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

Eliezer Rosario-Ramos and his brother were indicted for carjacking resulting in serious bodily injury and bank larceny after assaulting and robbing an elderly woman, Zulma Lebrón-Serrano. Rosario-Ramos pled guilty to the carjacking offense and proposed a fifteen-year sentence. The district court, citing the brutal nature of the attack and the victim's subsequent death, sentenced him to twenty-three years. Rosario-Ramos appealed, claiming procedural and substantive defects in his sentence.The United States District Court for the District of Puerto Rico initially reviewed the case. Rosario-Ramos contested the Probation Office's recommendation of a twenty-five-year sentence, arguing against the application of the murder cross-reference. The district court declined to apply the murder cross-reference but found that the attack contributed to the victim's death, leading to a twenty-three-year sentence.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's judgment, finding no procedural error in the determination that the attack contributed to the victim's death. The court also held that the district court did not abuse its discretion in imposing an upward variance based on the brutal nature of the attack and the personal connection between Rosario-Ramos and the victim. The court found the sentence substantively reasonable despite being higher than the Guidelines range and the sentence proposed by both parties, noting the district court's thorough explanation of the aggravating factors. The court concluded that the district court's rationale was plausible and the sentencing outcome defensible. View "United States v. Rosario-Ramos" on Justia Law

Victor Soto-Sanchez was convicted of possession of a controlled substance with intent to distribute. He appealed his conviction and sentence, arguing that his Sixth Amendment right to confront witnesses was violated when a police officer testified about an informant's tip. He also challenged the application of a two-point enhancement for obstruction of justice in his sentencing.The United States District Court for the District of Maine allowed the police officer's testimony, overruling Soto-Sanchez's objections on Confrontation Clause and hearsay grounds. The court provided a limiting instruction to the jury, stating that the informant's statements were not to be considered for their truth but to explain the officer's investigative steps. The jury found Soto-Sanchez guilty, and the court applied the obstruction of justice enhancement based on Soto-Sanchez's alleged attempts to influence a witness.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed that Soto-Sanchez's Sixth Amendment rights were violated but deemed the error harmless due to overwhelming evidence against him, including physical evidence and witness testimony. The court also rejected Soto-Sanchez's sentencing challenge, concluding that he had waived his arguments regarding the obstruction of justice enhancement. Consequently, the First Circuit affirmed Soto-Sanchez's conviction and sentence. View "United States v. Soto-Sanchez" on Justia Law

Anthony Basilici was convicted by a jury of conspiring to possess with intent to distribute heroin, commit kidnapping, and obstruct justice. He was also convicted of possession of a firearm in furtherance of a drug trafficking crime, which was discharged, resulting in an enhanced sentence. Basilici appealed his firearm conviction, arguing trial errors and insufficient evidence.The United States District Court for the District of Massachusetts heard the case initially. The jury found Basilici guilty on all counts, including the firearm charge under Count Five. Basilici filed motions for acquittal and a new trial, which the district court denied, holding that the evidence was sufficient to support the jury's verdict.The United States Court of Appeals for the First Circuit reviewed the case. Basilici contended that the evidence was insufficient to support his firearm conviction under the Pinkerton doctrine, which holds conspirators liable for reasonably foreseeable crimes committed by co-conspirators. He also argued that the jury instructions were misleading and confusing, and that the supplemental instruction given in response to a jury question was improper.The First Circuit affirmed the conviction, finding that the evidence was sufficient for the jury to conclude that the firearm discharge was reasonably foreseeable to Basilici. The court held that the district court did not err in giving the Pinkerton instruction and that the supplemental instruction was appropriate. The court also found no plain error in the district court's handling of the jury's note and the supplemental instruction. View "United States v. Basilici" on Justia Law

Carlos Cruz-Rivera filed a motion in 2020 to reduce his sentence under 18 U.S.C. § 3582(c)(1)(A), as amended by the First Step Act. Cruz was originally charged with multiple counts, including carjacking and weapons-related offenses, and received a nearly 73-year sentence, largely due to mandatory minimums under 18 U.S.C. § 924(c). The First Step Act amended § 924(c) to prevent "stacking" of sentences for first-time offenders, but this change was not retroactive. Cruz argued that the disparity between his original sentence and what it would be under the amended law constituted "extraordinary and compelling reasons" for a sentence reduction.The United States District Court for the District of Puerto Rico initially denied Cruz's motion, adopting the government's reasoning. Cruz appealed, and the United States Court of Appeals for the First Circuit vacated and remanded the case for reconsideration in light of its decision in United States v. Ruvalcaba, which clarified that district courts could consider nonretroactive sentencing amendments as part of the "extraordinary and compelling reasons" analysis. On remand, the District Court again denied the motion without specifying the grounds for its decision.The United States Court of Appeals for the First Circuit reviewed the case and found that the District Court's brief text order did not clarify whether it had properly considered the factors outlined in Ruvalcaba. The appellate court noted that the government's arguments might have led the District Court to apply an unduly narrow interpretation of what constitutes "extraordinary and compelling reasons." Consequently, the First Circuit vacated the District Court's decision and remanded the case for further consideration, ensuring that the correct legal standards are applied. The appellate court also denied Cruz's request to assign the case to a different judge on remand. View "United States v. Cruz-Rivera" on Justia Law

