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

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

After a jury trial, Petitioner was convicted in state court of murder in the first degree. The Massachusetts Supreme Judicial Court affirmed the conviction. Petitioner subsequently filed several motions for a new trial in state court without success. Petitioner later filed a petition for habeas corpus relief in federal district court, asserting numerous instances of ineffective assistance of counsel at both trial and postconviction proceedings as well as prosecutorial misconduct. The district court denied the motion, concluding that all of Petitioner’s claims had been procedurally defaulted. The First Circuit affirmed, holding (1) the district court did not err in holding that Petitioner’s claims of ineffective assistance of trial counsel and prosecutorial misconduct had been procedurally defaulted; and (2) the claim of ineffective assistance of postconviction counsel was not procedurally defaulted, but it was otherwise barred by 28 U.S.C. 2254(i). View "Lee v. Corsini" on Justia Law

Plaintiff, a town official for the town of Raymond, claimed that Michael Reynolds, a fellow town official, told the sheriff’s department that Plaintiff had driven while intoxicated, that the reports were false, and the false statements damaged his reputation. Plaintiff brought suit in state superior court, alleging state law claims for defamation and false light invasion of privacy, as well as federal claims under 42 U.S.C. 1983. The case was removed to federal court on the basis of the federal claims. The district court dismissed the federal claims and proceeded to resolve the state law claims. The First Circuit (1) affirmed the dismissal of the federal claim; and (2) vacated the dismissal of Plaintiff’s state law claims as to Reynolds and remanded the claims to state court, holding the state law claims involved resolution of a potential conflict between Maine’s Anti-SLAPP statute and Maine’s Constitution, a conflict that “is best resolved by the Maine courts.” View "Desjardins v. Willard" on Justia Law

Defendant, a former officer with the Puerto Rico Police Department, was charged with multiple drug-related and firearm-related charges for his participation in fifteen drug transactions that were part of an FBI sting operation. The jury acquitted Defendant of all the firearm charges and the drug charges arising out of the first drug transaction and convicted him on all other counts. The First Circuit affirmed, holding that the district court did not err by refusing to give jury instructions on entrapment and duress; denying Defendant’s proffered instructions on impeachment of witnesses for prior convictions; and denying Defendant’s motion for a new trial based on the trial court’s rulings and interjections during closing arguments. Lastly, the government’s remarks during its rebuttal argument did not render the trial unfair. View "United States v. Gonzalez-Perez" on Justia Law

Plaintiffs in this case were fourteen maintenance, domestic, and warehouse workers who were abruptly fired from the Puerto Rico executive mansion shortly after Luis Fortuño-Burset (“Fortuño”), the newly-elected governor, took office. In 2009, Plaintiffs sued Fortuño, Fortuño’s wife, and two executive staffers, alleging that they were terminated in violation of the First Amendment because they affiliated with Fortuño’s rival political parties. The district court entered summary judgment dismissing Plaintiffs’ political discrimination claim. The First Circuit affirmed both the summary judgment dismissals of Plaintiffs’ First Amendment claim and the denial of their motion to reconsider, holding (1) the record lacked sufficient evidence that Defendants were aware of Plaintiffs’ political affiliations, and thus, Plaintiffs’ First Amendment claim failed on that ground; and (2) the district court did not err in denying Plaintiffs’ request to reconsider the judgment. View "Ocasio-Hernandez v. Fortuno-Burset" on Justia Law

Appellant had leased the same apartment at a San Juan, Puerto Rico housing cooperative (Cooperative) for several years. While living at the cooperative, Appellant received benefits under the Section 8 federal housing assistance program, which enabled her to pay her rent. When the Housing Finance Authority concluded that Appellant’s apartment unit was “over-housed” for Section 8 purposes, the Cooperative informed Appellant that she would have to pay market-rate rent without the Section 8 assistance. Appellant subsequently submitted a request to the Cooperative for reasonable accommodation on account of her disability, stating that she could not move to a different unit without compromising her health. The Cooperative denied Appellant’s request. After filing an administrative complaint without success, Appellant filed suit in federal court, alleging that the Cooperative had violated the Fair Housing Act by failing to provide the requested accommodation, by engaging in a pattern of discriminatory actions against her, and by retaliating against her because she had recently prevailed in a separate HUD proceeding against the Cooperative. The district court (1) found in the defendants’ favor regarding the reasonable accommodation and disparate treatment claims; and (2) concluded that it lacked jurisdiction to decide the retaliation claim. The First Circuit (1) affirmed the district court’s grant of summary judgment on the reasonable accommodation and disparate treatment claims; and (2) reversed the district court’s decision to dismiss Appellant’s retaliation claim, holding that the district court had jurisdiction to decide this claim. View "Batista v. Cooperativa de Vivienda" on Justia Law

A jury found Appellant guilty of one count of possession with intent to distribute more than 500 grams of cocaine. Appellant was tried a second time on the drug trafficking charge after the First Circuit concluded that Appellant’s Sixth Amendment right to confrontation had been violated at his first trial. At retrial, a jury again found Appellant guilty of the drug possession charge. At sentencing, the district court treated Appellant as a career offender under the Sentencing Guidelines. The First Circuit affirmed the conviction but remanded for resentencing without the career offender enhancement, holding (1) the government’s delay in bringing the indictment did not violate Appellant’s due process rights; (2) the district court did not abuse its discretion in denying Appellant’s motion to dismiss the indictment for prosecutorial misconduct; (3) the court did not commit reversible error in its evidentiary rulings or in instructing the jury; (4) the court’s refusal to continue Appellant’s sentencing hearing, if error, was harmless; and (5) in designating Appellant as a career offender, the district court relied on a predicate offense that does not qualify for that purpose. View "United States v. Ramos-Gonzalez" on Justia Law