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

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

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