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

The First Circuit affirmed the federal convictions and sentences of Defendants - Herzzon Sandoval, Edwin Guzman, Erick Argueta Larios, and Cesar Martinez - stemming from a federal criminal investigation into La Mara Salvatrucha, a transnational criminal organization, in Massachusetts, holding that there was no prejudicial error.Specifically, the First Circuit held (1) Defendants' sufficiency of the evidence challenges to their respective convictions were without merit; (2) there was no merit to Defendants' claims that the district court erred in denying a motion for a continuance due to pretrial publicity or in denying their motion for a mistrial; (3) Defendants' challenges to the court's evidentiary rulings failed; (4) challenges concerning purported misstatements of the evidence in the government's closing argument and purported instructional errors provided no basis for overturning Defendants' convictions; and (5) Defendants' challenges to their sentences failed. View "United States v. Sandoval" on Justia Law

The First Circuit affirmed the judgment of the district court denying Petitioner's petition for a writ of habeas corpus under 28 U.S.C. 2254, as amended by the Antiterrorism and Effective Death Penalty Act (AEDPA), holding that the district court did not err in denying the petition.In his habeas petition, Petitioner alleged that the trial court violated his constitutional rights to a complete defense and to have effective assistance of counsel. The district court denied the petition. The First Circuit affirmed, holding (1) the exclusion of certain medical evidence, even if error, was harmless beyond a reasonable doubt; and (2) trial counsel was not constitutionally deficient for not consulting or calling a child abuse expert who could testify to the effects of Munchausen Syndrome by Proxy on fathers like Petitioner. View "Strickland v. Goguen" on Justia Law

The First Circuit affirmed the drug conspiracy and distribution convictions of five members of a drug trafficking organization, holding that none of the issues raised by the five defendants translated into reversible error warranting vacatur of their convictions or sentences.Fifty-five individuals were indicted on charges of conspiracy to distribute heroin, cocaine, cocaine base, marijuana, and prescription pills. By the time a jury trial began most of the defendants had pleaded guilty. Five of the defendants who were ultimately convicted appealed their convictions, and some of them appealed their sentences. The defendants were Joel Rivera-Alejandro, Carlos Rivera-Alejandro, Juan Rivera-George, Suanette Ramos- Gonzalez, and Idalia Maldonado-Pena. The First Circuit affirmed the judgments in their entirety, holding that there was no reversible error in this case. View "United States v. Maldonado-Pena" on Justia Law

The First Circuit affirmed Defendant's conviction of possession with intent to distribute cocaine, fentanyl, and methamphetamines, holding that Defendant's challenges on appeal were unavailing.During a probation compliance check in Defendant's apartment state probation officers discovered a black case containing illegal narcotics. The police then obtained and executed a warrant to search Defendant's apartment and his two cellphones for evidence of drug dealing. On appeal, Defendant argued, among other things, that there was no probable cause to search his cellphones and that the warrant did not adequately specify which files on the phones would be searched. The First Circuit affirmed, holding (1) the trial court did not err in denying Defendant's motion to suppress evidence recovered from the cellphones; (2) there was sufficient evidence to support the convictions; and (3) Defendant was not entitled to relief on his remaining allegations of error. View "United States v. Lindsey" on Justia Law

The First Circuit affirmed Defendant's conviction and sentence for one count of conspiracy to defraud the United States and eight counts of aiding or assisting in the filing of a false tax return, holding that Defendant's challenges on appeal were meritless.Specifically, the First Circuit held (1) the evidence was sufficient to support the convictions; (2) there was no error in the district court's imposition by reference of the conditions of supervised release stated in the United States Probation Office's Presentence Report; and (3) the district court did not err by failing to impose a specific schedule for payment of restitution at the time of sentencing. View "United States v. Nardozzi" on Justia Law

The First Circuit affirmed Defendant's conviction of possession of a firearm in furtherance of a drug trafficking crime and possession of a controlled substance with intent to distribute entered after Defendant pled guilty pursuant to a plea agreement, holding that Defendant's argument that his plea was invalid was without merit.On appeal, Defendant argued that his plea was invalid because he entered it without knowing that he was waiving his right to appeal the trial court's denial of his motion to suppress the drugs, gun, and statements he had made following his arrest. The First Circuit affirmed, holding that, even if there was error, it was not clear or obvious. View "United States v. Casiano-Santana" on Justia Law

The First Circuit affirmed Defendant's conviction of four counts of wire fraud and one count of obstruction of justice and his 156-month incarcerate sentence, holding that Defendant was fairly tried before a competent judge and an impartial jury, was justly convicted, and was lawfully sentenced.On appeal, Defendant raised two assertions of trial error and several claims of sentencing error. The First Circuit affirmed the convictions and sentence, holding (1) an implication of judicial bias was unwarranted; (2) any impropriety on the part of the prosecutor did not affect or influence the jury in any way; and (3) Defendant was not entitled to relief on his multiple claims of sentencing error. View "United States v. Kuljko" on Justia Law

The First Circuit rejected the efforts of the two defendants in this consolidated appeal to retroactively vacate the forfeiture judgment against them, holding that neither defendant was entitled to relief on their claims of error.The defendants in this case were Donna Saccoccia and her brother, Vincent Hurley. Defendants were convicted for their role in a money laundering conspiracy controlled by Donna's husband, Stephen Saccoccia. In this appeal, Defendants appealed the district court's denial of Donna's petition for a writ of error coram nobis - a petition that Hurley sought to adopt - seeking vacate of a forfeiture judgment of approximately $136 million in proceeds from the conspiracy, arguing that the Supreme Court's decision in Honeycutt v. United States, 137 S. Ct. 1626 (2017), should be applied retroactively to invalidate the forfeiture judgments against them. The First Circuit denied relief, holding (1) Donna's efforts to apply Honeycutt retroactively were unavailing for the same grounds applicable to Stephen, whose same attempt this Court recently rejected; and (2) Hurley waived his argument on appeal. View "United States v. Saccoccia" on Justia Law

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