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

In this case, Grace Katana appealed his conviction for conspiracy to interfere with interstate commerce by robbery in violation of the Hobbs Act. He argued that the indictment accused him of conspiring to rob Joseph Wilson, while the government only proved at trial that he had planned a break-in at Wilson's home. Katana claimed that this constituted a constructive amendment to the indictment in violation of his constitutional rights, that there was a prejudicial variance from the charge in the indictment, and that there was insufficient evidence to support his conviction.The United States Court of Appeals for the First Circuit rejected Katana's arguments and affirmed his conviction. The court found that the offense charged in the indictment was the same offense on which the court instructed the jury and on which the government presented evidence. The court also held that the identity of the robbery target was not an element of a robbery or conspiracy to commit robbery under the Hobbs Act, so focusing on Wilson's home business as the target at trial did not amount to a constructive amendment. The court further concluded that Katana failed to demonstrate that any variance from the indictment was prejudicial, as the record showed he had sufficient notice of, and was able to defend himself against, the government's theory at trial. Finally, the court ruled that a rational jury could have concluded that Katana and his co-conspirators planned to rob Wilson's home business, so there was sufficient evidence to support his conviction. View "US v. Katana" on Justia Law

In the case before the United States Court of Appeals for the First Circuit, the defendant, Randall Crater, was convicted of wire fraud, unlawful monetary transactions, and operating an unlicensed money transmitting business based on his involvement in a cryptocurrency scheme. The trial lasted eight days and was based on Crater's management of My Big Coin (MBC), a cryptocurrency company that allegedly misrepresented itself as a gold-backed digital currency and claimed a partnership with MasterCard. The defendant appealed two of the district court's rulings.Firstly, Crater argued that the district court violated his Sixth Amendment right to compulsory process by refusing to enforce subpoenas against three federal agency witnesses due to Crater's non-compliance with the agencies' Touhy regulations. Secondly, Crater contended that the district court did not perform its gatekeeping duty by admitting testimony from the government's cryptocurrency expert without holding a Daubert hearing.However, the Court of Appeals affirmed the district court's decision, stating that Crater's arguments could not be reconciled with controlling precedent or the record in the case. The court found that Crater's failure to show how the excluded testimony of the federal agents would have been both material and favorable to his defense invalidated his Sixth Amendment claim. Furthermore, the court held that Crater's objections to the expert witness's qualifications and methodology were insufficient to necessitate a Daubert hearing. View "US v. Crater" on Justia Law

The defendant, Michael Rand, was indicted and pleaded guilty to one count of distributing a controlled substance. His sentence was time served followed by 36 months of supervised release. Shortly thereafter, Rand violated his supervised release multiple times, leading to a revocation hearing. At the hearing, Rand was sentenced to 24 months of imprisonment followed by 24 months of supervised release. Rand appealed his sentence on the grounds that it was procedurally and substantively unreasonable. The United States Court of Appeals for the First Circuit affirmed the sentence. The court found that the district court had adequately explained its rationale for the sentence, which was based on a combination of Rand's lying and absconding shortly after his original sentence, his drug relapse, and his failure to comply with the terms of his supervised release. Lastly, the court found that the sentence fell within the broad range of reasonableness considering the totality of the circumstances. View "US v. Rand" on Justia Law

Juan Sierra-Jiménez was a felon who pled guilty to possessing a firearm. While on supervised release for a prior federal firearm offense, Sierra was arrested and found with a Glock 22 pistol, which had been modified to function as a machine gun. He was also in possession of extra ammunition and approximately five grams of a substance suspected to be heroin. Sierra was sentenced to fifty-eight months in prison and an additional consecutive eighteen-month supervised release violation sentence. Sierra appealed, arguing that the fifty-eight-month sentence was procedurally unreasonable and that the government breached the plea agreement regarding his eighteen-month sentence. The United States Court of Appeals for the First Circuit rejected Sierra's arguments and affirmed the lower court's decision. The court ruled that the district court did not clearly err in its factual findings and did not rely on the suspected heroin possession in determining Sierra's sentence. The court also found that Sierra failed to show that the government's lack of an oral recommendation for a concurrent sentence prejudiced him. View "US v. Sierra-Jimenez" on Justia Law

