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

The defendant, Roy Sastrom, was serving a term of supervised release, a condition of which was modified by the United States District Court for the District of Massachusetts. The court directed Sastrom, upon his release from federal custody, to report directly to a psychiatric hospital in Connecticut, as per his civil commitment order. This case was later transferred to the District of Connecticut. Sastrom appealed, arguing the Massachusetts district court abused its discretion by modifying his supervised release conditions.The United States Court of Appeals for the First Circuit determined that despite the transfer, it retained jurisdiction to review the pre-transfer order. However, the court recognized that Sastrom's case had already proceeded in Connecticut and that the Massachusetts court no longer had authority over his supervised release. Consequently, the court asserted it could not simply remand the case for reassessment of the supervised release conditions.The court concluded that although it had the power to grant relief, the controversy was so attenuated that considerations of prudence and comity for coordinate branches of government counseled the court to withhold relief. The only possible remedy would require significant judicial resources and provide only a remote benefit to Sastrom. Therefore, the court declined to grant this remedy and affirmed the lower court's decision. View "United States v. Sastrom" on Justia Law

In 2010, Ángel M. Ayala-Vázquez was indicted and convicted on multiple drug-related charges, including conspiring to possess with intent to distribute and aiding and abetting the possession of with intent to distribute over 280 grams of cocaine base. He was sentenced in 2011 to life imprisonment. In 2021, Ayala filed a motion to reduce his sentence under the First Step Act and for compassionate release due to his hypertension and obesity making him vulnerable to COVID-19.The District Court denied Ayala's motion, concluding that he was ineligible for a sentence reduction under the First Step Act because his sentences were imposed "in accordance with" the amendments made by the Fair Sentencing Act. The court also rejected his request for compassionate release, finding that Ayala failed to demonstrate extraordinary and compelling reasons to warrant such relief. Moreover, the court determined that Ayala posed a danger to other persons and the community.On appeal to the United States Court of Appeals for the First Circuit, the court affirmed the District Court's decision. It concluded that Ayala was indeed convicted of offenses involving 280 grams or more of cocaine base, and his life sentences were in accordance with the Fair Sentencing Act. Therefore, he was not eligible for a sentence reduction under the First Step Act. As for the compassionate release, the court found no abuse of discretion in the District Court's evaluation of Ayala's health conditions and perceived danger to the community. View "United States v. Ayala-Vazquez" on Justia Law

The case involves Joseph A. Jakuttis, a former officer and detective in the Dracut Police Department, who also served as a Task Force Officer for the federal Drug Enforcement Administration's Cross Borders Initiative. Jakuttis brought multiple federal and state claims against the Town of Dracut, certain Dracut police officers, and members of the federal law-enforcement task force. He alleged that he was demoted and faced retaliation after reporting serious criminal activities implicating two Dracut police officers, which he learned from a confidential drug informant.The United States Court of Appeals for the First Circuit affirmed the dismissal of Jakuttis's Bivens claims against Michael V. O'Hanlon and Richard P. Poirier, Jr., and his §1983 claim against the Town of Dracut, David J. Chartrand Jr., and Demetri Mellonakos. The court ruled that the defendants are entitled to qualified immunity, as they could have reasonably thought that Jakuttis was speaking as part of his official duties rather than as a private citizen when he reported the misconduct, thus not clearly violating his First Amendment rights.The court also affirmed the dismissal of Jakuttis's state-law tort claims against Poirier, as Poirier was deemed to be acting within the scope of his federal employment during the relevant times. However, the court remanded the Massachusetts Whistleblower Act claim against the Town of Dracut and the Intentional Interference with Advantageous Economic Relationship claim against Chartrand and Mellonakos to the District Court. The court reasoned that these state-law claims should be resolved by a state court due to reasons of comity. View "Jakuttis v. Town of Dracut" on Justia Law

In 1990, Mac Hudson and Charles Hughes were tried for charges relating to a shooting incident which resulted in the death of one person and injury of another. After being convicted, their verdict was reversed by the Massachusetts Appeals Court for unrelated reasons and a retrial was ordered.During the second trial in 1997, issues arose regarding the jury selection process and the admission of certain witness testimonies. The judge reduced the number of jurors from sixteen to fifteen, which Hudson claimed prejudiced his use of peremptory challenges. Furthermore, key witness Kimbrough, who recanted his testimony from the first trial, was deemed unavailable to testify. His previous testimony was, however, read into the record. Hudson argued that his right to due process was violated by these actions. Despite these objections, Hudson was again convicted and sentenced to life imprisonment for second-degree murder, among other charges.Following unsuccessful appeals in state court, Hudson petitioned for a writ of habeas corpus in federal court, arguing that his right to due process was violated during his trial. The United States Court of Appeals for the First Circuit affirmed the District Court's denial of Hudson's petition. The court found that the Massachusetts Appeals Court's rulings on Hudson's claims were not contrary to, nor involved an unreasonable application of, clearly established Federal law as determined by the Supreme Court of the United States. View "Hudson v. Kelly" on Justia Law

This case revolves around the dismissal of a case due to the plaintiff's counsel's unexcused absence from the final pretrial conference. The United States Court of Appeals for the First Circuit raised the question of whether a district court may dismiss a case for such a reason, especially when it's the first and only instance of non-compliance and the court did not consider a lesser sanction. In this case, the plaintiff had filed a complaint alleging RICO violations and related state-law claims. However, the plaintiff's counsel failed to appear at the final pretrial conference, leading to the dismissal of the case by the district court.Upon review, the Court of Appeals held that while a district court has inherent power to manage its docket and may dismiss a case sua sponte for reasons prescribed in Rule 41(b), such dismissal should only occur when a plaintiff's misconduct has been extreme or contumacious. The dismissal should not be viewed as a sanction of first resort or an automatic penalty for every failure to abide by a court order. Thus, the Court of Appeals found that the district court had erred in dismissing the case without first considering a lesser sanction or warning the disruptive party. The court vacated the district court's dismissal order and remanded the case for further proceedings. View "Vivaldi Servicios de Seguridad, Inc. v. Maiso Group, Corp." on Justia Law

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