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

Defendant was one of seventeen passengers in an open boat that was intercepted by Coast Guard and Border Patrol officials twenty-three nautical miles off the coast of Puerto Rico. Defendant was subsequently convicted of illegally attempting to return to the United States after being deported. Defendant appealed, contending that he was wrongly prevented from arguing at trial that he was passing Puerto Rico on his way to the island of St. Maarten and did not intend to enter the United States illegally. The First Circuit affirmed, holding (1) the government plainly violated Fed. R. Crim. P. 16 by announcing its intention to call an expert witness only five days before trial, but Defendant was not prejudiced by the violation; (2) the government did not violate Defendant’s due process rights by destroying the boat, which contained evidence of whether it had enough fuel to travel to St. Maarten, and by deporting other passengers who, Defendant argued, would have testified the boat was traveling to St. Maarten; and (3) there was sufficient evidence to support Defendant’s conviction. View "United States v. Bresil" on Justia Law

While Plaintiff was imprisoned in the Massachusetts Department of Correction (DOC) he committed misconduct that resulted in an administrative sanction of a ten-year term in the Department Disciplinary Unit (DDU), a segregated maximum security housing unit, as well as a state law criminal charge for armed assault with intent to murder. After Plaintiff completed his original criminal sentence he remained in the custody of the DOC as a pretrial detainee for the new criminal assault with intent to murder charge. After Plaintiff was sentenced on the criminal charge, he continued to serve out the balance of the ten-year administrative sanction in the DDU. The district court ruled that two high-ranking prison officials had violated Plaintiff’s due process rights by continuing to confine Plaintiff in the DDU, both as a pretrial detainee and as a sentenced inmate. In connection with these rulings, the court denied the defendants’ claims of qualified immunity and awarded Plaintiff partial money damages and equitable relief as well as attorneys’ fees and costs. The First Circuit reversed the denial of qualified immunity, reversed the award of money damages against the officials in their individual capacities and vacated all equitable relief, holding that the prison officials did not violate Plaintiff’s clearly established rights. Remanded. View "Ford v. Bender" on Justia Law

On October 27, 2011, the McLaughlin Group brought suit against the United States, the Secretary of Defense, the Attorney General, and the Secretary of Veterans Affairs, challenging the constitutionality of Section 3 of the Defense of Marriage Act (DOMA) as applied to definitions of marriage in Title 10, Title 32, and Title 38 of the United States Code as they affect same-sex military spouses. The district court stayed the proceedings in light of two similar challenges on appeal before the First Circuit. The First Circuit subsequently held Section 3 of DOMA invalid, and the Supreme Court held Section 3 unconstitutional as a violation of the Fifth Amendment. The district court then resumed proceedings in this case and entered summary judgment in favor of the McLaughlin Group. The McLaughlin Group moved for fees and costs under the Equal Access to Justice Act. The district court denied the motion, concluding that the government’s position was substantially justified. The First Circuit affirmed, holding that the district court correctly found that the position of the United States was substantially justified and thus properly denied fees as a matter of law. View "McLaughlin v. Hagel" on Justia Law

Appellants, employees of Puerto Rico’s Department of Transportation and Public Works and members of Puerto Rico’s Popular Democratic Party, were relieved of their job responsibilities and lost supervisory authority upon the change in political administration to the New Progressive Party in Puerto Rico (NPP). Appellants filed suit against Appellees, members of the NPP, claiming that Appellees discriminated on the basis of political affiliation in violation of the First Amendment. The district court dismissed Appellants’ First Amendment claims against the appellees who received Appellants’ cease and dismiss letters, concluding that Appellants’ letters did not identify Appellants’ political affiliation or refer to discriminatory conduct based on political animus, and therefore, Appellants did not adequately allege all elements of a First Amendment political discrimination claim. The First Circuit vacated the district court’s dismissal of Appellants’ First Amendment claims, holding that each appellant stated a plausible First Amendment claim against the appellees who received that appellant’s letter. View "Medina-Velazquez v. Hernandez-Gregorat" on Justia Law

After a jury trial in federal district court, Petitioner was convicted of child pornography and sentenced to 180 months’ imprisonment. The First Circuit Court of Appeals affirmed Petitioner’s conviction and sentence. Petitioner subsequently filed a petition under 28 U.S.C. 2255 collaterally attacking his conviction on four grounds. The district court rejected the petition. The First Circuit affirmed the district court’s denial of Petitioner’s petition for collateral relief, holding (1) because Petitioner did not show any prejudice, his ineffective assistance of counsel claim failed; (2) any error that the district court made in excluding certain testimony did not have a substantial and injurious effect on the jury’s verdict; (3) the conduct underlying Petitioner’s conviction was not constitutionally protected; and (4) Petitioner’s argument that he was actually innocent failed. View "Ortiz-Graulau v. United States" on Justia Law

