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

In these consolidated appeals the First Circuit affirmed Defendant's sentence imposed following his conviction on the charge of being a felon in possession of a firearm and Defendant's sentence imposed following the revocation of a supervised release term imposed in connection with a prior, unrelated conviction, holding that Defendant's claims of error were unavailing.The district court imposed a sixty-six term of immurement for the felon-in-possession charge and a twenty-four-month sentence with respect to the supervised release violation. The First Circuit affirmed the sentences, holding (1) the sentence imposed on the felon-in-possession conviction survived Defendant's challenges; and (2) the district court acted within its discretion in imposing the sentence in connection with the revocation of Defendant's supervised release term. View "United States v. Santa-Soler" on Justia Law

The First Circuit affirmed Defendant's conviction of one count of conspiracy to distribute and possess with intent to distribute drugs and one count of possessing a firearm as an alien unlawfully present in the United States, holding that Defendant failed to establish a reasonable probability that he would not have pled guilty had he been advised as required by Rehaif v. United States, 139 S. Ct. 2191 (2019).Defendant pled guilty without the benefit of a plea agreement and was sentenced to 144 months' imprisonment on the drug count and 120 months' imprisonment on the firearm count, to be served concurrently. One month after Defendant's sentencing, the United States Supreme Court issued its opinion in Rehaif. Before the First Circuit, Defendant asked that his conviction on the firearm count be vacated because he did not plead guilty to knowing the facts that made him a person prohibited from possessing a firearm, as Rehaif requires. The First Circuit affirmed, holding (1) Defendant failed to establish that his substantial rights were affected by the district court's failure to anticipate Rehaif; and (2) the district court did not err in imposing a livelihood enhancement that Defendant received at sentencing. View "United States v. Patrone" on Justia Law

In this consolidated appeal brought by Appellant to contest the sentences he received in two separate cases, the First Circuit affirmed the sentences, holding that there was no error or abuse of discretion.In the first case, Appellant pled guilty to attempted possession of cocaine with intent to distribute and was sentenced to 168 months' imprisonment. In this second case, Appellant was sentenced to eighteen months for violating supervised release terms that were imposed for an earlier conviction for conspiracy to attempt to possess with intent to distribute cocaine. The First Circuit affirmed both sentences, holding that the 168-month sentence was not unreasonably high and that the district court's sentencing rationale in the second case was not flawed. View "United States v. Quiles-Lopez" on Justia Law

The First Circuit affirmed Defendant's conviction of possession of child pornography and sentence of ninety-six months' imprisonment followed by lifetime supervised release, holding that Defendant's arguments on appeal were without merit.Specifically, the First Circuit held (1) the district court did not err in denying Defendant's motion to suppress statements made to investigating officers at his home and the evidence derived from the consensual seizure of his computer; (2) police officers did not unconstitutionally intrude onto the curtilage of Defendant's home; and (3) the district court did not err in denying Defendant's renewed motion to withdraw his guilty plea. View "United States v. Mumme" on Justia Law

The First Circuit affirmed the judgment of the district court granting Petitioner's habeas corpus petition after the Dominican Republic requested Petitioner for extradition, holding that the United States failed to file the necessary documents to support an extradition request.Upon receipt and review of the Dominican Republic's request to extradite Petitioner, the United States filed an extradition compliant. A federal magistrate judge certified Petitioner as eligible for extradition. Petitioner filed a petition for writ of habeas corpus, arguing that the Dominican Republic failed to provide the required documentation in its extradition request and that his extradition would violate the United Nations Convention Against Torture (CAT) because the Board of Immigration Appeals (BIA) had previously found that he qualified for CAT relief. The district court granted relief, finding both that the extradition was barred by the BIA's CAT determination and that the extradition request did not satisfy the documentary requirements of the Dominican Republic-United States Extradition Treaty. The First Circuit affirmed, holding (1) the district court erroneously determined that the United States was bound by the BIA's prior determination awarding Petitioner CAT relief; but (2) the district court properly found that the documentation was insufficient to support an extradition request under the treaty. View "Aguasvivas v. Pompeo" on Justia Law

