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

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

Petitioner was convicted of a felony requiring his removal. The Board of Immigration Appeals (BIA) affirmed an order that Petitioner be removed. Petitioner petitioned for review, arguing that because Padilla v. Kentucky described deportation as a “penalty,” his removal violated the Eighth Amendment’s prohibition on cruel and unusual punishment or related constitutional protections unless a court conducted an individual assessment to determine whether his order of removal was a proportional punishment relative to his underlying criminal conviction. The First Circuit denied Petitioner’s petition for review, holding that Padilla has not signaled a break from long-settled law that removal operates simply as “a refusal by the government to harbor persons whom it does not want,” not as a punishment within the meaning of the Constitution intended to acutely sanction a noncitizen for his underlying criminal conviction. View "Hinds v. Holder" on Justia Law

Plaintiffs, twenty graduates from medical schools outside of the United States, failed the Puerto Rico Medical Licensing Examination (the PRMLE), which made them ineligible to receive a medical license in Puerto Rico. Plaintiffs filed this 42 U.S.C. 1983 action requesting injunctive relief and damages, arguing that the Puerto Rico Board of Medical Licensure and Discipline and eight of its officers (collectively, Defendants), in their official and individual capacities, violated Plaintiffs’ due process and equal protection rights by imposing an arbitrary passing score in the PRMLE. The district court granted Defendants’ motion to dismiss. The First Circuit affirmed, holding that there was no plausible basis for a claim of relief in Plaintiffs’ claims. View "Mulero-Carrillo v. Roman-Hernandez" on Justia Law

At 4 a.m. one night, Plaintiff broke into his estranged wife’s apartment to talk about their relationship. The woman reported the break-in and provided a description of the car Plaintiff was driving. Defendant, a police officer, began to follow Plaintiff. The pursuit led to a tussle, which led to Defendant firing two shots in Plaintiff’s direction. Plaintiff later filed suit against Defendant, alleging that Defendant had violated his Fourth Amendment rights and committed common law assault. The district court awarded summary judgment to Defendant on the grounds of qualified immunity and discretion act immunity. The Supreme Court affirmed, holding that Defendant was entitled to qualified immunity. View "Mitchell v. Miller" on Justia Law

In 2007, Petitioner was convicted in a Massachusetts state court of living off or sharing the earnings of a minor prostitute. In 2013, Petitioner filed a petition for a writ of habeas corpus pursuant to 28 U.S.C. 2254 in federal court seeking to invalidate his conviction on a number of grounds. The district court found against Petitioner on every claim and ordered the petition dismissed. The First Circuit affirmed the district court’s denial of Petitioner’s habeas petition, holding (1) Petitioner’s ineffective assistance claim failed on the prejudice prong of the Strickland v. Washington standard; (2) the evidence was sufficient to support the conviction; and (3) Petitioner’s final claim was waived. View "Logan v. Gelb" on Justia Law