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

The First Circuit affirmed Defendant's conviction of possession with intent to distribute oxycodone, holding that the district court did not err in denying Defendant's motion to suppress.Defendant's vehicle was intercepted by the Maine State Police, and Defendant's vehicle was searched. Defendant entered a conditional guilty plea to possession with intent to distribute oxycodone. On appeal, Defendant argued that the authorities lacked probable cause to search his vehicle and that the district court erred by refusing to suppress statements he made both before and after Miranda warnings were administered. The First Circuit affirmed, holding (1) the authorities had probable cause to search Defendant's car, and therefore, the evidence seized during the vehicle search was admissible; and (2) the district court did not err in denying Defendant's motion to suppress his statements. View "United States v. Simpkins" on Justia Law

The First Circuit affirmed the decision of the district court denying Defendant's motion to suppress drug evidence that was seized without a warrant after an automobile stop and drug evidence from a subsequent visual body cavity search, holding that the police had reasonable suspicion to perform the automobile stop and particularized reasonable suspicion to perform the visual body cavity search.On appeal, Defendant argued that his rights under the Fourth and Fourteenth Amendments were violated because the law enforcement officers lacked reasonable suspicion to perform the initial stop of his vehicle and the requisite level of suspicion to perform the visual body cavity search of his person at the police station. The First Circuit disagreed, holding that the officers (1) had reasonable suspicion to stop Defendant's vehicle; and (2) had particularized reasonable suspicion to conduct the visual body cavity search. View "United States v. Perez" on Justia Law

The First Circuit affirmed the district court's grant of summary judgment on Plaintiff's racial discrimination and retaliation claims against the Massachusetts Bay Transportation Authority (MBTA), holding that both challenges were meritless.Plaintiff brought claims of racial discrimination, unlawful retaliation, and negligent infliction of emotional distress against the MBTA. The district court granted summary judgment to the MBTA on all claims. The First Circuit affirmed, holding (1) Plaintiff did not produce sufficient evidence to get to a jury on his claim that he was denied a promotion based on his race; and (2) Plaintiff did not establish a prima facie case of retaliation. View "Henderson v. Massachusetts Bay Transportation Authority" on Justia Law

The First Circuit reversed the decision of the district court denying Defendant's motion to strike the government's notice of intent to seek the death penalty on retrial in this case, holding that double jeopardy barred the government from seeking the death penalty.Defendant was charged with nine counts of committing a violent crime in aid of racketeering and nine counts of using a firearm during a crime of violence. In advance of trial, the government filed a notice of its intent to seek the death penalty on sixteen of those counts. The jury found Defendant guilty on all charges but could not reach a unanimous decision as to punishment. The district court imposed a life sentence without the possibility of release. The First Circuit vacated the conviction, concluding that a courtroom closure during trial constituted structural error. On remand, the government again notified the court of its intention to seek the death penalty. Defendant moved to strike the government's notice on double jeopardy grounds. The district court denied the motion. The First Circuit reversed, holding (1) the first life sentence was an "acquittal," and therefore, double jeopardy barred the government from seeking the death penalty on retrial; and (2) the assumption that the initial penalty-phase jury was properly discharged was incorrect. View "United States v. Candelario-Santana" on Justia Law

The First Circuit dismissed Appellant's appeal from the ruling of the district court granting in part and denying in part Avon Products, Inc.'s motion for the district court to tax costs, holding that the appeal was moot.In a previous appeal, the First Circuit affirmed judgment for Avon on three claims brought by Appellant. After the Court's mandate issued, Avon sought to recover some of its expenses by moving the district court to tax costs. After the district court granted the request in part, Appellant appealed. Thereafter, the parties settled the case for the purpose of avoiding litigation costs. The First Circuit dismissed the appeal and denied, without prejudice, the parties' request that the Court vacate the district court's costs order, holding that the appeal was moot, with the parties to be a their own appellate costs and fees, but that this decision was without prejudice to pursuit of vacatur relief in the district court. View "Villeneuve v. Avon Products, Inc." on Justia Law

