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

In this case, the defendant, Dominick Bailey, pleaded guilty to being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1). This was Bailey's third conviction for the same offense, with previous convictions in 1997 and 2006. In 2019, Bailey was involved in a guns-for-drugs transaction, where he admitted to possessing firearms despite his felon status. He was arrested in Boston with multiple firearms in his possession. Bailey pleaded guilty without a plea agreement during a virtual proceeding.The District Court for the District of Massachusetts sentenced Bailey to eighty-seven months of imprisonment, departing upward from the advisory sentencing guideline range due to Bailey's extensive criminal history. Bailey objected to the sentencing departure in the district court.On appeal to the United States Court of Appeals for the First Circuit, Bailey challenged the indictment, the voluntariness of his guilty plea, the procedural aspects of his sentencing, and the substantive reasonableness of his sentence. The appellate court reviewed Bailey's claims, applying plain error review to unpreserved claims and abuse of discretion to preserved claims.The First Circuit found no plain error in the district court's determination that Bailey's guilty plea was knowing and voluntary, despite Bailey's mental health conditions and medication use. The court also found that the district court did not err in its explanation for the upward departure, noting that Bailey's criminal history was extensive and warranted a higher sentence for public protection and deterrence. The appellate court affirmed the district court's judgment, concluding that the eighty-seven-month sentence was reasonable given Bailey's persistent criminality and the seriousness of the offense. View "United States v. Bailey" on Justia Law

In this case, the defendant, Domingo Emmanuel Bruno-Cotto, pleaded guilty to two counts of carjacking and one count of kidnapping following a multi-day crime spree in Puerto Rico. The spree included carjacking an Uber driver, kidnapping an airport passenger, and committing multiple sexual assaults on a woman at a beach. The district court sentenced Bruno-Cotto to 208 months in prison, which was 20 months above the advisory guideline range, citing the unusual cruelty of his actions.The United States District Court for the District of Puerto Rico initially reviewed the case. Bruno-Cotto did not contest the facts in the presentence report but requested a lower sentence based on his difficult childhood and mental health issues. The government argued for a high-end guideline sentence, emphasizing Bruno-Cotto's leadership role and the premeditated nature of his crimes. The district court ultimately imposed a higher sentence, highlighting the severity and cruelty of Bruno-Cotto's actions, particularly the repeated sexual assaults.The United States Court of Appeals for the First Circuit reviewed the case on appeal. Bruno-Cotto argued that the sentence was procedurally flawed due to the district court's reliance on unreliable hearsay and that it was substantively unreasonable compared to his co-defendant's sentence. The appellate court found no plain error in the district court's reliance on the presentence report, noting that the hearsay information had sufficient indicia of trustworthiness. The court also found the sentence substantively reasonable, given the egregious nature of Bruno-Cotto's conduct and the differences in culpability between him and his co-defendant. The First Circuit affirmed the district court's 208-month sentence. View "United States v. Bruno-Cotto" on Justia Law

The case involves Miguel Santana-Avilés, who was convicted of assaulting a correctional officer at the Metropolitan Detention Center in Guaynabo, Puerto Rico. On August 20, 2020, during an inmate count, Officer Efrén Rosario found an extra pillow in the cell shared by Santana-Avilés and two other inmates, which violated prison policy. When Officer Rosario attempted to remove the pillow, one of the cellmates, Héctor Maldonado-Maldonado, attacked him. Santana-Avilés then grabbed Officer Rosario from behind, allowing Maldonado to continue the assault. Santana-Avilés also encouraged the attack by shouting "Hit him." The officers eventually subdued both inmates with the help of reinforcements.The United States District Court for the District of Puerto Rico presided over the initial trial. Santana-Avilés did not testify but sought to introduce statements he made during the incident, claiming they were excited utterances. The court excluded these statements as hearsay. Additionally, the court admitted an email from a prison technician explaining the lack of video evidence due to technical issues, despite Santana-Avilés's objections. The jury found Santana-Avilés guilty of aiding and abetting the assault of a correctional officer, and he was sentenced to eighty-seven months in prison.The United States Court of Appeals for the First Circuit reviewed the case. Santana-Avilés argued that the district court made erroneous evidentiary rulings by excluding his statements and admitting the email. The appellate court found that even if the exclusion of Santana-Avilés's statements was an error, it was harmless given the overwhelming evidence against him. The court also held that the email was properly admitted to rebut an implied charge of fabrication or improper motive. Consequently, the First Circuit affirmed the conviction and sentence. View "United States v. Santana-Aviles" on Justia Law

