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

The First Circuit affirmed the judgment of the district court sentencing Defendant to 120 months in prison in connection with his conviction of possession with intent to distribute and distribution of fentanyl, holding that the records supported the district court's rulings.On appeal, Defendant argued, among other things, that the district court considered impermissible evidence in determining his sentence. The First Circuit affirmed, holding (1) the district court did not clearly err in determining that Defendant was not entitled to a two-level reduction for acceptance of responsibility; (2) the district court did not err in considering Defendant's acquitted conduct at sentencing; (3) Defendant's sentence was neither implausible nor indefensible; and (4) the district court did not err in imposing a variance. View "United States v. Carvajal" on Justia Law

The First Circuit vacated the judgment of the district court granting Plaintiff's petition for a federal writ of habeas corpus on his claim that his state court trial counsel was ineffective, holding that the district court erred in applying the standard set forth under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), Pub. L. No. 104-132, 110 Stat. 1214.After a jury trial, Petitioner was convicted of first-degree murder, unlawful possession of a firearm, and unlawful possession of ammunition. The Massachusetts Supreme Judicial Court (SJC) affirmed Petitioner's conviction and the trial court's denial of his motion for a new trial. Petitioner subsequently filed a petition for a federal writ of habeas corpus, arguing that his state court trial counsel was ineffective. The federal district court granted the petition. The First Circuit vacated the district court's judgment, holding (1) Petitioner did not meet his burden to show that the SJC's factual determinations were unreasonable, regardless of which standard applied; and (2) the SJC's decision was not an unreasonable application of the law. View "Ayala v. Alves" on Justia Law

The First Circuit affirmed Defendant's twenty-four-month sentence for violating conditions of his supervised release, holding that the sentence was neither procedurally nor substantively unreasonable.In 2014, Defendant pleaded guilty to being a prohibited person in possession of a firearm and was sentenced to sixty months in prison, followed by three years of supervised release. After Defendant reentered the community on supervised release he was arrested on firearms charges. The new arrest triggered revocation proceedings in his supervised release case. After a final revocation hearing, the district court found that Defendant violated the conditions of his supervised release and sentenced him to twenty-four months' imprisonment. The First Circuit affirmed, holding (1) Defendant was not entitled to relief on his claims of procedural error; and (2) Defendant's sentence was substantively reasonable. View "United States v. Colon-De Jesus" on Justia Law

The First Circuit vacated the judgment of the district court convicting Defendant on federal drug- and gun-related charges, holding that the district court erred by failing to suppress incriminating statements Defendant made to law enforcement because the government failed to satisfy its burden to show that Defendant validly waived his rights under Miranda v. Arizona, 384 U.S. 436 (1966).Defendant was charged with conspiracy to distribute and to possess with intent to distribute heroin, cocaine, cocaine base, and fentanyl; possession with intent to distribute those drugs; and being a felon in possession of a firearm. Defendant filed a motion to suppress statements he made to law enforcement immediately following his arrest, arguing that the statements were obtained in violation of his Miranda rights. The district court denied the motion to suppress, concluding that Defendant understood his Miranda rights and knowingly, intelligently and voluntarily waived them. The First Circuit reversed, holding that the government failed to show that Defendant validly waived his Miranda rights, and this error was not harmless. View "United States v. Donald" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant, following a jury trial, of four counts of wire fraud, in violation of 18 U.S.C. 1343, and one count of making false statements to a financial institution, in violation of 18 U.S.C. 1014, holding that Defendant was not entitled to relief on his claims of error.Specifically, the First Circuit held (1) there was sufficient evidence presented to the jury of Defendant's intent to defraud for his wire convictions; (2) there was sufficient evidence of Defendant's intent to influence a financial institution; and (3) there was no adequate record with which to determine the effectiveness of counsel's decisions, and therefore, Defendant's ineffective assistance of counsel claims were dismissed without prejudice. View "United States v. Buoi" on Justia Law

