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

Defendant entered into a plea agreement with the United States to several drug-related offenses. The district court sentenced Defendant at the bottom of the guidelines range to a term of imprisonment of 262 months. In 2009, Defendant filed his first motion to reduce his sentence pursuant to amendments 706 and 711 to the guidelines. The district court granted the motion and sentenced Defendant at the bottom of the newly amended guidelines range to a term of imprisonment of 210 months. In 2011, Defendant filed his second motion to reduce his sentence pursuant to amendments 748 and 750 to the guidelines. The district court granted the motion and sentenced Defendant at the bottom of the amended guidelines range to a term of imprisonment of 168 months. In 2014, Defendant filed his third motion to reduce his sentence pursuant to amendments 782 and 788 to the guidelines. The motion was opposed by the government and the probation officer. The district court denied the motion. The First Circuit affirmed, holding that the district court properly considered the sentencing factors set forth in 18 U.S.C. 3553(a) and gave sufficient reasons for its decision. View "United States v. Zayas-Ortiz" on Justia Law

The convictions of Karapet Dzhanikyan and Ronald Martinez arose out of a year-long wiretap investigation of a suspected drug trafficker. After a jury trial, Dzhanikyan was convicted of one count of conspiring to distribute oxycodone, and Martinez was convicted of one count of conspiring to attempt to collect a debt through extortionate means and two counts of possession crack cocaine with intent to distribute it. The First Circuit affirmed each of the convictions except for Martinez’s extortion conviction, holding (1) the district court did not err in deciding to try the two defendants together; (2) the district court did not err in instructing the jury as to how to consider the evidence as to each defendant; and (3) there was a lack of sufficient evidence to support Martinez’s extortion conviction. View "United States v. Dzhanikyan" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to one count of unlawful possession of a firearm. The Presentence Investigation Report calculated the guidelines sentencing range as forty-one to fifty-one months. After a sentencing hearing, the district court imposed a variant sentence and sentenced Defendant to sixty months’ imprisonment. Defendant appealed his sentence on the grounds that it was substantively unreasonable. The First Circuit affirmed, holding that the district court did not abuse its discretion in relying in part on the sentence’s supposed deterrent effect to justify an upward variance from the recommended sentencing range. View "United States v. Paulino-Guzman" on Justia Law

After a jury trial, Defendant, a former Massachusetts state trooper, was convicted of knowingly participating in the use of extortionate means to attempt to collect an extension of credit. The First Circuit affirmed, holding (1) the district court’s finding of discrimination with respect to the government’s attempt to strike one juror and the court’s chosen remedy was not inadequate under Batson v. Kentucky; (2) the district court did not err in denying Defendant’s motion for acquittal based on insufficiency of evidence; and (3) the district court did not err in instructing the jury, and even assuming that the district court committed error, the error was harmless. View "United States v. Analetto" on Justia Law

Appellant was indicted for second-degree murder and unlawful possession of a firearm. During jury selection for Appellant’s trial, the Massachusetts state prosecutor exercised peremptory challenge to strike three black men age twenty-five or under. The jury convicted Appellant, and he was sentenced to life imprisonment for murder. Appellant appealed, arguing that the prosecutor had improperly exercised peremptory challenges against young “men of color.” The appeals court affirmed. Appellant subsequently petitioned for a writ of habeas corpus in federal district court. The district court denied the petition, determining that the state court’s application of federal law was reasonable. The First Circuit remanded the case, concluding that Appellant had established a prima facie case of racial discrimination under step one of the framework established in Batson v. Kentucky. After an evidentiary hearing as to steps two and three of Batson, the district court ruled against Appellant on the final step of Batson. The First Circuit affirmed the district court’s denial of Appellant’s petition, holding that the district court did not abuse its discretion in concluding that Appellant had not proven that there was racial discrimination during jury selection. View "Sanchez v. Roden" on Justia Law

After a jury trial, Appellant was convicted of first degree murder. The Massachusetts trial court denied Appellant’s motion for a new trial, and the Supreme Judicial Court affirmed his conviction. Appellant later filed a habeas corpus petition alleging that the Commonwealth failed to disclose a document that was evidence of a possible cooperation agreement between one prosecution witness and the Commonwealth, in violation of his right to due process. The district court denied the petition. The First Circuit affirmed, holding that, had the document been timely disclosed to the defense, the there was no reasonable probability that the result of the proceeding would have been different. View "Rosario v. Roden" on Justia Law

After a jury trial, Defendant was convicted of the murder of his wife. Eight days later, Defendant was indicted by a federal grand jury on three counts of making false statements to a federal officer. One week later, a Puerto Rico Commonwealth court sentenced Defendant to 109 years’ imprisonment for the murder. Defendant moved to transfer the federal trial to another venue, arguing that the pretrial publicity about his murder conviction prevented a fair and impartial jury in Puerto Rico. The trial court overruled the motion to change venue. After a trial, the jury convicted Defendant of all three false-statement counts, but the court granted a motion of acquittal on two counts. The First Circuit reversed, holding that the district court abused its discretion by denying Defendant’s motion to change venue, as there was a significant risk that the level of prejudice permeating the trial was so high that Defendant could not possibly have received an impartial trial. Remanded. View "United States v. Casellas-Toro" on Justia Law

Defendant was charged in a sixty-count indictment with offenses arising from “masterminding one of the most avaricious frauds in Rhode Island history.” Pursuant to a plea agreement, Defendant pleaded guilty to one count of wire fraud and one count of conspiracy to commit wire fraud, mail fraud, and identity theft. Before sentencing, Defendant filed a motion to seek leave to retract his guilty plea. Following an evidentiary hearing, the district court denied the motion. The district court subsequently sentenced Defendant to a six-year term of immurement. The First Circuit affirmed, holding (1) the district court did not err in denying Defendant’s motion to withdraw his guilty plea; and (2) Defendant’s challenge to his sentence was barred by the waiver-of-appeal provision contained in his plea agreement. View "United States v. Caramadre" on Justia Law

Defendant was convicted of two counts of passport fraud, one count of false representation to the Social Security Administration, and one count of theft of public money. The First Circuit affirmed Defendant’s convictions, holding (1) the district court did not err in barring Defendant from presenting evidence of duress and necessity to the jury in defending against the first count of passport fraud, and the court did not err in declining to instruct the jury on those defenses; and (2) the district court did not err in denying Defendant’s motion for judgment of acquittal as to the second count of passport fraud. View "United States v. Lebreault-Feliz" on Justia Law

After a jury trial, Appellant was convicted of transportation, receipt, and possession of child pornography. The First Circuit affirmed on appeal. Appellant later filed a petition for a writ of habeas corpus under 28 U.S.C. 2255 claiming that the jury selection process for his trial violated his Fifth Amendment right to be present and his Sixth Amendment right to a public trial. Appellant did not raise either the Fifth Amendment or the Sixth Amendment claim at trial or on direct appeal. The district court denied habeas relief. The First Circuit affirmed, holding that Appellant could not overcome his procedural default from not pursuing either his Fifth Amendment or Sixth Amendment claim at trial or on appeal. View "Wilder v. United States" on Justia Law