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

The Supreme Court affirmed the judgment of the district court denying Defendant’s motion to suppress incriminating evidence found during a search and seizure by a local police officer after approaching Defendant, who was seated in a car with his friend in a parking lot, and asking him several questions, holding that the search and seizure were lawful.Based on Defendant’s answers to the officer’s questions, the officer searched the vehicle, found drugs and drug paraphernalia, and arrested Defendant. After Defendant consented to the search of his backpack, further incriminating evidence was found. Defendant moved to suppress the government’s evidence, arguing that the officer lacked reasonable suspicion to initiate and continue the inquiries that led to the discovery of the contraband. The district court denied the motion. The First Circuit affirmed, holding that the district court did not err in finding no Fourth Amendment violation and denying Defendant’s motion to suppress. View "United States v. Tanguay" on Justia Law

The First Circuit affirmed the district court’s denial of Appellant’s motion to dismiss the indictment against him on double jeopardy and issue preclusion grounds, holding that the Double Jeopardy Clause had no application and that Appellant’s issue preclusion claim would fail on the merits even if it were not waived.In preliminary hearings, Puerto Rico courts concluded that Commonwealth weapons charges against Appellant were not supported by probable cause. Thereafter, Appellant plead guilty to equivalent federal charges based on the same conduct. Appellant later moved the district court to dismiss his indictment as a violation of the Double Jeopardy Clause. After a magistrate judge made a report and recommendation, Appellant raised for the first time his issue preclusion claim. The district court denied Appellant’s motion. The First Circuit affirmed, holding that Appellant was not entitled to relief on his claims. View "United States v. Rosado-Cancel" on Justia Law

The First Circuit reversed an vacated the order of the district court granting Defendant’s motion to suppress identification evidence and giving preclusive effect to a Puerto Rico Court of Appeals’ order suppressing the same evidence in a local proceeding for different offenses, holding that the district court deviated from this Court’s precedent in so ruling.The district court concluded that because Puerto Rico and the United States are a single sovereign for purposes of the Double Jeopardy Clause, the court was bound by the local court’s judgment suppressing identification evidence, even where federal prosecutors did not participate in the proceedings. The First Circuit reversed, holding (1) the district court deviated from the holding in United States v. Bonilla Romero, 836 F.2d 39, 43-44 (1st Cir. 1987), that suppression of evidence by a Puerto Rico court does not require a federal court to suppress that same evidence unless federal prosecutors were a party, or were in privity with a party, to the suppression hearing in the Puerto Rico court; and (2) because there was no privity between the two prosecuting authorities in this case, collateral estoppel was inapplicable. View "United States v. Santiago-Colon" on Justia Law

The First Circuit affirmed Defendant’s conviction of interstate domestic violence and discharge of a firearm during and in relation to a crime of violence and sentence of life imprisonment, holding that there was no reason to vacate Defendant’s convictions or sentence on the grounds that he presented on appeal.Specifically, the First Circuit held (1) the district court did not err in denying Defendant’s motion to suppress evidence; (2) the evidence was sufficient to support Defendant’s convictions; (3) Defendant’s sentence was both procedurally and substantively reasonable; and (4) the district court did not err in denying Defendant’s motion to dismiss the indictment on double jeopardy grounds. View "United States v. Owens" on Justia Law

The First Circuit affirmed Appellant’s revocation sentence, holding that the district court’s upwardly-variant sentence following revocation was neither procedurally nor substantively unreasonable and that the district court’s imposition of Appellant’s supervised release term in addition to the statutory maximum term of imprisonment upon revocation was not in error.Appellant pleaded guilty to one count of cyberstalking in 2012. In 2016, Appellant commenced his supervised release term, but the supervised release term was revoked the next year because Appellant violated some of his conditions. The district court varied upwards from the Guidelines Sentencing Range of five to eleven months to impose a sentence of twenty-four months in prison and twelve months of supervised release. The First Circuit affirmed the revocation sentence, holding (1) under the totality of the circumstances, the district court’s sentence was neither procedurally nor substantively unreasonable and not an abuse of discretion; and (2) there was no error in the district court’s imposition of Appellant’s supervised release term on revocation. View "United States v. Sayer" on Justia Law

