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

Plaintiff filed this action alleging that she was stripped of various job duties and eventually terminated from her job at the Puerto Rico Highway and Transportation Authority due to her affiliation with the Popular Democratic Party. The district court granted summary judgment in favor of Defendants on Plaintiff’s First Amendment political discrimination claims, concluding that there was insufficient evidence that the stripping of Plaintiff’s job functions constituted adverse employment actions, and absent any political discrimination, Plaintiff would have in any event been terminated for nondiscriminatory reasons. The First Circuit reversed, holding (1) Plaintiff made out a prima facie case of political discrimination; and (2) a genuine dispute existed as to whether Defendants would have fired Plaintiff regardless of her political affiliation. Remanded. View "Reyes-Orta v. P. R. Highway and Transp. Auth." on Justia Law

Copia Communications, LLC, a Massachusetts company, brought this action in federal district court in Massachusetts against Seawind Key Investments, Limited, a Jamaican resort operator, and Seawind’s alleged alter-ego, AMResorts, LP, a Pennsylvania limited partnership, alleging breach of contract. The subject contract was proposed and executed in Jamaica, performance on the contract occurred almost exclusively in Jamaica, and the contract was governed by the laws of Jamaica. Both defendants, neither of which operated any business or had any corporate presence in Massachusetts, moved to dismiss, arguing lack of personal jurisdiction and forum non conveniens. The district court dismissed the case without prejudice, finding that it lacked personal jurisdiction over the defendants. The First Circuit affirmed, holding that the exercise of personal jurisdiction over the defendants was barred by the due process clause of the Fifth Amendment. View "Copia Commc’ns, LLC v. AMResorts, LP" on Justia Law

Plaintiff’s late father was formerly employed as a mechanic by the City of Boston. Plaintiff brought this lawsuit on behalf of her father’s estate, alleging that the City and her father’s supervisors discriminated against her father on the basis of race and retaliated against him by terminating his employment. Plaintiff’s federal claims appeared to arise under 42 U.S.C. 1981 and 1983. The district court dismissed Plaintiff’s complaint, concluding that Plaintiff had not pled facts sufficient to support her section 1983 claim and had failed to timely exhaust the administrative prerequisites necessary to bring suit on her section 1981 claim. The First Circuit (1) affirmed the dismissal of the section 1983 claim, holding that this claim was properly dismissed pursuant to Fed. R. Civ. P. 12(b)(6); but (2) reversed the dismissal of the section 1981 claim, holding that the district court erred by imposing an administrative exhaustion requirement where none exists. View "Buntin v. City of Boston" on Justia Law

In 2014, Perfect Puppy, Inc. signed a lease to use a City of East Providence building for a “Puppy Sales store.” Less than two months later, the East Providence city council formally passed an ordinance banning dog and cat sales. Perfect Puppy sued East Providence in state court. The case was removed to federal court on federal-question grounds. The district judge granted East Providence summary judgment on all claims except Perfect Puppy’s takings claim. As for any possible facial-takings challenge, the judge concluded that the claim lacked development. Noting that Perfect Puppy had not asked the state for compensation, the judge deemed the as-applied challenge unripe and remanded the suit to state court for lack of subject-matter jurisdiction. The First Circuit affirmed the judge’s handling of the facial-takings issue and dismissed Perfect Puppy’s appeal for lack of jurisdiction as to that part of the judge’s order remanding the as-applied claim to state court, holding (1) Perfect Puppy failed to bring a facial-takings challenge; and (2) the lack-of-jurisdiction ground for the remand of the as-applied challenge was colorable, which meant that the First Circuit lacked appellate jurisdiction to review the judge’s decision. View "Perfect Puppy, Inc. v. City of East Providence" on Justia Law

Appellant was indicted for second-degree murder and unlawful possession of a firearm. During jury selection for Appellant’s trial, the Massachusetts state prosecutor exercised peremptory challenge to strike three black men age twenty-five or under. The jury convicted Appellant, and he was sentenced to life imprisonment for murder. Appellant appealed, arguing that the prosecutor had improperly exercised peremptory challenges against young “men of color.” The appeals court affirmed. Appellant subsequently petitioned for a writ of habeas corpus in federal district court. The district court denied the petition, determining that the state court’s application of federal law was reasonable. The First Circuit remanded the case, concluding that Appellant had established a prima facie case of racial discrimination under step one of the framework established in Batson v. Kentucky. After an evidentiary hearing as to steps two and three of Batson, the district court ruled against Appellant on the final step of Batson. The First Circuit affirmed the district court’s denial of Appellant’s petition, holding that the district court did not abuse its discretion in concluding that Appellant had not proven that there was racial discrimination during jury selection. View "Sanchez v. Roden" on Justia Law

