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

The First Circuit affirmed Defendant's convictions on six counts covering a range of federal crimes that stemmed from Defendant's use of a social security number assigned to another person, holding that there was no error in the proceedings below.On appeal, Defendant argued that the district court erred in admitting into evidence a form that he submitted to the Social Security Administration in 2014 and wrongly permitted a former immigration officer to testify to the answers that Defendant gave in response to questioning at the Miami Intentional Airport. The First Circuit affirmed, holding that the district court (1) did not err by rejecting Defendant's objection to the admission of the form; and (2) did not err in denying Defendant's motion to suppress the testimony of the former immigration official. View "United States v. Doe" on Justia Law

The First Circuit affirmed Defendant's conviction of one count of conspiracy to possess with intent to distribute and to distribute 500 grams or more of cocaine, in violation of 21 U.S.C. 846, and one count of possession with intent to distribute 500 grams or more of cocaine, in violation of 21 U.S.C. 841(a)(1), holding that there was no error.Specifically, the First Circuit held (1) the district court did not err in denying Defendant's motion to suppress evidence obtained during a traffic stop and admitting items seized from the vehicle at trial; (2) the district court did not manifestly abuse its discretion in admitting certain statements of lay witnesses; (3) the proceedings did not contravene Defendant's constitutional right to a speedy trial; and (4) Defendant's absence at certain pre-trial proceedings did not violate his statutory or constitutional presence rights. View "United States v. Reyes" on Justia Law

The First Circuit affirmed Defendant's conviction for interfering with commerce by threats or violence, in violation of 18 U.S.C. 1951 and 2 (Hobbs Act robbery); and using, carrying, or possessing a firearm during and in retaliation to a crime of violence, in violation of 18 U.S.C. 924(c)(1)(A)(ii), holding that there was no error.Specifically, the First Circuit held (1) Defendant's claim that Hobbs Act robbery is not a crime of violence for purposes of section 924(c)(1)(A) was meritless; (2) the trial court did not err by admitting video surveillance footage; and (3) the trial court did not err in excluding impeachment evidence challenging the credibility of the government's cooperating witness. View "United States v. Torres-Correa" on Justia Law

The First Circuit affirmed in part and reversed in part the judgment of the district court convicting Defendants, two brothers, of gun and drug crimes and sentencing them to 111 months' imprisonment, holding that there was no error in Defendant's convictions but that remand was required for resentencing.Specifically, the First Circuit held (1) the jury had sufficient evidence to find that the sale of guns sufficiently promoted, advanced, and made more likely to occur the sale of marijuana; (2) the district court did not err in denying Defendants' Rule 29 motion allowing WhatsApp messages sent for a month after March 23, 2017 to be admitted when the indictment charged conduct only up through March 23, 2017; and (3) the district court erred in applying a four-point enhancement at sentencing pursuant to U.S.S.G. 2K2.1(b)(6)(B). View "United States v. Ramirez-Frechel" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motion for compassionate release under 18 U.S.C. 3582(c)(1)(A), as amended by the First Step Act (FSA), holding that the district court did not abuse its discretion.Defendant, an inmate, moved for compassionate release pursuant to the compassionate-release statute, arguing that, given his pre-existing medical conditions, his heightened risk of complications stemming from COVID-19 constituted an "extraordinary and compelling" reason warranting a sentence reduction. The district court denied the motion on the papers. The First Circuit affirmed, holding that Defendant's arguments on appeal were unavailing. View "United States v. Texeira-Nieves" on Justia Law

The First Circuit summarily affirmed the order of the district court imposing an aggregate sentence of 210 months, to be followed by a six-year term of supervised release, in connection with Defendant's guilty plea to two drug-related counts, holding that there was no error.Pursuant to a plea agreement, Defendant pled guilty to one count each of possession with with intent to distribute heroin and cocaine and one count of being a felon in possession of a firearm and ammunition. After the district court imposed its sentence, Defendant appealed, arguing that the government should have recommended a sentence reduction and that he pleaded guilty in reliance on that promise. The First Circuit affirmed, holding that there was no plain error in the district court's determination that the government had not reneged on any promise made to Defendant. View "United States v. Bynoe" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Appellants' action for declaratory relief against the Governor of Rhode Island and various Rhode Island officials and agencies (collectively, Rhode Island), holding that the district court did not err.On behalf of a putative class of Rhode Island students attending K-12 schools, Appellants brought this action under the Equal Protection, Due Process, and Privileges and Immunities Clauses of the Fourteenth Amendment and the Republican Guarantee Clause of U.S. Const. art. IV, 4, claiming that Rhode Island failed to provide them with an adequate education to function productively in civic activities. The district court dismissed the action. The First Circuit affirmed, holding that the district court properly concluded that an adequate civics education is not a fundamental constitutional right and that Rhode Island's approach to civics education satisfies rational basis review. View "A.C. v. McKee" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's petition for habeas relief, holding that the district court did not err in its treatment of Defendant's claim for habeas relief based on Batson v. Kentucky, 476 U.S. 79 (1986).Defendant was convicted of first-degree murder and sentenced to life in prison. On appeal, Defendant raised a Batson claim of race-based discrimination in jury selection. The state court denied Defendant's appeal. Thereafter, Defendant filed a petition for habeas relief based on Batson. The federal district court denied relief. The First Circuit affirmed, holding that the Massachusetts Supreme Judicial Court did not unreasonably apply clearly established Supreme Court case law in concluding that Defendant did not establish the prima facie case of purposeful race-based discrimination required by Batson. View "Yacouba-Issa v. Calis" on Justia Law

The First Circuit affirmed Defendant's sentences that he received at hearings conducted via videoconference during the COVID-19 pandemic, holding that all but one of Defendant's challenges were waived or otherwise without merit and that Defendant's remaining challenge was not ripe for review.Specifically, the First Circuit held (1) Defendant's arguments challenging the district court's procedure in conducting his revocation hearing were waived; (2) Defendant's revocation was both procedurally and substantively reasonable; (3) the trial court did not plainly err in conducting its Fed. R. Crim. P. 11(b)(1)(N) inquiry; and (4) Defendant failed to establish error sufficiently grave to warrant setting aside his otherwise valid appeal waiver. View "United States v. Rodriguez-Monserrate" on Justia Law

The First Circuit affirmed Defendant's conviction of unlawful possession of a machine gun in violation of 18 U.S.C. 922(o), holding that there was sufficient evidence on which to convict Defendant and that the district court did not err in admitting certain evidence.On appeal, Defendant argued that the district court erred in denying his motions for judgment of acquittal and in admitting photographs of various firearms and accessories found on Defendant's cell phone. The First Circuit affirmed, holding (1) there was sufficient evidence to support Defendant's conviction; and (2) the district court did not abuse its discretion in allowing the government to introduce into evidence four photographs of firearms and firearm accessories. View "United States v. Torres-Perez" on Justia Law