In this case, the petitioner was convicted by a jury in New Hampshire state court for the first-degree murder of Larry Lemieux. The petitioner admitted to shooting Lemieux but claimed he acted in self-defense or in defense of another, arguing he did not act with premeditation. After his conviction, the prosecution disclosed a proffer letter recommending a suspended sentence for drug charges against Jose Gomez, a key prosecution witness. The petitioner argued that the failure to disclose this letter violated his due process rights under Brady v. Maryland.The state trial court denied the petitioner's motion for a new trial, finding that the nondisclosure of the proffer letter did not prejudice the petitioner. The New Hampshire Supreme Court affirmed this decision, holding that the petitioner was not prejudiced under New Hampshire law, which sets stricter standards than Brady. The court found that the undisclosed evidence would not have altered the defense strategy or the trial's outcome, given the overwhelming additional evidence of premeditation presented by other witnesses.The United States Court of Appeals for the First Circuit reviewed the case, focusing on whether the New Hampshire Supreme Court's decision involved an unreasonable application of clearly established federal law under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). The First Circuit affirmed the denial of habeas relief, concluding that the New Hampshire Supreme Court reasonably determined that the petitioner was not prejudiced by the nondisclosure of the proffer letter. The court noted the overwhelming evidence of premeditation from multiple witnesses, which supported the jury's verdict independent of Gomez's testimony. View "Etienne v. Edmark" on Justia Law

The case involves Lucas Sirois and Alisa Sirois, who were indicted for conspiracy to distribute and possess with intent to distribute marijuana under the Controlled Substances Act (CSA). They sought to enjoin the Department of Justice (DOJ) from prosecuting them, arguing that their conduct was in substantial compliance with the Maine Medical Use of Cannabis Act, which allows for the use, distribution, possession, and cultivation of medical marijuana under state law. The defendants claimed that the DOJ's prosecution violated the Rohrabacher-Farr Amendment, which prohibits the DOJ from using funds to prevent states from implementing their medical marijuana laws.The United States District Court for the District of Maine denied the defendants' request for injunctive relief. The court held a hearing where the government presented evidence that the defendants' operations, particularly a grow operation known as the "Shoe Shop," violated Maine's medical marijuana laws by operating as a collective and engaging in black-market sales. The court found that the government had met its burden of production, showing a substantial evidentiary basis for the prosecution. However, the defendants failed to meet their burden of persuasion to demonstrate that the prosecution lacked a substantial evidentiary basis or was arbitrary or irrational.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the District Court's decision. The appellate court held that the defendants did not show by a preponderance of the evidence that they were in substantial compliance with Maine's medical marijuana laws. The court noted significant evidence that the Shoe Shop operated as a collective and that Lucas Sirois engaged in black-market sales. The court concluded that the defendants failed to demonstrate that the DOJ's prosecution would prevent Maine from giving practical effect to its medical marijuana laws, as required under the Rohrabacher-Farr Amendment. Therefore, the denial of the motion to enjoin the prosecution was affirmed. View "United States v. Sirois" on Justia Law

In this case, the defendants, Aurea Vázquez Rijos, Marcia Vázquez Rijos, and José Ferrer Sosa, were involved in a murder-for-hire plot that resulted in the death of Adam Anhang Uster in Old San Juan, Puerto Rico, in 2005. Adam, a Canadian entrepreneur, was attacked and killed by a man hired by the defendants while walking with his wife, Aurea. The motive was financial gain from a prenuptial agreement that favored Aurea significantly more in the event of Adam's death than in the case of a divorce.The United States District Court for the District of Puerto Rico tried the defendants. A federal jury convicted Aurea of murder for hire and all three defendants of conspiring to commit murder for hire. Each received a life sentence. The defendants appealed, raising numerous issues related to the trial, sentencing, and post-trial phases.The United States Court of Appeals for the First Circuit reviewed the case. The court addressed various claims, including the sufficiency of the evidence, the denial of severance, the admission of certain evidence, judicial bias, and the handling of post-trial motions related to the mental health of a key witness, Alex Pabón Colon. The court found that the evidence presented at trial was sufficient to support the convictions and that the district court did not abuse its discretion in its rulings on severance, evidentiary matters, and judicial conduct.The court also examined the defendants' claims regarding the mental health of Pabón, who testified that he was hired by the defendants to kill Adam. The court concluded that the district court did not err in its handling of Pabón's competency and the related post-trial motions. The court affirmed the district court's decisions across the board, upholding the convictions and sentences of the defendants. View "United States v. Vazquez-Rijos" on Justia Law

A priest residing in the rectory of St. Mary's Catholic Church in Providence, Rhode Island, was found to have over 12,000 images and 1,300 videos of child pornography on his laptop and external hard drive. The government obtained a search warrant for the rectory, which led to the seizure of these devices. Subsequently, a federal grand jury charged the priest with receipt and possession of child pornography. The priest entered a conditional guilty plea, reserving the right to appeal the district court's denial of his motion to suppress the evidence obtained from the search.The United States District Court for the District of Rhode Island denied the motion to suppress, finding that the rectory was best characterized as a single-family residence, thus validating the warrant's description. The court also held that even if the warrant lacked sufficient particularity, the good-faith exception to the exclusionary rule would apply, as the officers reasonably relied on the warrant.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court concluded that the warrant was sufficiently particular regarding the premises and the items to be seized. Even if it were not, the good-faith exception applied because the officers acted reasonably based on the detailed affidavit provided by Detective Evans. The court also noted that the appellant waived his right to appeal the denial of his motion for reconsideration by not reserving it in his conditional plea agreement. Thus, the judgment of the district court was affirmed. View "US v. Jackson" on Justia Law

