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

The First Circuit vacated Defendant's convictions on six counts relating to public corruption in the Commonwealth, holding that the district court's refusal to sever Defendant's trial from that of one of her codefendants was an abuse of discretion.Defendant worked as the administrator of the Puerto Rico Workforce Development Administration (ADL) for two years before she was charged with various federal offenses relating to public corruption. Defendant was tried jointly with three other individuals who were also charged in the indictment and convicted of all six counts that she faced. The First Circuit vacated the convictions, holding (1) there was sufficient evidence in the record supporting the convictions; but (2) the district court abused its discretion in declining to sever Defendant's trial from that of her codefendant, and the resulting prejudice was such that the matter must be remanded for a new trial. View "United States v. Lopez-Martinez" on Justia Law

The First Circuit affirmed Defendant's conviction for conspiring to commit drug trafficking offenses but remanded the case for resentencing, holding that the district court erred in imposing a two-level enhancement to Defendant's base offense level.A jury convicted Defendant of conspiracy to possess with intent to distribute a controlled substance and conspiracy to import narcotics into the United States, and the district court imposed a sentence of approximately 224 months, reflecting a sentence at the lowest end of the recommended range. The First Circuit affirmed, holding (1) the trial court erred in permitting the government to solicit "overview" testimony and in allowing the government to present evidence relating to a previous cocaine seizure, but both errors were harmless; and (2) while Defendant's claim that there was an unwarranted disparity between his sentence and those of his codefendants lacked merit, the district court erred by imposing a supervisory role enhancement without identifying evidence that Defendant played a supervisory role in the conspiracy. View "United States v. Garcia-Sierra" on Justia Law

The First Circuit affirmed the order of the district court imposing a sanction against Appellant under Fed. R. Civ. P. 11, holding that the district court did not abuse its discretion.Appellant was a Massachusetts lawyer who brought suit on behalf of Gerald Alston, a black man who formerly worked as a firefighter. Defendant Stanley Spiegel eventually moved to dismiss and for sanctions. The magistrate judge recommended that the district court dismiss the claims against Spiegel with prejudice and ruled that sanctions were in order. The First Circuit affirmed, holding that because Appellant persisted in pursuing claims against Spiegel without an adequate basis in law or fact and despite a warning from the magistrate judge, sanctions were in order. View "Ames v. Spiegel" on Justia Law

The First Circuit affirmed Defendant's conviction of one count of possession with intent to distribute various controlled substance and one count of possession of a firearm in furtherance of a drug-trafficking crime, holding that the district court did not err in denying Defendant's motion to suppress.Defendant sought to suppress drug evidence and a firearm seized pursuant to a search warrant for the car he was driving when he was arrested on an outstanding federal warrant. In his motion, Defendant argued that the search warrant for the car was invalid because it was issued based on an unlawful inventory search. The First Circuit affirmed the denial of Defendant's motion to suppress, holding that the district court did not err in concluding that (1) the officers had an objectively reasonable non-investigatory purpose; and (2) the inventory search of the car was unlawful. View "United States v. Sylvester" on Justia Law

The First Circuit affirmed the sentence imposed on Defendant after he pled guilty to unlawfully possessing a machine-gun, 18 U.S.C. 922(o), and being a felon in possession of a firearm, 18 U.S.C. 922(g)(1), holding that the sentence was reasonable.Defendant's Guidelines Sentencing Range was sixty-three to seventy-eight months. The district judge, however, sentenced Defendant to 100 months' imprisonment and two years of supervised release. The First Circuit affirmed the sentence, holding (1) where it was ambiguous whether the district court imposed a variance or departure, any error was harmless; and (2) the court's focus on Defendant's past convictions did not take the sentence out of the range of reasonable sentences, and the court did not consider Defendant's history of drug use. View "United States v. Laboy-Nadal" on Justia Law

The Supreme Court affirmed Defendant's 2019 sentence in the District of Maine for one count of conspiracy to distribute and to possess with intent with distribute forty grams or more of fentanyl, holding that the sentence was not unreasonable.Defendant pled guilty pursuant to a plea agreement. Under the plea agreement, Defendant and the government agreed that they would both recommend a base offense level (BOL) under the Guidelines of twenty-eight. The district court, however, adopted the presentence investigation report's calculation of Defendant's guidelines sentencing range (GSR), which was based on a BOL of thirty. The Supreme Court affirmed the sentence, holding that the sentence was neither procedurally nor substantively unreasonable. View "United States v. Ayala" on Justia Law

The First Circuit affirmed the judgment of the district judge imposing three special conditions of supervised release after the revocation of Defendant's supervised release, holding that the special conditions were not unreasonable.On appeal, Defendant argued that the imposition of the conditions was procedurally unreasonable because the judge's explanation for the special conditions was insufficient and that the contested special conditions were substantively unreasonable. The First Circuit disagreed, holding (1) the special conditions were procedurally reasonable; and (2) Defendant's substantive unreasonableness challenge failed. View "United States v. McCullock" on Justia Law

The First Circuit denied Petitioners' petition for a writ of mandamus claiming that the district court erred in denying their bail application despite the ongoing COVID-19 pandemic, holding that the petition was without merit.Petitioners, immigration detainees held primarily at the Bristol County House of Correction, brought this petition for a writ of mandamus against Respondents, state immigration officials and federal United States Immigration and Customs Enforcement officials who secured Petitioners' detention after they were picked up and found to be in the United States illegally. Petitioners had all been denied bail and claimed that the district court erred in denying their bail applications. The First Circuit denied relief, holding that, under the circumstances of this case, there was no basis for either supervisory or advisory mandamus relief. View "Da Graca v. Souza" on Justia Law

The First Circuit affirmed the district court's order denying Defendant's motion for resentencing, holding that the district court did not abuse its discretion in denying the motion.In 2008, Defendant pleaded guilty to possession with intent to distribute and distribution of cocaine base. While Defendant was serving his 228-month term of immurement Congress passed the Fair Sentencing Act, Pub. L. No. 111-220, 124 Stat. 2372, which reduced the penalties for most federal crimes involving crack cocaine. Thereafter, Defendant filed his motion for resentencing. The district court denied the motion. The First Circuit affirmed, holding that the sentencing court weighed the proper factors and made a reasonable judgment. View "United States v. Concepcion" on Justia Law

The First Circuit denied Defendant's appeal of his conviction for unlawful possession of a firearm by a prohibited person in violation of 18 U.S.C. 922(g) and 924(a)(2), holding that the district court did not commit plain error by accepting Defendant's guilty plea and in denying his motion to suppress.Following Defendant's plea, the Supreme Court decided Rehaif v. United States, 139 S. Ct. 2191 (2019), under which the government must prove that the defendant knew he had the relevant status prohibiting possession. On appeal, Defendant argued (1) under Rehaif, the district court committed plain error during his plea colloquy by failing to inform him that the government was required to prove that he knew he was prohibited from possessing firearms; and (2) the district court erred by denying his motion to suppress. The First Circuit affirmed, holding (1) the search warrant issued for Defendant's residence was supported by probable cause; and (2) the district court did not plainly err by accepting Defendant's guilty plea. View "United States v. Austin" on Justia Law