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

This putative class action was brought on behalf of ten foster children in the custody of the Rhode Island Department of Children, Youth and Families (DCYF). The complaint alleged that DCYF’s failings exposed foster children in its custody to an unreasonable risk of harm and that the State had failed to comply in various respects with the Adoption Assistance and Child Welfare Act. After much skirmishing between the parties and delay during discovery, trial commenced. At that point, the claims of all but two of the named plaintiffs had been rendered moot through aging or adoption. The district court concluded (1) Plaintiffs had presented insufficient evidence to establish that DCYF’s policies and customs had either harmed them or exposed them to an unreasonable risk of harm, and (2) Plaintiffs failed to carry their burden of proof with respect to their statutory causes of action. Plaintiffs appealed, claiming myriad errors relating to pretrial proceedings. The First Circuit vacated the judgment, holding that the district court abused its discretion when it, in two case management orders, denied Plaintiffs’ counsel access to their own clients and prevented Plaintiffs from seeking plainly relevant discovery. View "Danny B. v. Raimondo" on Justia Law

A police detective applied for a warrant to search Defendant’s home. The warrant application was supported by an affidavit in which the detective attested that he had probable cause to believe Defendant was hiding marijuana in his residence based on information the detective received from a confidential informant. A state justice of the peace signed off on the warrant. During a search of Defendant’s home, police found marijuana and an illegal gun. Defendant was subsequently indicted on drug and firearm charges. Defendant filed a motion to suppress the seized evidence and sought an evidentiary hearing to challenge the detective’s credibility. The magistrate judge denied the motion without an evidentiary hearing. The First Circuit affirmed, holding that the trial court did not err by denying Defendant the opportunity to challenge the detective’s affidavit at a formal Franks hearing. View "United States v. Graf" on Justia Law

Petitioner was convicted on several state charges, including unlawful possession of a firearm. The Massachusetts Supreme Judicial Court (SJC) affirmed. The SJC rejected Petitioner’s due process challenge to the Commonwealth’s failure to present evidence that he lacked a firearms license, concluding that the accused of unlawful possession of a firearm has the burden of producing evidence of a license as an affirmative defense. Petitioner sought federal habeas relief, which the district court denied. The First Circuit affirmed, holding (1) the SJC’s conclusion that this state criminal procedure comports with federal due process does not conflict with clearly established Supreme Court precedent; (2) Petitioner’s Second Amendment and related Equal Protection claims provide no basis for disturbing Petitioner’s state firearms convictions; and (3) Petitioner’s Sixth Amendment ineffective assistance of counsel claim is waived. View "Powell v. Tompkins" on Justia Law

An unidentified caller informed law enforcement officers that, as he was driving, he had observed a pistol being openly passed between the passengers of the the car in front of him. Acting on the information, police officers ordered Defendant to get out of a parked car and frisked him. The officers discovered a loaded pistol in Defendant’s possession. Defendant subsequently pled guilty to possession of a firearm by a prohibited person. Defendant appealed the denial of his motion to suppress the evidence of the firearm from the frisk, arguing that the information provided by the anonymous caller was not sufficiently reliable to provide the officers with the reasonable suspicion. The First Circuit affirmed, holding that the report from the unidentified caller was sufficiently reliable to create reasonable suspicion of criminal activity under Puerto Rico law, thus justifying the police officers’ decision to stop and frisk the vehicle’s occupants. View "United States v. Aviles-Vega" on Justia Law

Defendant pleaded guilty to two counts of drug-trafficking and one count of money laundering. Defendant was sentenced to a 168-month term of imprisonment, a sentence that was at the bottom of his Guidelines imprisonment range. The First Circuit affirmed, holding (1) the district court did not violate Defendant’s due process rights where it allowed Defendant to present evidence of his alleged minor role in the crimes, allowed Defendant to testify regarding the alleged coercion he felt from his co-defendants, and cross-examined Defendant as to whether he faced retaliation after he left the conspiracy; (2) Defendant was not entitled to a minor role adjustment; (3) the district court did not err by declining to award a downward departure for coercion and duress; and (4) Defendant’s sentence was reasonable. View "United States v. Torres-Landrua" on Justia Law

