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

The First Circuit vacated the federal convictions challenged on appeal by the two defendants in this case - Noel de Leon-De la Rosa and Juan Batista Johnson-Debel - holding that vacatur was required of Defendants' challenged convictions for different reasons.Defendants were both convicted of destruction of a controlleded substance while on a vessel and conspiracy to destroy a controlled substance while on a vessel (counts five and six). The First Circuit vacated Defendants' of counts five and six, holding (1) the evidence was sufficient to support the convictions; (2) the admission of Johnson's statement in the defendants' joint trial violated De Leon's rights under the Confrontation Clause to the Federal Constitution; and (3) as to Johnson's convictions, the district court constructively amended the indictment through its instructions to the jury. View "United States v. De Leon-De la Rosa" on Justia Law

The First Circuit reversed the judgment of the district court denying Defendant's motion to vacate her federal conviction and sentence on the grounds that her appellate counsel was constitutionally ineffective under Strickland v. Washington, 466 U.S. 668 (1984), for failing to raise a claim on direct appeal under Brady v. Maryland, 373 U.S. 83 (1963), holding that the district court erred.Defendant and her co-defendants were convicted of various drug-trafficking offenses. In their direct appeals, Defendant's co-defendants successfully argued that the government's failure to produce several clearly relevant documents that plainly called into question the credibility of the government's key witnesses against Defendant and her co-defendants violated their due process rights under Brady. The First Circuit vacated the co-defendants' convictions and remanded for a new trial. Because Defendant did not raise the Brady violation on her simultaneous appeal, she was denied relief. Thereafter, Defendant brought this action pursuant to 28 U.S.C. 2255. The First Circuit reversed, holding (1) Defendant established prejudice under Strickland; and (2) the failure to raise the Brady claim was the result of deficient performance by appellate counsel. View "Flores-Rivera v. United States" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's motion to dismiss the criminal proceedings against him, holding that Appellant was statutorily barred under 8 U.S.C. 1326(d) from bringing a collateral attack in his criminal proceeding.Defendant was charged with violating 8 U.S.C. 1326, which makes it a felony to unlawfully enter the United States while an order of removal is outstanding. Defendant filed a motion to dismiss the indictment against him, arguing that the government may not use his prior removal order to prove the "outstanding order of removal" element of the crime. Defendant thus sought to dismiss his indictment based on a due process-based collateral attack on the order of removal, arguing that the entry of the order was fundamentally unfair. The district court denied the motion. The First Circuit affirmed, holding (1) Defendant's first argument had already been rejected by this Court since the district's ruling; and (2) because the removal proceeding was not fundamentally unfair Defendant did not satisfy the conditions under 8 U.S.C. 1326(d) that would permit him to collaterally attack his prior removal. View "United States v. Castillo-Martinez" on Justia Law

The First Circuit affirmed the rulings of the district court denying the Commission of the New Hampshire Department of Health and Human Services' motion to dismiss Plaintiffs' complaints against her, holding that Plaintiffs' allegations of error were without merit.Plaintiffs were (1) a class of individuals who claimed to have been held against their will without due process on the basis of a certification of their need for emergency mental health treatment, and (2) a group of hospitals who claimed to have been forced to retain persons certified to be in need of such treatment. The Commissioner moved to dismiss the claims based on Eleventh Amendment immunity and Plaintiffs' asserted lack of standing. The district court denied the motion to dismiss. The First Circuit affirmed, holding that there was no merit to the Commissioner's challenges to the district court's standing and Eleventh Amendment immunity rulings. View "Doe v. Shibinette" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant of three drug trafficking offenses after law enforcement officers discovered cocaine and heroin inside of his vehicle, holding that the district court did not err in denying Defendant's motion to suppress.In his motion to suppress, Defendant argued that the officers stopped his vehicle without reasonable suspicion, in violation of the Fourth Amendment, and therefore, the drugs found inside of the vehicle were inadmissible as evidence. The district court denied Defendant's motion to suppress. The First Circuit affirmed, holding that the officers had probable cause to arrest Defendant when they conducted the vehicle containment in this case. View "United States v. Gonzalez" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellants' request for a preliminary injunction to prevent enforcement of a regulation promulgated by Maine's Center for Disease Control requiring all workers in licensed healthcare facilities to be vaccinated against COVID-19, holding that the district court did not err.Under Maine law, a healthcare worker may claim an exemption from the vaccination requirement only if a medical practitioner certifies that vaccination "may be medically inadvisable." Appellants - several Maine healthcare workers and a healthcare provider - brought this action alleging that the vaccination requirement violated their rights under 42 U.S.C. 1985 and the Free Exercise Clause, Supremacy Clause, and Equal Protection Clause of the United States Constitution. The district court denied Appellants' motion for a preliminary injunction. The First Circuit affirmed, holding that the district court did not err in concluding that Appellants were unlikely to succeed on the merits of their claims. View "Does v. Mills" on Justia Law

