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

Luis Javier Matta Quiñones was convicted of possession of firearms and ammunition as a prohibited person and possession of a machinegun. Matta claimed he was wrongfully accused by police officers who found contraband nearby. He attempted to discredit the officers' testimony that he threw a feed sack containing guns and ammunition onto a roof while fleeing. Matta argued on appeal that the district court hindered his defense in several ways, including allowing the government's case agent to be present during jury deliberations.The United States District Court for the District of Puerto Rico oversaw Matta's trial. The jury found Matta guilty on both charges. Matta moved for a judgment of acquittal and a new trial, arguing insufficient evidence and improper jury contact by the case agent. The district court denied both motions, reasoning that Matta had waived objections to the case agent's presence and that the contact was brief and non-prejudicial. Matta was sentenced to 96 months' imprisonment, with an additional 18 months for revocation of supervised release.The United States Court of Appeals for the First Circuit reviewed the case. The court found sufficient evidence to support Matta's convictions but agreed that the district court erred by allowing the case agent to be present during jury deliberations without proper investigation into potential juror misconduct. The appellate court vacated Matta's convictions and remanded for a new trial. The court also vacated the revocation of supervised release sentence and remanded for resentencing. Additionally, the court addressed evidentiary issues likely to recur, ruling that Matta should have been allowed to cross-examine Officer Vidal about prior statements and that the Receipt Form could be admissible under the business records exception. View "United States v. Matta-Quinones" on Justia Law

In the 1990s, José A. Vega-Figueroa was involved in a drug-trafficking operation in Puerto Rico. He was charged in 1994 with multiple offenses, including first-degree murder, but was acquitted by a jury in 1995. In 1997, a federal grand jury indicted him for his role in a criminal enterprise involving the distribution of various drugs and related violent acts. After a thirty-day trial, he was found guilty on all counts and sentenced to multiple life sentences. Vega has since made several unsuccessful attempts to challenge his conviction and sentence.In February 2021, Vega filed a motion for compassionate release in the District of Puerto Rico, citing his health conditions and the risk of COVID-19 complications. He also argued that his rehabilitation efforts and the double jeopardy of being tried for the same conduct warranted his release. The district court denied his motion, finding that the Bureau of Prisons had taken adequate measures to protect inmates from COVID-19 and that Vega's health conditions did not meet the criteria for compassionate release. The court also determined that Vega remained a danger to the community, given his criminal history and prison infractions.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's decision, agreeing that Vega's health conditions and the measures taken by the Bureau of Prisons did not constitute extraordinary and compelling reasons for release. The appellate court also upheld the district court's assessment that Vega continued to pose a danger to the community, thus justifying the denial of his motion for compassionate release. View "United States v. Vega-Figueroa" on Justia Law

The U.S. Department of Education announced a reduction in force (RIF) on March 13, 2025, affecting about half of its employees. Subsequently, twenty-one states and several labor organizations and school districts filed lawsuits against the Secretary of Education, the Department, and the President, claiming that the RIF violated the U.S. Constitution and the Administrative Procedure Act (APA). They also sought an injunction against the transfer of certain functions out of the Department, announced by the President on March 21, 2025.The U.S. District Court for the District of Massachusetts consolidated the cases and granted the plaintiffs' motions for a preliminary injunction. The court found that the plaintiffs were likely to succeed on the merits of their claims, determining that the RIF and the transfer of functions were likely ultra vires and violated the APA. The court concluded that the actions were arbitrary and capricious, lacking a reasoned explanation and failing to consider the substantial harms to stakeholders.The United States Court of Appeals for the First Circuit reviewed the case. The court denied the appellants' motion for a stay pending appeal. The court found that the appellants did not make a strong showing that they were likely to succeed on the merits, particularly regarding the APA claims. The court also determined that the plaintiffs would suffer substantial injury without the injunction, as the RIF made it effectively impossible for the Department to carry out its statutory functions. The court concluded that the public interest favored maintaining the injunction to ensure the Department could fulfill its legal obligations. View "New York v. McMahon" on Justia Law

