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

After a jury trial, Defendant was convicted of two counts of drug conspiracy and two counts of murder. Defendant was sentenced to life imprisonment. The First Circuit affirmed, holding that the district court did not err or abuse its discretion in (1) denying Defendant’s motion to suppress wiretap evidence; (2) denying Defendant’s motion to suppress evidence seized from his car and farm pursuant to a search warrant; (3) failing to hold an evidentiary hearing to investigate allegations of juror bias and by failing to grant a new trial on account of that alleged bias; (4) denying Defendant’s motions challenging the Government’s decision to seek the death penalty; and (5) denying Defendant’s motion for acquittal or new trial on the basis of insufficient evidence to convict. Lastly, the evidence presented at trial regarding the duration of the drug conspiracy did not constitute a fatal variance from that charged in the indictment, and any possible error in the district court’s evidentiary rulings was harmless beyond a reasonable doubt. View "United States v. Burgos-Montes" on Justia Law

After a jury trial, Junior H. De La Cruz-Feliciano and Sandri Rigo were convicted of conspiring to possess with intent to distribute five kilograms of cocaine and aiding and abetting the same. The First Circuit affirmed, holding (1) the district court’s questioning of a witness did not evince judicial bias in violation of De La Cruz’s right to due process; (2) the Government’s belated disclosure of errors in an investigative report prior to Rijo’s counsel’s opening statement did not prevent defense counsel from using it in preparing and presenting Rijo’s case; (3) the district court did not err in admitting evidence of Rijo’s prior bad acts; and (4) the Government’s closing argument accurately described Rijo’s role in the offense. View "United States v. De La Cruz-Feliciano" on Justia Law

Defendant pleaded guilty to conspiracy to distribute more than 500 grams of cocaine and more than 280 grams of crack. Defendant did not admit that he was responsible for a particular quantity of either form of drug. During the sentencing hearing, the district court found, by a preponderance of the evidence, that Defendant was personally responsible for 765.5 grams of crack. The court imposed a ten-year mandatory minimum sentence. While Defendant’s appeal was pending, the Supreme Court handed down Alleyne v. United States, which held that the Sixth Amendment guarantees that such qualifying fact issues are subject to jury findings beyond a reasonable doubt. The First Circuit affirmed, holding (1) the court’s judicial fact-finding of drug quantities in this case was impermissible; but (2) the error was harmless in light of concessions made by Defendant’s counsel and overwhelming evidence that Defendant was responsible for at least 280 grams of crack. View "United States v. Morris" on Justia Law

Before Defendant was under suspicion on federal child pornography charges, the Puerto Rico police carried out two searches that resulted in the seizure of various electronic devices. After the Puerto Rico police had informed federal authorities about images they had found on the devices, federal agents approached Defendant’s then-wife, who consented to the federal agents’ examination of the family’s desktop computer. A federal grand jury subsequently indicted Defendant for numerous child pornography counts. Defendant pleaded guilty and then appealed, arguing that the district court erred in denying his suppression motion. The First Circuit vacated the judgment of the district court, holding (1) the two searches carried out by the Puerto Rico police violated the Fourth Amendment; and (2) because the district court did not address whether those unlawful searches tainted the evidence federal authorities acquired pursuant to the consent of Defendant’s then-wife, the case must be remanded for an evidentiary hearing on the issue. View "United States v. Cordero-Rosario" on Justia Law

Defendant was convicted of conspiracy to distribute heroin and distribution of heroin. The First Circuit affirmed the convictions and sentences, holding that the district court (1) did not violate the Confrontation Clause by allowing into evidence testimony from an FBI agent that relayed the agent’s own observations and not statements made out of court by someone Defendant could not confront at trial; (2) did not deprive Defendant of his constitutional right to present a defense by denying his request to call a particular witness; and (3) did not err in its factual determinations under the Sentencing Guidelines or impose a term of imprisonment that was substantively unreasonable. View "United States v. Occhiuto" on Justia Law