James De La Cruz was indicted for conspiracy to distribute and possession with intent to distribute one kilogram or more of heroin and 400 grams or more of fentanyl. He pleaded guilty to both counts and was subsequently sentenced to 108 months in prison. De La Cruz appealed the sentence, arguing it was substantively unreasonable. The United States Court of Appeals for the First Circuit reviewed the case and affirmed the lower court's decision. The court noted that the sentence was within the properly calculated sentencing guideline range and considered the dangerous nature of fentanyl, the large quantity involved in the transaction, and De La Cruz's role as a manager in the drug trafficking organization. Moreover, the court rejected De La Cruz's argument that his sentence was disproportionate to sentences for violent crimes and that he was unfairly punished for the potential harm caused by the drugs, not actual harm. The court also dismissed his claim of sentencing disparity with a co-defendant, noting that De La Cruz and his co-defendant were not identically situated. Lastly, the court found that the district court did not abuse its discretion in considering deterrence when determining De La Cruz's sentence. View "US v. De La Cruz" on Justia Law

In the case before the United States Court of Appeals for the First Circuit, the defendant, Luis Ángel Colón-Cordero, was convicted of violating the terms of his supervised release and charged with new criminal conduct, including the possession of a firearm. The district court sentenced Colón-Cordero to an upwardly variant sentence for his new criminal conduct and a maximum term of imprisonment for violating his supervised release, which were to run consecutively. Colón-Cordero appealed, challenging the sentences as unreasonable.The appeals court vacated and remanded the case for resentencing. The court held that the district court had not adequately justified or explained its upward variance from the sentencing guidelines in the new criminal conduct case. Specifically, the appeals court found that the district court had not adequately engaged with the mitigating impact of Colón-Cordero's intellectual disability, despite this being a primary argument presented by his defense.In the case of the revocation sentence, the appeals court held that the district court's finding that Colón-Cordero was "constantly engaging in the illegal use of controlled substances" during his supervised release period was clearly erroneous. The record showed that Colón-Cordero had only tested positive for drug use twice during his release period, contradicting the district court's characterization of his drug use as constant. The court concluded that this error may have affected the sentencing outcome. The case was remanded for resentencing to a different judge. View "United States v. Colon-Cordero" on Justia Law

In this case, defendant Samuel Arce-Ayala, a leader of a drug trafficking organization, pled guilty to federal charges related to drug trafficking and firearm possession. He believed, based on his plea agreement and statements made by his lawyer and the district court, that his federal sentence would reflect "credit" for the prison time he served for related non-federal criminal convictions. However, after entering his guilty plea, Arce-Ayala discovered that such credit could not reduce his sentence below the applicable mandatory minimum terms of imprisonment. He moved to withdraw his plea before sentencing, arguing that he didn't understand the consequences of his guilty plea, but the district court denied the motion.The United States Court of Appeals For the First Circuit vacated Arce-Ayala's criminal judgment of conviction. The court held that Arce-Ayala did not have sufficient "knowledge of the consequences of the guilty plea" because he was told by his defense counsel and the district court that the time he spent in Commonwealth custody would be credited toward his federal sentence. He did not know that the mandatory minimum prison sentence set an inviolable floor as to the amount of credit he could receive for time served on the Commonwealth sentences. As such, his plea violated a "core concern" of Rule 11, which requires a defendant to understand the consequences of a guilty plea, and must be set aside. The case was remanded back to the district court for further proceedings. View "United States v. Arce-Ayala" on Justia Law

