribute a substance containing cocaine base and one count of malicious damage or destruction of property by fire. At sentencing, the trial court determined that Appellant was a career offender in part because his prior Maine state court conviction for unlawful trafficking in scheduled drugs qualified as a "controlled substance offense" under the U.S. Sentencing Guidelines. In this collateral challenge to his sentence, Appellant argued that he received constitutionally ineffective assistance of counsel during his sentencing hearing based on his counsel's failure to object to the use of the Maine drug conviction as a predicate offense for the career offender enhancement. The First Circuit denied relief, holding that Appellant's ineffective assistance claim failed. View "Thompson v. United States" on Justia Law