The First Circuit affirmed Defendant's conviction of two counts of making false statements during the purchase of a firearm and one count of making a false statement in a record required to be kept by federal law, holding that there was no reversible error in the jury instructions.On appeal, Defendant argued that his convictions must be vacated because of prejudicial errors in the jury instructions. The First Circuit affirmed, holding (1) the district court properly and accurately instructed the jury on the legal meaning of he term "gift" and did not direct a verdict on any element of the offense or otherwise invade the province of the jury; (2) there was no error in the court's "actual purchaser" instruction; and (3) there was no reversible plain error in instructing the jury on the first count of making false statements during the purchase of a firearm. View "United States v. Karani" on Justia Law

The First Circuit vacated Defendants' convictions for their roles in an expansive drug-trafficking conspiracy, holding that the evidence was sufficient to support the convictions but the trial was rendered unfair due to repeated, one-sided intercessions by the trial judge.The primary challenge of all four defendants on appeal was that they were entitled to a new trial because, throughout the eleven-day jury trial, the district court judge interjected during witness testimony in a manner that signaled an anti-defense bias to the jury and caused Defendants prejudice. The First Circuit agreed, holding that the trial judge's perceptible partiality impaired the integrity and fairness of the trial and that this judicial misconduct infringed upon all Defendants' right to a fair trial. View "United States v. Raymundi-Hernandez" on Justia Law

The First Circuit affirmed the district court's denial of Appellant's petition for a writ of habeas corpus, holding that the the Supreme Judicial Court of Massachusetts (SJC) reasonably applied clearly established law in holding that improper statements by the prosecutor during Appellant's trial did not render the trial fundamentally unfair.After a jury trial in Massachusetts state court Appellant was convicted of murder in the second degree and sentenced to life imprisonment. On appeal, Appellant argued that the prosecutor's closing argument was improper. The SJC affirmed Appellant's conviction, concluding that the prosecutor's "unfortunate" remarks did not warrant a new trial. Appellant later filed a habeas petition, which the district court denied. The First Circuit affirmed, holding that the district court's conclusion that the prosecutor's challenged statements did not render Appellant's trial fundamentally unfair was a reasonable application of clearly established federal law as determined by the Supreme Court. View "Taylor v. Medeiros" on Justia Law

The First Circuit vacated Defendant's plea of guilty to one count of violating 18 U.S.C. 922(g)(1), which makes it a crime for a convicted felon to possess a firearm, holding that there was a reasonable probability that Defendant would not have pled guilty had he been advised that the government need prove that he knew when he possessed the gun that he was a felon.Defendant pleaded guilty in 2018 to one count of violating section 922(g)(1). In 2019, the United States Supreme Court held in Rehaif v. United States, 139 S. Ct. 2191, 2200 (2019), that a conviction for that crime requires proof beyond a reasonable doubt that when the defendant possessed the gun he knew he had previously been convicted of an offense punishable by more than one year in prison. The First Circuit vacated Defendant's conviction, holding (1) the district court's failure to advise Defendant of Rehaif's knowledge requirement was clear error; and (2) there was a reasonable probability that Defendant would not have pled guilty had he been informed in accordance with Rehaif. View "United States v. Guzman-Merced" on Justia Law

The First Circuit affirmed Defendant's conviction of a drug offense, in violation of 21 U.S.C. 841(a)(1) and (b)(1)(B), holding that the district court did not err in denying Defendant's motion to suppress the drug evidence as having resulted from an unlawful search under the Fourth Amendment to the United States Constitution.Drug evidence was obtained from under the hood of a truck in which Defendant was a passenger. On appeal, Defendant argued (1) the government lacked probable cause to remove him from the truck and handcuff him during the search of the vehicle and to search the truck, and (2) the officers lacked reasonable suspicion to support their activities. The First Circuit affirmed, holding (1) the officers were operating from a tip from a reliable informant that the individuals in the truck had drugs and were about to complete a drug sale, and no more information was needed to justify the seizure of Defendant and the inspection of the vehicle; and (2) because the officers had probable cause to seize Defendant and search the truck, they also had reasonable suspicion. View "United States v. Garcia" on Justia Law