The First Circuit affirmed the order of the district court dismissing Defendants' motion for a new trial after a jury found them guilty of charges arising out of a large-scale marijuana farming operation, holding that there was no abuse of discretion warranting a new trial.After they were found guilty, Defendants filed a motion for a new trial, arguing that one juror had lied in filling out the written questionnaire given to prospective jurors before trial. The district court denied the motion. The First Circuit vacated the district court's order and remanded for further proceedings to investigate the alleged juror misconduct. On remand, the district court again denied the motion for a new trial. The First Circuit affirmed, holding that the district court did not abuse its discretion in (1) fashioning and executing a procedure on remand to investigate Defendants' allegations of juror bias; and (2) denying the motion for a new trial. View "United States v. Russell" on Justia Law

The First Circuit vacated the decision of the district court granting summary judgment for Defendants and dismissing Plaintiff's 42 U.S.C. 1983 action on the grounds that Plaintiff's claims were time barred, holding that there was no basis for summary judgment on the record.Plaintiff filed suit against the City of Biddeford, Captain Norman Gaudette with the Biddeford Police Department (BPD), and Chief of Police Roger Beaupre, alleging that Gaudette sexually abused him as a teenager in the later 1980s and that the City and Baupre were deliberately indifferent to Gaudette's violation of his constitutional rights when Plaintiff reported the abuse. Defendants argued that the suit was barred by the statute of limitations. In response, Plaintiff asserted that his claims did not accrue until 2015, when he learned that the BPD and Baupre allegedly knew of at least one other report of Gaudette sexually abusing a minor that pre-dated Plaintiff's experience. The district court granted summary judgment for Defendants. The First Circuit reversed, holding (1) a reasonable jury could find that Plaintiff had no duty to diligently investigate his claims against Defendants before 2015; and (2) therefore, the district court erred in concluding as a matter of law that Plaintiff's claims accrued at the time of his injury in the late 1980s. View "Ouellette v. Beaupre" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of the Town of Pembroke, New Hampshire and dismissing the complaint filed by Signs for Jesus and Hillside Baptist Church (collectively, the Church) challenging the Town's denial of the Church's application for a permit to install an electronic sign on its property, holding that the Town met its summary judgment burden on all counts.Hillside Baptist Church applied for a permit to install an electronic sign on its property to transmit messages provided by the nonprofit corporation Signs for Jesus. The Pembroke Zoning Board of Adjustment denied the permit, citing a provision in the Pembroke Sign Ordinance that bans the use of electronic signs in the zoning district where the Church was located. The Church later brought this complaint, alleging violations of the state and federal Constitutions, the Religious Land Use and Institutionalized Persons Act, and certain New Hampshire zoning laws. The district court granted summary judgment for the Town and declined to exercise supplemental jurisdiction over the Church's state statutory claims. The First Circuit affirmed, holding that the district court did not err. View "Signs for Jesus v. Pembroke, New Hampshire" on Justia Law

The First Circuit affirmed Defendant's sentence for carjacking and using a firearm during and in relation to a crime of violence, holding that the sentence was both procedurally and substantively reasonable.At the time of his sentencing, Defendant was serving a thirty-year prison sentence for unrelated offenses in the Commonwealth of Puerto Rico. The district court sentenced Defendant to eighty-seven months on the carjacking to be served consecutively to the Commonwealth sentence and to five years for use of a firearm. Defendant appealed, challenging his sentence. The First Circuit affirmed, holding (1) the district court's explanation was sufficient to justify its decision to impose the sentence consecutively, rather than concurrently, to the Commonwealth sentence; and (2) the sentence fell within the range of reasonable sentences. View "United States v. Acevedo-Vazquez" on Justia Law

The First Circuit affirmed Defendant's conviction for distribution of child pornography and Defendant's sentence, holding that there was no error in the proceedings below.Defendant pleaded guilty to five counts of sexual exploitation of a minor, one count of distribution of child pornography, and two counts of possession of child pornography. The district court sentenced Defendant to 180 years' imprisonment. On appeal, Defendant argued, among other things, that his conviction of distribution of child pornography could not stand because the difference between the crime it alleged and the one he pleaded guilty to committing resulted in a constructive amendment of the indictment. The First Circuit affirmed, holding (1) as to the constructive amendment challenge, Defendant did not establish the requisite prejudice to show reversible error; (2) Defendant's challenges to his sentence were unavailing; and (3) Defendant's remaining challenges were without merit. View "United States v. Gaccione" on Justia Law