In June 2022, Karen Read was indicted for murder in Massachusetts. She pled not guilty, and the trial in Norfolk County Superior Court ended in a mistrial due to a non-unanimous jury verdict. The case attracted significant public attention and demonstrators gathered near the courthouse. The demonstrators' behavior, including loud protests and displaying materials directed at trial participants, raised concerns about the fairness of the trial.The state court issued an order creating a 200-foot buffer zone around the courthouse to prevent demonstrations during the trial. This order was challenged in state court but upheld by the Massachusetts Supreme Judicial Court. Before the retrial, the Commonwealth sought a broader order, which the state court granted, expanding the buffer zone to include additional areas around the courthouse. This new order was based on evidence of disruptions during the first trial, including noise from demonstrators that could be heard by jurors.A group of demonstrators filed for a preliminary injunction in the District of Massachusetts to challenge the expanded buffer zone. The district court denied the motion, finding that the order was likely narrowly tailored to serve a significant governmental interest. The plaintiffs then appealed to the United States Court of Appeals for the First Circuit.The First Circuit noted that the plaintiffs clarified they did not challenge the order as applied to courthouse property or seek to engage in noisy protests. They only sought to demonstrate quietly on public property without interfering with trial participants. The court vacated the district court's denial of the preliminary injunction and remanded the case for further proceedings to determine if the order's lack of a mens rea requirement rendered it insufficiently tailored. The court suggested that the state court could amend the order to include a mens rea requirement to address the First Amendment concerns. View "Grant v. Trial Court of the Commonwealth of Massachusetts" on Justia Law

Dionel Guía-Sendeme was involved in a venture to smuggle 135 kilograms of cocaine from the Dominican Republic to Puerto Rico. He was recruited to move gasoline tanks onto a boat, initially believing it was for smuggling undocumented individuals. Upon learning it was for drug smuggling, he agreed to participate for $10,000. Guía and another individual, Abel, operated the vessel. Abel received a GPS device, a compass, phone numbers, and a handgun. They were informed that a second vessel would monitor for law enforcement. After transferring drugs from the second vessel and loading more drugs at another location, Guía agreed to accompany Abel to Puerto Rico for an additional $10,000. Upon arrival, law enforcement seized the drugs, and Guía was apprehended while Abel escaped.Guía was indicted on four counts related to drug trafficking and pleaded guilty to all counts without a plea agreement. The U.S. Probation Office recommended against a mitigating role adjustment and for a firearm enhancement. The district court adopted these recommendations, calculating an advisory guideline sentencing range of 108 to 135 months but imposed a 72-month sentence after granting a downward variance. Guía objected to the sentence, but the court stated it would have imposed the same sentence regardless of the objections.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the district court erred in its mitigating role analysis by not properly identifying the universe of participants involved in the criminal activity and failing to compare Guía's conduct to that of other participants. The appellate court vacated Guía's sentence and remanded for resentencing, instructing the district court to reconsider the mitigating role adjustment. The appellate court upheld the firearm enhancement, finding sufficient evidence that Guía knew his coconspirator possessed a firearm. View "US v. Guia-Sendeme" on Justia Law

Héctor Maldonado-Maldonado was involved in an altercation with a senior corrections officer (SCO) at the Metropolitan Detention Center Guaynabo in August 2020. During a routine lockdown, the SCO noticed Maldonado was not in his cell and found contraband (an extra pillow). When the SCO removed the pillow, Maldonado returned, yelled profanities, and punched the SCO. Maldonado and his cellmate, Miguel Santana-Avilés, then assaulted the SCO, causing bodily injuries. Maldonado was indicted and charged with assaulting a federal officer. He entered a plea agreement proposing a sentencing calculation resulting in a Total Offense Level (TOL) of 13.The probation officer prepared a Presentence Investigation Report (PSR) with a different guidelines calculation, applying the "aggravated assault" guideline and recommending a TOL of 24. Maldonado objected to the PSR, arguing that the facts did not support the aggravated assault guideline. The government’s sentencing memorandum and the prosecutor at the hearing advocated for a higher sentence, including a four-point enhancement for "serious bodily injury," which was not part of the plea agreement. The district court adopted the PSR’s calculation and sentenced Maldonado to 78 months in prison.The United States Court of Appeals for the First Circuit reviewed the case. The government conceded that it breached the plea agreement by advocating for a higher enhancement and not adhering to the agreed-upon sentencing range. The court agreed that the breach was clear and obvious, affecting Maldonado’s substantial rights and the fairness of the proceedings. The court vacated Maldonado’s sentence and remanded for resentencing before a different judge, emphasizing that the fault lay with the prosecutor, not the sentencing judge. View "United States v. Maldonado-Maldonado" on Justia Law