The First Circuit affirmed the district court's entry of summary judgment on Count I of Plaintiff's complaint seeking damages under 42 U.S.C. 1983 but reversed the entry of summary judgment on Count IX, holding that unconstitutional conduct of police officers violated the clearly established law of the Supreme Court, as set forth in Florida v. Jardines, 569 U.S. 1, 6 (2013).Plaintiff brought this complaint against the Town of Orono, the chief of the Orono Police Department, and four police officers with whom he interacted during two encounters in 2016 - one in February and one in September - both of which resulted in his being arrested without a warrant on charges that were subsequently dropped. The district court granted summary judgment in favor of Defendants. The First Circuit affirmed in part and reversed in part, holding that the district court (1) correctly granted summary judgment on Count I relating to the February incident; but (2) erred in granting summary judgment on Count IX relating to the September incident. View "French v. Merrill" on Justia Law

The First Circuit affirmed the district court's denial of Francis Lang's petition seeking a writ of habeas corpus to vacate his Massachusetts conviction for murder in the first degree, holding that the district court did not err in denying the petition.Lang was convicted in a Massachusetts court for murder in the first degree. In this action, filed pursuant to 28 U.S.C. 2254, Lang sought to vacate his conviction, arguing that his trial counsel provided ineffective assistance by failing to investigate Lang's mental health history. The district court denied the petition. The First Circuit affirmed, holding that Defendant failed to establish prejudice under Strickland v. Washington, 466 U.S. 668 (1984). View "Lang v. DeMoura" on Justia Law

The First Circuit affirmed Defendants' convictions connected with the murder of Steven DiSarro, holding that Defendants were not entitled to relief on their allegations of error.Defendants, Francis Salemme and Paul Weadick, were convicted of the 1993 murder of DiSarro. At the time of the murder, Salemme was the boss of a criminal organization known as the New England La Cosa Nostra. Defendants murdered DiSarro to prevent him from talking with federal agents about his activities with Salemme, Weadick and Salemme's son. On appeal, Defendants challenged the trial court's admission of a significant amount of evidence concerning the prior criminal activities of Salemme and several witnesses. The First Circuit affirmed, holding that the district court did not err in admitting the evidence. View "United States v. Weadick" on Justia Law

The First Circuit reversed the decision of the district court refusing to quash subpoenas seeking discovery from Rhode Island public officials and a state consultant, holding that Petitioners were entitled to a writ of advisory mandamus reversing the decision to allow the discovery sought from Rhode Island's former governor, the former speaker of Rhode Island's legislature, and former state representative.In these consolidated cases Petitioners sought to reverse the district court's decision refusing to quash subpoenas seeking discovery from Rhode Island public officials and a state consultant. Proponents of the discovery - trucking interests - asserted that the discovery was reasonably calculated to provide evidence that Rhode Island elected officials intended to discriminate against interstate commerce in charging bridge tolls. The First Circuit issued a writ of advisory mandamus reversing the decision to allow the discovery sought from certain Rhode Island public officials, holding that the district court erred in determining that the proponents' interest in obtaining evidence of the state officials' subject motives outweighed the comity considerations implicated by the subpoenas. View "American Trucking Associations, Inc. v. Raimondo" on Justia Law