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

In this case, four police officers in Puerto Rico pursued two young men suspected of engaging in a drug deal. One officer shot 17-year-old Calep Carvajal in the back as he fled on a bicycle. Defendant José Cartagena apprehended and handcuffed Carvajal, and was accused of pistol-whipping him while he was on the ground. Additional assaults allegedly occurred during and after transport to the police station. Cartagena later filed a false report about the incident and lied to a juvenile prosecutor about Carvajal’s injuries. Federal charges were brought under various statutes, including civil rights violations and obstruction of justice.After a grand jury indictment, three officers pleaded guilty. Cartagena initially entered a plea but withdrew it and went to trial in the United States District Court for the District of Puerto Rico. He was convicted by a jury on all counts and sentenced to concurrent prison terms. On appeal, he challenged the sufficiency of the evidence and asserted that his Sixth Amendment Confrontation Clause rights were violated when the prosecution introduced a hearsay statement from the victim, who was not available for cross-examination.The United States Court of Appeals for the First Circuit reviewed the case. It found the evidence sufficient to support convictions on most counts but determined that the admission of the victim’s testimonial hearsay statement, offered through a government medical expert, violated Cartagena’s Confrontation Clause rights as to the count involving the alleged pistol-whipping during the arrest. The court vacated the conviction on that count, affirmed the convictions on the other counts, and remanded the case for further proceedings consistent with its opinion. View "US v. Cartagena" on Justia Law

After a mass shooting in Lewiston, Maine in October 2023, which resulted in significant loss of life, the state enacted a law requiring a seventy-two-hour waiting period before a firearm seller may deliver a purchased firearm to the buyer. The law’s purpose was to reduce suicides and homicides associated with impulsive gun purchases. The statute contains exceptions for law enforcement officers, certain security personnel, family transactions, collectors, antiques, and cases where background checks are not required. Several individuals and firearms businesses challenged the law in federal court, alleging it violated their Second Amendment rights, both facially and as applied.The United States District Court for the District of Maine granted a preliminary injunction, concluding that the plaintiffs were likely to succeed on the merits of their facial Second Amendment claim. The court applied the two-step framework from New York State Rifle & Pistol Ass’n, Inc. v. Bruen, first finding that the law implicated conduct covered by the plain text of the Second Amendment, and then determining that the state had not shown that the law was consistent with the nation’s historical tradition of firearms regulation. The district court also found that the other factors for granting a preliminary injunction were present.On appeal, the United States Court of Appeals for the First Circuit reviewed the matter de novo. The appellate court concluded that the seventy-two-hour waiting period regulates conduct antecedent to “keeping” or “bearing” arms, and thus does not directly implicate the plain text of the Second Amendment. The court found that the law imposes, at most, a presumptively lawful condition on the commercial sale of firearms, akin to “shall-issue” licensing regimes, and is constitutional unless shown to be abusive. The court determined that the plaintiffs had not shown the law was abusive toward Second Amendment rights. Accordingly, the First Circuit vacated the preliminary injunction and remanded the case for further proceedings. View "Beckwith v. Frey" on Justia Law

A law firm and one of its clients challenged Maine’s Interest on Lawyers’ Trust Accounts (IOLTA) program, which requires attorneys to deposit certain client funds into pooled, interest-bearing accounts. The interest generated is collected by a nonprofit, the Maine Justice Foundation, and distributed to organizations supporting access to justice in Maine. The plaintiffs argued that being compelled to participate in the program forced them to subsidize advocacy with which they disagreed, violating their First and Fourteenth Amendment rights.The United States District Court for the District of Maine dismissed the claims against the Chief Justice of the Maine Supreme Judicial Court and the State Court Administrator on the merits, concluding that the plaintiffs failed to state a claim. Specifically, the District Court found that, under Maine’s rules, only client funds that could not generate net interest for the client (due to the amount or duration) are required to be deposited in IOLTA accounts, and the plaintiffs did not plausibly allege otherwise. The claim against the Maine Justice Foundation was dismissed for lack of jurisdiction, as the Foundation neither promulgates nor enforces the challenged rule.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s rulings. The appellate court held that the plaintiffs failed to plausibly allege they were compelled to deposit funds that would have generated net interest for the client, as required to make out a compelled-speech claim under controlling precedent. The court also found that any appeal of the dismissal against the Maine Justice Foundation was moot, since the complaint was fatally deficient regardless of the defendant. Thus, the First Circuit affirmed the judgment of the District Court. View "Wescott v. Stanfill" on Justia Law

