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

Articles Posted in Criminal Law
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The First Circuit vacated the district court's judgment denying Defendant's motion to vacate his 18 U.S.C. 924(c) conviction and to resentence him without a career offender enhancement, holding that because Johnson v. United States, 576 U.S. 591 (2015) established that the U.S. Sentencing Guidelines' residual clause before United States v. Booker, 54 U.S. 220 (2005), was decided was too vague to constitutionally enhance a defendant's sentence, Defendant's claims were timely.Defendant was convicted under section 924(c). The judge classified Defendant as a career offender under section 4B1.1 of the guidelines. Thereafter, the Supreme Court decided Booker, which held that the mandatory Guidelines system was unconstitutional. Thereafter, the Supreme Court announced a new rule of law in Johnson that imposing an increased sentence under the residual clause of the Armed Career Criminal Act is unconstitutionally vague. Defendant moved to vacate his conviction and sentence, arguing that the Court's reasoning in Johnson made similar residual clauses in section 942(c) and section 4B1.2(a) unconstitutionally vague as well. The district court denied the motion. The First Circuit vacated the judgment, holding (1) Johnson dictates that 4B1.2(a)'s residual clause is unconstitutionally vague; and (2) as a result, Defendant asserted the same right newly recognized in Johnson, making his petition timely. View "Shea v. United States" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed Defendant's sentence for federal charges of sex trafficking, drug trafficking, and interstate transportation of a person for prostitution in violation of the Mann Act, holding that the district court did not err in applying a "vulnerable victim" enhancement.At sentencing, the district court determined that Defendant's victim was a vulnerable victim for purposes of applying a two-level enhancement. The court then sentenced Defendant to 320 months' imprisonment on the sex and drug trafficking counts and to concurrent 120-month sentences on the Mann Act counts. The First Circuit affirmed the sentence, holding that Defendant's sentence was not affected by the district court's conclusion that the enhancement for vulnerable victims was warranted under the United States Sentencing Guidelines, and therefore, any alleged error in the application of that enhancement would have been harmless. View "United States v. Graham" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed Defendant's convictions for his role as a leader and organizer of a major drug-trafficking organization, holding that the district court did not err in denying Defendant's pro se motions to withdraw his guilty plea and to appoint new counsel.Defendant entered into a plea agreement with the government and, pursuant to that agreement, was sentenced to 240 months of imprisonment. Defendant later made a statement that the district court construed as making a motion to withdraw the guilty plea and a motion to appoint new counsel. After a hearing, the court denied both motions. The First Circuit affirmed, holding that the district court (1) did not abuse its discretion in denying Defendant's motion to appoint new counsel; and (2) did not err in denying Defendant's motion to withdraw his guilty plea. View "United States v. Valdez" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed Defendant's conviction of one count of transporting child pornography and one count of possessing child pornography, holding that Defendant's sentence was substantively reasonable and that the district court did not abuse its discretion when it imposed two special conditions of supervised release.Defendant pleaded guilty without a plea agreement. After a hearing, the district court sentenced Defendant to 156 months in prison and imposed conditions of supervised release that included restrictions on Defendant's contact with children. The First Circuit affirmed, holding (1) Defendant's 156-month sentence was not outside the universe of reasonable sentences; and (2) there was a sufficient relationship between Defendant's criminal conduct and the conditions limiting his contact with his son. View "United States v. Benoit" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed the ruling of the district court granting Defendant's motion for a judgment of acquittal on the grounds that there was insufficient evidence to support Defendant's conviction of one count of conspiracy to distribute and possess with intent to distribute heroin, holding that the district court did not err.After Defendant was found guilty the district court granted Defendant's motion for a judgment of acquittal pursuant to Fed. R. Crim. P. 29, finding that the evidence was insufficient to permit a reasonable juror to find beyond a reasonable doubt that Defendant knowingly either agreed to participate or participated in the alleged conspiracy. The First Circuit affirmed, holding that there was insufficient evidence to show beyond a reasonable doubt that Defendant agreed to participate or participated in the drug conspiracy. View "United States v. Guzman-Ortiz" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed Defendant's sentence for being a felon in possession of a firearm and ammunition and for unlawfully possessing a machine-gun but remanded for the district court to docket a sealed copy of the written statement of reasons (SOR) in order for Defendant to prepare his appeal, holding that there was no basis for withholding the SOR from Defendant.Specifically, the First Circuit held (1) the district court did not commit procedural error by unduly relying on conjecture to impose an upward variant sentence; (2) Defendant's sentence was substantively reasonable because it was within the "universe of reasonable sentences"; and (3) practice and policy required that defense counsel have access to the SOR. View "United States v. Morales-Negron" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed Defendant's convictions and sentences for several sex crimes, including using a facility and means of interstate commerce to knowingly induce a thirteen-year-old female to engage in sexual activity, in violation of 18 U.S.C. 2422(b), and transporting minors in a commonwealth with the same illicit intent, in violation of 18 U.S.C. 2423(a), holding that there was no reversible error.Specifically, the First Circuit held (1) there was sufficient evidence to support each one of Defendant's convictions; (2) any error in letting a law enforcement officer testify about text messages taken off Defendant's cell phone and about an app without being qualified as an expert in "cell phone extractions or forensic analysis" was harmless; and (3) Defendant's sentence was both procedurally and substantively reasonable. View "United States v. Montijo-Maysonet" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed Defendant's sentence that he received for his conviction for possession of a machine gun, holding that the sentence was neither procedurally nor substantively unreasonable.After the district court concluded that Defendant was competent Defendant pleaded guilty to violating 18 U.S.C. 922(o) and 924(a)(2). After a sentencing hearing, the district court imposed a ninety-six-month prison sentence followed by three years of supervised release. The First Circuit affirmed, holding (1) even assuming that Defendant failed to preserve his procedural challenges, there was no clear error in the district court's fact-finding; and (2) under the totality of the circumstances, the district court's chosen sentence was not outside the "universe of reasonable sentences." View "United States v. Lopez-Delgado" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed Defendant's sentence for being a felon in possession of a firearm, holding that the district court did not err in imposing a sentencing enhancement for possessing a firearm "in connection with another felony offense."Defendant pled guilty to being a felon in possession of a firearm and was sentenced to 120 months in prison. The sentencing court applied a four-level enhancement for handling at least eight firearms, a four-level enhancement for possessing a firearm in connection with another felony offense, and a two-level enhancement for obstructing justice. On appeal, Defendant challenged the district court's application of the four-level sentencing enhancement for possessing a firearm in connection with another felony offense. The First Circuit affirmed, holding that the evidence supported the finding that Defendant committed "another felony offense" and possessed a firearm "in connection with" such offense. View "United States v. Newton" on Justia Law

Posted in: Criminal Law
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The First Circuit affirmed Defendant's convictions, entered pursuant to his guilty plea, for eight counts of sexual exploitation of a minor and one count of possession of child pornography and dismissed Defendant's challenges to his sentence, holding that that the district court did not err.Specifically, the First Circuit held (1) th district court did not plainly error in concluding that the factual foundation for Defendant's plea to two of his eight convictions for sexual exploitation of a minor sufficed to give it a reasoned basis to believe that Defendant actually committed the crime to which he was admitting guilt; and (2) the appeal waiver in Defendant's plea agreement barred this Court's consideration of the substance of Defendant's challenges to the procedural and substantive reasonableness of his sentence. View "United States v. Goodman" on Justia Law

Posted in: Criminal Law