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

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

The First Circuit affirmed the district court’s rejection of Appellant’s claims that she, among other things, suffered discrimination in violation of the Americans with Disabilities Act (ADA) and its Massachusetts state-law corollary when Defendants failed to accommodate her request for transfer to another position in the Plymouth Police Department after she suffered an on-the-job injury. The district court concluded that Appellant failed to raise a genuine issues of material fact regarding her discrimination claims. The First Circuit affirmed, holding (1) the district court correctly entered summary judgment on Appellant’s handicap discrimination claims and gender discrimination claim; and (2) even if the court were able to glean an ADA retaliation claim from Appellant’s complaint, Appellant waived it during summary judgment proceedings. View "Audette v. Town of Plymouth, Mass." on Justia Law

In this immigration case, the First Circuit vacated the order of the Board of Immigration Appeals (BIA) upholding the decision of the Immigration Judge (IJ) denying Petitioner’s applications for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). In his petition for review, Petitioner, a native of Guatemala, argued that he presented sufficient evidence to establish both past persecution and a well-founded fear of future persecution and that he could not reasonably relocate within Guatemala. The First Circuit granted the petition for review and remanded for further proceedings, holding (1) there was significant evidence in the record supporting a conclusion that relocation would be unreasonable; and (2) given the limited analysis on this issue by the IJ and the BIA, remand was proper for the BIA to consider it fully. View "Garcia-Cruz v. Sessions" 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

Petitioner, a citizen of Guatemala, petitioned for review of a decision of the Board of Immigration Appeals (BIA) denying his requests for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). The BIA affirmed the decision of the Immigration Judge (IJ), concluding (1) the level of mistreatment Petitioner suffered did not rise to the level that could qualify as persecution to be entitled to a grant of asylum, and (2) Petitioner could not meet the requirements for withholding of removal and for protection under the CAT. The First Circuit denied Petitioner’s petition for review, holding (1) Petitioner failed to provide the court with a basis for reversing the BIA’s ruling denying his application for asylum; and (2) Petitioner failed to offer any basis on which to conclude that he could satisfy the requirements for withholding for removal or for protection under the CAT. View "Morales-Morales v. Sessions" 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