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

Appellant, a student at Brown University, was suspended for three semesters after a number of students and staff submitted complaints regarding his behavior. Appellant filed an eleven-count complaint in the district court of Rhode Island against the University, numerous individuals associated with the University, and its police department (collectively, Appellees), alleging, among other claims, that Appellees’ conduct during his disciplinary proceeding and during his removal from campus violated his constitutional rights and state law. The district court entered judgment in favor of Appellees. The First Circuit affirmed, holding that the district court did not err by (1) finding that the University was not a state actor subject to federal jurisdiction under 42 U.S.C. 1983; (2) granting Appellees’ motion to amend their answer to include a statute of limitations defense; and (3) disposing of Appellant’s claims on Appellees’ motions to dismiss and for summary judgment, as the Rhode Island tolling statute did not toll Appellant’s claims. View "Klunder v. Brown University" on Justia Law

Plaintiff was fired from his place of employment after his employer (Defendant) learned that Plaintiff had consistently falsified his time cards over the course of several years, costing the company “1.25 hours of labor per week.” Plaintiff filed suit, alleging that Defendant had terminated him in retaliation for taking family leave in violation of the Family and Medical Leave Act. The district court granted summary judgment for Defendant. The First Circuit affirmed, holding that because Plaintiff did not offer evidence of retaliatory animus sufficient to raise a disputed question of fact or to defeat Defendant’s right to judgment as a matter of law, Plaintiff did not meet his burden of proving that Defendant’s stated reason for his termination was a pretext. View "Ameen v. Amphenol Printed Circuits, Inc." on Justia Law

After a jury trial, Petitioner was convicted in state court of murder in the first degree. The Massachusetts Supreme Judicial Court affirmed the conviction. Petitioner subsequently filed several motions for a new trial in state court without success. Petitioner later filed a petition for habeas corpus relief in federal district court, asserting numerous instances of ineffective assistance of counsel at both trial and postconviction proceedings as well as prosecutorial misconduct. The district court denied the motion, concluding that all of Petitioner’s claims had been procedurally defaulted. The First Circuit affirmed, holding (1) the district court did not err in holding that Petitioner’s claims of ineffective assistance of trial counsel and prosecutorial misconduct had been procedurally defaulted; and (2) the claim of ineffective assistance of postconviction counsel was not procedurally defaulted, but it was otherwise barred by 28 U.S.C. 2254(i). View "Lee v. Corsini" on Justia Law

Plaintiff, a town official for the town of Raymond, claimed that Michael Reynolds, a fellow town official, told the sheriff’s department that Plaintiff had driven while intoxicated, that the reports were false, and the false statements damaged his reputation. Plaintiff brought suit in state superior court, alleging state law claims for defamation and false light invasion of privacy, as well as federal claims under 42 U.S.C. 1983. The case was removed to federal court on the basis of the federal claims. The district court dismissed the federal claims and proceeded to resolve the state law claims. The First Circuit (1) affirmed the dismissal of the federal claim; and (2) vacated the dismissal of Plaintiff’s state law claims as to Reynolds and remanded the claims to state court, holding the state law claims involved resolution of a potential conflict between Maine’s Anti-SLAPP statute and Maine’s Constitution, a conflict that “is best resolved by the Maine courts.” View "Desjardins v. Willard" on Justia Law

Defendant, a former officer with the Puerto Rico Police Department, was charged with multiple drug-related and firearm-related charges for his participation in fifteen drug transactions that were part of an FBI sting operation. The jury acquitted Defendant of all the firearm charges and the drug charges arising out of the first drug transaction and convicted him on all other counts. The First Circuit affirmed, holding that the district court did not err by refusing to give jury instructions on entrapment and duress; denying Defendant’s proffered instructions on impeachment of witnesses for prior convictions; and denying Defendant’s motion for a new trial based on the trial court’s rulings and interjections during closing arguments. Lastly, the government’s remarks during its rebuttal argument did not render the trial unfair. View "United States v. Gonzalez-Perez" on Justia Law

