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

The City of Springfield passed an ordinance creating a single-parcel historic district encompassing a church owned by the Roman Catholic Bishop of Springfield (RCB). Under the ordinance, RCB could not make any changes affecting the exterior of the church without the permission of the Springfield Historical Commission (SHC). RCB challenged the ordinance, claiming it violated RCB's rights under the First Amendment, the Religious Land Use and Institutionalized Persons Act, and the Massachusetts Constitution. The district court granted summary judgment for the City, concluding that some of RCB's claims were not ripe for review and that its remaining claims failed as a matter of law. The First Circuit Court of Appeals dismissed RCB's unripe claims without prejudice and rejected the remaining ripe claim, holding (1) the claims that the district court found were unripe should have been dismissed without prejudice, not resolved on summary judgment; (2) those of RCB's claims which depended on the potential consequences of compliance with the ordinance were not ripe for adjudication; and (3) RCB's claim based on the enactment of the ordinance was ripe for review but failed on the merits. View "Roman Catholic Bishop of Springfield v. City of Springfield" on Justia Law

Plaintiff served as the human resources director of two Puerto Rico governmental agencies. Plaintiff resigned one position and was terminated from the other. Plaintiff sued her former supervisors under 42 U.S.C. 1983 and Puerto Rico law, alleging that she was retaliated against due to her allegiance with a certain political faction disfavored by Defendants and because she refused to follow personnel-related orders that she considered illegal and politically motivated. The district court dismissed some of Plaintiff's claims and granted summary judgment on the remainder. The First Circuit Court of Appeals affirmed in all respects, holding that the district court did not err (1) in dismissing Plaintiff's First Amendment free speech claim, as Plaintiff's "speech" exclusively revolved around her professional duties as human resource director; (2) in dismissing a claim Plaintiff made under the Puerto Rico Whistleblowers Protection Act, as Plaintiff failed to raise her meritorious arguments regarding this claim in district court; and (3) in granting summary judgment on Plaintiff's freedom of association claim, as the First Amendment was inapplicable to Plaintiff's position as human resources director. View "O'Connell v. Marrero-Recio" on Justia Law

Appellant was charged with being a possession of a firearm and moved to suppress the firearm seized from him during a traffic stop. The district court denied the motion without a hearing, concluding that the seizure was justified under the plain view doctrine. Defendant subsequently filed a motion to reconsider and a second motion to suppress the firearm, requesting evidentiary hearings on both motions. After a non-evidentiary hearing, the district court denied both motions. The First Circuit Court of Appeals affirmed, holding that the district court did not abuse its discretion in denying an evidentiary hearing on Appellant's motion to reconsider and second motion to suppress. View "United States v. Cintron" on Justia Law

Defendant was convicted of willfully damaging federal property, creating a hazard on federal property, and creating a nuisance on federal property after he badly soiled a federal courtroom. Defendant appealed, arguing that because the regulations he was charged with violating were posted inside rather than outside the courthouse entrance, his conviction must be reversed pursuant to 40 U.S.C. 1315(c)(1) and a General Services Administration (GSA) regulation. The First Circuit Court of Appeals affirmed, holding (1) the regulations were posted in compliance with the statute, which requires posting of the regulations Defendant violated in a conspicuous place on the property; (2) while the GSA regulation specifies that the notice about the rules governing the building should be posted at the public entrance, the regulation does not provide that imperfect compliance with the exterior posting requirement nullifies a conviction for violating the prohibition; and (3) sufficient evidence established that Defendant had the mental state required for his conviction. View "United States v. Strong" on Justia Law

Pursuant to a nonbinding plea agreement, Defendant pleaded guilty to participating in a widespread drug-trafficking conspiracy. The district court sentenced Defendant to serve eighty-seven months in prison. Defendant appealed, contending (1) his guilty plea was neither knowing nor voluntary because he was unaware that the court intended to impose a consecutive sentence, and (2) the district court's sentencing methodology was flawed. The First Circuit Court of Appeals affirmed Defendant's conviction and sentence, holding (1) because the consecutive sentence was not a direct consequence of Defendant's guilty plea, Defendant did not need to be informed at the time of his plea that the court might impose a consecutive sentence; and (2) the district court did not procedurally err in the construction of Defendant's sentence. View "United States v. Ocasio-Cancel" on Justia Law

