Castagna v. Jean, No. 19-1677 (1st Cir. 2020)Annotate this Case
In this lawsuit brought against three Boston police officers who were involved in breaking up a party and arresting Plaintiffs, the First Circuit reversed the judgment for Plaintiffs, holding that the officers were entitled to qualified immunity for entering through the open door of a house under the community care taking exception to the Fourth Amendment's warrant requirement.
Plaintiffs brought civil rights claims under 42 U.S.C. 1983 and Mass. Gen. Laws ch. 12, 11H and 11I, as well as state tort claims for, among other things, false imprisonment. The jury reached a unanimous verdict in favor of Defendants on all counts. The district court, however, granted Plaintiffs' motion for a new trial, finding that the verdict was against the law as to the officers' warrantless entry into the home and that the warrantless entry on the facts as presented in the trial was not protected by qualified immunity. The court then amended its judgment so that it reflected a judgment in favor of Plaintiffs as to the section 1983 unlawful entry claim. The First Circuit reversed, holding that the officers were entitled to qualified immunity because, under the community caretaking exception, their entry through the home's open door did not violate Plaintiffs' constitutional rights.
The court issued a subsequent related opinion or order on July 2, 2021.