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

The case involves Hassan Abbas, who was convicted on several counts of wire fraud and money laundering. Abbas was found guilty of participating in an email-based fraud scheme that targeted citizens of Massachusetts. He appealed his conviction on several grounds, including the appropriateness of Massachusetts as the venue for his trial.In the lower courts, Abbas challenged the venue for his trial, arguing that the wire fraud and money laundering activities did not occur in Massachusetts. The district court denied his motion, determining that the issue of when the wired funds became "proceeds" was not capable of resolution before the trial.Upon review, the United States Court of Appeals for the First Circuit affirmed Abbas's convictions for wire fraud but vacated his convictions for money laundering. The court found that the money sent from the victims did not become "proceeds" until it reached Abbas's bank accounts in Illinois and California. Therefore, Abbas did not "participate in the transfer of proceeds" from Massachusetts, making Massachusetts an improper venue for the money laundering charges. The court remanded the case for resentencing and recalculation of restitution. View "US v. Abbas" on Justia Law

The defendant, Antonio Santonastaso, was convicted of making a false statement to federal investigators and attempted witness tampering. The charges stemmed from a 2018 investigation by the Federal Aviation Administration (FAA) into allegations that Santonastaso was flying a helicopter without the necessary certifications. During the investigation, Santonastaso falsely claimed that he had the requisite certifications to fly and that his previous involvement in a 2000 helicopter theft was part of an undercover operation.The case was first heard in the United States District Court for the District of Massachusetts, where Santonastaso was found guilty. He appealed the decision, arguing that the government's evidence was insufficient to prove his guilt and that the district court erred by not giving a materiality instruction based on the Supreme Court's decision in Maslenjak v. United States.The United States Court of Appeals for the First Circuit affirmed the lower court's decision. The court found that the evidence was sufficient for the jury to find Santonastaso guilty of making a false statement to federal investigators and attempted witness tampering. The court also ruled that the district court did not commit instructional error in rejecting Santonastaso's proposed materiality instruction. The court held that the law-of-the-circuit doctrine foreclosed the application of the Maslenjak materiality standard to § 1001(a) prosecutions, and that the district court's instruction correctly stated the controlling law on materiality. View "United States v. Santonastaso" on Justia Law

The case involves Reynaldo Rosa-Borges, who was sentenced to 72 months for unlawful firearm possession and 36 months for violating the terms of his supervised release from a previous conviction. The firearm and ammunition were discovered during two separate incidents. The first incident occurred when Rosa-Borges was found with a firearm during a police patrol at a beach. The second incident happened the following day when police searched Rosa-Borges' residence and found additional ammunition. Rosa-Borges' brother, Naim, claimed that the ammunition belonged to Rosa-Borges.In the lower courts, Rosa-Borges pleaded guilty to the charges. However, he disputed the claim that he possessed the additional 100 rounds of ammunition found at his residence, arguing that the information was derived from unreliable hearsay from his brother, who had a motive to avoid his own criminal liability. Despite these objections, the district court sentenced Rosa-Borges to a total of 108 months in prison.On appeal, the United States Court of Appeals for the First Circuit vacated and remanded the case for resentencing. The appellate court found that the district court had relied on unreliable hearsay evidence from Rosa-Borges' brother to extend Rosa-Borges' sentence. The court concluded that the brother's statement was self-serving and inconsistent with the government's version of events, and therefore, it was an abuse of discretion for the district court to find the statement reliable. The court did not address Rosa-Borges' argument that his limited confrontation right under Rule 32.1(b)(2)(C) was violated. View "United States v. Rosa-Borges" on Justia Law

Lashaun Casey was sentenced to life imprisonment after being found guilty by a jury of carjacking and murdering an undercover police officer. Casey sought a writ of habeas corpus, claiming that his trial attorney failed to seek exclusion of inculpatory statements he made during a period of improper delay in bringing him before a magistrate judge following his arrest and detention. The district court rejected this claim, concluding that while a delay occurred, it was reasonable and necessary for legitimate law enforcement purposes.The United States Court of Appeals for the First Circuit disagreed with the district court's conclusion that Casey's presentment was justifiably delayed. However, the court agreed with Casey that admission at trial of one of the two contested sets of statements was improper. Despite this, the court concluded that Casey had not demonstrated that his trial counsel's failure to press that error constituted ineffective assistance of counsel because his showing of prejudice fell short of the Sixth Amendment standard. Therefore, the court affirmed the district court's judgment denying the writ of habeas corpus. View "Casey v. US" on Justia Law

