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

Plaintiff was a customer service employee at a Bank. When Plaintiff could no longer endure disparate treatment due to her bisexuality she received at the Bank, she stopped reporting to work. The Bank then terminated her for job abandonment. Thereafter, Plaintiff sued the Bank for employment discrimination under the Maine Human Rights Act (MHRA) and for defamation under Maine common law. The case was removed to federal court on the basis of diversity jurisdiction. The district court granted summary judgment to the Bank. The First Circuit (1) vacated summary judgment as to the wrongful termination and hostile work environment portions of Plaintiff’s discrimination claim, holding holding that a reasonable fact-finder could conclude that (i) the Bank’s explanation for firing Plaintiff was pretextual and that she was actually fired because of her sexual orientation, and (ii) Plaintiff had endured sufficiently pervasive harassment to alter the conditions of her employment; and (2) affirmed as to the balance of Plaintiff’s discrimination claim as well as on her defamation claims, holding that, in regards to these claims, the district court did not err in its judgment. View "Flood v. Bank of Am. Corp." on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to conspiracy to distribute controlled substances, possession of controlled substances with intent to distribute, and three specific offense counts reflecting particular crack sales. The district court sentenced Defendant to a bottom-of-the-range incarcerative term of 135 months. The First Circuit affirmed the convictions and sentence, holding (1) Defendant was adequately apprised of the nature of the charges, and his guilty plea was knowing and voluntary; (2) the district court did not err in enhancing Defendant’s offense level on the ground that he maintained an apartment as a stash house; (3) the district court did not err in selecting Defendant’s criminal history category; (4) Defendant’s ineffective assistance of counsel claim was not properly before the Court; and (5) Defendant’s additional assignments of error were without merit. View "United States v. Jones" on Justia Law

Plaintiff, the former head chef at the Villa Cofresi Hotel, was at least forty years old at the time he was suspended and then fired. Plaintiff filed suit in federal court against the Hotel and its general manager under the Age Discrimination in Employment Act and Puerto Rico employment law, alleging that he was fired because of his age and in retaliation for his efforts to assert his rights against this discrimination. The district court granted summary judgment for the defendants on both the federal age discrimination and retaliation claims. The First Circuit vacated the judgment of the district court, holding (1) Plaintiff put forth a sufficient prima facie case of age discrimination to survive summary judgment; (2) there is a triable issue of fact as to whether the defendants’ stated grounds for firing Plaintiff were in fact a pretext for age discrimination; (3) in regard to Plaintiff’s retaliation claim, the record gives rise to competing plausible inferences from which a rational jury could find for Plaintiff; and (4) the dismissal of Plaintiff’s pendent state law claims must also be vacated. Remanded. View "Soto-Feliciano v. Villa Cofresi Hotels, Inc." on Justia Law

Three criminal defendants (“Defendants”) were indicted and convicted for conspiracy to import cocaine. Defendants appealed their convictions and sentences. The First Circuit affirmed the judgment of the district court, holding that the district court (1) did not err in denying Defendants’ motions for judgment of acquittal; (2) did not err in determining cocaine quantity at sentencing; (3) did not abuse its discretion in fashioning Defendants’ sentences; (4) did not violate Defendants’ right to a public trial; and (5) did not err in applying a two-level sentencing enhancement for the foreseeable presence of a firearm. The Court nevertheless remanded to the district court so that it may consider a sentencing reduction in accordance with the newly-promulgated Amendment 782 to the United States Sentencing Guidelines. View "United States v. Alejandro-Montanez" on Justia Law

Sterling Suffolk Racecourse, LLC (SSR) applied for a license to place a casino in certain areas of Massachusetts. Caesars Entertainment Corporation and three Massachusetts affiliates (collectively, Caesars) were the proposed operators of the casino. The Massachusetts Gaming Commission issued an investigatory report concluding that Caesars was unsuitable as an operator, which caused Caesars to accede to SSR’s request that it withdraw from their contractual relationship. Caesars brought this action under 28 U.S.C. 1983 against certain Commission officials in their individual and official capacities and also brought a state law claim subject to supplemental jurisdiction. The district court dismissed the federal claims under Fed. R. Civ. P. 12(b)(6) as beyond the scope of federal affordable relief and dismissed the state law claim as standing alone. The First Circuit affirmed, holding (1) because Caesars alleged no cognizable protected property interest, its Fifth and Fourteenth Amendment due process claims were correctly dismissed for failure to state a claim; and (2) Caesars’ class-of-one Fourteenth Amendment equal protection claim could not be recognized against a state actor given the breadth of discretion provided by the Massachusetts casino licensing statute. View "Caesars Mass. Dev. Co., LLC v. Crosby" on Justia Law

