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

The First Circuit affirmed the judgment of the district court denying Appellant's habeas petition, holding that the Massachusetts state court reasonably applied federal law in deeming the Commonwealth's proof constitutionally adequate.After a jury trial, Defendant was convicted of first-degree murder on a theory of felony murder based on a predicate of armed robbery and sentenced him to a term of life imprisonment on the felony murder charge. The Massachusetts Supreme Judicial Court (SJC) affirmed the conviction. Petitioner sought federal habeas review in the federal district court. The district court denied the petition. The First Circuit affirmed, holding that the district court did not err in denying Appellant's application for habeas relief. View "Webster v. Gray" on Justia Law

The First Circuit affirmed Defendant's conviction for four offenses relating to Defendant's possession of a handgun with an obliterated serial number and drugs found within the bag that he was carrying, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant challenged the denial of his motion to suppress evidence recovered during his arrest, alleging that his seizure violated his Fourth Amendment rights and that he was coerced into handing over the bag to law enforcement. The First Circuit affirmed, holding (1) the officer lacked reasonable suspicion to justify the initial seizure of Defendant but an intervening voluntary act provided independent probable cause to arrest Defendant; (2) suppression was not warranted under the fruit-of-the-poisonous-tree doctrine; and (3) the district court did not abuse its discretion in imposing limitations on cross-examination during the trial. View "United States v. Sierra-Ayala" on Justia Law

The First Circuit vacated the judgment of the district court sentencing Defendant to the statutory maximum of two years' imprisonment for violating two conditions of his supervised release, holding that the written judgment rendered unreliable this Court's assumption that the district court excluded from its consideration the comments it made before formally explaining its sentence.Specifically, the First Circuit held that the written judgment rendered unreliable the Court's otherwise controlling assumption that the trial court excluded from its consideration the express comments it made shortly before formally explaining its sentence. The Court remanded the case to a new district court judge for prompt resentencing. View "United States v. Serrano-Berrios" on Justia Law

The First Circuit affirmed Defendant's conviction of two counts of criminal copyright infringement and one count of mail fraud and his sentence of concurrent prison terms of thirty-six months for the copyright counts and sixty months for the mail fraud count, holding that Defendant's arguments on appeal were unavailing.On appeal, Defendant argued that the evidence failed to show that he willfully committed the copyright violations and that his sentence must be adjusted because the district court erred in its guideline loss calculation. The First Circuit affirmed, holding (1) it was within the bounds of reason for the jury to find Defendant's actions willful; and (2) there was no plain error in the court's loss calculation. View "United States v. Gordon" on Justia Law

The First Circuit vacated the judgment of the trial judge denying Defendants' motion for a new trial based on improper comments by the prosecutor, holding that the district court's denial of the new trial motions was plain error.Defendants Edward Canty, III and Melquan Jordan were prosecuted on charges that they had conspired to distribute and possess with intent to distribute both heroin and cocaine base. During their criminal trial, the prosecutor made four types of improper comments during the opening and closing statements and at rebuttal, to which Defendants did not object. After they were convicted Defendants moved for a new trial based on the improper comments by the prosecutor. The trial judge denied the motions under plain error review. The First Circuit vacated the decision below, holding that the fairness, integrity, and public reputation of the proceedings were seriously affected, requiring remand for a new trial. View "United States v. Canty" on Justia Law

The First Circuit affirmed Defendant's conviction and sentence for one count of possession of child pornography, holding that Defendant suffered no prejudice from any claims deficient performance of his trial counsel.Pursuant to a plea agreement, Defendant pleaded guilty to one count of possession of child pornography. The trial court sentenced him to an under-Guidelines-range sentence of forty-six months. Defendant appealed, arguing that he received ineffective assistance of counsel during his sentencing proceedings because counsel failed to object to the four-level enhancement under U.S.S.G. 2G2.2(b)(4)(B) on constitutional grounds. The First Circuit affirmed, holding that Defendant's claims of ineffective assistance of counsel were unavailing. View "United States v. Messner" on Justia Law

The First Circuit upheld the judgment of the district court denying Defendant's motion to dismiss the indictment against him and convicting Defendant of interstate violation of a protection order under 18 U.S.C. 2262(a)(1), holding that no-contact and stay-away provisions in a conditional release order may constitute a "protection order" as defined by the Violence Against Women Act of 1994 (VAWA), 108 Stat. 1796, 1902.Defendant was charged with the felony assault of T.N. A state-court judge issued a conditional release order following a bail hearing that included a no-contact provision with T.N. The assault charge was later dismissed due to T.N.'s death. Three years later, a federal grand jury returned an indictment charging Defendant with two counts of interstate violation of a protection order. Defendant filed a motion to dismiss on the grounds that the conditional release order was not a "protection order" as defined under 18 U.S.C. 2266(5). The district court denied the motion to dismiss. The First Circuit affirmed, holding that the no-contact and stay-away provisions in a conditional release order may, under certain circumstances, satisfy the VAWA's definition of a "protection order" as defined in section 2266(5). View "United States v. Dion" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's petition for habeas corpus, in which he alleged ineffective assistance of counsel, holding that Appellant failed to establish that his counsel's performance was deficient under Strickland v. Washington, 466 U.S. 668 (1984).After a retrial, Appellant was convicted of two counts of attempting to kill a federal witness with intent to prevent testimony and communication with law enforcement. The First Circuit affirmed. Appellant later filed a motion under 28 U.S.C. 2255 to vacate his conviction based on ineffective assistance of counsel. The district court denied relief. The First Circuit affirmed, holding that Appellant's claims of ineffective assistance of counsel were unavailing. View "Watson v. United States" on Justia Law

The First Circuit denied a writ of habeas corpus sought by Petitioner under 28 U.S.C. 2254 to vacate her conviction for murder in the first degree, holding that there was no error.Petitioner was convicted of first-degree murder based on deliberate premeditation and extreme atrocity or cruelty and was sentenced to life imprisonment without the possibility of parole. Petitioner later filed a habeas petition claiming ineffective assistance of counsel. The district court denied the petition. The First Circuit affirmed, holding that there was no prejudice on any of the alleged errors claimed by Petitioner. View "Field v. Hallett" on Justia Law

Watkins was convicted of first-degree murder in Massachusetts state court in 2005 for a fatal 2003 shooting. The Supreme Judicial Court affirmed his conviction. His federal habeas petition was denied.The First Circuit affirmed the denial of relief. The state courts made an error of fact in their decisions, rejecting a “Brady” claim that a withheld a police report could have been used for the impeachment of a witness (Rudolph), finding that the report did not show the investigating officers were aware that Rudolph was a witness against Watkins. Under the Antiterrorism and Effective Death Penalty Act's deferential standard of review or applying de novo review, Watkins has not shown prejudice arising from the error or with respect to any of his other claims. There was an extensive examination of bias, and the failure to add onto any such evidence hardly would be prejudicial. Rudolph's motivation for reaching out to the police and the agreement that Rudolph later reached with the Commonwealth were discussed at trial and clearly informed Watkins and the jury that Rudolph sought an incentive in return for his cooperation and testimony. View "Watkins v. Medeiros" on Justia Law