The First Circuit granted the government's petition for rehearing en banc in these consolidated appeals regarding Defendants' 2016 convictions for violating the Maritime Drug Law Enforcement Act, 46 U.S.C. 70501 et seq. (MDLEA), holding that 46 U.S.C. 70503(e)(1) does not limit the subject matter jurisdiction of federal courts under Article III of the United States Constitution.Defendants pleaded guilty unconditionally to the underlying charges, but a panel of the First Circuit vacated the convictions and ordered the underlying charges dismissed. The government petitioned for rehearing en banc. The First Circuit granted the petition, vacated the panel's ruling, and affirmed Defendant's convictions, holding that section 70503(e)(1) merely limits the substantive reach of the MDLEA and that Defendants' claims on appeal failed. View "United States v. Davila-Reyes" on Justia Law

The First Circuit vacated the judgment of the district court denying Defendant's prisoner-initiated motion for compassionate release, holding that because the district court did not undertake an evaluation of the 18 U.S.C. 3553(a) factors remand was necessary.Defendant was found guilty by a jury of conspiracy to distribute five kilograms or more of heroin, cocaine, cocaine base and marijuana. The district court sentenced Defendant to a term of life imprisonment. After Congress passed the First Step Act amending the compassionate-release statute Defendant moved for either compassionate release or a sentence reduction. The district court denied relief. The First Circuit vacated the judgment below, holding (1) the district court abused its discretion in concluding that Defendant's compassionate-release motion could not proceed as a matter of law; and (2) this Court declines Defendant's request to grant his motion for compassionate release. View "United States v. Quiros-Morales" on Justia Law

The First Circuit vacated the decision of the federal district court revoking Defendant's term of supervised release and ordering him to return to prison for an additional two years, holding that resentencing was required on the proper record.Defendant was convicted of a drug crime, sentenced, and placed on supervised release. The district court later revoked Defendant's supervised release term on ordered him returned to prison for two years, finding that Defendant made unlawful death threats in violation of a condition of his release. The First Circuit affirmed the order revoking Defendant's term of supervision but vacated Defendant's revocation sentence and remanded the case for resentencing, holding that the district court erred by admitting certain testimony and that the error may have affected the court's decision to impose an upwardly variant sentence. View "United States v. Navarro-Santisteban" on Justia Law

The First Circuit vacated Defendant's new sentence after concluding that it could sua sponte consider a claim of error not timely raised by Defendant, holding that the district court committed plain error during sentencing.Defendant pled guilty to two carjacking offenses and a firearm count. The district court varied upward and imposed concurrent sentences of eighty-seven months on the carjacking counts and a consecutive sentence of 108 months on the firearm count. The First Circuit remanded for resentencing. The district court ultimately imposed concurrent sentences of 132 months' imprisonment on the carjacking counts and a consecutive sentence of 108 months' imprisonment on the firearm count. The First Circuit vacated the sentence, holding (1) this Court may sua sponte raise an error that constitutes a violation of the mandate rule; and (2) the resentencing court in this case committed plain error under this Court's holding in United States v. Ticchiarelli, 171 F.3d 24 (1st Cir. 1999). View "United States v. Cheveres-Morales" on Justia Law

The First Circuit vacated Defendant's conviction for possession of a machine-gun in furtherance of a drug trafficking crime and remanded the case for a new trial as to that count, holding that the jury should have been instructed about Defendant's knowledge of the characteristics of the firearm he possessed.After a jury trial, Defendant was convicted of possession with intent to distribute controlled substances, possession of a firearm in furtherance of a drug trafficking crime, and possession of a machine-gun in furtherance of a drug trafficking crime. The First Circuit vacated the convictions in part, holding (1) the evidence was sufficient to support the convictions; (2) Defendant was not entitled to relief on his claims for pretrial and trial error; and (3) the district court improperly instructed the jury that the government was not required to prove that Defendant knew the firearm he possessed was a machine-gun. View "United States v. Perez-Greaux" on Justia Law