After a jury trial, Petitioner was found guilty of armed robbery and armed burglary. The state trial judge found Petitioner to be a habitual offender and sentenced him to life in prison. On appeal, the state appellate court determined (1) the victim’s pretrial identification of Petitioner’s voice on a recorded telephone call was not tainted by an improperly suggestive police procedure; and (2) Petitioner’s post-Miranda statements to the police were made voluntarily. Petitioner later sought federal habeas relief, alleging that his due process rights under the Fifth and Fourteenth Amendments were violated. The district court denied the petition. The First Circuit affirmed, holding (1) the state court’s decision that the pretrial identification of Petitioner’s voice was sufficiently reliable for the jury’s consideration was not the result of “extreme malfunction” sufficient to warrant relief under 28 U.S.C. 2254; and (2) the state court’s decision on voluntariness was objectively reasonable.. View "Cooper v. Bergeron" on Justia Law

After a jury trial, Appellant was convicted of five drug-related counts and one firearm-related count arising from his role in leading a conspiracy to distribute drugs in Puerto Rico public housing projects. The district court sentenced Appellant to concurrent terms of life imprisonment on all six counts. The First Circuit affirmed Appellant’s convictions on all counts and his life sentence on the five drug counts but remanded for a modified sentence on the firearm count, holding (1) the prosecutor did not engage in misconduct warranting a new trial; (2) the trial court did not err in its evidentiary rulings; (3) the district court erred in failing to make an individualized drug quantity finding, but the error did not require reversal on plain error review; and (4) the life sentence on the firearm count exceeded the applicable statutory maximum. View "United States v. Vazquez-Larrauri" on Justia Law

Defendant, a baseball coach, was convicted of three counts of sexual exploitation of children and one count of possession of child pornography. The district court sentenced Defendant to 480 months in prison. The First Circuit affirmed Defendant’s conviction and sentence in all respects, holding (1) the district court did not err in finding that the search warrant supplied a nexus to the place being searched; (2) the district court did not abuse its discretion in admitting testimony of uncharged child molestation; (3) Defendant’s argument that the Commerce Clause cannot support application to Defendant of the federal criminal statutes under which he was indicted was without merit in light of the Court’s earlier decision United States v. Burdulis; and (4) Defendant’s sentence was not substantively unreasonable. View "United States v. Joubert" on Justia Law

Rosaura Building Corp. (“Rosaura”) filed a lease contract petition form offering its building as property for Head Start classrooms. The Mayor of the Municipality of Mayguez rejected the contract. Rosaura brought a civil rights claim for equitable relief and damages pursuant to 42 U.S.C. 1983 against the Mayor and the municipal government (collectively, “Defendants”), claiming that Defendants’ rejection of the contract was solely motivated by Rosaura’s political beliefs. The district court granted summary judgment in favor of Defendants. The First Circuit affirmed, holding that the district court (1) did not err in granting the dismissal of the claims against the Municipality, as there was no practical effect in dismissing the claims against the municipal government where a mayor’s “employment decisions ipso facto” constitute the official policy of the municipality; and (2) did not err in dismissing the claims against the Mayor in his official capacity, as Rosaura failed to state a First Amendment retaliation cause of action and failed to state an equal protection claim by not alleging what protected activity it exercised and was a substantial motivating factor in bringing about the Mayor’s purported retaliation. View "Rosaura Building Corp. v. Municipality of Mayaguez" on Justia Law

Appellant, a student at Brown University, was suspended for three semesters after a number of students and staff submitted complaints regarding his behavior. Appellant filed an eleven-count complaint in the district court of Rhode Island against the University, numerous individuals associated with the University, and its police department (collectively, Appellees), alleging, among other claims, that Appellees’ conduct during his disciplinary proceeding and during his removal from campus violated his constitutional rights and state law. The district court entered judgment in favor of Appellees. The First Circuit affirmed, holding that the district court did not err by (1) finding that the University was not a state actor subject to federal jurisdiction under 42 U.S.C. 1983; (2) granting Appellees’ motion to amend their answer to include a statute of limitations defense; and (3) disposing of Appellant’s claims on Appellees’ motions to dismiss and for summary judgment, as the Rhode Island tolling statute did not toll Appellant’s claims. View "Klunder v. Brown University" on Justia Law