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

The First Circuit affirmed the judgment of the district court denying Appellant's petition for habeas corpus, in which he alleged ineffective assistance of counsel, holding that Appellant failed to establish that his counsel's performance was deficient under Strickland v. Washington, 466 U.S. 668 (1984).After a retrial, Appellant was convicted of two counts of attempting to kill a federal witness with intent to prevent testimony and communication with law enforcement. The First Circuit affirmed. Appellant later filed a motion under 28 U.S.C. 2255 to vacate his conviction based on ineffective assistance of counsel. The district court denied relief. The First Circuit affirmed, holding that Appellant's claims of ineffective assistance of counsel were unavailing. View "Watson v. United States" on Justia Law

The First Circuit denied a writ of habeas corpus sought by Petitioner under 28 U.S.C. 2254 to vacate her conviction for murder in the first degree, holding that there was no error.Petitioner was convicted of first-degree murder based on deliberate premeditation and extreme atrocity or cruelty and was sentenced to life imprisonment without the possibility of parole. Petitioner later filed a habeas petition claiming ineffective assistance of counsel. The district court denied the petition. The First Circuit affirmed, holding that there was no prejudice on any of the alleged errors claimed by Petitioner. View "Field v. Hallett" on Justia Law

Watkins was convicted of first-degree murder in Massachusetts state court in 2005 for a fatal 2003 shooting. The Supreme Judicial Court affirmed his conviction. His federal habeas petition was denied.The First Circuit affirmed the denial of relief. The state courts made an error of fact in their decisions, rejecting a “Brady” claim that a withheld a police report could have been used for the impeachment of a witness (Rudolph), finding that the report did not show the investigating officers were aware that Rudolph was a witness against Watkins. Under the Antiterrorism and Effective Death Penalty Act's deferential standard of review or applying de novo review, Watkins has not shown prejudice arising from the error or with respect to any of his other claims. There was an extensive examination of bias, and the failure to add onto any such evidence hardly would be prejudicial. Rudolph's motivation for reaching out to the police and the agreement that Rudolph later reached with the Commonwealth were discussed at trial and clearly informed Watkins and the jury that Rudolph sought an incentive in return for his cooperation and testimony. View "Watkins v. Medeiros" on Justia Law

The First Circuit affirmed Defendant's convictions for receipt and possession of child pornography, holding that the district court did not err in denying Defendant's pre-trial motion to suppress evidence obtained pursuant to a search warrant and did not abuse its discretion in excluding certain text-message evidence as inadmissible hearsay.On appeal, Defendant argued that the district court erred in denying his motion to suppress because the affidavit filed in support of the search warrant failed sufficiently to describe ether pornographic images to be found and that the court erred in excluding from his trial the text message evidence at issue. The First Circuit affirmed, holding (1) there was no error in the district court's denial of Defendant's motion to suppress; and (2) the district court did not err in barring the text messages from Defendant's trial. View "United States v. Chiu" on Justia Law

The First Circuit reversed the decision of the district court that the prosecutor in the underlying Rhode Island case transgressed the Batson rule in the course of jury selection but that Petitioner was not entitled to habeas corpus relief, holding that the decision of the Rhode Island Supreme Court could not withstand habeas review.Petitioner, a Rhode Island state prisoner and an African-American man who was convicted of murder and other crimes, claimed in his petition for writ of habeas corpus that the prosecutor violated Batson during jury selection. The federal district court concluded that Petitioner's rights under Batson were violated but that the Rhode Island Supreme Court did not abuse its discretion in finding sufficient race-neutral reasons for a peremptory challenge against the juror in question. The First Circuit reversed, holding (1) the prosecutor's explanation for his peremptory strike was not race-neutral on its face and thus violated Batson; and (2) the Rhode Island Supreme Court's decision rested on either an unreasonable application of clearly established federal law, an unreasonable determination of the facts, or both. View "Porter v. Coyne-Fague" on Justia Law

