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

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

The First Circuit affirmed Defendant's convictions for several contraband-possession offenses, including being a felon in possession of a firearm, holding that there was no reversible error in the proceedings below.Specifically, the First Circuit held (1) the district court properly instructed the jury on joint possession; (2) the government presented sufficient evidence on the element of possession for all counts; (3) any possible error in the admission at trial of lay opinion testimony from law enforcement witnesses was harmless; and (4) Defendant made no showing that errors in his indictment, evidence, and jury instructions under the Supreme Court's decision in Rehaif v. United States, 139 S. Ct. 2191 (2019), affected the outcome of his proceedings. View "United States v. Norris" on Justia Law

The First Circuit affirmed Defendant's conviction of possession with intent to distribute marijuana and possession of a firearm and ammunition by a convicted felon, holding that the district court did not err by not granting Defendant's motion to suppress.In his motion to suppress, Defendant sought to suppress evidence obtained after the execution of a search warrant at his residence, asserting errors and omissions in the underlying search warrant affidavit. The First Circuit affirmed the district court's denial of Defendant's motion, holding that the various motions that Defendant filed ultimately seeking to suppress the evidence seized from his residence were correctly denied. View "United States v. Maglio" on Justia Law

The First Circuit affirmed Defendant's upwardly variant sentence imposed in connection with his conviction for possessing a firearm in furtherance of a drug-trafficking crime, holding that the sentence was neither procedurally nor substantively unreasonable.Defendant entered a straight guilty plea to two counts of possession of drugs with intent to distribute and one count of possession of a firearm in furtherance of a drug-trafficking crime. The district court imposed an aggregate incarcerate sentence of eighty-eight months. On appeal, Defendant argued, among other things, that the sentencing court erred in imposing an upwardly variant sentence without providing adequate justification. The First Circuit affirmed, holding (1) there was no procedural error; and (2) the sentence was substantively reasonable. View "United States v. Valle-Colon" on Justia Law

The First Circuit affirmed the district court's judgment denying Defendant's motion to suppress evidence obtained during the execution of a no-knock search warrant at the apartment where he and his girlfriend lived, holding that the district court did not err.On appeal, Defendant argued that the district court erred by failing to suppress evidence obtained from the search of his backpack because his backpack was not properly subject to search and erred in failing to find that there was insufficient justification for the no-knock provision of the warrant. The First Circuit affirmed, holding (1) there was nothing improper about the search; and (2) the district court did not commit plain error by not ruling that the no-knock provision was unsupported. View "United States v. Congo" on Justia Law

The First Circuit affirmed the decision of the district court denying Defendant's motion for unconditional discharge, holding that there was no reversible error in the district court's decision.In 2009, Defendant was civilly committed under the Adam Walsh Child and Protection and Safety Act, 120 Stat. 587. In 2012, Defendant was discharged from his civil commitment under conditions, including that he received supervised probation and mental health treatment. In 2018, Defendant moved for an unconditional discharge. The district court denied the motion but did remove many of Defendant's conditions. The First Circuit affirmed, holding (1) the district court did not err in concluding that Defendant had failed to show he would not be sexually dangerous to others if released unconditionally; and (2) the district court did not err in finding that Defendant had failed to meet his burden to show that he would not have "serious difficulty in refraining from sexually violent conduct." View "United States v. Hunt" on Justia Law

The First Circuit affirmed Defendant's sentence of eighty-four months' imprisonment imposed in connection with his plea of guilty to being a felon in possession of a firearm, holding that the sentence was neither procedurally nor substantively unreasonable.On appeal, Defendant argued, among other things, that the district court erred by quashing subpoenas issued to victims and by imposing a sentence that Defendant argued was both procedurally and substantively unreasonable. The First Circuit affirmed, holding (1) the district court's quashing of the subpoenas did not violate Defendant's due process rights; and (2) the upwardly variant sentence was both procedurally and substantively reasonable. View "United States v. Hernandez-Negron" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motion for compassionate release, alleging "extraordinary and compelling" reasons pursuant to 18 U.S.C. 3582(c) 3582(c)(1)(A), as amended by the First Step Act, holding that the district court did not abuse its discretion when it denied Defendant's motion for compassionate release.Defendant admitted that he had violated the conditions of his supervised release, and the district court imposed a thirty-month revocation sentence to be served consecutively to any other term of imprisonment. Defendant later filed the instant motion for compassionate release, alleging, among other things, that his pre-existing medical infirmities, along with the conditions of his confinement, posed a substantial risk of severe illness if should contract COVID-19. The district court denied the motion. The First Circuit affirmed, holding that the district court did not abuse its discretion in denying Defendant's compassionate release motion. View "United States v. Canales-Ramos" on Justia Law