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

Defendant was charged with conspiracy to possess with intent to distribute and to distribute more than 1,000 grams of marijuana, among other charges. Defendant moved to suppress evidence taken from a warrantless search of his truck. The district judge denied the motion. Defendant later conditionally pled guilty, reserving his right to challenge the denial of his suppression motion. The First Circuit affirmed, holding (1) the questioning of Defendant was within the permissible scope of a traffic stop, and the questions did not impermissibly extend the duration of the stop; (2) the initial search of the truck was permissible in light of Defendant’s voluntary consent; (3) the continuation of the search after Defendant withdrew his consent was permissible because probable cause existed; and (4) there were no constitutional violations during the traffic stop. View "United States v. Dion" on Justia Law

The First Circuit affirmed the convictions of brothers Stanley Gonsalves and Joshua Gonsalves, who were convicted on multiple counts arising from their operation of an oxycodone-trafficking ring. The court held (1) the district court did not err in denying Joshua’s motion to suppress the evidence seized the night of his February 2012 arrest; (2) the district court did not abuse its discretion in denying Joshua’s and Stanley’s motions for a mistrial; (3) the evidence was sufficient to support Stanley’s convictions; and (4) Stanley’s sentence was procedurally reasonable because any error in calculating his Guidelines sentencing range did not impact his substantial rights. View "United States v. Gonsalves" on Justia Law

The First Circuit affirmed Defendant’s sentence for the crime of possession of stolen government property with intent to convert. The district court imposed an above-the-range sentence of thirty months’ imprisonment. The First Circuit held (1) the district court did not clearly err in refusing to find that Defendant’s criminal conduct was attributable to his substance abuse; (2) the district court made no finding that the offensive conduct involved identity fraud; (3) the district court adequately explained its reasons for imposing an upwardly variant sentence; and (4) Defendant’s sentence was substantively reasonable. View "United States v. Fields" on Justia Law

After a trial, Defendant was convicted of conspiracy to possess with intent to distribute and possession with intent to distribute at least fifteen kilograms but less than fifteen kilograms of cocaine. On appeal, Defendant argued that the evidence was insufficient to support his conspiracy conviction and that there were trial irregularities and errors. The First Circuit affirmed, holding (1) because the entire drug deal was captured on video and audio showing Defendant inspecting the drugs, there was sufficient evidence to convict Defendant; and (2) Defendant’s claims of trial error were without merit. View "United States v. Martinez-Lantigua" on Justia Law

Defendant entered a conditional guilty plea to possession with intent to distribute alpha-PHP and obstruction of justice, reserving the right to appeal the denial of four of his five motions to suppress. On appeal, Defendant challenged the district court’s denial of his four motions to suppress and claimed sentencing error. The First Circuit affirmed, holding (1) the district court did not commit clear error in denying Defendant’s four motions to suppress incriminating evidence; and (2) the district court did not err in fashioning Defendant’s sentences, which were substantively reasonable. View "United States v. Coombs" on Justia Law

Alvin Houston and Shawna Calhoun pleaded guilty to transporting Minor A from Maine to Massachusetts and back to Maine over an eight-day period with the intent that Minor A engage in prostitution. In these consolidated appeals, the defendants challenged their sentences of 108 months’ imprisonment each. The First Circuit affirmed, holding (1) the district court did not err in applying sentencing enhancements for undue influence and computer use; (2) the government did not breach the terms of a proffer agreement in its sentencing memorandum; and (3) the district court adequately weighed the 18 U.S.C. 3553(a) factors when fashioning Calhoun’s sentence. View "United States v. Houston" on Justia Law

Defendant pleaded guilty, without a plea agreement, to several federal firearms offenses. Defendant already had a long criminal record, including Massachusetts convictions for unarmed robbery, assault with a dangerous weapon, distribution of a controlled substance, and armed assault with intent to murder. Relying on the first three convictions, the district judge sentenced Defendant as an armed career criminal to fifteen years prison. The First Circuit affirmed, holding that Defendant’s convictions for unarmed robbery, assault with a dangerous weapon, and armed assault with intent to murder provided the necessary three predicates for his Armed Career Criminal Act sentence. View "United States v. Edwards" on Justia Law

The First Circuit affirmed Defendant’s conviction for conspiracy to commit access-device fraud. Before trial, Defendant and his co-defendant filed motions to suppress evidence and statements that had been obtained in the previous months in connection with three traffic stops. The district court denied the motions to suppress. The First Circuit affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress concerning a traffic stop in Kittery, Maine because the police had reasonable suspicion to justify the investigative stop as of 1:55 a.m. and the seizure was not unreasonably long; and (2) the district court did not err in denying the motion to suppress evidence obtained from a traffic stop in Ohio because there was reasonable suspicion to justify the detention. View "United States v. Ramdihall" on Justia Law

The First Circuit affirmed Defendant’s conviction for conspiracy to commit access-device fraud. Before trial, Defendant and his co-defendant filed motions to suppress evidence and statements that had been obtained in the previous months in connection with three traffic stops. The district court denied the motions to suppress. The First Circuit affirmed, holding (1) the district court did not err in denying the motion to suppress evidence obtained from a traffic stop in Ohio because there was no unlawful seizure, and therefore, the evidence Defendant sought to suppress did not constitute the fruits of an unlawful seizure; and (2) the district court did not err in concluding that the warrantless swiping of credit cards from in the trunk of a rental car through a card reader was constitutional. View "United States v. Hillaire" on Justia Law

Defendant appealed his conviction for carjacking in violation of 18 U.S.C. 2119. The First Circuit affirmed, holding (1) Defendant’s actions were sufficient to allow a rational jury to conclude beyond a reasonable doubt that Defendant actually intended to cause harm if that were necessary to steal the car; (2) the district court did not err by admitting Defendant’s confession and finding that it was voluntarily given; (3) the district court did not abuse its discretion in refusing to give a proposed supplemental jury instruction; and (4) Defendant failed to preserve his challenge to the admission of an in-court witness identification. View "United States v. Diaz-Rosado" on Justia Law