Brian Watson was convicted in 2017 by a jury for the felony sale of a controlled drug (fentanyl) resulting in death. The prosecution's evidence included testimony from Dr. Daniel Isenschmid, a forensic toxicologist, who discussed toxicology tests conducted by his colleagues, revealing fentanyl and its metabolites in the victim's blood. Watson appealed, arguing that the trial court erred by allowing Dr. Isenschmid to testify about tests he did not perform. The New Hampshire Supreme Court affirmed the conviction, finding that Dr. Isenschmid's involvement in the case was sufficient to satisfy the Confrontation Clause.Watson then filed a habeas corpus petition under 28 U.S.C. § 2254 in the United States District Court for the District of New Hampshire, claiming that his Confrontation Clause rights were violated by Dr. Isenschmid's testimony. The warden moved for summary judgment, which the district court granted, concluding that the state court's decision was neither contrary to nor an unreasonable application of Supreme Court precedent.The United States Court of Appeals for the First Circuit reviewed the case and upheld the district court's decision. The court found that Watson did not provide clear and convincing evidence to show that the state court's factual findings were incorrect. The court also determined that the state court's decision was not contrary to or an unreasonable application of clearly established federal law. The First Circuit noted that Dr. Isenschmid had personally reviewed all relevant documentation, data, and test results, and had issued and signed the toxicology report, making his testimony permissible under the Confrontation Clause. The court affirmed the district court's grant of summary judgment in favor of the warden. View "Watson v. Edmark" on Justia Law

In 2020, a federal grand jury indicted David DeQuattro, an architect, and Cedric Cromwell, Chairman of the Mashpee Wampanoag Tribal Council and President of the Mashpee Wampanoag Gaming Authority. They were charged with various federal offenses, including bribery and extortion, related to Cromwell allegedly soliciting and DeQuattro allegedly providing checks and other items of value to protect a contract between DeQuattro's firm and the Gaming Authority for building a casino on tribal land.The United States District Court for the District of Massachusetts held a jury trial where DeQuattro was convicted of one count of federal-program bribery, and Cromwell was convicted of two counts of federal-program bribery and multiple counts of Hobbs Act extortion. However, the District Court later entered a judgment of acquittal on the Hobbs Act-related counts, determining that the Hobbs Act did not clearly abrogate tribal immunity. Both defendants appealed their § 666 convictions, and the government cross-appealed the judgment of acquittal on the Hobbs Act counts.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed both the § 666 convictions and the judgment of acquittal. The court found that the evidence did not suffice to show that the RGB contract was "business" of the Tribe, as required under § 666, because the Gaming Authority, which entered the contract, was a separate legal entity from the Tribe and received almost all its funding from a third party. The court also reversed the District Court's judgment of acquittal on the Hobbs Act convictions, holding that tribal officials do not enjoy immunity from federal criminal prosecution and that the evidence was sufficient to show Cromwell's intent to engage in a quid pro quo arrangement. The case was remanded for further proceedings consistent with this opinion. View "United States v. Dequattro" on Justia Law

The defendant pleaded guilty to one count of coercion and enticement of a minor. The plea agreement included a joint recommendation for a 120-month sentence, which is the statutory minimum, despite the calculated Guidelines sentencing range being significantly higher. The government did not provide an explanation for this recommendation at the sentencing hearing. The district court sentenced the defendant to 292 months in prison, imposed a condition of supervised release prohibiting unsupervised contact with any minor, including his children, and ordered a special assessment and restitution.The defendant appealed, arguing that the government breached the plea agreement by not adequately supporting the recommended sentence and that the sentence and conditions imposed were unreasonable. The United States Court of Appeals for the First Circuit reviewed the case. The court agreed that the government breached the plea agreement by failing to provide a minimal explanation for the recommended sentence, which was necessary given the significant downward variance from the Guidelines range. However, the court concluded that this breach did not constitute plain error and affirmed the length of the sentence as reasonable.The court also upheld the restriction on the defendant's unsupervised contact with his children, finding it reasonably related to the nature of the offense and necessary to protect the community and minors. However, the court vacated the special assessment and restitution orders, remanding these issues to the district court for further consideration. The special assessment was vacated because the district court did not make a finding regarding the defendant's indigency, and the restitution order was vacated because the district court did not find that the victim's mother was a victim within the statutory definition. View "United States v. Acevedo-Osorio" on Justia Law