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

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

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