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

Carlos Reyes-Rosario was convicted of five federal offenses related to a drug trafficking conspiracy in the United States District Court for the District of Puerto Rico. The indictment charged him with conspiracy to possess with intent to distribute controlled substances within 1,000 feet of a protected location, and possession with intent to distribute heroin, cocaine base, cocaine, and marijuana within 1,000 feet of a protected location. He was also charged with possession of firearms in furtherance of a drug trafficking crime but was acquitted of this charge. Reyes was sentenced to concurrent terms of 168 months for four counts and 120 months for one count.Reyes filed a motion for judgment of acquittal, arguing insufficient evidence for his convictions, particularly for Count Two, which involved aiding and abetting the possession with intent to distribute heroin. The District Court denied his motion, finding sufficient evidence for the jury to convict him based on his involvement in the conspiracy and the actions of his co-conspirators under the Pinkerton doctrine. Reyes appealed, challenging the denial of his motion for acquittal, the admission of certain evidence, and the reasonableness of his sentence.The United States Court of Appeals for the First Circuit reviewed the case. The court upheld the District Court's decision, finding that the evidence presented at trial, including testimony and video recordings, was sufficient to support Reyes's conviction under the Pinkerton doctrine. The court also found no abuse of discretion in the admission of the video and items seized during the search, as they were properly authenticated by a cooperating witness. Additionally, the court rejected Reyes's Confrontation Clause challenges, noting that he had ample opportunity to cross-examine the witness about relevant topics.The First Circuit affirmed the District Court's rulings, including the denial of Reyes's motion for acquittal and the admission of evidence. The court also found Reyes's sentence to be procedurally and substantively reasonable, as the District Court had adequately considered the relevant factors and provided a sufficient explanation for the sentence imposed. View "United States v. Reyes-Rosario" on Justia Law

Orlando Miguel Martínez-Ramos pleaded guilty to carjacking resulting in serious bodily injury and aiding and abetting the same, following a home invasion, robbery, and brutal physical attack on a 77-year-old woman who died nine days later. The advisory guideline sentencing range was up to fourteen years, but Martínez-Ramos acknowledged that an upward variance was warranted due to the victim's death. At sentencing, Martínez-Ramos argued for a fifteen-year sentence, while the government requested sixteen years.The United States District Court for the District of Puerto Rico did not accept either recommendation. Instead, it considered a higher advisory guideline range based on the first-degree murder cross-reference, which would have recommended a life sentence, reduced to twenty-five years due to the statutory maximum. However, the court did not apply this cross-reference, citing insufficient causation evidence and the belief that a twenty-five-year sentence was too harsh given Martínez-Ramos's youth. The court imposed an eighteen-year sentence, a substantial upward variance from the guideline range, due to the physical attack contributing to the victim's death.Martínez-Ramos appealed, arguing that the upward variance was substantively unreasonable and that the court applied too lenient a standard of causation. The United States Court of Appeals for the First Circuit reviewed the case. The court found that Martínez-Ramos had acknowledged the victim's death as a factor in his plea agreement and that the autopsy listed facial and bodily trauma as contributory factors to the death. The court concluded that the district court's finding was not clearly erroneous and affirmed the eighteen-year sentence. View "United States v. Martinez-Ramos" on Justia Law

Richard Evans, a former Captain in the Boston Police Department (BPD), was convicted of wire fraud, conspiracy to commit wire fraud, federal programs theft, and conspiracy to commit federal programs theft. These charges stemmed from his submission of false claims for overtime pay and his involvement in a scheme to submit such claims. Evans and his subordinates falsely reported working four-hour overtime shifts, even when they worked fewer hours or when the Evidence Control Unit (ECU) was closed.The United States District Court for the District of Massachusetts found Evans guilty on all counts after a five-day jury trial. He was sentenced to one year and one day of incarceration for each count, to be served concurrently, fined $15,000, and ordered to pay $17,390.99 in restitution. Evans appealed, challenging the sufficiency of the evidence, the willful blindness instruction, and other aspects of the trial.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed Evans' convictions for wire fraud and conspiracy to commit wire fraud, finding that the willful blindness instruction was appropriate given the numerous "flags of suspicion" that Evans ignored. However, the court vacated Evans' convictions for federal programs theft and conspiracy to commit federal programs theft, concluding that the government failed to present sufficient evidence to establish that the BPD received more than $10,000 in federal benefits during the relevant period, as required by 18 U.S.C. § 666(b). The case was remanded for further proceedings consistent with the opinion. View "United States v. Evans" on Justia Law

