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

The First Circuit affirmed the district court’s dismissal of Appellant’s federal petition for writ of habeas corpus filed pursuant to 28 U.S.C. 2254, holding that the district court did not err in dismissing the petition.In his petition, Appellant challenged his convictions under Massachusetts law for murder and other offenses, arguing that he received ineffective assistance of counsel, in violation of the Sixth Amendment to the United States Constitution. The district court denied relief. Because Appellant’s case was adjudicated on the merits in state court, the Antiterrorism and Effective Death Penalty Act’s (AEDPA) highly deferential standard of review applied. See 28 U.S.C. 2254(d). The First Circuit affirmed the district court’s denial of habeas relief, holding that any error on the part of counsel was not unsustainable under AEDPA’s deferential review standard. View "Walker v. Medeiros" on Justia Law

The First Circuit affirmed Defendant’s convictions and sentence for conspiring to defraud the United States and stealing government property in violation of 18 U.S.C. 371, 641, holding that there was sufficient evidence to support Defendant’s convictions and that the sentence was procedurally reasonable.Specifically, the First Circuit held (1) there was ample evidence from which a jury could have reasonably determined that Defendant was a knowing and willing participant in a fraudulent scheme of claiming eligibility for Social Security benefits and receiving nearly $100,000 in disability insurance disbursements to which he was not entitled; and (2) the district court’s imposition of Defendant’s sentence was procedurally sound. View "United States v. Sostre-Cintron" on Justia Law

In this 42 U.S.C. 1983 case, the First Circuit affirmed the judgment of the district court granting summary judgment in favor of Kathy Bergeron, a corrections officer, holding that no reasonable juror could conclude that Bergeron was deliberately indifferent to the health and safety of Plaintiff, an inmate, under the Eighth Amendment based on the facts presented by Plaintiff.Plaintiff was severely beaten by other inmates in a cell at a medium-security prison. In his complaint, Plaintiff alleged that Bergeron was deliberately indifferent while doing a round, leading to a delay in his being provided with medical treatment, which exacerbated his injuries. The district court granted summary judgment for Bergeron. The First Circuit affirmed, holding that Plaintiff failed to produce enough evidence for a jury to conclude that Bergeron had the requisite culpable state of mind of deliberate indifference to Plaintiff’s need for medical care. View "Leite v. Goulet" on Justia Law

The First Circuit affirmed Defendant’s sentence for distribution of heroin and fentanyl, holding that the sentence was not substantively unreasonable.After a hearing, the district court sentenced Defendant to 168 months in prison, a sentence that fell within the range stipulated in the plea agreement, as well as between defense counsel’s recommendation and the government’s recommendation. On appeal, Defendant argued that while the sentence was within the range stipulated in the plea agreement, the court should have sentenced him to the stipulated range’s lower bound. Noting that Defendant’s arguments were largely a disagreement with the weight the district court assigned particular factors, the First Circuit affirmed, holding that the factors amply justified the sentence imposed. View "United States v. Gilley" on Justia Law

The First Circuit affirmed Defendant’s conviction of being a felon in possession of a firearm an ammunition and sentence to time served plus three weeks of imprisonment and three years of supervised release, holding that any error was harmless.Specifically, the Court found (1) the district court did not err in denying Defendant’s motion to suppress evidence of the firearm; (2) the district court did not err in granting the government’s motion in limine to preclude Defendant from asserting a necessity defense; and (3) the district court committed a significant procedural error in calculating Defendant’s Guidelines sentencing range, but the error was harmless. View "United States v. Henderson" on Justia Law

The First Circuit affirmed Defendant’s sentence of thirty months’ imprisonment for knowingly failing to update his registration, holding that the district court neither committed clear error in finding that Defendant perjured himself at trial or in imposing a two-level enhancement for obstruction of justice.Defendant, a registered sex offender, was convicted of knowingly failing to update his registration, in violation of 18 U.S.C. 2250(a). Finding that Defendant had committed perjury when he testified at trial in his own defense, the district court imposed a two-level obstruction of justice enhancement. The court then sentenced Defendant at the middle of his Guidelines sentencing range. The First Circuit affirmed, holding that the district court did not err in applying the sentencing enhancement for obstruction of justice because the record provided clear support for the finding that Defendant committed perjury. View "United States v. Nagell" on Justia Law

The First Circuit affirmed Appellant’s sentence of forty months for illegal possession of a machine gun, holding that there was no reversible error or abuse of discretion in the district court’s decision.After Appellant pled guilty to the offense, the district court calculated a Sentencing Guidelines range of twenty-four to thirty months. Ultimately, the district court imposed an above-Guidelines sentence of forty months. On appeal, Appellant argued that the district court erroneously relied on disputed facts and abused its discretion in imposing an above-Guidelines sentence. The First Circuit disagreed, holding (1) the district court did not err in adopting the facts as stated in the presentence report; and (2) the district court acted well within its discretion in imposing a forty-month sentence on Appellant. View "United States v. Severino-Pacheco" on Justia Law

The First Circuit affirmed the district court’s order revoking Appellant’s supervised release, holding that the district court’s decision was not an abuse of discretion.In 2009, Appellant was sentenced to a term of seventy-eight months of imprisonment for a drug offense, later reduced to sixty-three months and an eight-year period of supervised release. The district court subsequently found that Appellant unlawfully possessed and distributed a controlled substance and revoked Appellant's supervised release. The First Circuit affirmed, holding that the district court’s decision revoking Appellant’s supervised release was not an abuse of discretion and that the court did not violate Appellant’s due process rights. View "United States v. Bodon-Lespier" on Justia Law

The First Circuit dismissed Defendant’s appeal from his sentence as moot because Defendant had already completed serving the custodial sentence he attempted to challenge on appeal.Defendant pled guilty to unlawfully attempting to enter the United States after being removed therefrom following an aggravated felony conviction. The district court imposed a twenty-one month custodial sentence following by three years of supervised release. Defendant appealed his custodial sentence, and his appeal was still pending when he completed his custodial term and began serving his term of supervised release. The First Circuit summarily dismissed the appeal as moot because the appeal, even if successful, would not lead to any effectual relief. View "United States v. Suarez-Reyes" on Justia Law

The First Circuit affirmed the judgments of the district court convicting Alba Pena and Indranis Rocheford, sisters, of multiple counts of wire fraud and Rocheford’s sentence to thirty-three months in prison and three years of supervised release, holding that there was no error in the proceedings below.Specifically, the Court held (1) the evidence was sufficient to sustain both Rocheford’s and Pena’s convictions; (2) there was no merit to Pena’s contention that the district court erred by now allowing her to testify as to certain witness statements and that she was prejudiced in her ability to mount a “good faith” defense to the wire fraud charges; (3) the district court did not err in failing to give a particular instruction concerning unanimity; and (4) the district court did not abuse its discretion in imposing Rocheford’s sentence. View "United States v. Pena" on Justia Law