In this case, defendant Jason Colcord, appealed his sentence for knowingly accessing and viewing over 900 child pornography images. Colcord pled guilty to this charge and was subsequently sentenced to 145 months imprisonment, which was near the low end of his advisory guidelines sentencing range, followed by five years of supervised release. The defendant challenged his sentence on the grounds that the court's decision not to impose a downward variance was substantively unreasonable.The United States Court of Appeals for the First Circuit affirmed the lower court's decision. The court found that the district court's sentence was substantively reasonable. It noted that the district court had considered the nature of the offense, the need to protect the public, the defendant's personal history, and the need for punishment and deterrence, all of which are factors under 18 U.S.C. § 3553(a). The court rejected Colcord's argument that the district court conflated his conduct with those who committed more serious crimes depicted in the images and videos, stating that the comments were referring to Colcord's role as a consumer of child pornography.The court also rejected Colcord's argument that insufficient weight was given to his personal mitigating circumstances, stating that the district court was within its discretion to find that these factors were outweighed by the seriousness of the offense and the need to protect the public.Lastly, the court dismissed Colcord's argument that the district court should have accepted the parties' joint recommendation of a 120-month sentence. The court stated that the district court is not bound by the parties' recommendations as to the length of the sentence to be imposed. The court also found no evidence that the district court had imposed the sentence based on personal disgust towards the offense, as claimed by the defendant.Therefore, the court affirmed the district court's sentence of 145 months imprisonment followed by five years of supervised release. View "US v. Colcord" on Justia Law

Daniel Paul Sansone, the defendant-appellant, was convicted for being a felon in possession of a firearm. He was sentenced to 46 months of imprisonment, the upper end of the sentencing guideline range. Sansone challenged the procedural integrity and substantive reasonableness of his sentence. The United States Court of Appeals for the First Circuit reviewed his claims.Sansone had argued that his criminal history score was erroneously inflated due to the inclusion of his juvenile adjudications, asserting that his commitment to the Massachusetts Department of Youth Services (DYS) was not a sentence of confinement. The court rejected this argument, noting that prior case law had upheld the inclusion of such adjudications as constituting sentences of confinement.Sansone also claimed there was insufficient evidence to support the conclusion that his juvenile adjudications resulted in confinement for at least sixty days, which was necessary for the assignment of criminal history points under the United States Sentencing Guidelines (USSG). The Court of Appeals found that Sansone could not show a plain error in this regard, as the record was ambiguous and did not allow for a clear determination of the length of his confinement.Regarding the substantive reasonableness of his sentence, Sansone argued that the sentencing court had overstated the seriousness of his past criminal record and failed to adequately consider his personal history. The Court of Appeals disagreed, finding that the sentencing court had considered all relevant factors, and Sansone's real complaint was about the weight given to certain factors, not their consideration. The court upheld the sentence, affirming the district court's decision. View "US v. Sansone" on Justia Law

The case concerns the appeal of Gilbert Perez, who sought to have his federal drug conviction overturned on the basis that the United States District Court for the District of Maine had incorrectly denied his motion to suppress the outcomes of a warrantless search of his backpack. Perez argued that the search was not justified under the search-incident-to-arrest exception to the warrant requirement of the Fourth Amendment to the U.S. Constitution. The District Court, relying on a previous case (United States v. Eatherton), had upheld the search. Perez contended that subsequent Supreme Court decisions had undermined the validity of Eatherton.On the night of his arrest, Perez had been seen acting suspiciously in a McDonald’s parking lot in Lawrence, Massachusetts. When he left the lot, carrying a backpack, he was monitored by state troopers. He was seen exiting a taxi, and large quantities of cash were found in the vehicle, arousing suspicion that he had been involved in a drug transaction. When Perez returned to the McDonald’s lot, he was approached by Trooper Jason Conant, who identified himself as a state trooper. Perez ran but was caught, and the backpack was removed from him and searched. The search revealed it contained fentanyl and cocaine. Perez was subsequently indicted on a federal drug-related charge.In his appeal, Perez maintained that the backpack's search was a violation of the Fourth Amendment. The United States Court of Appeals for the First Circuit disagreed, affirming the judgement of conviction. It concluded that neither of the Supreme Court cases cited by Perez had invalidated the Eatherton ruling. The panel also rejected the notion that Perez's backpack could be considered separate from his person at the time of arrest. As such, it fell within the search-incident-to-arrest exception to the Fourth Amendment's warrant requirement. View "US v. Perez" on Justia Law