Plaintiffs in this case were fourteen maintenance, domestic, and warehouse workers who were abruptly fired from the Puerto Rico executive mansion shortly after Luis Fortuño-Burset (“Fortuño”), the newly-elected governor, took office. In 2009, Plaintiffs sued Fortuño, Fortuño’s wife, and two executive staffers, alleging that they were terminated in violation of the First Amendment because they affiliated with Fortuño’s rival political parties. The district court entered summary judgment dismissing Plaintiffs’ political discrimination claim. The First Circuit affirmed both the summary judgment dismissals of Plaintiffs’ First Amendment claim and the denial of their motion to reconsider, holding (1) the record lacked sufficient evidence that Defendants were aware of Plaintiffs’ political affiliations, and thus, Plaintiffs’ First Amendment claim failed on that ground; and (2) the district court did not err in denying Plaintiffs’ request to reconsider the judgment. View "Ocasio-Hernandez v. Fortuno-Burset" on Justia Law

Appellant had leased the same apartment at a San Juan, Puerto Rico housing cooperative (Cooperative) for several years. While living at the cooperative, Appellant received benefits under the Section 8 federal housing assistance program, which enabled her to pay her rent. When the Housing Finance Authority concluded that Appellant’s apartment unit was “over-housed” for Section 8 purposes, the Cooperative informed Appellant that she would have to pay market-rate rent without the Section 8 assistance. Appellant subsequently submitted a request to the Cooperative for reasonable accommodation on account of her disability, stating that she could not move to a different unit without compromising her health. The Cooperative denied Appellant’s request. After filing an administrative complaint without success, Appellant filed suit in federal court, alleging that the Cooperative had violated the Fair Housing Act by failing to provide the requested accommodation, by engaging in a pattern of discriminatory actions against her, and by retaliating against her because she had recently prevailed in a separate HUD proceeding against the Cooperative. The district court (1) found in the defendants’ favor regarding the reasonable accommodation and disparate treatment claims; and (2) concluded that it lacked jurisdiction to decide the retaliation claim. The First Circuit (1) affirmed the district court’s grant of summary judgment on the reasonable accommodation and disparate treatment claims; and (2) reversed the district court’s decision to dismiss Appellant’s retaliation claim, holding that the district court had jurisdiction to decide this claim. View "Batista v. Cooperativa de Vivienda" on Justia Law

A jury found Appellant guilty of one count of possession with intent to distribute more than 500 grams of cocaine. Appellant was tried a second time on the drug trafficking charge after the First Circuit concluded that Appellant’s Sixth Amendment right to confrontation had been violated at his first trial. At retrial, a jury again found Appellant guilty of the drug possession charge. At sentencing, the district court treated Appellant as a career offender under the Sentencing Guidelines. The First Circuit affirmed the conviction but remanded for resentencing without the career offender enhancement, holding (1) the government’s delay in bringing the indictment did not violate Appellant’s due process rights; (2) the district court did not abuse its discretion in denying Appellant’s motion to dismiss the indictment for prosecutorial misconduct; (3) the court did not commit reversible error in its evidentiary rulings or in instructing the jury; (4) the court’s refusal to continue Appellant’s sentencing hearing, if error, was harmless; and (5) in designating Appellant as a career offender, the district court relied on a predicate offense that does not qualify for that purpose. View "United States v. Ramos-Gonzalez" on Justia Law

After a jury trial in 2007, Defendant was convicted of two drug trafficking counts. At sentencing, the sentencing judge made a drug quantity finding and increased the mandatory minimum sentence for each count. Defendant appealed, arguing that a jury must find beyond a reasonable doubt any fact leading to the imposition of a higher mandatory minimum sentence. The First Circuit affirmed. After Alleyne v. United States was decided, Defendant initiated a collateral attack on his sentence. The district court denied Defendant’s motion for habeas relief under 28 U.S.C. 2255. The First Circuit affirmed, holding that the rule announced in Alleyne does not apply retroactively to sentences challenged on an initial petition for collateral review. View "Butterworth v. United States" on Justia Law

Defendant, a Colombian national, was convicted of participating in a conspiracy to import cocaine to the United States. Prior to trial, Defendant moved to suppress an identification that he argued had been obtained by a highly suggestive means. The district court denied the motion, finding that the means used to obtain the identification was unduly suggestive but that the identification was still reliable enough to put to the jury. Defendant appealed, arguing, among other things, that the government’s use of the identification at trial violated his constitutional right to due process. The First Circuit affirmed, holding (1) the district court did not err in finding that the method of obtaining the identification was problematic but that there was reason enough to credit the identification to permit a jury to decide its worth; and (2) Defendant’s remaining allegations of error were without merit. View "United States v. Castro-Caicedo" on Justia Law