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

After a jury trial in 2007, Defendant was convicted of two drug trafficking counts. At sentencing, the sentencing judge made a drug quantity finding and increased the mandatory minimum sentence for each count. Defendant appealed, arguing that a jury must find beyond a reasonable doubt any fact leading to the imposition of a higher mandatory minimum sentence. The First Circuit affirmed. After Alleyne v. United States was decided, Defendant initiated a collateral attack on his sentence. The district court denied Defendant’s motion for habeas relief under 28 U.S.C. 2255. The First Circuit affirmed, holding that the rule announced in Alleyne does not apply retroactively to sentences challenged on an initial petition for collateral review. View "Butterworth v. United States" on Justia Law

Defendant, a Colombian national, was convicted of participating in a conspiracy to import cocaine to the United States. Prior to trial, Defendant moved to suppress an identification that he argued had been obtained by a highly suggestive means. The district court denied the motion, finding that the means used to obtain the identification was unduly suggestive but that the identification was still reliable enough to put to the jury. Defendant appealed, arguing, among other things, that the government’s use of the identification at trial violated his constitutional right to due process. The First Circuit affirmed, holding (1) the district court did not err in finding that the method of obtaining the identification was problematic but that there was reason enough to credit the identification to permit a jury to decide its worth; and (2) Defendant’s remaining allegations of error were without merit. View "United States v. Castro-Caicedo" on Justia Law

In 2011, a tornado ripped through the downtown area of the City of Springfield, Massachusetts and caused significant damage. City officials quickly determined that the South Commons Condominiums were among the properties that suffered substantial damage. The City hired a private company to demolish most of those buildings the next evening. The owners of the condos brought suit against the City, its officials, and the demolition company that took down the buildings, claiming violations of the owners’ procedural and substantive due process rights under 42 U.S.C. 1983, as well as various violations of Massachusetts state law. The district court dismissed the federal claims for failure to state a claim and dismissed the state claims without prejudice as an exercise of its discretion to deal with pendent claims. The Supreme Court affirmed, holding that when a city decides buildings are so damaged that they must be immediately demolished, and when the city does so pursuant to a state law that authorizes the use of summary procedure to respond to such an emergency, the remedy for any wrong, absent behavior that objectively “shocks the conscience,” must come from the remedies the state itself supplies rather than from a federal suit premised on the U.S. Constitution’s due process clause. View "South Commons Condo. Ass’n v. Charlie Arment Trucking, Inc." on Justia Law

Under current Transportation Security Administration (TSA) security protocols, some passengers cannot pass through some security checkpoints in U.S. airports without submitting to a standard pat-down, which includes security officials touching areas around the groin and breasts to look for concealed metallic and nonmetallic weapons. Plaintiff, whose job requires her to fly frequently, has had at least one metallic joint replacement and is often subject to the standard pat-down. After Plaintiff petitioned the TSA to change its protocols, without success, Plaintiff filed this action challenging the TSA’s security procedures, claiming that the standard pat-downs constitute an unreasonable search under the Fourth Amendment and violate federal disability discrimination law. The First Circuit denied Plaintiff’s petition asking that the Court set aside the decision of the TSA, holding (1) the TSA’s screening procedures do not violate the Fourth Amendment; and (2) the TSA’s refusal to implement the changes suggested by Plaintiff did not violate the Rehabilitation Act of 1973. View "Ruskai v. Pistole" on Justia Law

Rosana Claudio-de Leon (Claudio) and the University of the East of the Ana G. Mendez University System (SUAGM) entered into an employment contract that contained a forum selection clause precluding adjudication in federal court. Claudio, Luis F. Carrasquillo-Rivera, and the conjugal partnership Carrasquillo-Claudio (collectively, Appellants) filed suit against SUAGM in the district court, alleging, among other claims, pregnancy and gender discrimination. The district court dismissed Appellants’ Title VII pregnancy and gender discrimination claim and supplemental state law claims due to the forum selection clause. The First Circuit affirmed as modified, holding (1) the forum selection clause was applicable and enforceable; but (2) the district court should have dismissed the case without prejudice to permit Appellants to refile in the appropriate forum. Remanded. View "Claudio de-Leon v. Ayala" on Justia Law

