The U.S. Court of Appeals for the First Circuit affirmed a lower court's dismissal of civil rights and tort claims filed by Sharon Radfar against multiple Revere, Massachusetts police officials in a decision issued Jan. 6, 2026.
The case, *Radfar v. Covino* (1st Cir. 2026), involved claims against Sergeant Joseph I. Covino of the Revere Police Department, who was Radfar's former romantic partner, as well as Mayor Brian M. Arrigo, former Police Chief James Guido, and the City of Revere itself. All defendants were sued both individually and in their official capacities.
The First Circuit panel, consisting of Circuit Judges Aframe, Lipez, and Howard, issued a brief opinion that praised the district court's handling of the case. Writing for the court, Circuit Judge Aframe noted that the appeals court follows the principle that "where a trial court correctly takes the measure of a case and authors a convincing decision, it rarely will serve any useful purpose for a reviewing court to wax longiloquent."
The opinion characterized the case as "an exemplar case for following that maxim," indicating the First Circuit found the district court's analysis thorough and well-reasoned.
According to the appeals court record, Radfar brought both civil rights claims and tort claims against the defendants. The nature of her relationship with Covino as a "former romantic interest" suggests the case may have involved allegations of abuse of police power in a personal context, though the specific factual allegations were not detailed in the appeals court opinion.
U.S. District Judge Indira Talwani of the District of Massachusetts issued two separate opinions in the case, both dismissing claims against what the First Circuit termed the "Revere Defendants." The district court found that Radfar failed to state a claim upon which relief could be granted, a standard legal ruling that typically means the plaintiff's allegations, even if true, would not support a viable lawsuit under applicable law.
The dismissal encompassed claims against Mayor Arrigo, former Chief Guido, and other unnamed officers of the Revere Police Department, in addition to the city itself. This suggests Radfar may have alleged a pattern of misconduct or supervisory liability extending beyond just Covino's individual actions.
Civil rights lawsuits against police officers and municipalities are typically brought under 42 U.S.C. Section 1983, which allows individuals to sue government officials for violations of constitutional rights. Such cases often involve claims of excessive force, false arrest, or other police misconduct. The involvement of municipal defendants suggests Radfar may have alleged institutional problems or inadequate training and supervision.
The fact that both individual and official capacity claims were dismissed indicates the court found no basis for either personal liability or institutional responsibility. Individual capacity claims seek damages from the officers personally, while official capacity claims effectively sue the government entity that employs them.
The appeals court's decision to issue only a brief opinion affirming the dismissal suggests the legal issues were straightforward and the district court's reasoning was sound. The First Circuit's practice of deferring to well-reasoned trial court decisions reflects judicial efficiency and respect for the lower court's factual findings and legal analysis.
Elizabeth M. Clague represented Radfar on appeal, while Kenneth H. Anderson of Anderson, Goldman, Tobin, Pasciucco, L.L.P., represented Covino. Daniel E. Doherty represented the other municipal defendants.
The case adds to the body of law governing civil rights claims against police officers, particularly in situations involving personal relationships. Courts often scrutinize such cases carefully to distinguish between legitimate civil rights violations and personal disputes that may not rise to the level of constitutional violations.
For plaintiffs bringing Section 1983 claims, the decision illustrates the importance of adequately pleading both the constitutional violation and the defendants' personal involvement. Municipal liability requires showing either an official policy or custom that caused the violation, or deliberate indifference by supervisory officials.
The brief nature of the First Circuit's opinion, while efficient, leaves the specific legal reasoning unexplored in the public record. The notation that the opinion is "Not for Publication in West's Federal Reporter" means it will have limited precedential value for future cases.
The affirmance represents the final resolution of Radfar's claims against the Revere officials, absent any petition to the Supreme Court. The case demonstrates the challenges plaintiffs face in civil rights litigation against law enforcement, particularly when personal relationships complicate the legal landscape.
While the specific facts underlying Radfar's allegations remain unclear from the appeals court record, the decisive dismissal at both the district and circuit court levels suggests significant legal obstacles to her claims under federal civil rights law.