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

The First Circuit affirmed Defendant's sentence of twenty-four months' imprisonment imposed in connection with his plea of guilty to health care fraud, holding that the sentence was neither procedurally nor substantively unreasonable.Defendant pleaded guilty to health care fraud for his multiyear scheme to defraud MaineCare, a state-run program that administers Medicaid benefits in the state of Maine and reimburses Maine health care providers for MaineCare services. After a hearing, the court varied downward and imposed a sentence of twenty-four months' imprisonment. The First Circuit affirmed Defendant's sentence, holding (1) the district court did not err in its loss calculations or in imposing a four-level leader/organizer enhancement; and (2) Defendant's downward variant sentence satisfied the substantive reasonableness standard. View "United States v. Ahmed" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Employer and dismissing all of Employee's claims alleging retaliatory behavior under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-2 et seq., discrimination and retaliation under the Uniformed Services Employment and Reemployment Rights Act, 38 U.S.C. 4301 et seq., and violations of Puerto Rico Law 115, holding that there was no error or abuse of discretion.The district court granted Employer's motion for summary judgment, finding that Employee failed to make a prima facie showing of retaliation and, in the alternative, failed to rebut Employer's explanations for why the behavior in question was non-discriminatory in nature. The First Circuit affirmed, holding (1) there was no abuse of discretion in the district court's conclusion that Employee's statement in opposition to Employer's statement of uncontested material facts was noncompliant with Local Rule 56; (2) the district court properly found that Employee failed to make out a prima facie case for retaliation under Title VII; and (3) the dismissal of Employee's antiretaliation law claims was proper. View "Rodriguez-Severino v. UTC Aerospace Systems" on Justia Law

The First Circuit affirmed Defendant's conviction of enticement of a fifteen-year-old minor for unlawful sexual activity, in violation of 18 U.S.C. 2422(b), and transportation of a minor to engage in criminal sexual activity, in violation of 18 U.S.C. 2423(a), holding that there was no error.On appeal, Defendant asserted numerous challenges to the criminal judgment related to the district court's evidentiary rulings and argued that the evidence was insufficient to support his conviction. The Supreme Court affirmed, holding (1) there was no error in the district court's denial of Defendant's motion to suppress; (2) a defendant can be found to persuade, entice, or induce a victim in violation of section 2422 despite purported evidence that the victim agreed to engage in sexual activity; and (3) Defendant's remaining claims failed. View "United States v. Greaux-Gomez" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant of all counts in a 41-count indictment charging him with sexual exploitation of a child and possessing, promoting, and distributing child pornography and sentencing him to a term of eighty years' imprisonment, holding that Defendant's arguments on appeal were unavailing.On appeal, Defendant argued that the total length of his term-of-hears sentence violated the constitutional prohibition on cruel and unusual punishment contained in the Eighth Amendment to the United States Constitution. The First Circuit affirmed, holding that Defendant's eighty-year sentence for dozens of child pornography offenses did not reach the level of gross disproportionality. View "United States v. Raiche" on Justia Law

The First Circuit affirmed the judgment of the district court sentencing Appellants to terms of imprisonment and imposing conditions of supervised release on all Appellants, including "Standard Condition of Supervised Release Number 12," holding that Appellants' constitutional challenges to Standard Condition 12 failed on the merits.Appellants - Akeem Cruz, Taylor Lovely, and Jeremiah Mitchell - pleaded guilty to drug-related crimes and were each sentenced to a term of imprisonment followed by supervised release. The district courts imposed conditions of supervised release on all Appellants, including Standard Condition 12. For the first time on appeal, Appellants argued that Standard Condition 12 was unconstitutionally vague and an unconstitutional delegation of judicial authority. The First Circuit affirmed, holding that the Standard Condition 12 is neither unconstitutionally vague, nor does it unconstitutionally delegate judicial authority to a probation officer. View "United States v. Cruz" on Justia Law

The First Circuit affirmed Defendant's conviction for drug-trafficking and firearms charges, holding that the district court did not err in denying Defendant's motion to suppress or in finding Defendant eligible for a mandatory minimum sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924 (e).Reports of a parking-lot confrontation following a road-rage incident led law enforcement to stop Defendant in his vehicle the next day. The ensuing searches of Defendant's car and motor home led to the discovery of evidence supporting drug-trafficking and firearms charges. Defendant pleaded guilty. The First Circuit affirmed Defendant's conviction and sentence, holding (1) there was no error in the district court's denial of Defendant's motion to suppress; and (2) Defendant's sentence under the ACCA was lawfully imposed. View "United States v. Mulkern" on Justia Law

The First Circuit affirmed Defendant's conviction, entered upon his guilty plea, for one count of being a felon in possession of a firearm and sentence of fifteen years of incarceration followed by three years of supervised release, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant failed to establish plain error on his argument that his plea colloquy was facially invalid because of an omission that rendered his guilty plea unknowing and involuntary; (2) Defendant waived his right challenge the sufficiency of the indictment by pleading guilty; (3) although Defendant's challenge to the government's failure to file substantial assistance motions fell outside the scope of the appeal waiver, this Court nevertheless holds that the district court did not err in declining to hear evidence before sentencing; (4) Defendant's prior convictions under the Massachusetts drug distribution statute were properly characterized as Armed Career Criminal Act predicates; and (5) the district court did not err in deciding to proceed with sentencing despite argument from defense counsel that the government had failed to honor the terms of a cooperation agreement. View "United States v. Doe" on Justia Law

The First Circuit affirmed the convictions of Appellants Edilio Benjamin-Hernandez (Benjamin) and Johanni Balbuena-Hernandez (Balbuena) on multiple charges stemming from a conspiracy to transport cocaine from the Dominican Republic to Puerto Rico, holding that Appellants were not entitled to relief on their claims of error.On appeal, Appellants challenged the district court's denial of their motion to dismiss and argued that the evidence presented at trial was insufficient to support the convictions. Benjamin also raised two evidentiary challenges. The First Circuit affirmed, holding (1) there was no violation of the Speedy Trial Act's seventy-day limit; (2) no Sixth Amendment violation occurred in this case; and (3) there was sufficient evidence supporting Appellants' convictions. View "United States v. Benjamin-Hernandez" on Justia Law

The First Circuit affirmed the judgment of a federal district judge in Maine sentencing Defendant on drug-distribution and communications-device counts, holding that the sentence was neither procedurally nor substantively unreasonable.In 2019, a Maine federal grand jury indicted Defendant for possessing drugs (crack and heroin) with intent to distribute and for using a communications device to commit a drug crime. Defendant pled guilty. The Maine federal judge varied downwards to 137 months and structured his term to run concurrently with the remainder of a Connecticut sentence. The First Circuit affirmed the sentence imposed, holding that nothing Defendant argued on appeal persuaded the Court that his below-guidelines sentence was implausible or indefensible. View "United States v. Perry" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motion to withdraw his guilty plea and sentencing him to consecutive sentences of life imprisonment for discharging a firearm during and in relation to a crime of violence resulting in death and attempted carjacking, holding that there was no error or abuse of discretion.On appeal, Defendant argued that the district court abused its discretion in denying his motion to withdraw his guilty plea and that his sentence was neither procedurally nor substantively reasonable. The First Circuit disagreed and affirmed, holding (1) the district court did not abuse its discretion in denying Defendant's motion to withdraw his guilty plea; and (2) there was no significant procedural or substantive error. View "United States v. Bruzon-Velazquez" on Justia Law