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

Defendant’s vehicle was stopped and searched by officers with the Maine Drug Enforcement Agency, the Maine Police, and the Portland Police Department. The search involved the use of a drug-sniffing dog and resulted in the discovery of cocaine and a firearm. Defendant pleaded guilty to one count of possession with intent to distribute 500 grams or more of cocaine and one count of possession of a firearm in furtherance of a drug trafficking crime. Defendant appealed, challenging the district court’s denial of his motion to suppress and the court’s denial of his motion for discovery of records. The First Circuit affirmed, holding that the district court did not err in finding that the warrantless search and seizure of Defendant’s vehicle were justified by the automobile exception. View "United States v. White" on Justia Law

Employer terminated Employee for engaging in sexually inappropriate workplace conduct. Employee sued Employer and the company’s Puerto Rico Human Resources manager (collectively, Defendants), claiming unjust termination under Puerto Rico’s Law 80 and that he had been the victim of sexual harassment by the Human Resources manager in violation of Title VII of the Civil Rights Act and analogous Puerto Rico law. The district court granted Defendants’ motion for summary judgment. The First Circuit affirmed, holding that the district court properly granted summary judgment to Defendants on Employee’s federal claims and correctly granted summary judgment to Defendants on the Law 80 claim. View "Perez v. Horizon Lines, Inc." on Justia Law

In 2006, Appellants - Paul A. DeCologero, Paul J. DeCologero, and John P. DeCologero, Jr. - were convicted of violations of the Racketeer Influenced and Corrupt Organizations Act (RICO) and related crimes. In 2011, all three appellants filed motions under 28 U.S.C. 2255 to vacate their convictions, arguing that the government violated their Fifth Amendment due process rights under Brady v. Maryland by failing to disclose exculpatory evidence before trial. The district court denied the motions, concluding that the prosecution team was not aware of the reports before trial and that, even if the prosecution team had been aware of the reports, the reports were not material for Brady purposes. The First Circuit affirmed, holding that the district court correctly found that the reports were not material. View "DeCologero v. United States" on Justia Law

After a jury trial, Russell Rose and Kelvin Frye were convicted of conspiring to distribute arising from their respective roles in a Cape Cod-based drug-distribution conspiracy. The First Circuit affirmed the convictions and sentences, holding (1) no error occurred in the authorization of the government’s applications for phone wiretaps that produced tapes of intercepted phone calls between the co-conspirators; (2) the government properly utilized its central witness, and the witness’s testimony was not improper overview testimony; (3) a jury would have convicted Defendants even if evidence recovered from the search of the curtilage of Rose’s home was improperly admitted; and (4) even the district court violated Alleyne v. United States in sentencing Defendants, neither party could establish the necessary prejudice to sustain their claim of Alleyne error. View "United States v. Rose" on Justia Law

In 1998, Jason Davis received a punitive damages award in a federal civil rights action that he brought against six state employees, who were held responsible for restraining and beating him in a state mental hospital. In 2009, Joshua Messier was killed while being restrained by multiple corrections officers. The personal representative of Messier’s estate brought suit against the Commonwealth of Massachusetts and others. The Messier case settled, resulting in the payment of $2 million from Massachusetts. In 2014, Appellant, in his capacity as the personal representative of Davis’s estate, filed a complaint in the district court alleging that former Massachusetts Governor Deval Patrick and former Attorney General Martha Coakley violated the Davis estate’s due process and equal protection rights by agreeing to settle the Messier case while, at the same time, refusing to pay for the outstanding punitive damages award owed to the Davis estate. The district court granted Patrick and Coakley’s motion to dismiss. The First Circuit affirmed, holding that Appellant’s due process and equal protection arguments were without merit. View "Davis v. Coakley" on Justia Law

At issue in this case was whether an ordinance in the City of Portland, Maine that prohibited standing, sitting, staying, driving, or parking on median strips violated the First Amendment. The district court ruled in favor of Plaintiffs, concluding that the ordinance violated their freedom of speech. The court permanently enjoined the City from enforcing the ordinance in any respect. The First Circuit affirmed the district court’s permanent injunction barring the ordinance’s enforcement, holding that the ordinance violates the constitutional guarantee of the freedom of speech because it indiscriminately bans virtually all expressive activity in all of the City’s median strips and is not narrowly tailored to serve the City’s interest in protecting people in the streets and in protecting people on medians. View "Cutting v. City of Portland, Maine" on Justia Law

After a jury trial, Defendants Jose Laureano-Salgado, Pedro Ramirez-Rivera, and Ismael Cruz-Ramos were convicted of multiple drug and gun offenses. Defendants were all sentenced to life in prison. The First Circuit (1) vacated Cruz-Ramos’s conviction and sentence and remanded his case for a new trial, holding that the district court erred in denying his motion to suppress the fruits of a police search of his home and car and that including the erroneously admitted evidence at trial was not harmless; and (2) affirmed Laureano-Salgado’s and Ramirez-Rivera’s convictions and sentences, holding that the evidence was sufficient to support their convictions, that there was no merit to Defendants’ claims regarding jury selection, that the district court’s evidentiary rulings made during the trial did not amount to reversible error, that the jury was properly instructed, and that there was no sentencing error. View "United States v. Ramirez-Rivera" on Justia Law

Plaintiff was an associate at a Boston law firm (Defendant) when he was informed that his Defendant would not advance him for further consideration as a partner. Plaintiff filed an action pursuant to Title VII in federal district court, contending that Defendant’s decision was the result of racial discrimination and that Defendant retaliated against him after he filed a complaint with the Equal Employment Opportunity Commission. The district court granted summary judgment to Defendant on the discrimination claim. After a trial, the jury concluded that Defendant had not unlawfully retaliated against Plaintiff. The First Circuit affirmed, holding (1) the district court did not err in instructing the jury in connection with Plaintiff’s retaliation claims; and (2) the district court properly granted summary judgment to Defendant on Plaintiff’s discrimination claim. View "Ray v. Ropes & Gray LLP" on Justia Law

Plaintiff filed a complaint against the Municipality of Carolina in the federal district court of Puerto Rico alleging gender-based employment discrimination and retaliation. Before trial, Carolina extended to Plaintiff what it labeled as an offer of judgment pursuant to Fed. R. Civ. P. 68. Later that day, Carolina informed the district court that no settlement had been reached. One half of an hour later, Plaintiff informed the court that she was accepting Carolina’s offer of judgment. The district court entered judgment for Plaintiff. Carolina appealed, arguing that because Plaintiff had rejected the offer of judgment prior to informing the court of her acceptance, the district court erred in entering judgment. The First Circuit affirmed, holding that because even an express rejection of a Rule 68 offer of judgment does not terminate a Rule 68 offeree’s power to accept the offer within the fourteen-day period, the district court did not err in entering judgment for Plaintiff. View "Garayalde-Rijos v. Municipality of Carolina" on Justia Law

Petitioner brought this habeas corpus petition after he was released from federal custody, arguing that the Bureau of Prisons violated his right to due process when it failed to hold an in-person hearing before revoking his good-time credits, thus causing him to over-serve his prison sentence. The district court concluded that although Petitioner had over-served his sentence, no due process violation occurred. The First Circuit affirmed, holding that there were no facts that Petitioner could assert or constitutional claim that he could muster that would entitle him to the specific remedy he now requests, and therefore, Petitioner failed to present a petition upon which relief could be granted. View "Francis v. Maloney" on Justia Law