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

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

The First Circuit affirmed the judgment of the district court denying Petitioner's petition for a writ of habeas corpus filed pursuant to 28 U.S.C. 2254 alleging that the prosecution violated Batson v. Kentucky, 476 U.S.C. 79 (1986) during his criminal trial, holding that there was no error.Based on an interaction with four white men outside an apartment building Petitioner was convicted in the Maine Superior Court of reckless conduct with a dangerous weapon and criminal threatening with a dangerous weapon. Petitioner later filed his petition for habeas corpus. The superior court denied the petition, concluding that the prosecution's race-neutral explanation for striking the sole person of color from the jury pool was not pretextual and, therefore, that there was no purposeful discrimination. The First Circuit affirmed, holding that there was no error. View "Hollis v. Magnusson" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Defendants, the Town of Marblehead and its buildings commissioner, and dismissing this lawsuit brought under the Religious Land Use and Institutionalized Persons Act (RLUIPA), holding that the district court did not err.St. Paul's Foundation and the Shrine of St. Nicholas the Wonderworker, Patron of Sailors, Brewers and Repentant Thieves (collectively, St. Paul's), brought this action alleging that Defendants substantially burdened St. Paul's religious exercise. Specifically, St. Paul's sought to reinstate a building permit that it had secured for the redevelopment of a site on which the Shrine of St. Nicholas was located but that had been suspended prior to the completion of that construction. The district court granted summary judgment in favor of Defendants. The First Circuit affirmed, holding that St. Paul's did not successfully advance a basis for reversing the summary judgment in this case. View "St. Paul's Foundation v. Ives" on Justia Law

The First Circuit affirmed Appellant's plea of guilty to one count of investment adviser fraud, four counts of wire fraud, and one count of aggravated identity theft, holding that there was no prejudicial error in the proceedings below.On appeal, Appellant argued that her plea was not knowing and voluntary, that the evidence was insufficient to convict her of wire fraud and aggravated identity theft, that several sentencing enhancements were improperly applied, and that her counsel was ineffective. The First Circuit affirmed, holding (1) there was no error in the district court's acceptance of Appellant's guilty plea; (2) Appellant's conduct clearly satisfied the statutory requirements for wire fraud and aggravated identity theft; and (3) Appellant's challenges to several aspects of her sentence were unavailing. View "United States v. Kitts" on Justia Law

The First Circuit affirmed Defendant's conviction for being a felon in possession of a firearm, holding that the district court did not err in denying Defendant's motion to suppress.Upon executing a no-knock search warrant following reports of discharged shots the police found two shotguns and related paraphernalia in Defendant's bedroom. In his motion to suppress, Defendant argued that the police exceeded the scope of the warrant by searching his bedroom, which was located on the third floor of the building, because the searched warrant was for "88 Foundation St. 2nd floor." The district court denied the motion, concluding that the good-faith exception to the exclusionary rule applied. The First Circuit affirmed, holding that the officers reasonably believed that the warrant permitted the search of Defendant's third-floor bedroom. View "United States v. Pimentel" on Justia Law

The First Circuit affirmed Defendants' convictions for conspiring to distribute twenty-eight grams or more of cocaine base, holding that neither Defendant was entitled to relief on his claims of error.Defendants Juan Pena and Rosnil Ortiz were convicted for conspiring to distribute twenty-eight grams or more of cocaine base. On appeal, Defendants argued that the district court erred in allowing the jury to consider certain video recordings and the "out-of-court" statements captured therein. The First Circuit affirmed, holding that the district court (1) did not commit reversible error in admitting certain portions of two videos and the audio statements therein; (2) did not deny Defendants' constitutional rights to confront witnesses and to present a complete defense by excluding certain statements, as Defendants intended to use them; and (3) did not deprive Defendants of their right to an impartial tribunal by instructing the jury mid-cross-examination that it was proper for law enforcement agents to use confidential informants and to take drug weight into account when directing controlled drug purchases. View "United States v. Pena" on Justia Law

The First Circuit affirmed Defendant's conviction of one count of conspiracy to possess with intent to distribute and to distribute 500 grams or more of cocaine, in violation of 21 U.S.C. 846, and one count of possession with intent to distribute 500 grams or more of cocaine, in violation of 21 U.S.C. 841(a)(1), holding that there was no error.Specifically, the First Circuit held (1) the district court did not err in denying Defendant's motion to suppress evidence obtained during a traffic stop and admitting items seized from the vehicle at trial; (2) the district court did not manifestly abuse its discretion in admitting certain statements of lay witnesses; (3) the proceedings did not contravene Defendant's constitutional right to a speedy trial; and (4) Defendant's absence at certain pre-trial proceedings did not violate his statutory or constitutional presence rights. View "United States v. Reyes" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Appellants' action for declaratory relief against the Governor of Rhode Island and various Rhode Island officials and agencies (collectively, Rhode Island), holding that the district court did not err.On behalf of a putative class of Rhode Island students attending K-12 schools, Appellants brought this action under the Equal Protection, Due Process, and Privileges and Immunities Clauses of the Fourteenth Amendment and the Republican Guarantee Clause of U.S. Const. art. IV, 4, claiming that Rhode Island failed to provide them with an adequate education to function productively in civic activities. The district court dismissed the action. The First Circuit affirmed, holding that the district court properly concluded that an adequate civics education is not a fundamental constitutional right and that Rhode Island's approach to civics education satisfies rational basis review. View "A.C. v. McKee" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's petition for habeas relief, holding that the district court did not err in its treatment of Defendant's claim for habeas relief based on Batson v. Kentucky, 476 U.S. 79 (1986).Defendant was convicted of first-degree murder and sentenced to life in prison. On appeal, Defendant raised a Batson claim of race-based discrimination in jury selection. The state court denied Defendant's appeal. Thereafter, Defendant filed a petition for habeas relief based on Batson. The federal district court denied relief. The First Circuit affirmed, holding that the Massachusetts Supreme Judicial Court did not unreasonably apply clearly established Supreme Court case law in concluding that Defendant did not establish the prima facie case of purposeful race-based discrimination required by Batson. View "Yacouba-Issa v. Calis" on Justia Law