Justia U.S. 1st Circuit Court of Appeals Opinion Summaries
Articles Posted in Constitutional Law
29 Greenwood, LLC v. City of Newton
A developer purchased a historical property in Newton, Massachusetts, and began restoration work. The Newton Historical Commission issued a stop-work order, claiming the developer violated the permit by demolishing large portions of the building. The developer, 29 Greenwood, LLC, disagreed but complied with the order and submitted revised proposals, all of which were denied. The developer then filed a lawsuit, alleging a violation of the Takings Clause of the U.S. Constitution and state law.The case was initially filed in state court but was removed to the U.S. District Court for the District of Massachusetts. The district court dismissed the complaint, ruling that the dispute was a typical zoning issue not rising to the level of a constitutional taking. The developer appealed the dismissal, arguing that the Commission acted in bad faith and would never permit the reconstruction.The United States Court of Appeals for the First Circuit reviewed the case. The court noted that two related actions were pending in state court, which could potentially resolve or narrow the federal constitutional issues. The court decided to abstain from ruling on the federal issues until the state court proceedings concluded, invoking the Pullman abstention doctrine. The court vacated the district court's dismissal and remanded the case with instructions to stay the federal proceedings pending the outcome of the state court cases. Each party was ordered to bear its own costs. View "29 Greenwood, LLC v. City of Newton" on Justia Law
Cotto v. Campbell
Two state forensic chemists in Massachusetts tampered with drug evidence and falsified test results, affecting tens of thousands of drug cases. The Massachusetts Supreme Judicial Court (SJC) vacated over 30,000 criminal cases due to this misconduct. The SJC ruled that under the Fourteenth Amendment, affected individuals were entitled to the repayment of most funds collected due to their vacated convictions but not the automatic return of forfeited property. Instead, individuals had to file motions for relief from judgment under Rule 60(b) of the Massachusetts Rules of Civil Procedure.The plaintiffs, whose criminal convictions were vacated, sought a federal court order for the automatic return of their forfeited property and related relief. The Commonwealth defendants moved to dismiss the complaint, arguing that the claims were barred by the Eleventh Amendment, which prohibits suits in federal court against a state by its own citizens. The United States District Court for the District of Massachusetts dismissed the complaint in part, ruling that it could not order the automatic return of forfeited property but allowed other claims to proceed under the Ex parte Young exception to the Eleventh Amendment.The United States Court of Appeals for the First Circuit reviewed the case and concluded that the Eleventh Amendment bars all the relief sought by the plaintiffs. The court held that the plaintiffs' claims focused on a past wrong, and the Ex parte Young exception applies only to prospective relief against ongoing violations of federal law. Additionally, the state officials sued lacked the authority to enforce or change the state court procedures. The court reversed the district court's partial denial of the motion to dismiss and remanded with instructions to dismiss the case in full. View "Cotto v. Campbell" on Justia Law
Lowe v. Gagne-Holmes
The case involves Maine healthcare workers who were terminated from their employment for refusing to comply with a COVID-19 vaccine mandate based on their religious beliefs. The mandate, initially promulgated by emergency rule on August 12, 2021, was no longer enforced as of July 12, 2023, and was repealed effective September 5, 2023. The plaintiffs filed suit in the United States District Court for the District of Maine, asserting that the mandate's lack of religious exemptions violated the First and Fourteenth Amendments. Their motion for a temporary restraining order and preliminary injunction was denied, and the denial was affirmed by the First Circuit. The Supreme Court also denied their application for emergency injunctive relief.The defendants moved to dismiss the complaint for failure to state a claim, which was granted. The First Circuit affirmed in part and reversed in part, reinstating the First Amendment Free Exercise and Fourteenth Amendment Equal Protection Clause claims for declaratory and injunctive relief against state health officials. Following the repeal of the mandate, the defendants moved to dismiss the remaining claims as moot, and the district court granted the motion, also denying the plaintiffs leave to amend the complaint.The United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the district court's determinations. The court held that the challenge was moot because the COVID-19 vaccine mandate had been repealed and was no longer in effect. The court also found that no exceptions to mootness, such as voluntary cessation or capable of repetition yet evading review, applied. The court further affirmed the denial of the plaintiffs' request to amend their complaint, concluding that justice did not require permitting further amendments to broaden the scope of their claims. View "Lowe v. Gagne-Holmes" on Justia Law
Posted in:
Civil Procedure, Constitutional Law
Thornton v. Ipsen Biopharmaceuticals, Inc.
