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

The First Circuit affirmed Defendant's prison sentence for possessing with intent to distribute cocaine base, in violation of 21 U.S.C. 841(a), holding that Defendant invited any error in regards to his challenge to the determination of his criminal history category.Pursuant to a plea agreement, Defendant pled guilty to possessing with intent to distribute cocaine base. At the sentencing hearing, the district court acknowledged that the parties recommended a statutory minimum sentence of sixty months' imprisonment. The district court proceeded to impose an eighty-four-month prison sentence to be followed by five years of supervised release. On appeal, Defendant argued that the district court erred in applying the "intervening arrest" rule in section 4A1.2(a)(2) of the United States Sentencing Guidelines when determining his criminal history. The First Circuit affirmed, holding that, through his counsel, Defendant invited any error in that respect. View "United States v. Miranda-Carmona" on Justia Law

The First Circuit affirmed Defendant's convictions and sentence for one count of conspiracy to distribute and to possess with intent to distribute heroin and one count of distribution of heroin, holding that Defendant was not entitled to relief on her allegations of error.For the convictions, the district court imposed a downward variant sentence of forty-eight months' imprisonment followed by two years of supervised release. The First Circuit affirmed, holding (1) the district court did not abuse its discretion by finding certain coconspirator statements were non-hearsay under Fed. R. Evid. 801(d)(2)(E) and admitting the statements into evidence; (2) Defendant waived her claim of error regarding the propriety of the jury instructions about the elements of the offenses; and (3) the district court did not clearly err by applying a three-level mitigating role reduction under U.S.S.G. 3B1.2 rather than a four-level minimal role reduction. View "United States v. Ruiz" on Justia Law

The First Circuit vacated the judgment of the district court imposing a five-year prison sentence upon Defendant for committing a federal firearms offense, holding that the district court erred in resolving what constitutes a "controlled substance" within the meaning of section 2K2.1(a)(2) of the United States Sentencing Guidelines.On appeal, Defendant argued that the district court erred in applying at his sentencing the enhancement set forth in section 2K2.1(a)(2), which subjects a defendant who has been convicted of a 18 U.S.C. 922(g) offense to a higher base offense level under the Guidelines if he committed the offense "subsequent to sustaining at least two felony convictions of either a crime of violence or a controlled substance offense." Specifically, Defendant argued that his prior Massachusetts conviction for possession with intent to distribute "marihuana" did not qualify as a conviction of a "controlled substance offense" under section 2K2.1(a)(2). The First Circuit vacated the judgment below, holding that Defendant's Massachusetts conviction was not a conviction of a "controlled substance offense" within the meaning of that term as it was used in the version of section 2K2.1(a)(2) that was applicable at Defendant's sentencing. View "United States v. Abdulaziz" on Justia Law

The First Circuit affirmed Defendant's convictions for possessing and aiding and abetting the possession of drugs with intent to distribute them and possessing and aiding and abetting the possession of a gun in furtherance of a drug-trafficking crime, holding that Defendant was not entitled to reversal of his convictions.On appeal, Defendant challenged four of the trial judge's evidentiary rulings and three jury instructions. The First Circuit affirmed, holding (1) any error in the district court's evidentiary rulings was harmless; and (2) the district court committed no reversible error in its instructions to the jury. View "United States v. Rivera-Galindez" on Justia Law

