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

Over a period of 35 years, the defendant operated a dogfighting enterprise known as Stone City Kennel, where he bred, trained, and sold dogs for fighting, mentored others in the practice, and participated in over 150 dogfights across the Americas and the Caribbean. He was known as a prominent figure in the dogfighting world. After admitting incriminating information to an undercover agent, he was indicted in the District of Puerto Rico for conspiracy to violate the Animal Welfare Act (AWA) and for possession of dogs for use in animal fighting. A search of his property revealed four dogs in poor condition, leading to a superseding indictment with additional possession counts. He ultimately pleaded guilty to one conspiracy count and two possession counts.The United States District Court for the District of Puerto Rico grouped the offenses and calculated a Sentencing Guidelines Range (GSR) of 12 to 18 months. However, the Presentence Investigation Report and the government argued for a much higher sentence, citing the exceptional scale and cruelty of the defendant’s conduct. At sentencing, the court heard expert testimony and considered the defendant’s extensive involvement, the cruelty involved, and the need for deterrence. The court imposed an 84-month sentence: 36 months for conspiracy and 24 months for each possession count, to be served consecutively, and described the sentence as an upward variance based on the statutory sentencing factors.On appeal, the United States Court of Appeals for the First Circuit reviewed the defendant’s challenges, including claims of double jeopardy, inadequate explanation, and substantive unreasonableness. The court held that consecutive sentences for conspiracy and possession did not violate double jeopardy, that the statutory text allowed separate punishment for each dog possessed, and that the district court adequately explained and justified the upwardly variant sentence. The First Circuit affirmed the judgment of the district court. View "United States v. Casillas-Montero" on Justia Law

Plaintiffs, committed animal rights activists, filed this action seeking declaratory and injunctive relief that the Animal Enterprise Terrorism Act (“Act”), which criminalizes “force, violence, and threats involving animal enterprises,” violates the First Amendment. Plaintiffs had never been prosecuted or threatened with prosecution under the Act but claimed that fear of future prosecution and present self-restraint caused them to suffer injury in fact. The district court dismissed the complaint, holding that Plaintiffs failed to establish an injury in fact as required by Article III. The First Circuit Court of Appeals affirmed, holding that Plaintiffs’ unsubstantiated and speculative fear of prosecution under the Act was not a basis for standing under U.S. Const. art. III. View "Blum v. Holder" on Justia Law