Regina M. Thornton was employed by Ipsen Biopharmaceuticals, Inc. as Associate Director - Patient Safety. In September 2021, Ipsen required employees to receive COVID-19 vaccinations. Thornton requested a religious exemption, which Ipsen denied. After she did not comply with the vaccination requirement, Ipsen terminated her employment. Thornton sued Ipsen in the Superior Court of Massachusetts, alleging violations of Title VII, Massachusetts law (Chapter 151B), the Fourteenth Amendment, and the Massachusetts Declaration of Rights (MDR). Ipsen removed the case to the United States District Court for the District of Massachusetts and moved to dismiss all counts. The Magistrate Judge granted Ipsen's motion, dismissing Thornton's complaint. Thornton appealed.The United States District Court for the District of Massachusetts dismissed Thornton's complaint, finding that she failed to state a plausible claim of religious discrimination under Title VII or Chapter 151B. The court concluded that Thornton did not adequately state her religious beliefs or how they related to vaccines. The court also found that Thornton's federal constitutional claims failed because Ipsen was not a state actor, and her MDR claims failed because the MDR does not provide a private right of action.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed the Magistrate Judge's dismissal of Thornton's religious discrimination claims under Title VII and Chapter 151B, finding that she had plausibly alleged that her religious beliefs conflicted with the vaccination requirement. However, the court affirmed the dismissal of her federal constitutional claims, as the Fourteenth Amendment does not apply to private actors like Ipsen. The court also affirmed the dismissal of her MDR claims, noting that Thornton had waived any argument that her claim should be reimagined under the Massachusetts Civil Rights Act. View "Thornton v. Ipsen Biopharmaceuticals, Inc." on Justia Law
United States v. Giambro
Dario Giambro was convicted under 18 U.S.C. § 922(g)(1) for being a felon in possession of a firearm. The conviction stemmed from evidence found by police officers who forcibly entered his home in Hebron, Maine, without a warrant. The officers entered the home based on information from Giambro's son, Antonio, who reported that his mother, Arline, had died and was not in the house. Giambro argued that the warrantless entry violated his Fourth Amendment rights and that the evidence should be suppressed. He also challenged the charge on Second Amendment grounds.The United States District Court for the District of Maine denied Giambro's motion to suppress, ruling that the entry fell within the emergency aid exception to the Fourth Amendment's warrant requirement. The court found that the officers had an objectively reasonable basis to believe that Arline might be in need of immediate aid, despite Antonio's report that she had died and was not in the house. The court also denied Giambro's motion to dismiss the charge on Second Amendment grounds.The United States Court of Appeals for the First Circuit reviewed the case and disagreed with the district court's application of the emergency aid exception. The appellate court held that the officers did not have an objectively reasonable basis to believe that Arline was alive and in need of immediate aid, given that Antonio had been in the house that morning and reported that she was not there. The court emphasized that the officers should have spoken to Antonio and Giambro, who were available for questioning, before forcibly entering the home. Consequently, the First Circuit reversed the district court's denial of the motion to suppress, vacated Giambro's conviction and sentence, and remanded the case for further proceedings. The court did not address the Second Amendment claim due to its ruling on the Fourth Amendment issue. View "United States v. Giambro" on Justia Law
Posted in:
Constitutional Law, Criminal Law
3137, LLC v. Town of Harwich
Justin and Jared Brackett own and operate two restaurants in Harwich, Massachusetts: Ember Pizza, Inc. and The Port Restaurant and Bar, Inc. Both establishments held liquor and entertainment licenses issued by the town. Allegedly, they violated Harwich's noise ordinance and Massachusetts COVID-19 restrictions, leading to suspensions and restrictions on their permits. In response, they sued Harwich, several town officials, and other individuals in federal district court, asserting various federal and state claims.The United States District Court for the District of Massachusetts largely granted the defendants' dispositive motions, rejecting all of Ember and The Port's claims. The court also denied their request for leave to amend their complaint, finding that an amendment would be futile. Ember and The Port then appealed the district court's decisions.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's rulings. The appellate court held that Ember and The Port failed to state a plausible claim for relief under federal law, including their First Amendment, Fourteenth Amendment, and procedural due process claims. The court also found that the Massachusetts Civil Rights Act claims and common law claims, including civil conspiracy and defamation, were inadequately pleaded. The court concluded that the district court did not abuse its discretion in denying the request for leave to amend the complaint, as the proposed amendments would not have cured the deficiencies in the original complaint. View "3137, LLC v. Town of Harwich" on Justia Law
Heredia v. Roscoe
In the early hours of May 11, 2018, Chasrick Heredia, while celebrating his birthday, had a violent encounter with Manchester Police officers, including Officer Michael Roscoe. Heredia filed a complaint alleging excessive force and other constitutional violations. At trial, the jury found Roscoe liable for excessive force and awarded Heredia nominal and punitive damages. The district court denied Roscoe's motions for judgment as a matter of law (JMOL) and for remittitur of the punitive damages award.The United States District Court for the District of New Hampshire presided over the initial trial. The jury found in favor of Heredia on the excessive force claim against Roscoe but in favor of the defendants on all other claims. Roscoe's post-trial motions for JMOL and remittitur were denied by the district court, which concluded that a reasonable juror could find that Roscoe violated Heredia's constitutional rights and that qualified immunity did not apply.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's denial of Roscoe's motions. The appellate court held that a reasonable jury could find that Roscoe used excessive force when he performed a takedown on Heredia after Heredia had submitted to arrest by raising his hands. The court also held that Roscoe was not entitled to qualified immunity because it was clearly established that increasing the use of force after an arrestee had submitted was unconstitutional. Additionally, the court found that the punitive damages awarded were justified based on Roscoe's reckless indifference to Heredia's constitutional rights. View "Heredia v. Roscoe" on Justia Law