Defendant was indicted for violating 18 U.S.C. 922(n), which makes it unlawful for a person who is under indictment for a certain category of crime to receive any firearm or ammunition which has been transported in interstate or foreign commerce. Defendant filed a motion to suppress, alleging that the evidence seized from his home was discovered pursuant to a state search warrant filled with false statements, and that without those statements, probable cause for the warrant was lacking. After a Franks hearing, the magistrate judge recommended that the district court grant the motion to suppress, concluding that the sworn statement in support of the search warrant had false and misleading information, without which probable cause for the search warrant was insufficient. After a de novo Franks hearing, the district court rejected the magistrate’s report and recommendation and denied Defendant’s motion to suppress. The First Circuit affirmed, holding that because Defendant’s argument boiled down to a credibility determination by the district court - something that the First Circuit will not second-guess - there was easily probable cause to issue the search warrant, and therefore, Defendant’s motion to suppress was properly denied. View "United States v. Guzman-Batista" on Justia Law

This putative class action was brought on behalf of ten foster children in the custody of the Rhode Island Department of Children, Youth and Families (DCYF). The complaint alleged that DCYF’s failings exposed foster children in its custody to an unreasonable risk of harm and that the State had failed to comply in various respects with the Adoption Assistance and Child Welfare Act. After much skirmishing between the parties and delay during discovery, trial commenced. At that point, the claims of all but two of the named plaintiffs had been rendered moot through aging or adoption. The district court concluded (1) Plaintiffs had presented insufficient evidence to establish that DCYF’s policies and customs had either harmed them or exposed them to an unreasonable risk of harm, and (2) Plaintiffs failed to carry their burden of proof with respect to their statutory causes of action. Plaintiffs appealed, claiming myriad errors relating to pretrial proceedings. The First Circuit vacated the judgment, holding that the district court abused its discretion when it, in two case management orders, denied Plaintiffs’ counsel access to their own clients and prevented Plaintiffs from seeking plainly relevant discovery. View "Danny B. v. Raimondo" on Justia Law

A police detective applied for a warrant to search Defendant’s home. The warrant application was supported by an affidavit in which the detective attested that he had probable cause to believe Defendant was hiding marijuana in his residence based on information the detective received from a confidential informant. A state justice of the peace signed off on the warrant. During a search of Defendant’s home, police found marijuana and an illegal gun. Defendant was subsequently indicted on drug and firearm charges. Defendant filed a motion to suppress the seized evidence and sought an evidentiary hearing to challenge the detective’s credibility. The magistrate judge denied the motion without an evidentiary hearing. The First Circuit affirmed, holding that the trial court did not err by denying Defendant the opportunity to challenge the detective’s affidavit at a formal Franks hearing. View "United States v. Graf" on Justia Law

Petitioner was convicted on several state charges, including unlawful possession of a firearm. The Massachusetts Supreme Judicial Court (SJC) affirmed. The SJC rejected Petitioner’s due process challenge to the Commonwealth’s failure to present evidence that he lacked a firearms license, concluding that the accused of unlawful possession of a firearm has the burden of producing evidence of a license as an affirmative defense. Petitioner sought federal habeas relief, which the district court denied. The First Circuit affirmed, holding (1) the SJC’s conclusion that this state criminal procedure comports with federal due process does not conflict with clearly established Supreme Court precedent; (2) Petitioner’s Second Amendment and related Equal Protection claims provide no basis for disturbing Petitioner’s state firearms convictions; and (3) Petitioner’s Sixth Amendment ineffective assistance of counsel claim is waived. View "Powell v. Tompkins" on Justia Law

An unidentified caller informed law enforcement officers that, as he was driving, he had observed a pistol being openly passed between the passengers of the the car in front of him. Acting on the information, police officers ordered Defendant to get out of a parked car and frisked him. The officers discovered a loaded pistol in Defendant’s possession. Defendant subsequently pled guilty to possession of a firearm by a prohibited person. Defendant appealed the denial of his motion to suppress the evidence of the firearm from the frisk, arguing that the information provided by the anonymous caller was not sufficiently reliable to provide the officers with the reasonable suspicion. The First Circuit affirmed, holding that the report from the unidentified caller was sufficiently reliable to create reasonable suspicion of criminal activity under Puerto Rico law, thus justifying the police officers’ decision to stop and frisk the vehicle’s occupants. View "United States v. Aviles-Vega" on Justia Law