The defendant, Carlos Vázquez-Narvaez, pleaded guilty to one count of possession of child pornography in violation of 18 U.S.C. § 2252A(a)(5)(B). The probation office calculated a guideline sentencing range of fifty-one to sixty-three months of imprisonment and five years to life of supervised release. However, the district court sentenced Vázquez to time served (twenty-one days) and seven years of supervised release. The government appealed, arguing that the sentence was substantively unreasonable due to a lack of a plausible sentencing rationale.The United States District Court for the District of Puerto Rico accepted Vázquez's guilty plea and agreed with the probation office's guideline calculation. Despite this, the court imposed a significantly lower sentence than the guideline range, citing Vázquez's cooperation, compliance with bail conditions, and participation in specialized treatment for sex offenders. The court also noted that Vázquez had no direct contact with the victims and did not produce or entice child pornography. The government objected, arguing that the sentence was too lenient given the seriousness of the offense and the potential for sentencing disparities.The United States Court of Appeals for the First Circuit reviewed the case and concluded that the district court did not adequately explain its basis for the extraordinary downward variance. The appellate court emphasized that the district court's rationale focused almost exclusively on Vázquez's post-arrest conduct and potential for rehabilitation, without sufficiently addressing the seriousness of the offense, the need for general deterrence, or the potential for sentencing disparities. The First Circuit vacated the sentence and remanded the case for resentencing, requiring a more thorough and comprehensive explanation for any significant variance from the guideline range. View "United States v. Vazquez-Narvaez" on Justia Law

In November 2004, Julio Rodríguez-Méndez participated in a carjacking in Puerto Rico while possessing a firearm. He was first prosecuted in a Puerto Rico Commonwealth court for robbery of a motor vehicle and carrying a weapon without a license, to which he pleaded guilty and was sentenced to twelve years in prison. Subsequently, a federal grand jury indicted him on three counts related to the same carjacking, including unlawful possession of a firearm by a felon. Rodríguez pleaded guilty to the felon-in-possession count, and the other charges were dismissed. He was sentenced to 216 months in prison, partly due to being classified as an armed career criminal under the Armed Career Criminal Act (ACCA).Rodríguez filed a motion under 28 U.S.C. § 2255 seeking to vacate his conviction on double jeopardy grounds and to challenge his ACCA enhancement. The United States District Court for the District of Puerto Rico denied his motion, holding that double jeopardy did not apply and that his prior convictions for motor vehicle robbery qualified as ACCA predicates.The United States Court of Appeals for the First Circuit reviewed the case. The court rejected Rodríguez's double jeopardy claim, stating that the federal felon-in-possession offense and the Commonwealth firearm offense are separate offenses under the Blockburger test, as each requires proof of an element that the other does not. However, the court agreed with Rodríguez that his prior convictions under Article 173B of the Puerto Rico Penal Code did not qualify as ACCA predicates. The court found that the statute's definition of "intimidation" was broader than the ACCA's requirement for violent felonies, as it included threats against property, not just persons.The First Circuit affirmed the district court's denial of Rodríguez's double jeopardy claim but reversed the denial of his § 2255 motion regarding the ACCA enhancement, vacating his sentence and remanding for resentencing. View "Rodriguez-Mendez v. United States" on Justia Law

The case involves Jean Carlos Marrero-Burgos, who pleaded guilty to possession of a firearm in furtherance of drug trafficking and possession with intent to distribute cocaine base. Marrero was arrested after police received a tip and found him with a modified Glock pistol, ammunition, and drugs in a house in Bayamón, Puerto Rico. The police also recovered a significant amount of ammunition and drugs from the house.Following his arrest, Marrero was temporarily detained, and a Grand Jury indicted him on four counts. He initially pleaded not guilty but later entered a plea agreement, pleading guilty to two counts. The parties jointly recommended a ninety-month sentence, but the district court imposed a 108-month sentence, citing the dangerous nature of the firearm, the amount of ammunition, and community-based concerns such as gun violence in Puerto Rico.The United States Court of Appeals for the First Circuit reviewed the case. Marrero argued that the district court's sentence was based on erroneous factfinding and undue reliance on community-based characteristics. The appellate court found no clear error in the district court's finding that Marrero possessed the ammunition. The court also held that the district court did not give undue weight to community-based characteristics and that the upward variance was justified based on the dangerousness of the firearm and other factors.The First Circuit affirmed the district court's 108-month sentence, finding it both procedurally and substantively reasonable. The court emphasized that the district court had considered a mix of individualized and community-based factors in arriving at the sentence. View "United States v. Marrero Burgos" on Justia Law