Plaintiff, an African-American woman who was serving in the United States Coast Guard Housing Office at Air Station Cape Cod, filed an employment discrimination action against the Secretary of Homeland Security, asserting that the Secretary failed to promote her to the position of housing manager because of her race and gender. The district court granted summary judgment in favor of the Secretary, concluding that Plaintiff failed to generate a genuine issue of material fact as to whether the Secretary’s non-discriminatory reason for choosing another candidate was pretextual. The First Circuit Court of Appeals affirmed, holding (1) the district court acted within the bounds of its discretion in denying Plaintiff’s motion to reopen discovery shortly after retaining counsel; and (2) the Secretary was entitled to summary judgment because Plaintiff failed to generate a genuine issue of material fact on the issue of pretext. View "Hicks v. Napolitano" on Justia Law

After a jury trial in Massachusetts state court, Appellant was convicted of the first-degree murder of his estranged wife under both the theory of deliberate premeditation and extreme atrocity or cruelty. The Massachusetts Supreme Judicial Court (SJC) affirmed on appeal. Appellant subsequently filed a petition for a writ of habeas corpus in the federal district court, alleging (1) his constitutional right to confrontation was violated when the testimony of the chief medical examiner in Massachusetts was admitted, and (2) his attorney provided ineffective assistance by failing to introduce certain mental health related evidence. The district court denied the petition. The First Circuit Court of Appeals affirmed, holding (1) the SJC’s rejection of Appellant’s Confrontation Clause argument was not contrary to governing Supreme Court precedent; and (2) the SJC did not unreasonably apply Strickland or commit clear factual error when it concluded that Appellant’s attorney’s performance was not deficient. View "Hensley v. Roden" on Justia Law

In 2013, the City of Worcester, Massachusetts adopted the Aggressive Panhandling Ordinance and the Pedestrian Safety Ordinance, which prohibited coercive or risky behavior by panhandlers, other solicitors, and demonstrators seeking the attention of motor vehicle drivers. Two plaintiffs were homeless people who solicited donations from the City’s sidewalks. The third plaintiff was a City school committee member who had customarily displayed political signs near traffic during the campaign season. Plaintiffs brought suit challenging the new ordinances as violating their First and Fourteenth Amendment rights. The district court denied a preliminary injunction against enforcing the ordinances, concluding that Plaintiffs failed to demonstrate a likelihood of success on the merits of any of their constitutional claims. The First Circuit Court of Appeals affirmed the district court’s denial of a preliminary injunction as to all provisions of the ordinances except for the Aggressive Panhandling Ordinance’s prohibition against nighttime solicitation, holding that the district court did not abuse its discretion in denying the preliminary injunction. View "Thayer v. City of Worcester" on Justia Law

When control of the Puerto Rican government changes parties, the political party assuming office often terminates the employment of public employees affiliated with the party going out of power and fills the vacancies with its own members. Plaintiff, a Popular Democratic Party (PDP) activist, was employed with a trust position at Puerto Rico’s State Insurance Fund Corporation (SIFC) while the PDP was in power. Plaintiff was moved into a career position at the SIFC when it became clear the opposing party would win an upcoming election. Had Plaintiff remained in a trust position, his employment could have been terminated without violating the First Amendment. A subsequent audit of employees performed by the new administration revealed that Plaintiff’s appointment did not conform with Puerto Rican law. Plaintiff’s reclassification to a career position was subsequently annulled, and he was dismissed. Plaintiff filed suit against SIFC and other defendants, alleging that he was terminated because of his political association in violation of the First and Fourteenth Amendments. The district court concluded that Defendants were entitled to summary judgment under the Mt. Healthy doctrine. The First Circuit affirmed, holding that Plaintiff failed to produce any evidence that undermined Defendants’ proffered nondiscriminatory reasons for his reclassification and later termination. View "Reyes-Perez v. State Ins. Fund Corp." on Justia Law

Corizon, Inc. was a private independent contractor that provided healthcare services to inmates at Cumberland County Jail (CCJ) under a contract with the jail. After Paul Galambos, died from self-inflicted injuries that he sustained while he was a pretrial detainee at CCJ, Galambos’s estate brought a 42 U.S.C. 1983 action alleging that three employees of Corizon were deliberately indifferent to Galambos’s serious medical needs. Defendants moved for summary judgment, claiming that they were entitled to qualified immunity. The magistrate judge denied Defendants’ motions, concluding that material and disputed issues of fact existed that precluded the grant of immunity. Defendants appealed. The First Circuit dismissed the appeal for want of appellate jurisdiction under Johnson v. Jones because the district court’s denial of immunity turned on findings that there remained disputed issues of material fact and inference. View "Cady v. Cumberland County Jail" on Justia Law