Two individuals challenged the Puerto Rican electoral commission and its acting president, arguing that restrictions on early and absentee voting during the 2020 general election unlawfully burdened the right to vote for citizens over sixty, especially considering the COVID-19 pandemic. In August 2020, they brought suit under 42 U.S.C. § 1983, seeking relief on constitutional grounds. The district court promptly issued a preliminary injunction, then a permanent injunction, allowing voters over sixty to vote early by mail. After judgment, the plaintiffs were awarded nearly $65,000 in attorneys’ fees under 42 U.S.C. § 1988.While the fee motion was pending, Puerto Rico’s government was in the process of debt restructuring under Title III of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA). The restructuring plan, confirmed in January 2022, discharged claims against Puerto Rico arising before the plan’s effective date unless creditors filed proof of claim by a set deadline. Defendants argued in the U.S. District Court for the District of Puerto Rico that the attorneys’ fees award was subject to the plan’s discharge and enjoined from collection, because the plaintiffs had not filed a timely administrative expense claim. The district court rejected this, finding the fee award unrelated to the bankruptcy case.On appeal, the United States Court of Appeals for the First Circuit concluded that the claim for attorneys’ fees, though arising from post-petition litigation, related to events before the plan’s effective date. The court held that because the plaintiffs had actual knowledge of the restructuring proceedings but did not file a timely proof of claim, their fee claim was discharged under the confirmed plan and enjoined from collection. The First Circuit reversed the district court’s order, holding that the discharge injunction applied to the attorneys’ fee award. View "Ocasio v. Comision Estatal de Elecciones" on Justia Law

Four employees of the University of Puerto Rico sought to stop the deduction of union dues from their paychecks after the Supreme Court’s decision in Janus v. American Federation of State, County, & Municipal Employees, Council 31, which held that public sector employees could not be compelled to pay union dues without consent. Despite their requests, the University and the union continued to deduct dues for nearly three years. The employees then brought suit against the University’s president and the union, alleging violations of their First Amendment rights and seeking declaratory and injunctive relief, as well as damages.The United States District Court for the District of Puerto Rico largely granted summary judgment to the University president and the union, finding no constitutional violation. However, the court ordered the union to reimburse the employees for dues deducted after their resignations but denied interest and did not grant declaratory or injunctive relief. The court also declined to exercise supplemental jurisdiction over the employees’ Puerto Rico law claims.On appeal, the United States Court of Appeals for the First Circuit was asked only to direct the district court to issue declaratory judgments stating that the past and potential future deductions were unconstitutional. The First Circuit dismissed the appeal as moot. It held that a declaration regarding past conduct would be merely advisory because the deductions had already ceased and a judgment ordering reimbursement was in place. The court also found the request for prospective relief moot, as the University and union had admitted their error, stopped the deductions, and adopted new policies to comply with Janus. The court concluded there was no substantial controversy remaining and that the voluntary cessation doctrine did not apply under these facts. The appeal was therefore dismissed as moot. View "Ramos-Ramos v. Jordan-Conde" on Justia Law

The case involves parents of two children with disabilities, both of whom attend private religious schools in Massachusetts. State law entitles all students with disabilities, including those in private schools, to publicly funded special education services. However, a state regulation requires that while public school students can receive these services at their school of enrollment, private school students may only receive them at a public school or another public or neutral location. The parents, who observe Jewish law and prefer their children’s education be informed by Judaism, found it burdensome and disruptive to transport their children to and from different locations for services and chose to forgo the publicly funded services.The parents sued the Massachusetts Department of Elementary and Secondary Education, individual board members, and the commissioner in the United States District Court for the District of Massachusetts. They alleged that the regulation violated the Due Process, Equal Protection, and Privileges or Immunities Clauses of the Fourteenth Amendment by interfering with their fundamental right to direct the upbringing and education of their children. The district court dismissed the complaint for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6).On appeal, the United States Court of Appeals for the First Circuit affirmed the dismissal. The Court held that while parents have a fundamental right to choose private schooling, the regulation does not restrict that right but merely defines the terms under which the state provides public benefits. The regulation does not ban or penalize private schooling or deprive meaningful access to it. Instead, it survives rational basis review because it is rationally related to the legitimate state interest of providing special education services while complying with the Massachusetts Constitution’s prohibition on aiding private schools. The court also rejected the Equal Protection and Privileges or Immunities claims. View "Hellman v. Department of Elementary and Secondary Education" on Justia Law

The plaintiff filed a putative class action against the Treasurer of the Commonwealth of Massachusetts, challenging the Massachusetts Disposition of Unclaimed Property Act under the Takings Clause of the Fifth Amendment. He alleged that the Act’s provisions regarding payment of interest on unclaimed property resulted in an uncompensated taking of his private property for public use. The plaintiff’s complaint included evidence that the state held property in his name, but did not explain his connection to the listed address or further describe the property. He had not filed a claim to recover the property through the statutory process.The United States District Court for the District of Massachusetts dismissed the action, finding that the plaintiff lacked standing to seek injunctive or declaratory relief since he did not demonstrate any future harm, and that the Commonwealth had not waived its Eleventh Amendment immunity. The district court also concluded that the plaintiff failed to state a plausible claim for relief under the Takings Clause, reasoning in part that the statute provides a mechanism for reclaiming the property in full and that any taking resulted from the plaintiff’s own neglect. The district court did not address the ripeness argument raised by the Treasurer.Upon review, the United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The appellate court held that if the plaintiff’s challenge was to the statutory interest rate, his claim was not ripe, as he had not yet made a claim for the property or been denied interest. Alternatively, if the claim was that a taking had already occurred when the state took possession, he lacked standing to seek prospective relief because any injury was in the past and not ongoing. The court thus affirmed the dismissal for lack of Article III jurisdiction. View "Narrigan v. Goldberg" on Justia Law