The First Circuit vacated the judgment of the district court granting summary judgment to Defendants and dismissing Plaintiff's claims challenging the termination of his employment on free speech grounds, holding that summary judgment was improper in this case.Plaintiff, a former bus driver for the Worcester Regional Transit Authority (WRTA), brought this action under 42 U.S.C. 1983 claiming that Defendants violated his right to free speech under the First Amendment to the federal constitution and the Massachusetts Civil Rights Act (MCRA) when they terminated his employment following public comments that he made to a television network about proposed budget cuts to the WRTA. The district court granted summary judgment for Defendants. The First Circuit remanded the case, holding (1) the district court erred in concluding that, as a matter of law, Plaintiff was not speaking "as a citizen" during the television interview; and (2) Defendants did not have an adequate justification for treating Plaintiff differently from other members of the general public by terminating him for his protected speech. View "Bruce v. Worcester Regional Transit Authority" on Justia Law

In this interlocutory appeal, the First Circuit affirmed the judgment of the district court denying Defendant's motion to dismiss this suit pursuant to both the Eleventh Amendment and the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA), 48 U.S.C. 2101 et seq., holding that the district court did not err.The plaintiff in this case was the Centro de Periodismo Investigativo (CPI), a non-profit media organization based in Puerto Rico. Plaintiff sued the Financial Oversight and Management Board for Puerto Rico, alleging that the Board improperly ignored their requests for documents or provided less than complete responses in violation of P.R. Const. 4. The Board moved to dismiss the claim for lack of subject-matter jurisdiction and for failure to state a claim. The district court denied the motion. The First Circuit affirmed, holding that Defendants were not entitled to Eleventh Amendment sovereign immunity. View "Centro de Periodismo Investigativo, Inc. v. Financial Oversight & Management Board for Puerto Rico" on Justia Law

The First Circuit reversed the judgment of the district court denying Defendants' motion for entry of an automatic stay under 11 U.S.C. 922, incorporated into Title III of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA), 48 U.S.C. 2101-2241, through 48 U.S.C. 2161(a), holding that Defendants were entitled to an automatic stay.Plaintiffs, who owned an operated the Integrand Assurance Company, sued Defendants, Puerto Rico government officials whose defense was assumed by the Commonwealth of Puerto Rico pursuant to the Commonwealth's legal representation and indemnification statute, alleging, among other claims, that the government officials violated their First Amendment rights, the Equal Protection Clause, and the Due Process Clause. Defendants, who were granted legal representation under Law 9, filed a notice of automatic stay. The district court denied the motion, concluding that PROMESA did not stay the litigation. The First Circuit reversed, holding that the automatic stay provision in Title III of PROMESA applied to this action. View "Victor J. Salgado & Associates v. Cestero-Lopategui" on Justia Law

The First Circuit vacated the judgment of the district court dismissing this complaint alleging a First Amendment claim and seeking a preliminary injunction, holding that Plaintiffs plausibly alleged a First Amendment violation.At issue was the electronic case filing system piloted by the Maine Supreme Judicial Court (SJC) for the state's trial courts, which resulted in delayed access. Plaintiffs, state and federal news agencies, sued Defendants, state court officials, alleging violations of their First Amendment rights. Thereafter, the SJC changed its rules. The district court held that Plaintiffs had failed to state a claim, dismissed the complaint, and denied the motion for a preliminary injunction as moot. The Supreme Court reversed, holding that Plaintiffs plausibly alleged a First Amendment violation. View "Courthouse News Service v. Quinlan, Bangor Publishing Co., Inc." on Justia Law

The First Circuit affirmed Defendant's conviction of possession with intent to distribute forty grams or more of fentanyl, holding that the district court did not err in denying Defendant's motion to suppress evidence seized during a stop and warrantless search of his vehicle.After Defendant was indicted he filed a motion to suppress the evidence obtained a result of the stop and search in this case. The district court denied the motion and found Defendant guilty. On appeal, Defendant argued that the district court abused its discretion in failing to hold an evidentiary hearing on his motion to suppress and that, alternatively, the district court erred in denying his motion to suppress because he was de facto placed under arrest without probable cause. The First Circuit affirmed, holding (1) if there was an arrest it was a lawful one; and (2) no evidentiary hearing was necessary in this case. View "United States v. Batista" on Justia Law