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

Plaintiffs held licenses from the Puerto Rico Treasury Department (Treasury) authorizing them to own and operate “adult entertainment machines” (AEMs). Special Treasury task-force agents later seized AEMs belonging to Plaintiffs. Plaintiffs sued Defendants, the parties supposedly responsible for damages, in a federal district court under 42 U.S.C. 1983, alleging that the inspections and confiscations of the AEMs violated their constitutional rights. Plaintiffs also asserted supplemental local-law claims mirroring their federal-law claims. The court granted Defendants summary judgment on the federal law claims and relinquished jurisdiction over the local-law claims. The First Circuit (1) vacated the summary judgment on the search-and-seizure and local-law claims, holding that the case must be remanded so the district court can address timing and scope matters in the qualified-immunity context; and (2) affirmed in all other respects. View "Rivera-Corraliza v. Puig-Morales" on Justia Law

In Sprint Commc’ns, Inc. v. Jacobs, the Supreme Court revisited the doctrine of abstention enunciated in Younger v. Harris. That doctrine requires federal courts, in the absence of extraordinary circumstances, to refrain from interfering with certain state proceedings. In this case, David Knight, an employee of Sirva Relocation, LLC, filed a charge of discrimination with the Massachusetts Commission Against Discrimination (MCAD) alleging that Sirva and Aetna Life Insurance Company (together, Appellants) had discriminated against him on the basis of disability in violation of Mass. Gen. Laws ch. 151B and the Americans with Disabilities Act (ADA). Appellants filed a federal complaint against the Commonwealth of Massachusetts, the MCAD, its commissioners, and Knight, asking the court to enjoin the MCAD proceeding on the basis that ERISA preempted the chapter 151B claim. The MCAD and Knight moved to dismiss the complaint, entreating the district court to abstain. While the case was pending, the Supreme Court decided Sprint. The district court dismissed the federal court action, concluding that Younger abstention was appropriate in this case. The First Circuit affirmed the district court’s decision to abstain and further clarified its own case law concerning the exception to the Younger doctrine for facially conclusive claims of preemption. View "Sirva Relocation, LLC v. Golar Richie" on Justia Law

Plaintiff, a naturalized United States citizen, alleged that, in 2009, she was unlawfully detained in violation of her Fourth And Fifth Amendment rights when she was imprisoned for 24 hours pursuant to an immigration detainer so that U.S. Immigration and Customs Enforcement (ICE) agents could investigate her immigration status. Plaintiff named as defendants three ICE agents - defendants Edward Donaghy, Bruce Chadbourne, and David Riccio. Defendants filed motions for summary judgment and to dismiss, all on the basis of qualified immunity. The district court denied Defendants’ motions. The First Circuit (1) affirmed the district court’s denial of qualified immunity on Plaintiff’s Fourth Amendment claim against Donaghy on the ground that the law was clearly established in 2009 that an ICE agent was required to have probable cause before issuing a detainer; (2) dismissed Donaghy’s appeal on his Fourth Amendment argument regarding the circumstances surrounding the issuance of the detainer and his Fifth Amendment equal protection argument for want of jurisdiction because these arguments did not present pure issues of law; and (3) affirmed the district court’s denial of qualified immunity on Morales’s Fourth Amendment supervisory liability claim against Chadbourne and Riccio, as Plaintiff had sufficiently alleged that Chadbourne and Riccio violated a clearly established Fourth Amendment right. View "Morales v. Chadbourne" on Justia Law

Plaintiff, a sales representative for Wyndham Vacation Resorts, Inc., brought this claim of retaliation under Title VII of the Civil Rights Act of 1964 alleging that her supervisor subjected her to a hostile work environment on the basis of race and national origin and that Wyndham retaliated against her for complaining about the supervisor’s conduct. The magistrate judge recommended that the district court grant summary judgment for Wyndham. The district court summarily affirmed the recommendation. The First Circuit affirmed, holding that Plaintiff did not present sufficient evidence to establish a retaliation claim under Title VII. View "Planadeball v. Wyndham Vacation Resorts, Inc." on Justia Law

Plaintiff was a supervisor at the Programmatic Area of the Department of Education’s Special Education Center in Bayamon when the New Progressive Party came to power in Puerto Rico. Plaintiff claimed that, as a result of his membership in the Popular Democratic Party, he was subject to impermissible political discrimination when he was reassigned to a new position, a diminution of his supervisory responsibilities, and other adverse employment actions. The district court granted summary judgment for Defendants. The First Circuit affirmed, holding (1) Plaintiff failed to generate facts that would allow a rational jury to conclude that Plaintiff’s reassignment was an act of political discrimination or that his job responsibilities were diminished in his new position; and (2) Plaintiff’s remaining allegations of workplace discrimination were insufficient to constitute adverse employment actions. View "Santiago-Diaz v. Rivera-Rivera" on Justia Law

