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

The First Circuit affirmed Defendant's conviction and sentence imposed after he pled guilty to six counts stemming from a robbery of a federal confidential informant during a guns-for-cash deal, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the First Circuit held (1) Defendant's challenge based on Rehaif v. United States, 139 S. Ct. 2191 (2019), to his conviction for possession of a firearm by a felon, in violation of 18 U.S.C. 922(g), was without merit; (2) Defendant's challenge to the plea colloquy failed; (3) Defendant's challenge based upon United States v. Davis, 139 S. Ct. 2319 (2019), to the acceptance of his plea to aiding and abetting the use of a firearm during and in relation to a crime of violence, in violation of 18 U.S.C. 2, 924(c), failed on plain error review; (4) the prosecutor did not breach plea agreement; and (5) Defendant's sentence of 198 months' imprisonment was neither procedurally nor substantively unreasonable. View "United States v. Farmer" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant of committing, or aiding and abetting others in committing, the crimes of RICO conspiracy, drug conspiracy, and other crimes, holding that Defendant was not entitled to relief on his allegations of error.After Defendant was originally convicted the First Circuit vacated the convictions, concluding that the police lacked probable cause to search Defendant's house, and therefore, the seized evidence should have been suppressed. On remand, a jury again convicted Defendant of the relevant charges. Defendant appealed, claiming trial error and sentencing issues. The First Circuit affirmed, holding (1) Defendant's claims of trial error were without merit; (2) there was sufficient evidence to support the convictions; (3) the trial court did not err in instructing the jury; (4) there was no abuse of discretion in the denial of Defendant's motion for a new trial; and (5) Defendant's sentence was not procedurally unreasonable. View "United States v. Cruz-Ramos" on Justia Law

The First Circuit affirmed Defendant's conviction for two counts of drug trafficking in international waters while aboard a stateless vessel in violation of the Maritime Drug Law Enforcement Act (MDLEA), 46 U.S.C. 70501-08, holding that international law does not generally prohibit the United States from prosecuting drug traffickers found on a stateless vessel stopped and boarded by the United States on the high seas as if the drug traffickers had been found on a United States vessel subject to the territorial jurisdiction of the United States.Specifically, the First Circuit held (1) Defendant's prosecution in the United States for drug trafficking on a stateless vessel stopped and boarded by the United States in waters subject to the rights of navigation on the high seas violated no recognized principle of international law; but (2) because Amendment 794 to the Sentencing Guidelines applies retroactively, this case must be remanded for resentencing so that the district court can have an opportunity to apply the new factors. View "United States v. Aybar-Ulloa" on Justia Law

The First Circuit held that the Wire Act's prohibitions are limited to interstate wire communications related to bets or wagers on sporting events or contests, thus affirming the district court's grant of Plaintiffs' motions for summary judgment.In 2011, the Office of Legal Counsel (OLC) of the U.S. Department of Justice (DOJ) issued a legal opinion concluding that the Wire Act's prohibitions were uniformly limited to sports gambling. In 2018, the OLC issued an opinion, which was later adopted by the DOJ, that all prohibitions in the Wire Act, with one exception, applied to all forms of bets or waters. In 2019, the New Hampshire Lottery Commission and one of its vendors commenced this action seeking relief under the Administrative Procedure Act and the Declaratory Judgment Act. The district court granted relief, ruling that the Wire Act was limited to sports gambling. The First Circuit affirmed, holding (1) this controversy is justiciable; and (2) the Wire Act applies only to interstate wire communications related to sporting events or contests. View "New Hampshire Lottery Commission v. Rosen" on Justia Law

The First Circuit affirmed the district court's denial of Petitioner's petition under 28 U.S.C. 2255 to vacate his sentence on the basis that he received ineffective assistance of counsel regarding his rejection of a plea offer, holding that Petitioner failed to show prejudice from any deficient performance by counsel.After a jury trial, Petitioner was found guilty of several charges arising out of a drug enterprise operating in a public housing project. Acting pro se, Petitioner filed a timely petition for postconviction relief, claiming that he received ineffective assistance of counsel. The district court denied the petition. The First Circuit affirmed, holding (1) Petitioner's counsel's performance was deficient when counsel failed to give Petitioner sufficient time to consider a plea offer and failed to advise him of the exposure to a life sentence; but (2) Petitioner failed to satisfy the prejudice prong of Strickland v. Washington, 466 U.S. 668 (1984). View "Feliciano-Rodriguez v. United States" on Justia Law