José Luis Meléndez-Rivera and an associate committed a carjacking in Bayamón, Puerto Rico, during which Meléndez shot one of the victims in the face. Meléndez was arrested and charged with multiple offenses, including carjacking resulting in serious bodily injury and firearm-related charges. He initially pled not guilty but later negotiated a plea agreement with the government, agreeing to plead guilty to the carjacking charge in exchange for the dismissal of other charges.The United States District Court for the District of Puerto Rico did not accept the initial plea agreement, prompting Meléndez to withdraw his plea. A new plea agreement was reached, recommending a 180-month sentence for the carjacking charge. At sentencing, the court considered the presentence investigation report (PSR), the plea agreement, and Meléndez's sentencing memorandum, which detailed his difficult upbringing and history of recidivism. The court ultimately imposed a 198-month sentence, citing Meléndez's extensive criminal history and the need for deterrence and punishment.On appeal to the United States Court of Appeals for the First Circuit, Meléndez argued that the government breached the plea agreement by failing to meaningfully advocate for the recommended 180-month sentence and that the sentence was procedurally unreasonable because the court did not consider his mitigation arguments. The First Circuit found no plain error in the government's conduct, concluding that the prosecutor fulfilled her obligation by requesting the agreed-upon sentence. The court also held that the sentence was procedurally reasonable, as the district court had considered the relevant factors and Meléndez's mitigation arguments, even if it did not explicitly address each one. The First Circuit affirmed the district court's judgment. View "United States v. Melendez-Rivera" on Justia Law

Lester Aceituno was convicted of conspiracy to commit bank fraud and two counts of aggravated identity theft. The fraudulent scheme involved using stolen identification information to open bank accounts, change addresses to rented mailboxes, deposit fraudulent checks, and withdraw funds using debit cards. Aceituno opened accounts in New Hampshire and Massachusetts using stolen identities and signed documents attesting to the accuracy of the information. He also created a mailbox using a stolen identity. The scheme was led by a man known as "Abby," who provided the stolen information.The United States District Court for the District of New Hampshire denied Aceituno's Rule 29 motion, which argued insufficient evidence to prove he knew he was using real persons' identifying information. The court also rejected his claim of prosecutorial misconduct during the government's closing argument and rebuttal. Aceituno was sentenced to 30 months in prison.The United States Court of Appeals for the First Circuit reviewed the case. The court held that sufficient evidence supported the jury's finding that Aceituno knew the identification information belonged to real people. The evidence included Aceituno's repeated use of stolen identities, the bank's verification process, and testimony from a co-conspirator. The court also found that the prosecution's statements during closing arguments were fair inferences from the evidence and did not constitute misconduct. The court affirmed Aceituno's conviction. View "United States v. Aceituno" on Justia Law

Dana A. Pullman, a former Massachusetts State Police trooper and president of the State Police Association of Massachusetts (the Union), and Anne M. Lynch, head of the lobbying firm Lynch Associates, were involved in a kickback scheme. Pullman hired Lynch Associates to assist with a grievance negotiation, initially agreeing to a $200,000 fee. Later, Pullman verbally agreed to increase the fee to $350,000. After the Union received reimbursement from the Commonwealth, Pullman pressured the Union treasurer to issue a $250,000 check to Lynch Associates. Lynch then paid $20,000 to Pullman's wife. Both Pullman and Lynch were convicted of honest-services wire fraud, among other charges.The United States District Court for the District of Massachusetts convicted Pullman and Lynch of honest-services wire fraud, wire fraud, obstruction of justice, conspiracy to defraud the United States, and a racketeering conspiracy. Pullman and Lynch challenged the sufficiency of the evidence and the jury instructions, particularly regarding the honest-services wire fraud convictions. They argued that the evidence did not support a quid pro quo arrangement and that the jury instructions improperly suggested Pullman owed a fiduciary duty to the Commonwealth.The United States Court of Appeals for the First Circuit reviewed the case. The court found sufficient evidence to support the honest-services wire fraud convictions, noting the jury could reasonably infer a quid pro quo arrangement. The court also held that any instructional error regarding Pullman's fiduciary duty to the Commonwealth was harmless, as the evidence overwhelmingly showed he breached his fiduciary duty to the Union. The court reversed the wire fraud convictions and one of Lynch's tax fraud convictions based on the government's concession. The court affirmed the other convictions, including those for honest-services wire fraud, obstruction of justice, and the RICO conspiracy. The case was remanded for resentencing. View "United States v. Pullman" on Justia Law

The case involves Jovan Vavic, a former head coach of the men's and women's water polo teams at the University of Southern California (USC), who was implicated in the "Varsity Blues" college admissions scandal. Vavic was accused of facilitating the admission of students as fake athletic recruits in exchange for payments from Rick Singer, a college consultant orchestrating the scheme. The payments were allegedly made to benefit Vavic's water polo program and his sons' private school tuition.In the lower court, the United States District Court for the District of Massachusetts presided over the case. A jury convicted Vavic on three counts: conspiracy to commit mail and wire fraud and honest services mail and wire fraud, conspiracy to commit federal programs bribery, and wire fraud and honest services wire fraud. However, the district court granted Vavic a new trial, concluding that certain statements made by the government during its rebuttal closing amounted to prosecutorial misconduct. The court found that the government's statements misrepresented the law and facts, particularly regarding the payments to USC and the alleged $100,000 bribe for Agustina Huneeus's recruitment.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's order for a new trial on the honest services fraud charge (Count Sixteen) due to a Yates error, as it was impossible to determine if the jury's verdict rested on an invalid legal theory following the decision in United States v. Abdelaziz. However, the appellate court reversed the new trial order for the federal programs bribery conspiracy charge (Count Three), concluding that the government's statements did not constitute plain error and that there was no prejudicial variance or Napue error. The case was remanded for further proceedings consistent with the appellate court's opinion. View "US v. Vavic" on Justia Law