Plaintiff, a Maine dairy farmer, had a business dispute with Defendant, his neighbor, and the former Commissioner of the Maine Department of Agriculture (DOA). Soon after taking office, the Commissioner recused himself from regulatory matters involving Plaintiff. The DOA eventually took four adverse regulatory actions against Plaintiff, including the action of ceasing to protect Plaintiff from the regulatory authority of the Maine Department of Environmental Protection (DEP). The DEP then issued several notices of violation of Plaintiff’s license conditions. As a result, the federal Environmental Protection Agency (EPA) began administrative and judicial proceedings against Plaintiff that resulted in Plaintiff losing his farm. Plaintiff brought this suit for damages against Defendant, claiming that Defendant had violated his First Amendment rights through the adverse actions taken by the DOA. The district court awarded summary judgment against Plaintiff. The First Circuit reversed in part, holding (1) summary judgment was correctly granted with respect tot he three adverse regulatory actions that the DOA was alleged to have taken after the Commissioner’s purported recusal; but (2) there was a genuine issue of material fact with respect to whether the Commissioner’s retaliatory intent was a substantial or motivating factor in the one alleged adverse action that occurred prior to the recusal. Remanded. View "McCue v. Bradstreet" on Justia Law

Appellant was indicted on one count of sexual exploitation of children and one count of transporting child pornography. The district court denied Appellant’s request for a Franks hearing, as well as Appellant’s motion to suppress the evidence seized during the search of Appellant’s bedroom. Appellant pleaded guilty, specifically reserving his right to appeal the district court’s rulings. The First Circuit affirmed, holding that the district court (1) did not err in denying Appellant’s request for a Franks hearing where Appellant failed to make a preliminary showing that certain omitted information from an FBI agent’s affidavit would have negated the magistrate judge’s probable cause finding; and (2) did not err in concluding that the warrant was sufficiently particular and in thus denying Appellant’s motion to suppress the warrant. View "United States v. McLellan" on Justia Law

Appellant was charged with possessing an unregistered shotgun with a barrel measuring less than eighteen inches. Appellant moved to suppress the sawed-off shotgun and his statements about it, arguing that his relinquishment of the sawed-off shotgun to police officers was coerced and that his subsequent admissions were fruit of the poisonous tree. The district court denied the motion to suppress. The First Circuit affirmed the denial of the motion to suppress, holding that the district court did not err in denying Appellant’s motion to suppress where the officers were lawfully in Appellant’s home by virtue of his voluntary consent and, once they had served the orders there, they were entitled to seize firearms, such as the sawed-off shotgun, that were in plain sight. View "United States v. Gamache" on Justia Law

Plaintiffs, on their own behalf and on behalf of their minor children Valerie and Jesus, brought an action against a Puerto Rico Police Department (PRPD) superintendent, a PRPD regional director, a PRPD district commander (collectively, the Supervisory Defendants), and a PRPD police officer, alleging that Valerie’s Fourth, Fifth, Ninth, and Fourteenth Amendment rights were violated when she was arrested and subjected to excessive force during an incident at a high school. The district court struck Plaintiffs’ expert report, granted summary judgment in favor of the supervisory defendants, and dismissed with prejudice the claims against the PRPD officer. The First Circuit reversed the dismissal of Plaintiffs’ Fourth Amendment unconstitutional arrest claim against the police officer and remanded for a new trial, and otherwise affirmed, holding (1) the district court did not err in excluding the expert report; (2) the district court correctly concluded that Defendants were entitled to judgment as a matter of law on Plaintiffs’ excessive force claim; but (3) the district court erred in dismissing Plaintiffs’ Fourth Amendment unconstitutional arrest claim against the police officer, as Plaintiffs provided sufficient evidence to establish a genuine dispute over key material facts. View "Fernandez-Salicrup v. Figueroa-Sancha" on Justia Law

After a three-month jury trial, the five defendants in this case were convicted as members of an extended drug conspiracy. When voir dire was conducted in this case, Defendants’ family members and friends were excluded from the courtroom purportedly based on the Puerto Rico court’s “longstanding district policy” of not allowing the public into the courtroom during voir dire. Defendants appealed, arguing that they were denied their right to a public trial when their family members were excluded from the courtroom during voir dire. The First Circuit vacated Defendants’ convictions, holding that the complete exclusion of the public from jury selection was a structural error that infringed on Defendants’ Sixth Amendment rights. Remanded for a new trial. View "United States v. Negron-Sostre" on Justia Law