Edison Burgos-Montes, serving a life sentence, sought compassionate release due to serious medical conditions, including severe hypertension and obstructive sleep apnea. He argued that the Bureau of Prisons (BOP) failed to provide adequate treatment for these conditions. Burgos filed a motion with the district court in late 2021, presenting evidence of his ongoing severe hypertension and lack of treatment for his sleep apnea. The district court found that Burgos was receiving adequate medical care and denied his motion without prejudice.Burgos appealed, contending that the district court's finding was clearly erroneous. He pointed to evidence that, nearly a year after his sleep apnea diagnosis, the BOP had not provided him with a CPAP machine, the standard treatment for sleep apnea. The district court had relied on a letter from Dr. Gary Venuto, Clinical Director at FCC Coleman, stating that Burgos was receiving adequate care. However, Burgos argued that this assessment overlooked significant evidence of inadequate treatment.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the district court clearly erred in concluding that Burgos was receiving adequate treatment for his sleep apnea. The appellate court noted that Burgos had not received a CPAP machine or any other treatment for his sleep apnea, despite a diagnosis and a recommendation from an outside cardiologist. The court vacated the district court's order and remanded the case for further proceedings to determine if Burgos had demonstrated an "extraordinary and compelling" reason for compassionate release under 18 U.S.C. § 3582(c)(1)(A). View "United States v. Burgos-Montes" on Justia Law

Martin Flanagan, a former employee of Fresenius Medical Care Holdings, Inc., filed a qui tam lawsuit under the False Claims Act (FCA) against his former employer. He alleged that Fresenius engaged in a fraudulent kickback scheme to induce referrals to its dialysis clinics, violating the Anti-Kickback Statute (AKS). Flanagan claimed that Fresenius offered below-cost contracts to hospitals, overcompensated medical directors, and provided other benefits to secure patient referrals, which were then billed to Medicare and Medicaid.The U.S. District Court for the District of Maryland initially handled the case, which was later transferred to the U.S. District Court for the District of Massachusetts. The district court dismissed Flanagan's complaint for failing to meet the heightened pleading standard under Rule 9(b) of the Federal Rules of Civil Procedure. The court found that the amended complaint did not adequately allege specific false claims or provide representative examples. Additionally, the court ruled that some of Flanagan's claims were barred by the FCA's public-disclosure and first-to-file rules. The district court also denied Flanagan's motion to amend his complaint, citing undue delay and potential prejudice to Fresenius.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's dismissal, agreeing that Flanagan failed to plead the alleged fraud with the required particularity. The appellate court also upheld the denial of the motion to amend, noting that Flanagan had ample time to address the deficiencies in his complaint but failed to do so. The First Circuit concluded that the district court did not abuse its discretion in its rulings. View "Flanagan v. Fresenius Medical Care Holdings, Inc." on Justia Law

In this case, the defendant, Xavier O. Maldonado-Negroni, was appealing a sentence imposed for violations of his supervised release conditions. Maldonado had a history of supervised release violations following his 2013 conviction for drug trafficking. His most recent violations included testing positive for drugs and committing domestic violence, for which he received a six-year sentence under Commonwealth law.The United States District Court for the District of Puerto Rico determined that Maldonado's violations fell within the most serious category of supervised-release violations, classified as Grade A, and sentenced him to the statutory maximum of thirty-six months' imprisonment, to run consecutively to his Commonwealth sentence. Maldonado appealed, arguing that the district court's error in classifying his violations as Grade A rather than Grade B influenced the sentencing determination.The United States Court of Appeals for the First Circuit reviewed the case and agreed with Maldonado. The court found that the district court's brief statement that it would have imposed the same sentence regardless of the violations' category was inadequate to satisfy the government's burden to show harmless error. The appellate court noted that the district court's explanation did not make clear that the erroneous Guidelines range did not influence the sentence. Consequently, the First Circuit vacated the sentence and remanded the case for resentencing, emphasizing the need for a clear and unmistakable record that the Guidelines error did not affect the sentencing decision. View "United States v. Maldonado-Negroni" on Justia Law

Luis Javier Matta Quiñones was convicted of possession of firearms and ammunition as a prohibited person and possession of a machinegun. Matta claimed he was wrongfully accused by police officers who found contraband nearby. He attempted to discredit the officers' testimony that he threw a feed sack containing guns and ammunition onto a roof while fleeing. Matta argued on appeal that the district court hindered his defense in several ways, including allowing the government's case agent to be present during jury deliberations.The United States District Court for the District of Puerto Rico oversaw Matta's trial. The jury found Matta guilty on both charges. Matta moved for a judgment of acquittal and a new trial, arguing insufficient evidence and improper jury contact by the case agent. The district court denied both motions, reasoning that Matta had waived objections to the case agent's presence and that the contact was brief and non-prejudicial. Matta was sentenced to 96 months' imprisonment, with an additional 18 months for revocation of supervised release.The United States Court of Appeals for the First Circuit reviewed the case. The court found sufficient evidence to support Matta's convictions but agreed that the district court erred by allowing the case agent to be present during jury deliberations without proper investigation into potential juror misconduct. The appellate court vacated Matta's convictions and remanded for a new trial. The court also vacated the revocation of supervised release sentence and remanded for resentencing. Additionally, the court addressed evidentiary issues likely to recur, ruling that Matta should have been allowed to cross-examine Officer Vidal about prior statements and that the Receipt Form could be admissible under the business records exception. View "United States v. Matta-Quinones" on Justia Law