Posted in:
Civil Rights, Constitutional Law
American Trucking Associations, Inc. v. Rhode Island Turnpike and Bridge Authority
In 2016, Rhode Island enacted the RhodeWorks Act, which imposed tolls on tractor-trailers crossing thirteen bridges within the state. The toll revenue was intended for the replacement, reconstruction, operation, and maintenance of these bridges. The tolls were subject to three statutory caps: a truck could not pay more than once in each direction, more than $40 per day, or more than $20 for a single through trip from Connecticut to Massachusetts. The American Trucking Associations and several trucking companies challenged the tolls, arguing they violated the dormant Commerce Clause by discriminating against interstate commerce and failing to fairly approximate use of the bridges.The U.S. District Court for the District of Rhode Island permanently enjoined the tolls, finding that they discriminated against interstate commerce and did not fairly approximate use. The court concluded that the tolls' application solely to tractor-trailers and the statutory caps each violated the dormant Commerce Clause.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed that the statutory caps on tolls were unconstitutional because they disproportionately benefited in-state over out-of-state tractor-trailers, thus discriminating against interstate commerce. However, the court held that the tolls' application solely to tractor-trailers did not violate the fair-approximation test, as it was not wholly unreasonable for Rhode Island to rely on studies showing that tractor-trailers caused the most damage to the bridges.The First Circuit concluded that the unconstitutional caps were severable from the rest of the statute. Therefore, the court affirmed the district court's judgment in part, reversed it in part, and remanded the case for the entry of judgment consistent with its opinion. View "American Trucking Associations, Inc. v. Rhode Island Turnpike and Bridge Authority" on Justia Law
Posted in:
Constitutional Law, Transportation Law
National Association of Government Employees, Inc. v. Yellen
The National Association of Government Employees, Inc. (NAGE) challenged the constitutionality of the Debt Limit Statute, alleging that it posed an imminent risk to its members, who are federal employees. NAGE claimed that if the debt limit was not raised, its members would face layoffs, furloughs, unpaid work, and loss of pension funding. NAGE sought declaratory and injunctive relief against Treasury Secretary Janet Yellen and President Joseph R. Biden.The United States District Court for the District of Massachusetts dismissed the case for lack of subject matter jurisdiction. The court found that NAGE's claims of past injuries were moot due to the passage of the Fiscal Responsibility Act, which suspended the debt limit until January 1, 2025, and required the Treasury Secretary to make whole the G Fund accounts. The court also determined that NAGE's claims of future harm were too speculative to establish standing, as they relied on a series of unlikely events, including a federal default, which has never occurred.The United States Court of Appeals for the First Circuit affirmed the district court's dismissal. The appellate court agreed that NAGE lacked standing to pursue prospective relief because the anticipated future harms were speculative and not certainly impending. The court also found that NAGE's claims of past injuries were moot, as the Fiscal Responsibility Act had addressed the immediate concerns, and there was no reasonable expectation that the same harm would recur. The court rejected NAGE's arguments that the voluntary-cessation and capable-of-repetition-yet-evading-review exceptions to mootness applied, concluding that the legislative action was independent and not related to the litigation, and that the risk of future harm was not reasonably expected. View "National Association of Government Employees, Inc. v. Yellen" on Justia Law
Etienne v. Edmark
In this case, the petitioner was convicted by a jury in New Hampshire state court for the first-degree murder of Larry Lemieux. The petitioner admitted to shooting Lemieux but claimed he acted in self-defense or in defense of another, arguing he did not act with premeditation. After his conviction, the prosecution disclosed a proffer letter recommending a suspended sentence for drug charges against Jose Gomez, a key prosecution witness. The petitioner argued that the failure to disclose this letter violated his due process rights under Brady v. Maryland.The state trial court denied the petitioner's motion for a new trial, finding that the nondisclosure of the proffer letter did not prejudice the petitioner. The New Hampshire Supreme Court affirmed this decision, holding that the petitioner was not prejudiced under New Hampshire law, which sets stricter standards than Brady. The court found that the undisclosed evidence would not have altered the defense strategy or the trial's outcome, given the overwhelming additional evidence of premeditation presented by other witnesses.The United States Court of Appeals for the First Circuit reviewed the case, focusing on whether the New Hampshire Supreme Court's decision involved an unreasonable application of clearly established federal law under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). The First Circuit affirmed the denial of habeas relief, concluding that the New Hampshire Supreme Court reasonably determined that the petitioner was not prejudiced by the nondisclosure of the proffer letter. The court noted the overwhelming evidence of premeditation from multiple witnesses, which supported the jury's verdict independent of Gomez's testimony. View "Etienne v. Edmark" on Justia Law