In 1974, a fatal shooting occurred in a Boston park, resulting in the death of a fourteen-year-old victim. The suspect, who was twenty years old at the time, was identified by witnesses and a murder complaint was issued against him. Shortly after the incident, the suspect was arrested in Indiana under an alias for an unrelated crime. After being acquitted of that charge, he was mistakenly released, and his whereabouts were unknown to Massachusetts authorities for nearly two decades. During this period, he lived under his own name in Indiana, worked, attended university, and occasionally used aliases when interacting with law enforcement.Following a renewed discovery of his location in 1994, Massachusetts authorities interviewed and indicted him for murder in 1997. He was tried and convicted in 2004. Prior to trial, the defendant filed multiple motions to dismiss the indictment on speedy-trial grounds, all unsuccessful. The Massachusetts Superior Court and then the Supreme Judicial Court (SJC) rejected his arguments, finding that the delay was largely attributable to his own conduct, including the use of aliases. The SJC also denied his ineffective-assistance-of-counsel claims on direct appeal.The United States District Court for the District of Massachusetts denied his habeas petition, which alleged violations of his Sixth Amendment right to a speedy trial and ineffective assistance by counsel. On appeal, the United States Court of Appeals for the First Circuit held that, under binding federal precedent, the speedy-trial right only attached upon indictment, not at the issuance of the complaint, and since the relevant delay was seven years, not thirty, his federal speedy-trial claim failed. The court also found his ineffective-assistance claims unavailing, as the record showed no deficient performance or prejudice. Therefore, the First Circuit affirmed the denial of habeas relief. View "Carr v. Lizotte" on Justia Law

A witness was subpoenaed to testify in a federal criminal trial in the United States District Court for the District of Maine. After answering a few questions, she invoked her Fifth Amendment privilege against self-incrimination, refusing to answer further questions from the government. The government then sought and obtained an order from the District Court granting her statutory immunity under 18 U.S.C. §§ 6002-6003, which precluded the use of her compelled testimony or information derived from it against her in any criminal case, except for prosecution for perjury, giving a false statement, or failing to comply with the order. Despite this grant of immunity and a direct order from the court, the witness continued to refuse to testify.Following her refusal, the District Court found her in criminal contempt and issued an order accordingly. Her attorney argued that the statutory immunity provided was not as broad as her Fifth Amendment privilege, specifically asserting that the immunity did not protect her from potential prosecution for perjury based on her compelled testimony. The District Court rejected this argument, clarifying that the immunity was coextensive with the Fifth Amendment privilege as it protected against self-incrimination for prior acts but did not extend to potential perjury in the immunized testimony itself.The United States Court of Appeals for the First Circuit reviewed the District Court’s criminal contempt order for abuse of discretion, reviewing factual findings for clear error and legal questions de novo. The First Circuit held that the statutory immunity granted under 18 U.S.C. §§ 6002-6003 was indeed coextensive with the Fifth Amendment privilege against self-incrimination, except for future perjury or false statements given under immunity. Accordingly, the Court of Appeals affirmed the District Court’s order of criminal contempt. View "United States v. McBreairty" on Justia Law

A man was convicted of sex trafficking a minor after police located the missing child in an apartment where he was staying. The police had responded to a missing persons report filed by the minor’s father, who believed the child was endangered. Investigators traced the minor’s Snapchat activity to an IP address at the apartment and, after gaining access from a tenant in the building, entered the unlocked apartment briefly to ask about the missing child. During this encounter, the defendant emerged from a bedroom. Subsequent evidence, including text messages from a phone recovered from the minor, supported the prosecution’s case.The United States District Court for the District of Massachusetts denied the defendant’s motion to suppress evidence related to the police entry and admitted several text messages and emails as evidence. During jury selection, the court temporarily sealed the courtroom while questioning potential jurors about sensitive matters, with defense counsel expressly stating there was no objection. At the close of trial, the court mistakenly allowed alternate jurors into the deliberation room but promptly removed them and instructed the jury to disregard any statements by the alternates and restart deliberations if needed. The defendant was convicted by a jury and sentenced to 180 months’ imprisonment plus supervised release.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the police entry was justified under the emergency-aid exception, the temporary courtroom sealing did not violate the public trial right due to waiver, and the evidentiary rulings were not an abuse of discretion. The court also found no reversible error in the alternate juror incident, as there was no showing of prejudice. The First Circuit affirmed the district court’s judgment. View "United States v. Rowell" on Justia Law