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

In this case, the defendant, a radio talk show host and church founder, began selling bitcoin in 2014. The government investigated his bitcoin sales and charged him with conspiracy to operate an unlicensed money transmitting business, operation of an unlicensed money transmitting business, conspiracy to commit money laundering, money laundering, and tax evasion. After a jury convicted him on all counts, the district court acquitted him of the substantive money laundering count due to insufficient evidence but upheld the other convictions.The defendant appealed, arguing that the district court should not have allowed the money-transmitting-business charges to proceed to trial, citing the "major questions doctrine" which he claimed should exempt virtual currencies like bitcoin from regulatory statutes. He also contended that the evidence was insufficient to support his tax evasion conviction and that he should be granted a new trial on the money laundering conspiracy count due to prejudicial evidentiary spillover. Additionally, he argued that his 96-month sentence was substantively unreasonable.The United States Court of Appeals for the First Circuit reviewed the case. The court rejected the defendant's major questions doctrine argument, holding that the statutory definition of "money transmitting business" under 31 U.S.C. § 5330 includes businesses dealing in virtual currencies like bitcoin. The court found that the plain meaning of "funds" encompasses virtual currencies and that the legislative history and subsequent congressional actions supported this interpretation.The court also found sufficient evidence to support the tax evasion conviction, noting that the defendant had substantial unreported income and engaged in conduct suggesting willful evasion of taxes. The court rejected the claim of prejudicial spillover, concluding that the evidence related to the money laundering conspiracy was admissible and relevant.Finally, the court upheld the 96-month sentence, finding it substantively reasonable given the defendant's conduct and the factors considered by the district court. The court affirmed the district court's rulings and the defendant's convictions and sentence. View "United States v. Freeman" on Justia Law

From 1990 to 1999, Patrick Rose, Sr., a Boston Police Department (BPD) officer, sexually abused two children, John and Jane Doe. Rose pled guilty to 21 counts of child rape and sexual assault in April 2022. The Does, now adults, sued Rose, the BPD, and other defendants involved in the investigation and response to their abuse allegations, claiming the defendants deprived them of their Fourteenth Amendment right to bodily integrity by enhancing the danger from Rose's abuse.The United States District Court for the District of Massachusetts dismissed the case before discovery, concluding that the defendants could not be held responsible under the state-created danger doctrine because the Does did not sufficiently allege that the defendants' actions enhanced Rose's abuse and caused them harm. The court also dismissed the Does' remaining claims.The United States Court of Appeals for the First Circuit vacated the district court's decision regarding the Does' Fourteenth Amendment claims. The appellate court concluded that the Does plausibly alleged that some of the defendants' actions enhanced the danger to them, meeting the first requirement of the state-created danger test. The court remanded the case for the district court to evaluate those actions under the test's remaining requirements. The appellate court also vacated the dismissal of the claims against the City of Boston and the DCF defendants, allowing the Does to address those claims. However, the appellate court affirmed the dismissal of the Does' § 1985 claims, agreeing with the district court that the Does failed to allege membership in a protected class or class-based discrimination. View "Doe v. City of Boston" on Justia Law

Three appellants, Anthony Rivera-Rivera, Victor M. Hernández-Carrasquillo, and Jimmy Ríos-Alvarez, were convicted of armed carjacking and using a firearm in a crime of violence. They were part of a group that committed a violent home invasion targeting a family. During the invasion, the group assaulted the family members, causing serious injuries, and stole valuables. Two members of the group took the family's car to withdraw money from an ATM, while the appellants stayed behind to guard the family.The United States District Court for the District of Puerto Rico held a joint trial for the appellants. The jury found them guilty on both counts. The appellants filed motions for judgment of acquittal, which the court denied, concluding that the government had presented sufficient evidence for a rational factfinder to find each appellant guilty beyond a reasonable doubt. Rivera and Hernández also filed motions to dismiss the indictment due to delayed Brady disclosures, which the court denied. Additionally, Rivera and Hernández sought severance from Ríos to call him as a witness, but the court denied this motion as well.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the convictions, finding sufficient evidence to support the jury's verdicts. The court held that the appellants had knowledge of the carjacking and took affirmative acts to further the crime. The court also found no abuse of discretion in the district court's denial of the motions to dismiss the indictment and for severance. The court rejected Rivera's Confrontation Clause claims and upheld the sentences for Rivera and Hernández, finding them procedurally and substantively reasonable. View "United States v. Rivera-Rivera" on Justia Law