Defendant pleaded guilty to being a felon in possession of a firearm without a plea agreement. Defendant so pleaded without reserving the right to appeal the denial of his motion to suppress the firearm. Defendant was sentenced under the Armed Career Criminal Act (Act) to fifteen years' imprisonment and three years of supervised release. The First Circuit Court of Appeals affirmed, holding (1) the district court correctly denied Defendant's motion to suppress, and therefore, the Court did not reach Defendant's argument that his counsel was ineffective for failing to inform Defendant of the consequences of not preserving his right to appeal the denial of his suppression motion; (2) the police had reasonable suspicion to initiate a Terry stop in this case and acted reasonably in making sure Defendant was seized and handcuffed as part of the investigatory stop; and (3) the district court correctly found that Defendant qualified as an armed career criminal for purposes of the ACCA. View "United States v. Carrigan" on Justia Law

Appellant attempted to smuggle approximately $543,000 from Puerto Rico to the Dominican Republic. United States Customs and Border Patrol agents arrested Appellant and seized the cash, and Appellant was convicted after a jury trial of bulk cash smuggling and failure to report the export of currency. The cash used by Appellant was forfeitable to the United States as property used to commit a violation of the bulk smuggling and failure to report statutes. Instead of entering an order as part of Appellant's sentence specifying the forfeiture of the cash to the United States and authorizing the attorney general to seize the cash, the district court instead entered a series of orders and amendments resulting in the entry of a personal judgment against Appellant in the amount of the cash. Appellant and a third party, who claimed the cash belonged to him, both appealed. The First Circuit Court of Appeals (1) remanded the third party's case, after which the district court found the third party had no cognizable interest in the cash; and (2) affirmed the judgment against Appellant, finding that the United States may retain the nexus property in satisfaction of the money judgment entered against Appellant. View "United States v. Zorrilla-Echevarria" on Justia Law

After Defendant sold crack cocaine to an FBI confidential informant, the police searched her home. Based on the evidence obtained from the search, Defendant was convicted of three drug-related offenses and sentenced to seventy-eight months' imprisonment. Defendant appealed, claiming, inter alia, that her consent to the FBI's warrantless search of her home was secured by a false claim that a lawful, warrantless search of her home would be conducted without her consent. The First Circuit Court of Appeals affirmed Defendant's conviction on two of the three offenses and vacated her conviction on the third, holding (1) the district court erred in failing to determine whether there were reasonable grounds to support the claim made to Defendant that a lawful, warrantless search of her home would ensue without her consent; and (2) admission of the results of the search at trial was not harmless as to one of the convictions. Remanded. View "United States v. Vazquez" on Justia Law

At the time of the criminal conduct at issue, Defendant was a twenty-nine-year-old physician and resident in psychiatry whose special interest was adolescent psychiatry. After pursuing a sexual relationship with a fifteen-year-old girl, two states charged Defendant with statutory rape and two courts ordered him to cease contact with the girl. Federal authorities took Defendant into custody when he continued to pursue the relationship. Defendant subsequently pled guilty to five federal charges. The district court sentenced him to 365 months' imprisonment followed by 360 months' supervised release. The First Circuit Court of Appeals affirmed the sentence, holding that, based on the facts on the record, the district court did not err in determining that Defendant's long stay behind prison bars was required. View "United States v. Batchu" on Justia Law

After a judge issued a warrant for Plaintiff's arrest, Plaintiff was arrested. A magistrate judge ordered Plaintiff detained pending trial and transferred him to a federal prison, where he was incarcerated for nearly three months. The charges against Plaintiff were subsequently dismissed. Plaintiff filed a complaint alleging that the unlawful conduct of two law enforcement officers (Defendants) caused him to be held for three months in pretrial detention without probable cause. The district court allowed Plaintiff to proceed on his malicious prosecution claim. Defendants filed a motion to dismiss on the basis of qualified immunity, which the circuit court denied after concluding that the Fourth Amendment prohibits a police officer from manufacturing probable cause by knowingly including false statements in a warrant affidavit. The First Circuit Court of Appeals affirmed the denial of qualified immunity, holding (1) an individual's Fourth Amendment right to be free from seizure without probable cause continues through the pretrial period, and in certain circumstances, injured parties can vindicate that right through a 42 U.S.C. 1983 or a Fourth Amendment malicious prosecution claim; and (2) Plaintiff pleaded facts which, if true, would be sufficient to establish that Defendants violated his Fourth Amendment rights. View "Hernandez-Cuevas v. Taylor" on Justia Law