The case revolves around Carlos Rubén Boyrie-Laboy, a Puerto Rico Police officer, who was convicted under 18 U.S.C. §§ 1951, 371, and 641 for his involvement in a conspiracy to commit robbery and theft of government property. Boyrie-Laboy was part of the Humacao Drugs Division, responsible for seizing illegal weapons, drugs, and other contraband. In 2015, Officer Gabriel Maldonado-Martínez joined the division and began working with Boyrie-Laboy. Maldonado-Martínez later became an undercover FBI informant to identify corrupt police officers. Boyrie-Laboy was involved in two thefts of fireworks and was present during two FBI operations designed to catch corrupt officers. However, he did not accept any stolen goods or money from these operations.The government indicted Boyrie-Laboy and three other officers based on these activities. Boyrie-Laboy was charged with conspiracy to commit robbery, conspiracy to steal and convert government property, and theft and conversion of government property. He proceeded to a five-day jury trial, where the jury found him guilty on all counts. Boyrie-Laboy appealed the convictions, arguing that there was insufficient evidence to support them.The United States Court of Appeals for the First Circuit reviewed the case. Boyrie-Laboy's counsel had declined the opportunity to move for a judgment of acquittal twice during the trial and did not make a post-trial motion for judgment of acquittal. As a result, the court applied the "clear and gross injustice" standard of review. The court found that the evidence sufficiently supported the jury's findings and that upholding Boyrie-Laboy's convictions did not result in a clear and gross injustice. Therefore, the court affirmed the convictions. View "United States v. Boyrie-Laboy" on Justia Law

The case involves Ricardo Perez-Delgado, who was sentenced to forty years in prison for his role in a violent robbery that resulted in the death of a businessman. The sentence was significantly higher than the guideline sentencing range (GSR), which had a maximum of thirty years and five months. Perez-Delgado appealed, arguing that the district court did not adequately explain its rationale for imposing a sentence nearly a decade over the top of the GSR.The district court had adopted the probation office's GSR calculation and considered the relevant statutory factors, Perez-Delgado's background, the nature and circumstances of the offense, and the arguments of both parties. However, the court's explanation for the upward variance was limited to a single sentence stating that the recommended sentence did not reflect the seriousness of the offense, promote respect for the law, protect the public from further crimes by Perez-Delgado, or address issues of deterrence and punishment.The United States Court of Appeals for the First Circuit agreed with Perez-Delgado's argument. The court found that the district court's explanation was insufficient to justify the significant upward variance from the GSR. The court noted that the greater the variance, the greater the explanation must be. The court vacated Perez-Delgado's sentence and remanded the case for resentencing, instructing the district court to provide an individualized explanation proportional to the length of the variance if it decided to upwardly vary again. View "United States v. Perez-Delgado" on Justia Law

The defendant, Heclouis Nieves-Díaz, was on supervised release for a federal drug conviction when he was convicted of possession of ammunition as a convicted felon, illegal possession of a machine gun, and possession with intent to distribute cocaine. He received an 84-month prison term for each conviction, to be served concurrently. His supervised release was also revoked, resulting in an additional 18-month prison term to be served consecutively to his 84-month sentences.Nieves had previously pleaded guilty to one count of drug conspiracy and was sentenced to 80 months of imprisonment and 96 months of supervised release. His term of supervised release was twice revoked. While on his third term of supervised release, Nieves was arrested following a search of an apartment where he was residing. The search yielded cocaine, marijuana, approximately 149 rounds of .223 caliber ammunition, and a device that could convert a Glock pistol into a fully automatic weapon.Nieves appealed his 84-month sentences and the revocation sentence. He argued that the District Court improperly calculated his Guidelines Sentencing Range (GSR) for each of the underlying offenses and that the court's application of a four-level enhancement was incorrect.The United States Court of Appeals for the First Circuit found that the District Court did err in applying the four-level enhancement, as the record did not support the determination that the ammunition in this case had the required potentially facilitative effect. Therefore, the court vacated the District Court's sentences and remanded for resentencing. However, the court affirmed the revocation sentence, finding it both procedurally and substantively reasonable. View "United States v. Nieves-Diaz" on Justia Law

