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

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

In February 2013, a correctional officer named Osvaldo Albarati was murdered while driving home from the federal prison where he worked. Oscar Martínez-Hernández, an inmate at the prison, was convicted and sentenced to life imprisonment for orchestrating the murder. The prosecution argued that Martínez-Hernández, along with another inmate, planned the killing in retaliation for Albarati's efforts to confiscate contraband, including cellphones, from inmates. The defense contended that the evidence was insufficient and that the government had manipulated evidence and allowed false testimony.The United States District Court for the District of Puerto Rico oversaw the trial, which lasted twelve days and included testimony from twenty government witnesses. The defense presented two witnesses. The jury found Martínez-Hernández guilty on all counts, including aiding and abetting the murder of a federal officer, conspiracy to commit murder, murder for hire, and related firearms charges. The defense's motion for a new trial, based on the late disclosure of a prison logbook and other alleged errors, was denied by the district court.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the evidence presented at trial was sufficient to support the jury's verdict. The court also concluded that the late disclosure of the prison logbook did not warrant a new trial, as the logbook's contents did not significantly undermine the overwhelming evidence of Martínez-Hernández's guilt. The court rejected the defense's claims of prosecutorial misconduct and improper admission of hearsay statements, finding no abuse of discretion by the district court. The court affirmed Martínez-Hernández's conviction and the denial of his motion for a new trial. View "United States v. Martinez-Hernandez" on Justia Law

Joseph Segrain, an inmate at Rhode Island's Adult Correctional Institutions, filed a civil lawsuit against the Rhode Island Department of Corrections and several correctional officers, alleging violations of his Eighth Amendment rights and various state laws. Segrain claimed that on June 28, 2018, officers used excessive force by executing a leg-sweep maneuver, spraying him with pepper spray, and delaying his decontamination. The district court granted summary judgment in favor of the officers on all claims, leading Segrain to appeal.The United States District Court for the District of Rhode Island initially reviewed the case. The court found that no reasonable jury could conclude that the officers' conduct constituted an Eighth Amendment violation. It granted summary judgment on the basis that the force used was minimal and necessary to maintain order. The court also dismissed the state law claims, concluding that the officers' actions did not meet the legal standards for battery, intentional infliction of emotional distress, or excessive force under Rhode Island law.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed the district court's judgment regarding the 42 U.S.C. § 1983 claim that Officer Walter Duffy's use of pepper spray violated Segrain's Eighth Amendment rights. It found that a reasonable jury could conclude that Duffy's use of pepper spray was excessive and not in good faith. The court vacated the district court's judgment on the Rhode Island Constitution Article I, Section 8 claim regarding Duffy's use of pepper spray and remanded for further proceedings. However, the court affirmed the district court's judgment on all other claims, including the leg-sweep maneuver and the delayed decontamination, granting qualified immunity to the officers on those issues. View "Segrain v. Duffy" on Justia Law

In this case, the petitioner, a state prisoner, challenged the dismissal of his federal habeas petition, which alleged violations of his constitutional rights under the Fifth, Sixth, and Fourteenth Amendments. The petitioner, along with two accomplices, planned and executed a robbery that resulted in the murder of a pizza delivery driver. The petitioner was convicted of first-degree murder, armed robbery, and breaking and entering, and was sentenced to life in prison without parole.The Massachusetts Supreme Judicial Court (SJC) affirmed the petitioner's conviction, rejecting his claims of insufficient evidence, improper admission of redacted statements from a co-defendant, and errors in jury instructions. The SJC found that the evidence was sufficient to support the petitioner's conviction under theories of felony-murder and extreme atrocity or cruelty. It also held that the redacted statements did not violate the petitioner's Confrontation Clause rights and that the trial court's jury instructions were appropriate.The United States Court of Appeals for the First Circuit reviewed the district court's denial of the habeas petition de novo. The court applied the standards set forth in the Antiterrorism and Effective Death Penalty Act (AEDPA), which requires deference to state court decisions unless they are contrary to or involve an unreasonable application of clearly established federal law, or are based on an unreasonable determination of the facts.The First Circuit affirmed the district court's decision, holding that the SJC's rulings were not unreasonable. The court found that the evidence was sufficient to support the petitioner's conviction, the redacted statements did not violate the Confrontation Clause, and the jury instructions were proper. The court also concluded that any errors in the trial court's rulings were harmless and did not prejudice the petitioner. View "St. Jean v. Marchilli" on Justia Law