The First Circuit vacated Defendant’s sentence for violating the terms of his supervised release and remanded the matter for resentencing, holding that the judge erred in citing rehabilitation needs and unproven domestic-violence allegations, and the errors were presumptively prejudicial.Defendant was sentenced to 168 months in prison in connection with his conviction of conspiracy to distribute cocaine followed by five years of supervised release. After Defendant began supervised release, the government filed a motion to revoke Defendant’s supervised release. Defendant admitted that he violated the terms of his release, and the district court imposed an upward variance, sentencing Defendant to two years’ imprisonment plus two years of supervised release. The First Circuit vacated the sentence and remanded the matter for resentencing, holding (1) the district court likely did rely on rehabilitation in fixing the sentence in a way that is at odds with the Sentencing Reform Act; and (2) the unproven domestic-violence charges are not to be considered upon resentencing. View "United States v. Vazquez-Mendez" on Justia Law

The First Circuit affirmed Defendant’s conviction of attempted coercion and enticement of a minor to engage in sexual activity for which Defendant could be charged with sexual assault under the laws of Puerto Rico, holding that the evidence was sufficient to support the conviction and that Defendant could not prevail on his challenges to the jury instructions.At issue on appeal was whether Defendant could be charged with sexual assault under Puerto Rico law when the person he tried to entice was an adult federal agent posing as a minor. The First Circuit held (1) because Defendant was clearly attempting to have sex with a child, he was plainly violating Puerto Rico law; and (2) Defendant’s challenges to the jury instructions failed. View "United States v. Saldana-Rivera" on Justia Law

The First Circuit affirmed the decision of the district court dismissing Plaintiff’s action on the grounds that the lawsuit was, in essence, an appeal from a state-court judgment, and therefore, the court lacked jurisdiction to hear it under the Rooker-Feldman doctrine, holding that the district court correctly held that it lacked jurisdiction to hear Plaintiff’s claims.This appeal arose from Plaintiff’s legal challenge seeking to void two Massachusetts Superior Court conditions of probation imposed on the adult male who was convicted of statutory rape after impregnating Plaintiff when she was a minor. One of those conditions ordered the defendant to acknowledge paternity of the child. The district court decided that it did not have jurisdiction over the claims. The First Circuit affirmed, holding that because the relief Plaintiff sought was based on her claim that the Massachusetts Supreme Judicial Court erred in the adjudication of her case, the district court properly dismissed this case for want of jurisdiction. View "Tyler v. Supreme Judicial Court of Massachusetts" on Justia Law

The First Circuit reversed the district court’s pretrial dismissal of four charges of violations of the National Firearms Act (NFA), 26 U.S.C. 5801 et seq. brought against Defendant, reinstated those counts, and remanded this case for further proceedings, holding that the result reached by the district court was contrary to the complete text and context of the NFA and not what Congress intended.The charges against Defendant arose from Defendant’s act of purchasing four military M67 fragmentation grenades from an FBI agent during an undercover sting operation. Before the sale, the FBI had replaced each grenade’s original, operable fuze with an inoperable one. The district court concluded that because the operable fuzes had been replaced with inoperable fuzes, the grenades were not “explosive grenades” under the NFA. The First Circuit reversed, holding that, based on the admitted facts, statutory context, and Congress’s intent in enacting the “explosive grenade” provision of the NFA, each grenade as purchased by Defendant was an “explosive grenade” under the NFA. View "United States v. Musso" on Justia Law

The First Circuit vacated Defendant’s sentence and remanded this matter for resentencing, holding that no weight should be given in sentencing to arrests listed in the presentence report (PSR) that did not result in convictions or were not buttressed by independent proof of conduct.Defendant pleaded guilty to two counts of possessing a firearm while prohibited from doing so because of a prior felony conviction and his fugitive status. The district court imposed a variant sentence of seventy-two months. On appeal, Defendant challenged the judge’s possible reliance on arrests not resulting in convictions in his upward variance. The First Circuit vacated the sentence, holding that Defendant made a strong enough case that the sentencing judge relied on such arrests in determining his sentence and remand was required. View "United States v. Marrero-Perez" on Justia Law