Plaintiff was formerly employed by the Civilian Health Promotion Services Program at Hanscom Air Force Base in Bedford, Massachusetts. After the government contractor that employed Plaintiff terminated her employment, Plaintiff filed this lawsuit against the government contractor that employed her, her supervisor, and several government agencies and officials that Plaintiff believed were involved in her termination. Plaintiff asserted a claim under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics for violation of her First Amendment rights and a claim of gender discrimination under Title VII. Plaintiff’s Bivens claims was dismissed, and summary judgment was granted against Plaintiff on her Title VII claim. The First Circuit affirmed, holding (1) Plaintiff’s Bivens claim failed to plausibly demonstrate her right to recover against any of the defendants it named, and therefore, its dismissal was proper; and (2) the entry of summary judgment against Plaintiff on her Title VII claim was proper. View "Casey v. Dep’t of Defense" on Justia Law

Defendant, Plaintiff’s co-worker at a mental health facility in Norton, Massachusetts, issued an order, pursuant to Mass. Gen. Laws ch. 123, 12, authorizing Plaintiff to be seized from her home and brought to a hospital for a psychiatric evaluation, certifying that there was a “very substantial risk” that Plaintiff would injure herself. Pursuant to that order, the police took Plaintiff from her home and drove her to the hospital. A doctor at the hospital determined that Plaintiff was lucid and released her. Plaintiff subsequently brought a 42 U.S.C. 1983 claim against Defendant. The district court dismissed Plaintiff’s claim for failure to state a claim that Defendant had violated Plaintiff’s federal constitutional rights. The First Circuit affirmed, holding that Plaintiff failed to state a plausible claim for relief. View "Durand v. Harpold" on Justia Law

After a jury trial, Defendant was convicted of the murder of his wife. Eight days later, Defendant was indicted by a federal grand jury on three counts of making false statements to a federal officer. One week later, a Puerto Rico Commonwealth court sentenced Defendant to 109 years’ imprisonment for the murder. Defendant moved to transfer the federal trial to another venue, arguing that the pretrial publicity about his murder conviction prevented a fair and impartial jury in Puerto Rico. The trial court overruled the motion to change venue. After a trial, the jury convicted Defendant of all three false-statement counts, but the court granted a motion of acquittal on two counts. The First Circuit reversed, holding that the district court abused its discretion by denying Defendant’s motion to change venue, as there was a significant risk that the level of prejudice permeating the trial was so high that Defendant could not possibly have received an impartial trial. Remanded. View "United States v. Casellas-Toro" on Justia Law

Plaintiff filed suit against officials at the University of Massachusetts at Dartmouth after the university had commenced termination proceedings against him, alleging, inter alia, claims under 42 U.S.C. 1983 for violations of his First and Fourteenth Amendment rights. Plaintiff then filed a second amended complaint along with an amended motion for preliminary injunction requesting that the termination proceedings be halted and Plaintiff be reinstated to his position. Defendants moved to dismiss the amended complaint. The district court granted in part and denied in part the motion to dismiss and sua sponte combined the motion for preliminary injunction with a trial on the merits. The university subsequently terminated Plaintiff. During the pendency of Plaintiff’s interlocutory appeal of the district court’s order combining the preliminary injunction hearing with the trial, the district court proceeded with the case. The First Circuit dismissed the appeal, holding that the Court had no jurisdiction over the underlying decision to consolidate the motion for preliminary injunction with trial. Therefore, the Court also lacked jurisdiction over the district court’s denials of Plaintiff’s motions to reconsider its order. View "Nwaubani v. Grossman" on Justia Law

After a jury trial, Appellant was convicted of transportation, receipt, and possession of child pornography. The First Circuit affirmed on appeal. Appellant later filed a petition for a writ of habeas corpus under 28 U.S.C. 2255 claiming that the jury selection process for his trial violated his Fifth Amendment right to be present and his Sixth Amendment right to a public trial. Appellant did not raise either the Fifth Amendment or the Sixth Amendment claim at trial or on direct appeal. The district court denied habeas relief. The First Circuit affirmed, holding that Appellant could not overcome his procedural default from not pursuing either his Fifth Amendment or Sixth Amendment claim at trial or on appeal. View "Wilder v. United States" on Justia Law