After a jury trial in a Massachusetts state court, Petitioner was found guilty of operating a motor vehicle under the influence of alcohol, third offense, and negligent operation of a motor vehicle. Petitioner appealed, asserting that the prosecutor’s comments during cross-examination and closing argument constituted unconstitutionally forbidden commentary on his post-Miranda silence. The Massachusetts Appeals Court (MAC) affirmed, and the Supreme Judicial Court summarily denied Petitioner’s application for further appellate review. Thereafter, Petitioner sought habeas relief in the federal district court, arguing that the MAC’s decision was contrary to or an unreasonable application of clearly established federal law because the prosecutor’s questions and comments on his post-Miranda silence contravened Doyle v. Ohio and, therefore, abridged his due process rights. The district court denied habeas relief. The First Circuit affirmed, holding that even if the MAC misapplied the Doyle rule and a Doyle error occurred, any comment on Petitioner’s silence was harmless when considered in the context of the trial as a whole. View "Cronin v. Comm’r of Probation" on Justia Law

Plaintiff was a life insurance agent with the New Life Insurance Company for more than forty years. In 2009, Plaintiff was informed that his agent contract would be terminated. In 2012 and 2014, Plaintiff filed two separate suits against New York Life, alleging, in addition to several common-law claims, age discrimination under both Massachusetts law and the federal Age Discrimination in Employment Act. The U.S. District Court of the District of Massachusetts consolidated the two cases. The district court then granted summary judgment for New York Life on all claims. The First Circuit affirmed, holding (1) Plaintiff’s state law age discrimination claims were time barred; (2) no reasonable jury could conclude that New York Life engaged in age discrimination under federal law in terminating his agent contract; and (3) no reasonable jury could conclude that the termination breached Plaintiff’s contract with New York Life or violated any of Plaintiff’s common law rights. View "Santangelo v. New York Life Ins. Co." on Justia Law

When the government of Puerto Rico changed hands after the November 2012 General Elections, the government passed laws to “reorganize” different agencies. One of those laws was Law 180-2013, which made the position of the Chair of the Puerto Rico Industrial Commission (PRIC) freely removable. The Governor subsequently removed Plaintiff, the then-Chair, and appointed a replacement. Plaintiff brought suit against the Governor and the new PRIC Chair, alleging violations of his First, Fifth, and Fourteenth Amendment constitutional rights and violations of Puerto Rico constitutional and statutory law. The district court found that Plaintiff was likely to succeed on his due process claim and issued a preliminary injunction that vacated the appointment of his replacement and reinstated Plaintiff. The First Circuit remanded with instructions to vacate the preliminary injunction and to dismiss without prejudice Plaintiff’s due process claim, holding that Plaintiff was not entitled to federal injunctive relief for his due process claim given the conceded adequacy of Commonwealth remedies. View "Torres-Rivera v. Lozada-Crespo" on Justia Law

In 2012, Defendant pleaded guilty to one count of failing to register as a sex offender. Defendant was sentenced to twenty-one months in prison and seven years of supervised release. The terms of Defendant’s supervised release included a series of special conditions prohibiting him from contact with minors and requiring him to undergo sex offender treatment. Defendant sought to vacate his conviction or, alternatively, the special conditions. The First Circuit affirmed in part and reversed in part, holding (1) a waiver of appeal barred Defendant’s appeal of his conviction as well as his appeal of most of the special conditions; but (2) in order to avoid a miscarriage of justice, the Court declined to enforce the waiver as to Defendant’s appeal of the conditions that would prevent him from having contact with or residing with his son or other minors, as these conditions would deprive Defendant of far more liberty than was reasonably necessary. Remanded. View "United States v. Del Valle-Cruz" on Justia Law

Appellant, an inmate at the Bristol House of Correction, filed this action pursuant to 42 U.S.C. 1983 against Appellees, both of whom were staff nurses at the correctional institution, alleging that the medical treatment he received from Appellees for injuries resulting from a fight with several correctional officers violated his Eighth and Fourteenth Amendment rights because Appellees exhibited “deliberate indifference” to his serious medical needs. The district court granted summary judgment in favor of Appellees and dismissed the section 1983 action. The First Circuit reversed and remanded, holding that this case presented triable issues of fact to be resolved by fact-finders. View "Perry v. Roy" on Justia Law