Federal agents executed a search warrant at Corey Donovan's rural property in New Hampshire, discovering a shotgun, ammunition, and modified oil filters suspected to be homemade silencers. Donovan, a convicted felon, was charged with being a felon in possession of a firearm. His girlfriend, Kelley Finnigan, claimed ownership of the shotgun but invoked her Fifth Amendment right when called to testify.The United States District Court for the District of New Hampshire denied Donovan's motion to grant Finnigan immunity and allowed her to invoke a blanket Fifth Amendment privilege. The court also permitted the introduction of evidence related to Donovan's prior arrest and possession of non-firearm weapons, offering to provide limiting instructions if requested during the trial. Donovan did not object to the lack of contemporaneous limiting instructions or the final jury instructions.The United States Court of Appeals for the First Circuit reviewed Donovan's appeal, which challenged the district court's decisions on Finnigan's Fifth Amendment invocation, the lack of limiting instructions, and the application of a sentencing enhancement for the modified oil filters. The appellate court found no clear or obvious error in allowing Finnigan to invoke her Fifth Amendment right, as her testimony could reasonably incriminate her. The court also determined that Donovan waived his right to challenge the lack of limiting instructions by failing to object during the trial.Regarding the sentencing enhancement, the appellate court upheld the district court's finding that the modified oil filters qualified as homemade silencers under 18 U.S.C. § 921(a)(25). The court affirmed Donovan's conviction and sentence, concluding that the evidence supported the application of the sentencing enhancement. View "US v. Donovan" on Justia Law

In May 2021, a police officer in Goffstown, New Hampshire, observed a vehicle driving without headlights. When the officer attempted to stop the vehicle, the driver, later identified as Brian Elliott, fled, leading to a high-speed chase. Elliott eventually stopped and fled on foot, during which he allegedly pointed a firearm at the officer and threatened to shoot. Elliott was later apprehended, and a search revealed firearms, ammunition, and fentanyl in his possession.A federal grand jury in the District of New Hampshire indicted Elliott on four counts, including drug and firearm charges. Elliott pled guilty to three counts in exchange for the dismissal of one count and a sentencing recommendation within the guideline range. The district court accepted the plea agreement and, after a hearing, applied a six-level enhancement for assaulting a police officer during the offense. The court found the officer's testimony credible and calculated a guideline range of 108 to 135 months, ultimately sentencing Elliott to 120 months.The United States Court of Appeals for the First Circuit reviewed Elliott's appeal, which challenged the procedural and substantive reasonableness of his sentence. Elliott argued that the district court erred in applying the enhancement and that his sentence was substantively unreasonable. The First Circuit found no clear error in the district court's credibility determination regarding the officer's testimony and upheld the application of the enhancement. The court also held that the 120-month sentence was substantively reasonable, given the seriousness of the offense and Elliott's criminal history. Consequently, the First Circuit affirmed the district court's judgment. View "US v. Elliott" on Justia Law

Carlos Gonzalez's residence was searched by the government for evidence of an illegal pill-making operation. Gonzalez moved to suppress the evidence found during the search, arguing that the search warrant was based on stale information and lacked probable cause. The district court agreed, finding that the facts supporting the search warrant were too old and that the affidavit was so bare bones that no reasonable officer could have relied on it. The court noted that the mastermind of the operation had moved out months earlier, there was little suspicious activity afterward, and the equipment was portable.The United States District Court for the District of Massachusetts granted Gonzalez's motion to suppress the evidence. The court concluded that the information in the affidavit was too stale to support probable cause and that the connection between the residence and any recent criminal activity was extremely thin. The court also determined that the good-faith exception did not apply because the affidavit was too conclusory and lacked sufficient detail to justify reliance on the warrant.The United States Court of Appeals for the First Circuit reviewed the case. The court decided to bypass the probable-cause determination and focused on whether a reasonable officer could have relied on the warrant in good faith. The court found that a reasonable officer could have believed that the pill-making operation was still ongoing at the residence, given the long-standing nature of the operation, the continued ownership of the house by the mastermind, and the involvement of Gonzalez and his girlfriend. The court vacated the district court's ruling on the motion to suppress and remanded the case for further proceedings. View "US v. Gonzalez" on Justia Law

The case involves Juan Rodriguez and Junito Melendez, who were convicted of conspiracy to distribute and possess with intent to distribute more than 500 grams of cocaine. Melendez was identified as the front man of the operation, interacting with customers and suppliers, while Rodriguez managed backend operations from his residence. The operation involved acquiring cocaine from suppliers, cooking some into crack cocaine, and selling it. The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) began investigating the defendants in 2018, leading to the seizure of Melendez's iPhone and subsequent wiretaps that provided evidence of their drug activities.In the United States District Court for the District of Massachusetts, a jury found both defendants guilty of the conspiracy charges. Melendez was also found guilty of distributing 500 grams or more of cocaine and had a prior conviction for a serious drug felony. He pleaded guilty to conspiracy to commit Hobbs Act robbery. The district court sentenced Rodriguez to 52 months and Melendez to 156 months in prison. Melendez's sentence included enhancements for drug quantity and his role as an organizer or leader in the conspiracy.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's decisions, finding no error in the denial of motions to suppress evidence from Melendez's iPhone and wiretaps, the admission of certain evidentiary testimony, and the jury instructions. The court also upheld the sentencing enhancements for Melendez, concluding that the evidence supported the drug quantity attributed to him and his role as an organizer in the conspiracy. The court found that any potential errors were harmless and did not affect the overall outcome of the case. View "United States v. Rodriguez" on Justia Law