In the 1990s, José A. Vega-Figueroa was involved in a drug-trafficking operation in Puerto Rico. He was charged in 1994 with multiple offenses, including first-degree murder, but was acquitted by a jury in 1995. In 1997, a federal grand jury indicted him for his role in a criminal enterprise involving the distribution of various drugs and related violent acts. After a thirty-day trial, he was found guilty on all counts and sentenced to multiple life sentences. Vega has since made several unsuccessful attempts to challenge his conviction and sentence.In February 2021, Vega filed a motion for compassionate release in the District of Puerto Rico, citing his health conditions and the risk of COVID-19 complications. He also argued that his rehabilitation efforts and the double jeopardy of being tried for the same conduct warranted his release. The district court denied his motion, finding that the Bureau of Prisons had taken adequate measures to protect inmates from COVID-19 and that Vega's health conditions did not meet the criteria for compassionate release. The court also determined that Vega remained a danger to the community, given his criminal history and prison infractions.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's decision, agreeing that Vega's health conditions and the measures taken by the Bureau of Prisons did not constitute extraordinary and compelling reasons for release. The appellate court also upheld the district court's assessment that Vega continued to pose a danger to the community, thus justifying the denial of his motion for compassionate release. View "United States v. Vega-Figueroa" on Justia Law

José Luis Meléndez-Rivera and an associate committed a carjacking in Bayamón, Puerto Rico, during which Meléndez shot one of the victims in the face. Meléndez was arrested and charged with multiple offenses, including carjacking resulting in serious bodily injury and firearm-related charges. He initially pled not guilty but later negotiated a plea agreement with the government, agreeing to plead guilty to the carjacking charge in exchange for the dismissal of other charges.The United States District Court for the District of Puerto Rico did not accept the initial plea agreement, prompting Meléndez to withdraw his plea. A new plea agreement was reached, recommending a 180-month sentence for the carjacking charge. At sentencing, the court considered the presentence investigation report (PSR), the plea agreement, and Meléndez's sentencing memorandum, which detailed his difficult upbringing and history of recidivism. The court ultimately imposed a 198-month sentence, citing Meléndez's extensive criminal history and the need for deterrence and punishment.On appeal to the United States Court of Appeals for the First Circuit, Meléndez argued that the government breached the plea agreement by failing to meaningfully advocate for the recommended 180-month sentence and that the sentence was procedurally unreasonable because the court did not consider his mitigation arguments. The First Circuit found no plain error in the government's conduct, concluding that the prosecutor fulfilled her obligation by requesting the agreed-upon sentence. The court also held that the sentence was procedurally reasonable, as the district court had considered the relevant factors and Meléndez's mitigation arguments, even if it did not explicitly address each one. The First Circuit affirmed the district court's judgment. View "United States v. Melendez-Rivera" on Justia Law

Lester Aceituno was convicted of conspiracy to commit bank fraud and two counts of aggravated identity theft. The fraudulent scheme involved using stolen identification information to open bank accounts, change addresses to rented mailboxes, deposit fraudulent checks, and withdraw funds using debit cards. Aceituno opened accounts in New Hampshire and Massachusetts using stolen identities and signed documents attesting to the accuracy of the information. He also created a mailbox using a stolen identity. The scheme was led by a man known as "Abby," who provided the stolen information.The United States District Court for the District of New Hampshire denied Aceituno's Rule 29 motion, which argued insufficient evidence to prove he knew he was using real persons' identifying information. The court also rejected his claim of prosecutorial misconduct during the government's closing argument and rebuttal. Aceituno was sentenced to 30 months in prison.The United States Court of Appeals for the First Circuit reviewed the case. The court held that sufficient evidence supported the jury's finding that Aceituno knew the identification information belonged to real people. The evidence included Aceituno's repeated use of stolen identities, the bank's verification process, and testimony from a co-conspirator. The court also found that the prosecution's statements during closing arguments were fair inferences from the evidence and did not constitute misconduct. The court affirmed Aceituno's conviction. View "United States v. Aceituno" on Justia Law