Appellant was involved in a wide-ranging drug trafficking organization. After a trial, in which she was tried alone, Appellant was found guilty of conspiracy to possess with intent to distribute controlled substances and conspiracy to launder money. The district court sentenced Appellant to 121 months’ imprisonment as to each count, to be served concurrently. The First Circuit affirmed the convictions and sentence, holding (1) the evidence was sufficient to support the drug conspiracy conviction; (2) Appellant’s argument that the money laundering conviction should be vacated pursuant to United States v. Santos because the government failed to prove that the monies laundered were net profits of drug-trafficking failed because the government needed only to prove that the laundered funds were gross revenues; (3) the district court did not err when it gave a willful blindness instruction to the jury; and (4) the district court did not plainly err when it relied on the money laundering proceeds to establish a base offense level at sentencing. View "United States v. Adorno-Molina" on Justia Law

After a jury trial in Massachusetts state court, Petitioner was convicted of assaulting and raping a two-year-old child and sentenced to life imprisonment. Petitioner’s application for further appellate review was denied. Petitioner filed this petition for a writ of habeas corpus in the federal district court, arguing (1) the evidence against him, which was entirely circumstantial, was so insufficient that no reasonable jurist could have concluded that a rational jury could have found him guilty beyond a reasonable doubt; and (2) the trial court erred in refusing to permit him to cross-examine the victim’s mother about her potential bias arising from pending criminal charges against her. The district court denied the petition but issued a certificate of appealability as to both issues. The First Circuit affirmed, holding (1) the state courts could reasonably conclude that a rational jury could find beyond a reasonable doubt that Petitioner was the perpetrator; and (2) the state court’s exclusion of evidence about the victim’s mother’s pending criminal charges was not an unreasonable application of law clearly established by Supreme Court precedent. View "Winfield v. O'Brien" on Justia Law

Plaintiff was an anatomically male prisoner in her mid-sixties who suffered from gender identity disorder and self-identified as a female. Plaintiff, who was incarcerated in a medium security male prison in Massachusetts, filed a complaint against the Massachusetts Department of Correction (DOC), alleging that the DOC was denying her adequate medical care by not providing her with sex reassignment surgery. Although the DOC was providing Plaintiff with hormonal and other medical treatment, the district court issued an order requiring the Commissioner of the DOC to provide Plaintiff with sex reassignment surgery, concluding that the DOC’s failure to provide the surgery violated Plaintiff’s Eighth Amendment rights. The First Circuit affirmed. The First Circuit reversed the district court’s order of injunctive relief, holding that, in light of the community standard of medical care, the adequacy of the provided treatment, and the DOC’s concerns related to safety and prison security, the care provided to Plaintiff by the DOC did not violate the Eighth Amendment. Remanded with instructions to dismiss the case. View "Kosilek v. Spencer" on Justia Law

Defendants in this case were the Governor of Massachusetts, the Secretary of the Executive Office of Health and Human Services, and the Commissioner of the Massachusetts Department of Children and Families (DCF). Six children brought this class action in federal court on behalf of an estimated 8,500 children who are (or will be) committed to Massachusetts foster care custody as a result of their having suffered from abuse or neglect. Plaintiffs asserted that DCF so exposes the plaintiff class to harm or the risk of harm that it is unconstitutional and violates the Adoption Assistance and Child Welfare Act of 1980. Plaintiffs sought a broad injunction preventing Defendants from subjecting the plaintiff children to practices that violate their rights. The district court granted judgment for Defendants on all claims. The First Circuit affirmed, holding that Plaintiffs failed to demonstrate class-wide constitutional violations, nor a violation of the AACWA, and so injunctive relief was not warranted. View "Connor B. v. Patrick" on Justia Law

A district court issued an arrest warrant for Brian Hunt for failing to pay a fine. Hunt had actually paid the fine, but the payment wasn’t recorded. Four police officers served the warrant at the home of Hunt and his wife (together, Plaintiffs). Hunt requested that he be handcuffed with his hands in front of him because he had recently undergone surgery on his stomach. The officers refused Hunt’s request and, after a scuffle, handcuffed Hunt with his hands behind his back. Plaintiffs sued the officers, asserting violations of Hunt’s federal constitutional rights under 42 U.S.C. 1983 as well as pendent state law claims. The district court declined to grant the police officers qualified immunity on summary judgment. The First Circuit reversed in part, holding (1) Defendants were entitled to qualified immunity on Plaintiffs’ excessive force claim under section 1983, as Hunt had no clearly established right to be cuffed with his hands in front of him when the officers reasonably understood their actions in effectuating the arrest to be constitutional; (2) Defendants were entitled to summary judgment on Plaintiffs’ state law claims of battery and violation of the Massachusetts Civil Rights Act; and (3) the Court lacked jurisdiction to review Plaintiffs’ malicious prosecution claims. View "Hunt v. Massi" on Justia Law