Edgar Centariczki, the defendant, pleaded guilty to aiding and abetting the distribution of methamphetamine and fentanyl in 2021. He was sentenced to time served (two days) and three years of supervised release. His case was transferred to the District of Maine, where he resided. Between June and October of 2021, Centariczki tested positive for marijuana and cocaine multiple times and missed several probation office appointments. Despite warnings from the court, he continued to violate the terms of his supervised release, leading to his arrest in November. In January 2022, a revocation hearing was held due to multiple violations, including drug and alcohol use and failures to report to probation office appointments.The District Court for the District of Maine held a final revocation hearing in February 2023. The court calculated a guideline sentencing range of four to ten months, with thirty months of supervised release. However, the government advocated for an above-guidelines sentence of eighteen months' incarceration with no supervised release to follow, arguing that Centariczki had received multiple chances to seek drug treatment and yet continued to violate the terms of his probation. The court agreed and sentenced Centariczki to eighteen months' incarceration with no supervised release to follow.Centariczki appealed to the United States Court of Appeals for the First Circuit, arguing that his sentence was substantively unreasonable because the district court lacked a sufficiently above-guidelines plausible rationale for imposing an eighteen-month sentence. The Court of Appeals disagreed, holding that the district court's rationale was plausible and its sentence was reasonable. The court noted that Centariczki's repeated violations of his supervised release terms and the multiple second chances afforded to him by the court and probation officer justified the above-guidelines sentence. The court affirmed the district court's decision. View "US v. Centariczki" on Justia Law

The case involves Francis M. Reynolds, who was convicted of three counts of obstruction of a United States Securities and Exchange Commission proceeding and one count of securities fraud. The District Court sentenced him to seven years of imprisonment plus three years of supervised release, ordered him to pay restitution to the victims of his fraud in the amount of $7,551,757, a special assessment of $400, and to forfeit $280,000 to the United States. Reynolds appealed his conviction, but he died while the appeal was pending.Reynolds was convicted in the United States District Court for the District of Massachusetts. He appealed his conviction to the United States Court of Appeals for the First Circuit. While the appeal was pending, Reynolds died. The government suggested that the court should either dismiss the appeal as moot or follow the practice of the Supreme Judicial Court of Massachusetts and dismiss the appeal as moot while instructing the District Court to add a notation in the record.The United States Court of Appeals for the First Circuit had to decide whether to apply the doctrine of abatement ab initio, which holds that when a criminal defendant dies during the pendency of a direct appeal from his conviction, his death abates not only the appeal but also all proceedings had in the prosecution from its inception. The court decided to apply the doctrine, aligning itself with other federal courts of appeals and its own past decisions. The court dismissed the appeal and remanded the case to the District Court to vacate the convictions and dismiss the indictment. The court also instructed the District Court to vacate the orders of restitution and criminal forfeiture that were imposed in this case, as well as the special assessment. View "United States v. Reynolds" on Justia Law

The case involves John Michael Rathbun, who was convicted for creating a homemade firebomb and placing it near a Jewish living facility in Longmeadow, Massachusetts. The bomb was discovered and Rathbun was identified as a suspect when his blood was found on the device. He was charged with attempting to transport and receive an explosive device, attempting to damage and destroy buildings, vehicles, and real and personal property by fire and explosion, and making false statements during an interview. Rathbun appealed his conviction, arguing that the district court erred in admitting irrelevant, biased, and prejudicial testimonial evidence, and in allowing repeated references to inappropriate and highly charged religious topics.The United States Court of Appeals for the First Circuit affirmed the conviction. The court found that the testimonies of the government's witnesses were relevant and probative, and that the district court had taken reasonable steps to limit any potential prejudice. The court also rejected Rathbun's argument that the cumulative effect of the testimonies and the government's opening and closing arguments unfairly prejudiced him. The court concluded that the government's case against Rathbun was strong and that it was highly probable that the admission of the challenged evidence did not affect the jury's verdict. View "United States v. Rathbun" on Justia Law