Plaintiffs, who own or operate gasoline service stations in Puerto Rico, offered two different prices to consumers: a higher price for those using credit or debit cards and a lower price for those paying with cash. In 2013, Puerto Rico's legislature enacted Law 152-2013, amending Law 150-2008 by removing a provision that allowed merchants to offer cash discounts. Plaintiffs ceased offering the lower price due to the threat of fines and criminal prosecution. They sued the Commonwealth of Puerto Rico, arguing that Law 150 is preempted by federal law and is unconstitutionally vague.The United States District Court for the District of Puerto Rico rejected the plaintiffs' arguments and granted the Commonwealth's motion to dismiss for failure to state a claim. The court found that neither the Cash Discount Act (CDA) nor the Durbin Amendment preempted Law 150. The court also declined to address the constitutional vagueness argument, noting that the complaint did not allege that Law 150 is unconstitutionally vague.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the CDA and the Durbin Amendment do not preempt Law 150. The CDA regulates the conduct of credit card issuers, not merchants or states, and does not confer an absolute right to offer cash discounts. The Durbin Amendment regulates payment card networks, not states, and does not preempt state legislation restricting cash discounts. The court also found that the plaintiffs did not properly plead a vagueness claim in their complaint, rendering the claim unpreserved for appellate review. Consequently, the First Circuit affirmed the district court's dismissal of the case. View "Asociacion de Detallistas de Gasolina de PR Inc. v. Commonwealth of Puerto Rico" on Justia Law

In this case, the defendant, Admilson Pires, was convicted by a jury of conspiracy to commit sex trafficking of a minor and sex trafficking of a minor. The case began when the Norwood Police Department received a tip about a missing sixteen-year-old girl, Daisy, who was found at an apartment in Norwood, Massachusetts. Daisy revealed that she had been engaging in commercial sex. During the investigation, it was discovered that Pires and another individual, Sandro Rosa (known as Eli), were involved in trafficking Daisy.The United States District Court for the District of Massachusetts conducted the trial, where Pires was found guilty on both counts. He was sentenced to 132 months' imprisonment for each count, to be served consecutively. Pires appealed, arguing that the evidence was insufficient to support his conspiracy conviction and that there were errors in the trial, including the admission of expert testimony and statements made by the prosecution during summation.The United States Court of Appeals for the First Circuit reviewed the case. The court found that there was sufficient evidence to support the conspiracy conviction, noting that Eli's involvement went beyond merely providing shelter and included actions that indicated a tacit agreement to traffic Daisy. The court also held that the expert testimony about typical patterns of sex trafficking was admissible and relevant to the case, and that the prosecutor's statements during summation did not amount to misconduct that would warrant a reversal of the conviction.The First Circuit affirmed the district court's judgment, upholding Pires's convictions and sentences. View "U.S. v. Pires" on Justia Law

Bruce Anderson killed his estranged wife in 1983 and was convicted of first-degree murder by a Massachusetts jury in 1989, receiving a life sentence without parole. After an unsuccessful appeal to the Massachusetts Supreme Judicial Court, Anderson filed a federal habeas corpus petition in 1991, which was denied by the United States District Court for the District of Massachusetts. The First Circuit affirmed the denial, and the United States Supreme Court denied certiorari in 1994.In 2019, Anderson filed a second habeas petition under section 2254, claiming ineffective assistance of counsel by Attorney Stephen Hrones, who represented him at trial, on direct appeal, and during the first federal habeas proceedings. The district court dismissed the petition without prejudice, citing it as a "second or successive habeas corpus application" that lacked authorization from the First Circuit. Anderson did not appeal this dismissal but instead sought authorization from the First Circuit, which was denied.The United States Court of Appeals for the First Circuit reviewed whether Anderson's second habeas petition was "a second or successive habeas corpus application" under 28 U.S.C. § 2244(b)(2). The court concluded that it was, emphasizing that pre-AEDPA practice and AEDPA's purposes support treating such petitions as successive. The court noted that Anderson's choice to retain the same counsel for his first habeas petition did not exempt his second petition from being considered successive. The court vacated the district court's denial of the petition and remanded it with instructions to dismiss. The court also affirmed the district court's decision that any Rule 60(b) motion by Anderson would be untimely. View "Anderson v. Divris" on Justia Law