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

After a jury trial, Petitioner was found guilty of second degree murder and unlawful possession of a firearm. Petitioner appealed his conviction, contending that the Commonwealth used its peremptory challenges to exclude young African Americans in violation of the equal protection principles laid down in Batson v. Kentucky. The Massachusetts Appeals Court (MAC) concluded that Petitioner had failed to make a prima facie showing that the Commonwealth’s use of peremptory challenges was likely motivated by the jurors’ race. Petitioner failed to obtain relief on appeal in the Massachusetts courts and subsequently sought a writ of habeas corpus from the United States District Court. The district court denied the petition. The First Circuit vacated the judgment of the district court, holding that the MAC’s application of the first Batson prong was clear error and represented an objectively unreasonable application of clearly established federal law. Remanded to the district court to conduct an evidentiary hearing and to complete the Batson inquiry. View "Sanchez v. Roden" on Justia Law

Defendant was charged with several drug trafficking crimes. Defendant engaged in several pre-trial antics in an apparent effort to put off the trial, including seeking continuances of the trial and ostensibly firing his attorney. Because of Defendant’s continued complaints about his attorney, Defendant ended up representing himself at trial. The jury ultimately convicted Defendant on all counts. The First Circuit affirmed Defendant’s convictions, holding (1) the trial judge did not deprive Defendant of his Sixth Amendment right to counsel of his choice when she allowed Defendant to represent himself at trial; and (2) the district judge did not err in refusing Defendant’s motions to continue. View "United States v. Robinson" on Justia Law

Petitioner was convicted as an accessory before the fact to George Carpenter’s murder. The Massachusetts Supreme Judicial Court (SJC) reversed the conviction, concluding that the indictment charging Petitioner improperly defined the offense on which he was tried. The Commonwealth subsequently indicted Petitioner for the murder of Carpenter. Petitioner moved to dismiss the indictment, arguing that the second prosecution was barred by double jeopardy as incorporated against the states. The SJC affirmed the trial judge’s denial of Petitioner’s motion, concluding that its earlier reversal had been based on a variance between the crime charged and the crime proved at trial under state law, and a second prosecution under these facts did not give rise to a double jeopardy problem. Petitioner filed a petition for habeas relief, claiming that his pending prosecution was barred by double jeopardy. The district court granted the petition. The First Circuit reversed, holding that under Tibbs v. Florida, the SJC’s interpretation of its earlier reversal and the requirements of Massachusetts law bound the Court, and therefore, Petitioner’s double jeopardy argument necessarily failed. View "Marshall v. Bristol Superior Court" on Justia Law

Plaintiff brought sex discrimination and retaliation claims under Title VII of the Civil Rights Act against his former employer, DDR Corp., after his employment was terminated. Specifically, Plaintiff claimed that DDR discriminated against him on the basis of sex by terminating him after his co-worker, whose sexual advances he refused, maligned his job performance. The district court granted summary judgment to DDR. The First Circuit (1) vacated the portion of the district court’s judgment granting summary judgment against Plaintiff on his sex discrimination claim, holding (i) a reasonable jury could find that the jilted co-worker’s discriminatory efforts were the proximate cause of Plaintiff’s termination, and (ii) although the co-worker was not Plaintiff’s direct supervisor, DDR could nonetheless be found liable for negligently allowing the co-worker’s discriminatory acts to cause Plaintiff’s firing; and (2) otherwise affirmed the judgment of the district court. Remanded. View "Velazquez-Perez v. Developers Diversified Realty" on Justia Law

Defendant was prosecuted in federal court for possession of child pornography, in violation of 18 U.S.C. 2252(a)(4)(B), after police officers took several digital devices from his home, including a thumb drive that contained child pornography. To establish that the pornography was “produced using materials which have been…shipping or transported” in interstate commerce, the prosecution relied on an inscription on the thumb drive stating, “Made in China.” The First Circuit affirmed Defendant’s conviction, holding (1) copying pornography onto a thumb drive is “producing” pornography under the statute, and the Court’s interpretation of the law did not put it beyond Congress’s authority to regulate interstate commerce; (2) the district court did not err by admitting as evidence the drive’s inscription over Defendant’s hearsay objection; and (3) the warrant to search Defendant’s home and the devices inside it was constitutional. View "United States v. Burdulis" on Justia Law

