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

In January 2018, Nycole Amaury Rosario Sánchez, then fifteen years old, and six accomplices committed a series of violent crimes in Puerto Rico, including three robberies, two carjackings, and four murders. Rosario brandished and discharged firearms during these crimes, resulting in multiple injuries and deaths. He was arrested on January 25, 2018, and agreed to be prosecuted as an adult. Rosario pleaded guilty to six counts, including interference with commerce by robbery, carjacking, and using a firearm during a crime of violence causing murder.The United States District Court for the District of Puerto Rico sentenced Rosario to 480 months' imprisonment. Rosario appealed, arguing that the district court failed to consider mitigating factors such as his age, mental and emotional condition, and the sentencing disparity between him and his co-defendants. He also claimed that his sentence was both procedurally and substantively unreasonable.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the district court had considered Rosario's age, mental and emotional condition, and other mitigating factors, as evidenced by the sentencing transcript and the Presentence Investigation Report (PSR). The court also noted that Rosario's co-defendants were sentenced by a different judge and that Rosario had not provided sufficient information to establish an unwarranted sentencing disparity.The First Circuit held that the district court did not commit procedural error in its consideration of the section 3553(a) factors or in addressing the sentencing disparity. The court also found that Rosario's sentence was substantively reasonable, given the seriousness of his offenses and his behavior while incarcerated. Consequently, the First Circuit affirmed Rosario's 480-month sentence. View "United States v. Rosario Sanchez" on Justia Law

Daniel Paul Sansone, the defendant-appellant, was convicted for being a felon in possession of a firearm. He was sentenced to 46 months of imprisonment, the upper end of the sentencing guideline range. Sansone challenged the procedural integrity and substantive reasonableness of his sentence. The United States Court of Appeals for the First Circuit reviewed his claims.Sansone had argued that his criminal history score was erroneously inflated due to the inclusion of his juvenile adjudications, asserting that his commitment to the Massachusetts Department of Youth Services (DYS) was not a sentence of confinement. The court rejected this argument, noting that prior case law had upheld the inclusion of such adjudications as constituting sentences of confinement.Sansone also claimed there was insufficient evidence to support the conclusion that his juvenile adjudications resulted in confinement for at least sixty days, which was necessary for the assignment of criminal history points under the United States Sentencing Guidelines (USSG). The Court of Appeals found that Sansone could not show a plain error in this regard, as the record was ambiguous and did not allow for a clear determination of the length of his confinement.Regarding the substantive reasonableness of his sentence, Sansone argued that the sentencing court had overstated the seriousness of his past criminal record and failed to adequately consider his personal history. The Court of Appeals disagreed, finding that the sentencing court had considered all relevant factors, and Sansone's real complaint was about the weight given to certain factors, not their consideration. The court upheld the sentence, affirming the district court's decision. View "US v. Sansone" on Justia Law

The First Circuit affirmed in part and reversed in part the order of the district court ordering A.R., who was adjudicated delinquent in a proceeding under the Federal Juvenile Delinquency Act (FJDA), 18 U.S.C. 5031-5042, detained in a juvenile institution until he reached the age of twenty-one, followed by a term of juvenile delinquent supervision, holding that remand was required.A.R., who was born in 2003, was adjudicated delinquent pursuant to his admission of aiding and abetting an attempted robbery of a motor vehicle and five carjackings, each of which would have been a violation of 18 U.S.C. 2119 had A.R. been an adult. On appeal, A.R. primarily challenged the district court's order of a detention period rather than a probationary one. The First Circuit affirmed as to the court's imposition of detention but reversed and remanded as to two other matters, holding (1) A.R.'s disposition was both procedurally and substantively reasonable; (2) the district court erred in failing to recommend that A.R. be placed in a local detention facility; and (3) the district court erred in imposing a term of detention and supervision that together exceeded the applicable statutory maximum. View "United States v. A.R." on Justia Law

The district court did not err in granting the government’s motion for J.C.D. to be tried as an adult for an armed carjacking J.C.D. allegedly committed when he was seventeen years old.J.C.D. was charged with one count of carjacking. The government filed a motion to transfer J.C.D. to adult status. After balancing the statutory factors, the magistrate judge recommended that the government’s motion to transfer the case be denied. The district court granted the government’s motion to transfer, contrary to the magistrate judge’s recommendation, concluding that the statutory factors, when balanced, warranted transfer of J.C.D. to adult status in the interest of justice. The First Circuit affirmed, holding that J.C.D.’s challenges raised on appeal failed. View "United States v. J.C.D." on Justia Law

The government filed a juvenile information against Y.C.T. alleging two acts of delinquency. The government filed a motion for a discretionary transfer of Y.C.T. to the district court’s criminal jurisdiction. A magistrate judge issued a written report recommending that Y.C.T. be transferred to adult status for criminal prosecution. The district court adopted the recommendation after conducting a de novo review, concluding that the transfer best served the interest of justice. The First Circuit affirmed the transfer order, holding that the district court’s reliance on the record, as developed by the magistrate judge, to conduct its de novo review was not an abuse of discretion and did not violate Y.C.T.’s right to due process. View "United States v. Y.C.T." on Justia Law

A disabled child, born in 1996, was a student in the Sutton public school system from 1999 until 2005, when his parent were dissatisfied with the individualized education program developed under the Individuals with Disabilities Education Act, 20 U.S.C. 1400-1491, and the services he was receiving. They removed him from the school and enrolled him in a private learning center. The Massachusetts Bureau of Special Education Appeals determined that the 2005 IEP complied with the IDEA. The district court upheld the decision on summary judgment. The First Circuit affirmed, rejecting an argument that the court could not determine compliance without first determining the child's potential for learning and self-sufficiency. The district court properly concluded that the child's potential was unknowable and that the IEP was reasonably calculated to confer educational benefits. The parents did not raise triable claims under the First Amendment, the Rehabilitation Act of 1973, Titles II and V of the Americans with Disabilities Act, or 42 U.S.C. 1983 and 1985; plaintiffs “cannot disguise an IDEA claim in other garb.” View "D.B., a minor v. Esposito" on Justia Law

An 11-year-old child suffered long-term horrific abuse and, in 2005, was beaten nearly to death by her adoptive mother and stepfather. The child's legal guardian, brought suit against Carson Center and one of its employees, a licensed social worker, alleging that they failed to detect or report signs of ongoing physical abuse. The state court suit led to insurance coverage litigation in federal court. Insurers sought a declaratory judgment that the allegations fell within exclusions to coverage. The First Circuit affirmed entry of declaratory judgment for the insurers. The language of the policy exclusions precludes coverage for abuse that occurs to anyone in the insureds' "care, custody or control." At the time of the abuse the victim was not in the physical custody of the insureds, but had been receiving bi-weekly outpatient therapeutic services from them for 14 months covered by the policies in question. The exclusions are unambiguous. View "Valley Forge Ins. Co. v. Field" on Justia Law