The First Circuit affirmed the district court's order granting the government's request to garnish Appellant's husband's 401(k) account and apply the proceeds to his nearly four million dollar criminal restitution obligations, holding that Appellant had no vested legal interest in her husband's account.Appellant's husband (Husband) pleaded guilty to eight counts of wire fraud, money laundering, and unlawful monetary transactions. The district court sentenced him to a term of incarceration and ordered him to pay $3,879,750 in restitution. The government later asked the district court for a writ of garnishment directed at Husband's 401(k) plan, which Husband held individually in his own name. The district court rejected Appellant's objections and issued a garnishment order. The First Circuit affirmed, holding (1) Massachusetts law did not give Appellant a vested legal interest in Husband's 401(k) account; and (2) it was not plain error for the district court to issue the writ of garnishment without compensating Appellant for her contingent death benefit under the policy. View "United States v. Abell" on Justia Law

The First Circuit affirmed Defendant's sentences imposed in connection with his guilty plea to being a felon in possession of a firearm, holding that the sentences were procedurally and substantively reasonable.Defendant pleaded guilty to being a felon in possession of a firearm. Defendant was sentenced to sixty months' imprisonment for that offense and to eighteen months' imprisonment for violating the conditions of his supervised release. Defendant appealed, challenging both the procedural and substantive reasonableness of his sentences, which were above the United States Sentencing Guidelines range. The First Circuit affirmed, holding that Defendant's variant sentences were both procedurally and substantively reasonable. View "United States v. Flores-Quinones" on Justia Law

In these consolidated cases, the First Circuit affirmed the decision of the district court rejecting Plaintiffs' suits seeking to enjoin the enforcement of Section 12616 of the Agriculture Improvement Act of 2018, which bans the sponsorship and exhibition of cockfighting matches in Puerto Rico, holding that Section 12616 is a valid exercise of Congress's Commerce Clause power and does not violate Plaintiffs' individual rights.On their complaints, Plaintiffs argued that Section 12616 violated their First Amendment and Due Process rights and that Congress exceeded its powers under the Commerce and Territorial Clauses and further lodged both facial and as-applied pre-enforcement challenges to the statute. The district court granted the government's motion for summary judgment. The First Circuit affirmed, holding (1) Plaintiffs had standing to bring these lawsuits; (2) Section 12616 is a legitimate exercise of the Commerce Clause power; and (3) Section 12616 does not infringe on Plaintiffs' First Amendment freedoms of speech and association. View "Hernandez-Gotay v. United States" on Justia Law

The First Circuit affirmed the decision of the district court granting the government's motion in limine to admit a recording of a 911 call placed by Defendant's girlfriend, holding that the Confrontation Clause was not implicated and that the district court did not abuse its discretion in applying a hearsay exception.Defendant was indicted for possessing a stolen firearm and being a felon in possession of a firearm. Prior to trial, the government filed a motion in limine seeking to introduce the 911 recording without calling Defendant's girlfriend as a witness. The district court granted the motion. Defendant then entered a conditional guilty plea, reserving his right to appeal the district court's order granting the motion. The First Circuit affirmed, holding that the Confrontation Clause was not implicated by the non-testimonial statements and that the district court did not abuse its discretion in admitting the 911 recording. View "United States v. Estes" on Justia Law

The First Circuit affirmed Defendant's sentence imposed in connection with his plea of guilty to one count of possession of a firearm by a felon, holding that the sentence was reasonable.After Defendant pleaded guilty, the district court sentenced Defendant to seventy-two months of incarceration. On appeal, Defendant challenged his sentence, arguing that the district court miscalculated his base offense level under the United States Sentencing Guidelines. The First Circuit affirmed, holding (1) it was in the district court's discretion to impose a sentence outside of the Guidelines range, and any alleged error in calculating Defendant's base offense level was harmless; and (2) Defendant's sentence was substantively reasonable. View "United States v. Ouellette" on Justia Law