Lopera v. Town of Coventry, 640 F.3d 388

Central Falls High School soccer team traveled to Coventry for a 2006 match; Coventry locker room access was open and security escorted some players to bathroom.
After the game, about 50–60 Coventry supporters surrounded the Central Falls team bus, accusing players of theft and using racial epithets.
Coventry police boxed in the bus and sought Coach Marchand's consent to search the players’ belongings; Marchand had already searched his players' bags.
Coach Marchand consented to a police search; a 45–60 minute search occurred with items not found; crowd persisted nearby.
Plaintiffs alleged coercion and racial animus; officers defended qualified immunity and argued consent was voluntary under Schneckloth framework.
District court granted summary judgment for defendants; First Circuit affirmed the grant on Fourth Amendment and state privacy, and on equal protection claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers are entitled to qualified immunity for the Fourth Amendment search	Lopera argues Marchand lacked authority and coercion vitiated consent.	Officers argue Marchand had power to consent and coercion did not vitiate it.	Yes, officers entitled to qualified immunity
Whether Marchand's consent was coerced under Schneckloth framework	Consent was coerced by crowd coercion and police conduct.	Consent was voluntary; officers did not coerce in a way that violated law.	Yes, consent not clearly coerced; qualified immunity upheld
Whether plaintiffs' Equal Protection and Rhode Island racial discrimination claims survive	Police actions were motivated by race; crowd and officers discriminated.	No proven discriminatory intent; actions not clearly established as race-based.	No, claims fail under qualified immunity

Schneckloth v. Bustamonte, 412 U.S. 218 (Sup. Ct. 1973) (consent must be voluntary considering all circumstances)
United States v. Drayton, 536 U.S. 194 (Sup. Ct. 2002) (politeness and absence of coercive signals do not defeat coercion analysis)
Florida v. Bostick, 501 U.S. 429 (Sup. Ct. 1991) (voluntariness of consent assessed by totality of circumstances and liberty to decline)
United States v. Vanvliet, 542 F.3d 259 (1st Cir. 2008) (factors in voluntariness of consent, including coercive tactics and detentions)
United States v. Robinette, 519 U.S. 33 (Sup. Ct. 1996) (consent to search must be voluntary; voluntariness is a question of fact)
Pearson v. Callahan, 555 U.S. 223 (Sup. Ct. 2009) (courts may apply second prong of qualified immunity without first prong)
Anderson v. Creighton, 483 U.S. 635 (Sup. Ct. 1987) (objective reasonableness in qualified immunity depends on information possessed)
Kaupp v. Texas, 538 U.S. 626 (Sup. Ct. 2003) (coercion analysis requires considering whether defendant felt free to leave)
Colorado v. Connelly, 479 U.S. 157 (Sup. Ct. 1986) (due process coercion standard does not extend to Fourth Amendment consent cases)