On December 15, 2021, Nashalie Rodríguez-Bermúdez was charged with possession with intent to distribute five kilograms or more of cocaine and conspiracy to possess with intent to distribute the same. Rodríguez entered a straight plea on July 7, 2022, and was sentenced by the federal District Court for the District of Puerto Rico on March 3, 2023, to 46 months of incarceration with five years of supervised release. Rodríguez appealed the sentence, arguing that the district court erred in its sentencing process.The District Court for the District of Puerto Rico received a presentence investigation report (PSR) and sentencing memoranda from both the defense and the government. The PSR recommended a four-point minimal participant adjustment, resulting in a Guidelines range of 46 to 57 months. The defense argued for a time-served sentence, while the government recommended 57 months, or alternatively, 48 months. During the sentencing hearing, the district court declined to definitively determine the applicable Guidelines range, stating that the sentence would be the same regardless of whether Rodríguez was a minimal participant.The United States Court of Appeals for the First Circuit reviewed the case and found that the district court committed procedural error by failing to adequately explain why the 46-month sentence was appropriate irrespective of the applicable Guidelines range. The appellate court noted that the district court's reliance on the high end of the defense's proposed Guidelines range without a clear explanation of how the other § 3553(a) factors supported the sentence was insufficient. Consequently, the First Circuit vacated the sentence and remanded the case for resentencing, emphasizing the need for a clear and adequate explanation for the chosen sentence. View "United States v. Rodriguez-Bermudez" on Justia Law

Between February 2014 and December 2015, United States Postal Inspection Service (USPIS) agents in Puerto Rico identified a pattern of suspicious packages being sent between Puerto Rico and New York. Upon inspection, these packages were found to contain cocaine and large sums of money concealed in household items. The investigation led to Miguel A. Reyes-Ballista (Reyes) and two co-conspirators. Reyes was indicted and, after a six-day trial, a jury convicted him of participating in two conspiracies to possess with intent to distribute cocaine and three counts of possession with intent to distribute cocaine.Reyes was sentenced to 170 months in prison with four years of supervised release. He appealed his convictions, arguing that the government provided insufficient evidence to support the jury's verdict. Reyes also sought a new trial, claiming ineffective assistance of counsel due to inadequate communication with his attorney and poor performance at trial, which he argued violated his Sixth Amendment right to counsel.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the evidence presented at trial, including testimony from co-conspirators, surveillance footage, and fingerprint evidence, was sufficient to support Reyes's convictions for conspiracy. The court noted that Reyes's arguments regarding the credibility of witnesses and the lack of direct evidence placing him inside the post office did not undermine the jury's verdict. The court also dismissed Reyes's Sixth Amendment claim as premature, indicating that such claims are typically better suited for collateral proceedings where a more developed record can be established.The First Circuit affirmed Reyes's convictions and dismissed his Sixth Amendment claim without prejudice, allowing him the opportunity to raise the issue in a future collateral proceeding. View "United States v. Reyes-Ballista" on Justia Law

In this case, the defendant was convicted of kidnapping resulting in death under 18 U.S.C. § 1201(a)(1). The incident occurred in February 2019, when the defendant encountered the victim in downtown Boston, Massachusetts. They walked to his car together, and he later drove to his apartment in Providence, Rhode Island. Surveillance footage showed him carrying the victim's limp body into his apartment. Four days later, police found the victim's dead body in the defendant's car trunk in Delaware. The defendant was arrested and charged with kidnapping resulting in death.The United States District Court for the District of Massachusetts conducted the trial, where the jury found the defendant guilty. The court sentenced him to life in prison without the possibility of parole. The defendant appealed, alleging various errors in the district court proceedings, including issues with the indictment, denial of a bill of particulars, and the admission and exclusion of certain evidence.The United States Court of Appeals for the First Circuit reviewed the case. The court found no error in the district court's proceedings. It held that the indictment was sufficient, the denial of a bill of particulars was not an abuse of discretion, and the evidence admitted and excluded was handled appropriately. The court also found that the jury instructions were proper and that there was sufficient evidence to support the conviction. The court affirmed the defendant's conviction and sentence. View "United States v. Coleman" on Justia Law

Derek Muñoz-Gonzalez was indicted on multiple charges related to child pornography, including production, possession, and distribution. He agreed to plead guilty to two counts of producing child pornography. The plea agreement included a waiver-of-appeal clause, which stated that Muñoz waived his right to appeal if sentenced to 327 months or less. The district court sentenced him to 327 months. Muñoz appealed, claiming the prosecutor breached the plea agreement by advocating for two enhancements not included in the agreement's sentencing guidelines calculation and argued that the waiver-of-appeal clause did not preclude him from raising this breach claim.The United States District Court for the District of Puerto Rico initially reviewed the case. Muñoz was charged by a federal grand jury and subsequently pleaded guilty to two counts of producing child pornography. The plea agreement stipulated an advisory guideline range of 262 to 327 months' imprisonment, and the government agreed to dismiss the other counts. At sentencing, the district court considered the stipulated facts and sentenced Muñoz to 327 months, within the waiver-of-appeal limit.The United States Court of Appeals for the First Circuit reviewed the case. Muñoz argued that the prosecutor breached the plea agreement by highlighting facts not included in the guidelines calculation. The court held that the prosecutor did not breach the plea agreement, as the comments made were consistent with the stipulated facts and were in response to the defense's arguments for a lesser sentence. The court also noted that Muñoz failed to address the plain-error standard in his opening brief, resulting in a waiver of his breach-of-plea-agreement claim. Consequently, the court affirmed the district court's decision. View "United States v. Munoz-Gonzalez" on Justia Law

