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

The First Circuit affirmed the 194-month sentence imposed upon Defendant after he pled guilty to using, carrying, brandishing, and discharging a firearm in furtherance of a crime of violence, holding that the sentence was neither procedurally or substantively unreasonable.On appeal, Defendant argued, among other things, that the district court erred by making conflicting statements about his applicable guidelines sentence and that his sentence was substantively unreasonable because it was "unmoored from any particular factor." The First Circuit affirmed, holding that Defendant's 194-sentence was both procedurally and substantively reasonable. View "United States v. Melendez-Hiraldo" on Justia Law

The First Circuit affirmed in part and reversed in part the order of the district court ordering A.R., who was adjudicated delinquent in a proceeding under the Federal Juvenile Delinquency Act (FJDA), 18 U.S.C. 5031-5042, detained in a juvenile institution until he reached the age of twenty-one, followed by a term of juvenile delinquent supervision, holding that remand was required.A.R., who was born in 2003, was adjudicated delinquent pursuant to his admission of aiding and abetting an attempted robbery of a motor vehicle and five carjackings, each of which would have been a violation of 18 U.S.C. 2119 had A.R. been an adult. On appeal, A.R. primarily challenged the district court's order of a detention period rather than a probationary one. The First Circuit affirmed as to the court's imposition of detention but reversed and remanded as to two other matters, holding (1) A.R.'s disposition was both procedurally and substantively reasonable; (2) the district court erred in failing to recommend that A.R. be placed in a local detention facility; and (3) the district court erred in imposing a term of detention and supervision that together exceeded the applicable statutory maximum. View "United States v. A.R." on Justia Law

The First Circuit vacated Defendant's statutory maximum thirty-six-month sentence that the district court imposed following a revocation of supervised release, holding that the district court's failure adequately to justify the sentence was procedural error.After a revocation hearing, the district court revoked Defendant's supervised release term for violations of the conditions of his release. The district court sentenced Defendant to thirty-six months' imprisonment, the statutory maximum for Defendant's violation. The First Circuit vacated the sentence and remanded the case for resentencing, holding that none of court's rationales explained why Defendant's case was so distinct from other such revocation cases that he deserved a 400 percent increase over the guidelines sentencing range. View "United States v. Reyes-Correa" on Justia Law

The circuit court affirmed Defendant's sentence, imposed in connection with his drug-related offenses, holding that the district court did not err by adopting a four-level role-in-the-offense enhancement when formulating Defendant's guideline sentencing range.After applying the relevant enhancements and reductions, the court imposed a downwardly variant sentence of 216 months' imprisonment on each count of conviction, to run concurrently. The First Circuit affirmed, holding that Defendant was not entitled to relief on his argument that his exercise of control in the underlying operation was of an insufficient duration to ground application of the four-level enhancement. View "United States v. Poliero" on Justia Law

The First Circuit affirmed Defendant's 516-month sentence entered upon his guilty plea to one count of conspiracy to conduct enterprise affairs through a pattern of racketeering activity (RICO), holding that there was no error relating to Defendant's sentence.On appeal, Defendant argued that the district court erroneously applied a sentencing enhancement for the use or attempted use of a minor in the commission of the offense under the United States Sentencing Guidelines and imposed a substantively unreasonable sentence. The First Circuit affirmed, holding (1) the minor-use enhancement was properly applied in this case; and (2) the sentence imposed by the district court was substantively reasonable. View "United States v. Vaquerano Canas" on Justia Law

The First Circuit affirmed Defendant's sentence in his underlying criminal case, holding that the district court did not err in imposing a sentencing enhancement for the use or attempted use of a minor in the commission of the offense under the sentencing guidelines.Defendant pleaded guilty to one count of RICO conspiracy in violation of 18 U.S.C. 1962(d) and, in doing so, admitted to two murders. After a sentencing hearing, the district court sentenced Defendant to life imprisonment. Defendant appealed, arguing that the district court erred in applying the guideline enhancement under U.S.S.G. 3B1.4 for Defendant's use or attempted use of a minor. The First Circuit affirmed, holding that Defendant was not entitled to relief on his allegations of error. View "United States v. Salvador Gutierrez" on Justia Law

The First Circuit affirmed Defendant's conviction and sentence for violating 18 U.S.C. 666, holding that Defendant was not entitled to relief on his allegations of error.Defendant was indicted on four counts of violating section 666(a)(1)(B) stemming from his role in the allegedly corrupt awarding of contracts by certain Puerto Rico municipalities. After a jury trial, Defendant was found guilty on all counts and sentenced to 120 months of imprisonment and three years' supervised release. The First Circuit affirmed, holding (1) there was sufficient evidence to support Defendant's convictions; (2) Defendant's two evidentiary challenges were unavailing; and (3) Defendant's 120-month prison sentence was neither procedurally nor substantively unreasonable. View "United States v. Carrasco" on Justia Law

The First Circuit vacated in part and reversed in part the judgment of the district court convicting Defendants, sisters Ivonne Falcon-Nieves and Marielis Falcon-Nieves, on various federal charges relating to the Commonwealth of Puerto Rico's alleged public corruption, holding that the evidence was insufficient to support some of Ivonne's convictions.Specifically, the First Circuit held (1) the evidence was sufficient to support one of the counts of honest services wire fraud with which Ivonne was charged, Ivonne's convictions for conspiracy to commit honest services wire fraud or federal program bribery, and Marielis's conviction for aiding and abetting extortion; (2) the evidence was insufficient to support Ivonne's conviction for federal program bribery, her other two convictions for honest services wire fraud, and her aiding and abetting extortion conviction; (3) one of Ivonne's conspiracy convictions must be vacated due to a prejudicial variance; and (4) the remaining convictions must be vacated because the district court erred in denying the sisters' motions for severance of their trials. View "United States v. Falcon-Nieves" on Justia Law

In this interlocutory appeal the First Circuit affirmed the decision of the district court granting Defendant's motion to suppress items seized during a traffic stop, holding that the government was not entitled to relief on its allegations of error.Defendant was stopped by a New Hampshire police officer for failing to use a turn signal on a road that narrowed from two lanes to one lane. After the officer discovered that Defendant had outstanding arrest warrants the officer arrested Defendant and seized a bag from him containing narcotics. Defendant moved to suppress the evidence on the grounds that New Hampshire law did not require use of a turn signal at the merge point on the roadway at issue. The district court agreed and granted the motion to suppress. The First Circuit affirmed, holding (1) it was not objectively reasonable for the officer to rely on a yield sign in the roadway to govern the factual situation he was encountering; and (2) it was not a reasonable mistake of law for the officer to believe that a turn signal was required at the merge point. View "United States v. Potter" on Justia Law

The First Circuit affirmed Defendant's sentence that he received in connection with a robbery committed in Maine, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the trial court erred in finding that two of his earlier convictions under Massachusetts law and one under Maine law were crimes of violence under the sentencing guidelines. The First Circuit disagreed and affirmed, holding (1) Defendant's Massachusetts conviction for assault with a dangerous weapon qualified as a crime of violence under the guidelines; and (2) Defendant's Maine conviction for robbery with the use of a dangerous weapon was a crime of violence under the guidelines. View "United States v. Williams" on Justia Law