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

The First Circuit affirmed the judgment of the district court denying Defendant's latest request to withdraw his guilty plea to conspiring to import Cocaine into the United States and money laundering to promote this conspiracy, holding that the district court did not err in denying Defendant's motion to withdraw his guilty plea.Multiple times before he was sentenced Defendant filed motions to withdraw his guilty plea. As to Defendant's most recent withdrawal motion, the magistrate judge recommended that the district court grant the motion. The district court disagreed and denied Defendant's request to withdraw his plea. The First Circuit affirmed, holding (1) the district court's analysis of the plea withdrawal motion was flawed in two respects, but the district court did not abuse its discretion in denying Defendant's motion to withdraw the guilty plea; and (2) the district court did not err in exercising jurisdiction over Defendant. View "United States v. Fonseca" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant of one count of possession with intent to distribute fentanyl and cocaine base after a traffic stop near Wells, Maine, holding that the district court did not commit plain error in accepting Defendant's guilty plea.On appeal, Defendant argued that the district court impermissibly failed to advise him that he was giving up the right to file pretrial motions at his Rule 11 hearing and that this Court should reverse the denial of his motion to withdraw his guilty plea. The First Circuit affirmed, holding that Defendant's claim on appeal was meritless. View "United States v. Williams" on Justia Law

On the government's appeal from the district court's grant of Appellant's motion for compassionate release the First Circuit reversed, holding that remand was required for further review.Nearly thirty years ago, Appellant was convicted of several crimes stemming from his role in a 1991 car bombing and sentenced to life imprisonment. The district court later concluded that a sentencing error constituted an "extraordinary and compelling" reason to grant compassionate release and reduced Appellant's sentence to forty-one years, crediting time served. The First Circuit reversed, holding that remand was required for further proceedings with the benefit of guidance of United States v. Ruvalcaba, 46 F.4th 14 (1st Cir. 2022). View "United States v. Trenkler" on Justia Law

The Supreme Court remanded this immigration case to the Boards of Immigration Appeals (BIA) after it affirmed an immigration judge's (IJ) decision to deny Petitioner's applications for relief from removal based on two marijuana offenses found by the IJ and the BIA to be "particularly serious" pursuant to 8 U.S.C. 1158(b)(2)(A)(ii) and 1231(b)(3)(B)(ii), holding that remand was required.The IJ found Petitioner removable based on two Massachusetts state court convictions involving marijuana. The BIA upheld the IJ's determination that Petitioner was ineligible for asylum and withholding of removal for having been convicted of a particularly serious crime. The Supreme Court granted Petitioner's petition for review, holding that there was not a sufficient rational explanation to explain the BIA's conclusion that Petitioner's minor marijuana offenses were particularly serious crimes and that remand was required. View "Dor v. Garland" on Justia Law

The First Circuit vacated the judgment of the district court dismissing this complaint after concluding that it lacked subject matter jurisdiction over Appellant's suit under the Anti-Injunction Act of the Internal Revenue Code, 26 U.S.C. 7241, holding that the district court erred in dismissing the complaint.Appellant brought a complaint against the Internal Revenue Service (IRS) and some of the IRS's agents alleging that Defendants violated the Fourth and Fifth Amendments and 26 U.S.C. 7609(f) by acquiring Appellant's personal financial information through a third-party summons process. The district court dismissed Appellant's claims for declaratory and injunctive relief for lack of subject matter jurisdiction, ruling that the Anti-Injunction Act of the Internal Revenue Code, 262 U.S.C. 7421, constituted an exception to the APA's waiver of sovereign immunity. The First Circuit vacated the judgment, holding that the Anti-Injunction Act did not bar Appellant's suit. View "Harper v. Rettig" on Justia Law

The First Circuit affirmed Defendant's conviction of one count of false impersonation of an employee of the United States, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant primarily challenged the sufficiency of the evidence offered for the jury to convict him. The Supreme Court affirmed, holding (1) Defendant's argument that the "intent to defraud" remains an inherent part of an 18 U.S.C. 9212 violation which the government move prove despite Congress's removal of that language in 1948 was waived for inadequate briefing; and (2) the district court did not abuse its discretion in granting the government's motion to quash a request for testimony of federal officers to corroborate his claims that he was working as an FBI agent at the time of his arrest. View "United States v. Vazquez-Rosario" on Justia Law

The First Circuit dismissed Appellant's appeal from his mandatory minimum sixty-month sentence, holding that Appellant knowingly and voluntarily agreed to an appeal waiver, barring this appeal.Pursuant to a written agreement, Appellant pleaded guilty to one count of conspiracy to possess with intent to distribute cocaine. The sentencing court sentenced Defendant to sixty months' imprisonment and eight years of supervised release. Appellant appealed, stating that enforcing his appeal waive would work a miscarriage of justice. The First Circuit dismissed the appeal, holding that even if Appellant hadn't waived his argument on appeal, there was no miscarriage of justice. View "United States v. Candelario-Ramos" on Justia Law

The First Circuit vacated Defendant's conviction of attempting to persuade, induce, or entice a minor to engage in criminal sexual activity, holding that the trial was tainted by the erroneous limitation of Defendant's expert testimony.On appeal, Defendant argued that the evidence was constitutionally insufficient to convict him of the charged crimes and that the district court erred in barring his expert witness from testifying about whether Defendant's actions fit the mold of a sexual predator. The First Circuit vacated the judgment below, holding that the district court (1) did not err in denying Defendant's motion for a judgment of acquittal; but (2) erroneously excluded a portion of the testimony of Defendant's proposed expert, and the error was not harmless. View "United States v. Soler-Montalvo" on Justia Law

The First Circuit affirmed Defendant's conviction of three counts of engaging in the business of dealing a firearm without a license and sentence of sixty months' imprisonment, holding that there was no error or abuse of discretion in the district court's imposition of Defendant's sentence.Defendant admitted to engaging in the business of illegally dealing firearms on three separate occasions over more than one year. The district court imposed a sixty-month sentence. Defendant appealed his sentence, arguing that his sentence was procedurally and substantively unreasonable. The First Circuit affirmed, holding that there was no error as to the procedural objections and no abuse of discretion in the length of the sentence imposed. View "United States v. Andujar-Colon" on Justia Law

The First Circuit vacated Appellant's upwardly variant sentence of sixty months imposed in connection with his plea of guilty to one count of racketeering, holding that the sentencing court procedurally erred by basing Appellant's variant sentence, in part, upon certain evidence that lacked any indicia of reliability.Appellant, a former police officer with the Puerto Rico Police Department (PRPD), was convicted for his involvement with a corrupt group of PRPD officers. On appeal, Appellant challenged, among other things, the procedural reasonableness of his sentence, contending that the district court erred by relying upon his record of unadjudicated administrative complaints filed against Appellant during his career as an officer. The First Circuit agreed and vacated the sentence, holding that the district court's reliance upon Defendant's record of administrative complaints was insufficiently supported, and the error was not harmless. View "United States v. Rivera-Ruiz" on Justia Law