In 2024, the United States District Court for the District of Puerto Rico revoked Kelvin García-Oquendo's terms of supervised release and imposed concurrent terms of 21 months and 18 months of imprisonment. This decision was based on findings that García had violated the conditions of his release by engaging in new criminal conduct, including identity theft and bank fraud.Previously, in 2013, García had pleaded guilty to conspiracy to commit bank fraud and aggravated identity theft, and in 2015, he pleaded guilty to unauthorized use and transfer of access devices. He was sentenced to a total of 89 months' imprisonment and five years of supervised release. In 2023, the Probation Office alleged that García had committed new crimes, leading to his arrest and a preliminary revocation hearing where probable cause was found for some of the allegations.The United States Court of Appeals for the First Circuit reviewed the case. García argued that the District Court erred by admitting hearsay testimony without proper balancing under Federal Rule of Criminal Procedure 32.1(b) and the Due Process Clause. The First Circuit agreed that the District Court erred in admitting the testimony but concluded that the error was harmless due to the strong circumstantial evidence supporting the violation findings. The court held that Rule 32.1's limited confrontation right applies to the entirety of the revocation proceeding, including the determination of post-revocation sanctions. However, it found that any error in considering the hearsay testimony during sentencing was also harmless, as the other evidence strongly supported the District Court's findings.The First Circuit affirmed the District Court's revocation order and sentences. View "United States v. Garcia-Oquendo" on Justia Law

Jadnel Flores-Nater, a member of a gang, participated in the kidnapping and murder of a victim in Puerto Rico. On June 8, 2018, Flores-Nater and four other gang members kidnapped the victim from a public housing complex, each carrying an assault rifle. They drove the victim to a remote area, where Flores-Nater and other gang members shot and killed him. Flores-Nater was charged with kidnapping resulting in death, using a firearm in furtherance of a crime of violence, and using a firearm in furtherance of a crime of violence causing murder. He pleaded guilty to discharging a firearm in furtherance of a crime of violence, and the government agreed to dismiss the other charges.The United States District Court for the District of Puerto Rico initially sentenced Flores-Nater to 360 months in prison, which was above the 120-month guideline and the 300-month recommendation in the plea agreement. Flores-Nater appealed, and the United States Court of Appeals for the First Circuit vacated the sentence, finding it substantively unreasonable due to the district court's failure to articulate a plausible rationale for the upward variance. On remand, the district court again imposed a 360-month sentence, citing the high crime rate in Puerto Rico and the need for deterrence, but did not address Flores-Nater's argument regarding his age at the time of the offense.The United States Court of Appeals for the First Circuit reviewed the case again. The court found that the district court committed procedural error by failing to explain whether and why it rejected Flores-Nater's argument that his youth at the time of the offense should be considered a mitigating factor. The appellate court vacated the sentence and remanded the case for resentencing, requiring the district court to provide a clear explanation of its reasoning, particularly regarding the defendant's age. The court did not find that the government breached the plea agreement by defending the higher sentence on appeal. View "United States v. Flores-Nater" on Justia Law

José Miguel Guzmán-Ceballos was sentenced to ninety months' imprisonment for his involvement in transporting 385 kilograms of cocaine from the Dominican Republic to Puerto Rico. He pleaded guilty to all counts without a plea agreement and sought a mitigating role adjustment under § 3B1.2 of the United States Sentencing Guidelines, which the district court denied. Guzmán-Ceballos argued that he was merely a fisherman recruited for the smuggling operation due to economic hardship and had no significant role in planning or organizing the venture.The District Court of Puerto Rico held a change-of-plea hearing where Guzmán-Ceballos pleaded guilty. At the sentencing hearing, he objected to the presentence report (PSR) for not applying the mitigating role adjustment. The district court denied his objection, adopted the PSR's recommendations, and sentenced him to ninety months' imprisonment, noting it considered the 18 U.S.C. § 3553(a) factors and his role in the offense. Guzmán-Ceballos timely appealed, arguing the district court failed to conduct the necessary legal analysis for the mitigating role adjustment.The United States Court of Appeals for the First Circuit reviewed the case and agreed with Guzmán-Ceballos. The court found that the district court did not engage in the required four-part analysis to determine his role in the offense. Specifically, the district court failed to identify the universe of participants, order them along a continuum of culpability, and compare Guzmán-Ceballos's role to the average participant using the § 3B1.2 factors. The appellate court vacated the sentence and remanded the case for resentencing, instructing the district court to perform the correct mitigating role analysis. View "United States v. Ceballos" on Justia Law