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

The First Circuit affirmed the district court’s denial of Defendant’s motion to suppress drug evidence as having resulted from an unlawful search under the Fourth Amendment, holding that the search was constitutional.At issue was whether, after completing a license check that is usual when a car is stopped for a driving offenses, the police had reasonable suspicion that a drug offense was being committed so as to justify a further period of detention while a drug detection dog repeatedly circled Defendant’s car, and whether the added time exceeded the permissible duration for the dog’s investigation. The First Circuit held (1) probable cause justified the search that led to discovery of the drugs; and (2) the approximately three minutes from the beginning of the dog’s reconnaissance to the dog’s response fell within the zone considered reasonable under the Terry rationale. View "United States v. Favreau" on Justia Law

Amendment 794 to the U.S. Sentencing Commission Guidelines clarifies the Sentencing Commission’s original intent regarding section 3B1.2 of the Sentencing Guidelines and therefore applies retroactively.Defendant pleaded guilty to two cocaine-related charges under the Maritime Drug Law Enforcement Act (MDLEA). On appeal, Defendant challenged the constitutionality of the MDLEA and section 3B1.2 and argued that he should be resentenced under the Sentencing Commission’s amended guidance in Amendment 794. The First Circuit vacated Defendant’s sentence and remanded for resentencing, holding (1) Congress did not exceed its constitutional authority in promulgating the MDLEA; (2) section 3B1.2 is not void for vagueness; but (3) Amendment 794 is clarifying, not substantive, and is therefore retroactively applicable. View "United States v. Sarmiento-Palacios" on Justia Law

Here, the First Circuit clarified its circuit’s emergency aid doctrine, holding that police officers seeking to justify their warrantless entry into homes need only demonstrate an objectively reasonable basis for believing that a person within the house is in need of immediate aid. See Michigan v. Fisher, 558 U.S. 45, 47 (2009). The court thus modified its previous pronouncements in United States v. Martins, 413 F.3d 139 (1st Cir. 2005), and its progeny, clarifying that police officers need not establish that their belief approximated probable cause that such an emergency existed.In this case, the district court entered judgment for Defendants, police officers and the City of Taunton, concluding that the officers did not commit a Fourth Amendment violation because their conduct fell within the emergency aid exception to the warrant requirement. The First Circuit took the opportunity in this case to clarify its emergency aid doctrine to bring its case law in line with Supreme Court precedent. The court then affirmed on the basis that the officers were entitled to qualified immunity and no claim was stated against the City. View "Hill v. Walsh" on Justia Law

The First Circuit affirmed the district court’s denial of Defendant’s motion to suppress, holding that the seizure of contraband in Defendant’s undershorts did not violate the “plain feel” doctrine.During a pat-down incident to a Terry stop, a Drug Enforcement Administration agent discovered a softball-sized object stashed in Defendant’s undershorts. The agent arrested Defendant under the suspicion that the object was contraband. A subsequent search of Defendant’s person confirmed the agent’s suspicion that the object contained controlled substances. The district court denied Defendant’s motion to suppress. The First Circuit affirmed, holding that, under the totality of the circumstances, the search and seizure were reasonable, and thus, Defendant’s Fourth Amendment rights were not violated. View "United States v. Rasberry" on Justia Law

The First Circuit affirmed the district court’s denials of Defendant’s motions for suppression and severance and declined to vacate Defendant’s sentence.Defendant pled guilty to crimes related to the distribution of drugs. Defendant filed a motion to suppress evidence seized as a result of a stop and search of a taxi and also filed a motion to sever his trial from that of his codefendants and for relief from prejudicial joinder. The district court denied both motions after hearings. The sentencing judge sentenced Defendant to a term of imprisonment of thirty-six months, followed by thirty-six months of supervised release. The First Circuit affirmed, holding (1) the district court properly denied Defendant’s motion to suppress and did not abuse its discretion in denying his motion to sever; and (2) Defendant’s sentence was substantively reasonable. View "United States v. Azor" on Justia Law

The First Circuit affirmed the district court’s denials of Defendant’s motions for suppression and severance and declined to vacate Defendant’s sentence.Defendant pled guilty to crimes related to the distribution of drugs. Defendant filed a motion to suppress evidence seized as a result of a stop and search of a taxi and also filed a motion to sever his trial from that of his codefendants and for relief from prejudicial joinder. The district court denied both motions after hearings. The sentencing judge sentenced Defendant to a term of imprisonment of thirty-six months, followed by thirty-six months of supervised release. The First Circuit affirmed, holding (1) the district court properly denied Defendant’s motion to suppress and did not abuse its discretion in denying his motion to sever; and (2) Defendant’s sentence was substantively reasonable. View "United States v. Azor" on Justia Law

The First Circuit affirmed Defendant’s conviction for being a felon in possession of ammunition but vacated his sentence. On appeal, Defendant argued that the district court erred in denying his motion to suppress evidence obtained from a warrantless search of the vehicle he was driving and that the district court erred in finding that he qualified for a mandatory minimum sentence under the Armed Career Criminal Act (ACCA). The First Circuit held (1) under the circumstances of this case, the automobile exception to the Fourth Amendment’s warrant requirement applied, and the search of the vehicle Defendant was driving was reasonable; and (2) Defendant was improperly sentenced as an armed career criminal. The court remanded the case for resentencing with the ACCA enhancement. View "United States v. Kennedy" on Justia Law

The First Circuit affirmed Defendant’s conviction for being a felon in possession of ammunition but vacated his sentence. On appeal, Defendant argued that the district court erred in denying his motion to suppress evidence obtained from a warrantless search of the vehicle he was driving and that the district court erred in finding that he qualified for a mandatory minimum sentence under the Armed Career Criminal Act (ACCA). The First Circuit held (1) under the circumstances of this case, the automobile exception to the Fourth Amendment’s warrant requirement applied, and the search of the vehicle Defendant was driving was reasonable; and (2) Defendant was improperly sentenced as an armed career criminal. The court remanded the case for resentencing with the ACCA enhancement. View "United States v. Kennedy" on Justia Law

The First Circuit affirmed the district court's dismissal of a complaint filed by unions representing the firefighters and police officers employed by the City of Cranston. The Unions filed a complaint claiming that legislation modifying various state-run pension plans for government employees, including a plan that covered municipal firefighters and police officers, unconstitutionally repudiated contractual obligations owed to the City employees. The district court dismissed the complaint. The First Circuit affirmed, holding (1) the complaint failed to allege that the legislation at issue unconstitutionally impaired any contractual rights of the Unions' members; (2) federal court was not the proper forum to litigate the Unions' undeveloped claims that the City was failing to abide by the terms of its ordinances or collective bargaining agreements; and (3) this lawsuit provided no opportunity to challenge the terms of a settlement by other parties in another lawsuit. View "Cranston Firefighters, IAFF v. Raimondo" on Justia Law

The First Circuit affirmed the decision of the district court granting the Rhode Island State Board of Election's motion for judgment on the pleadings with respect to Plaintiff's claims that his constitutional rights were violated by the manner in which his employment was brought to an end. The district court concluded that Plaintiff, a quondam employee of the Board, had not shown a deprivation of any constitutionally protected interest. The First Circuit affirmed, holding (1) Plaintiff failed to allege facts sufficient to show a constitutionally protected property interest in his job, and therefore, Plaintiff's loss-of-employment claim failed; and (2) Plaintiff failed to allege sufficient facts to make his claim that the Board stigmatized him plausible. View "Kando v. Rhode Island Board of Elections" on Justia Law