The First Circuit affirmed Defendant's sentence for several drug-related offenses, including violations of the Maritime Drug Law Enforcement Act (MDLEA), 46 U.S.C. 70503 and 70506, holding that the MDLEA offenses were not eligible for "safety valve" relief under the then-applicable safety valve provision.At the time Defendant pleaded guilty to all counts in the indictment, the MDLEA offenses carried a minimum sentence of ten years' imprisonment. Before sentencing, Defendant argued that he qualified for safety valve relief authorizing a district court to impose a sentence below the statutorily prescribed mandatory minimum sentence. The district court sentenced Defendant to the mandatory minimum sentence of ten years' imprisonment, holding that Defendant was not entitled to safety valve relief because his MDLEA offenses were not among those specifically enumerated in the safety valve statute. The First Circuit affirmed, holding that an MDLEA offense is not offense eligible for safety valve relief. View "United States v. De La Cruz" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment to Defendants - various prison officials, the Massachusetts Department of Correction (DOC), and Plaintiff's prison physician - and dismissing Plaintiff's complaint for injunctive and declaratory relief and damages, holding that there was no error in the proceedings below.Plaintiff, an inmate at MCI-Concord in Massachusetts, brought this pro se complaint challenging the termination of his access to the prison's first-floor Lexis Nexis terminal and typewriter, where Plaintiff spent more than two years conducting legal research and creating legal documents. The district court granted summary judgment in favor of Defendants. The First Circuit affirmed, holding (1) Plaintiff's speculative arguments as to the summary judgment in favor of his prison doctor were not enough to summary judgment; (2) the district court properly found that the DOC defendants' legitimate explanations were not pretextual; and (3) the district court did not err in determining that there was no triable issue of material fact that Defendants subjected Plaintiff to cruel and unusual punishment by discontinuing Plaintiff's reliance upon the first-floor terminal. View "Snell v. Neville" on Justia Law

The First Circuit affirmed Defendant's conviction of one count of making a materially false statement to the Federal Bureau of Investigation (FBI), in violation of 18 U.S.C. 1001(a)(2), holding that Defendant's arguments on appeal lacked merit.Specifically, the First Circuit held (1) Defendant's argument that multiple circumstances may have caused the jury to convict him of a second statement that had not been charged, causing a mismatch or variance between the indictment and the proof, was unavailing; (2) there was no clear prosecutorial misconduct in either the opening or the closing arguments; (3) Defendant waived his claim regarding the indictment not going to the jury and the verdict form; and (4) the district court did not err in denying Defendant's motion for a new trial. View "United States v. Chen" on Justia Law

The First Circuit affirmed Defendant's convictions and sentence for three counts of perjury and two counts of fraud and misuse of visas, permits, and other documents, holding that there was no reversible error in the proceedings below.Defendant's convictions were based on his alleged failure to disclose to immigration authorities the role he played in the Rwandan genocide. The First Circuit affirmed the convictions, holding (1) Defendant's challenges to certain statements made at trial by a government expert witness were unavailing; and (2) the district court did not err in calculating Defendant's sentencing range under the U.S. Sentencing Guidelines by applying a two-level, obstruction-of-justice enhancement. View "United States v. Teganya" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendants - James Stewart-Carrasquillo and Harold Esquilin-Montanez - of various narcotics offenses, holding that the evidence was sufficient to support the verdicts and that there was no prejudicial error.Specifically, the First Circuit held (1) the evidence was sufficient to sustain Defendants' convictions for, inter alia, aiding and abetting the possession with intent to distribute a controlled substance onboard a vessel subject to the jurisdiction of the United States; (2) the district court did not commit reversible error by excluding a demonstrative aid in the form of a videotaped "reenactment"; and (3) a misstatement made by the prosecutor during closing argument did not constitute reversible error. View "United States v. Stewart-Carrasquillo" on Justia Law

The First Circuit affirmed the judgment of the district court ruling that Appellant, a state prisoner, had not satisfied the good cause requirement for his failure to have exhausted his claim in state court, holding that the district court acted within the bounds of its discretion.Appellant was convicted in a Massachusetts superior court of assault and battery with a dangerous weapon and assault and battery with a dangerous weapon causing serious bodily injury. The Massachusetts Appeals Court affirmed, concluding that Appellant's claim that the trial court abused its discretion in excluding his proffered witness was waived. Appellant eventually filed a habeas petition in the federal district court. The district court denied Appellant's motion for a stay in abeyance and dismissed his habeas petition. The First Circuit affirmed, holding that Petitioner failed to satisfy the good cause requirement. View "Sena v. Kenneway" on Justia Law