After Plaintiff attempted to film a police officer as he was conducting a traffic stop, Plaintiff was arrested and charged with violating New Hampshire’s wiretapping statute, among other crimes. Plaintiff was not brought to trial. Plaintiff subsequently brought a First Amendment claim against the police officers, the police department, and the Town of Weare, alleging that the wiretapping charge constituted retaliatory prosecution. The officers moved for summary judgment, claiming that they were entitled to qualified immunity because there was no clearly established right to film the traffic stop. The district court denied the officers’ motions for summary judgment. The First Circuit affirmed, holding (1) it was clearly established at the time of the stop that the First Amendment gives citizens the right to film police carrying out their duties in public if no reasonable restriction is imposed or in place; and (2) therefore, the district court properly denied qualified immunity to the officers on Plaintiff’s claim that the wiretapping charge constituted retaliatory prosecution in violation of the First Amendment. View "Gericke v. Begin" on Justia Law

Petitioner was convicted in Massachusetts state court of drug distribution and trafficking. While Petitioner’s appeal was pending in the Supreme Judicial Court (SJC), the U.S. Supreme Court decided Melendez-Diaz v. Massachusetts. On appeal, Petitioner argued that his conviction must be reversed because the trial proceedings violated his federal Confrontation Clause rights as articulated in Melendez-Diaz. The SJC decided that there was a Melendez-Diaz error in this case but that the error was harmless beyond a reasonable doubt. Petitioner petitioned for habeas review in federal district court, arguing that the state proceedings had violated his Sixth Amendment rights under Melendez-Diaz. The district court denied the petition, concluding that Petitioner could not show sufficient injury under the Brecht v. Abrahamson standard of review. The First Circuit affirmed, holding that under the highly deferential standard announced in Brecht, Petitioner failed to show the “substantial and injurious effect or influence” on the verdict required to set aside the SJC’s affirmance of his conviction. View "Connolly v. Roden" on Justia Law

Appellant, a Muslim and a native of Algeria, filed an amended complaint alleging that he was denied a promotion at the U.S. Department of Homeland Security (“Department”) based on his religion, race, and national origin. The district court granted summary judgment in favor of Appellee, the Secretary of the Department, concluding that Appellant failed to rebut the Department’s legitimate non-discriminatory reason for rejecting Appellant’s promotion. The First Circuit vacated the district court’s judgment and remanded, holding that Appellant’s proffered evidence raised material disputes of fact that would allow a jury to infer that Appellant was the victim of intentional discrimination. View "Ahmed v. Napolitano" on Justia Law

Plaintiff filed suit against Defendant, her employer, pursuant to Title VII and analogous Puerto Rico law, alleging adverse employment action and a failure to hire on account of sex. After deliberations, the jury returned a verdict for Plaintiff on both counts. On appeal, Defendant (1) sought a reversal of the jury verdict, arguing that there was insufficient evidence to support the jury’s findings; and (2) in the alternative, requested remittitur on the issue of damages. The First Circuit Court of Appeals affirmed, holding (1) Defendant’s sufficiency-of-the-evidence claim was unpreserved for appellate review; and (2) the district court did not err in denying Defendant’s motion for remittitur. View "Climent-Garcia v. Autoridad de Transporte" on Justia Law

After a jury trial, Appellant was convicted of conspiracy to distribute cocaine, distribution of cocaine, and possession of cocaine with intent to distribute. Before Appellant’s sentencing, he learned of the existence of certain evidence that the government had failed to disclose to him. Appellant filed a motion to set aside the verdict and for a new trial, contending that the government had failed to disclose exculpatory evidence that could have been used to impeach the credibility of the key government witness against him at trial. The district court denied the motion. Appellant was subsequently sentenced to life imprisonment, which was “legally required” by the quantities of cocaine at issue and by virtue of this being Appellant’s third felony drug conviction. The First Circuit Court of Appeals (1) affirmed the denial of Appellant’s motion, holding that the suppression did not result in prejudice to Appellant; and (2) rejected the constitutional challenges Appellant raised to the district court’s imposition of a life sentence. View "United States v. Paladin" on Justia Law