Justia Criminal Law Opinion Summaries

Appellant was convicted of first degree murder. Appellant subsequently commenced this action under the Freedom of Information Act (FOIA) seeking information from the FBI he believed would exonerate him. The government asserted various exemptions to disclosure of the documents' full contents and produced certain heavily redacted documents. After producing these documents, the government moved for summary judgment. The district court granted the government's motion, concluding that the FBI's search was adequate and that it properly claimed the exemptions asserted. The court also awarded Appellant attorneys' fees after significantly reducing the number of compensable hours and the requested hourly rate of Appellant's counsel. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in granting summary judgment to the government, as Appellant failed to raise a triable issue as to the government's treatment of his FOIA request; and (2) the district court did not abuse its discretion in calculating the fee award in this case. View "Moffat v. United States Dep't of Justice" on Justia Law

Plaintiff was a company that sold aviation fuel at a Puerto Rico airport. Plaintiff filed this action Defendants, the Puerto Rico Ports Authority (PRPA), Airport Aviation Services (AAS), and employees of those entities, claiming that Defendants wrongfully interfered with its business. Specifically, Plaintiff alleged that a corrupt relationship existed between AAS and PRPA and that Defendants took improper actions in order to drive Plaintiff out of business. Before trial, the district court dismissed the claims against some defendants and, after a bench trial, granted judgment for the remaining defendants. The First Circuit Court of Appeals affirmed, holding (1) Plaintiff did not indicate a sufficiently clear intent to appeal the judgments dismissing the PRPA defendants from the case; and (2) the district court did not err in finding no conspiracy on the part of AAS and its employees to restrain trade, and the court correctly concluded that Plaintiff failed to proffer evidence to prove Defendants' actions were unreasonable or anticompetitive. View "Diaz Aviation Corp. v. Airport Aviation Servs., Inc." on Justia Law

Defendant was charged with failing to register under the Sex Offender Registration and Notification Act. After a competency hearing, the district court found that Defendant was mentally incompetent and committed him to the custody of the attorney general to be hospitalized. While this interlocutory appeal was pending, the district court issued an order finding it unlikely that Defendant would be able to face the charges against him and ordering that Defendant be further evaluated. The First Circuit Court of Appeals affirmed the district court's order, holding (1) a defendant challenging an order finding him incompetent and committing him to the custody of the attorney general under 18 U.S.C. 4241(d)(1) can seek immediate review of such order; (2) the issue on appeal did not become moot after the district court issued its order finding it unlikely that Defendant would attain competency in the foreseeable future; (3) the district court applied the correct legal standard to determine Defendant's competency; and (4) the district court did not clearly err in finding Defendant incompetent. View "United States v. Mahoney" on Justia Law

Pursuant to a non-binding plea agreement, Defendant pled guilty to a charge of conspiracy with intent to distribute controlled substances. The district court imposed a 210-month incarcerative sentence after applying a sentencing enhancement for possession of a dangerous weapon during and in the course of the crime of conviction and construing the guideline sentencing range accordingly. The First Circuit Court of Appeals affirmed Defendant's sentence, holding (1) the district court's rejection of the sentencing recommendation vitiated Defendant's waiver of appeal in its entirety, and therefore, this appeal was not circumscribed; (2) the dangerous weapons enhancement was adequately grounded in the record; and (3) the sentencing court considered the relevant 18 U.S.C. 3553(a) factors and adequately explained the sentence. View "United States v. Murphy-Cordero" on Justia Law

The police, after seizing a cell phone from Defendant's person as part of his lawful arrest, searched the phone's data without a warrant. Based on information obtained from the cell phone, Defendant was charged with possessing with intent to distribute and distributing cocaine base and with being a felon in possession of a firearm and ammunition. Defendant unsuccessfully filed a motion to suppress the evidence obtained as a result of the warrantless search of his phone, and the district court subsequently convicted Defendant as charged. The First Circuit Court of Appeals reversed the denial of Defendant's motion to suppress and vacated his conviction, holding (1) the search in this case exceeded the boundaries of the Fourth Amendment search-incident-to-arrest exception; and (2) because the government did not argue that the search here was justified by any exception to the warrant requirement, Defendant's motion to suppress must be granted. Remanded. View "United States v. Wurie" on Justia Law

Defendant, a thrice-convicted felon, and his confederates attended a backyard barbecue at which firearms were openly displayed. They subsequently reconvened at the scene of a planned robbery. The robbery was never consummated, but the police arrested Defendant on firearms charges. During the jury trial, the district court admitted evidence of Defendant's statements to the police about events occurring at the cookout. Defendant was convicted as charged. The First Circuit Court of Appeals, holding (1) the government proved beyond a reasonable doubt that Defendant knowingly possessed firearms charged in the indictment, and therefore, the district court correctly denied Defendant's motion for judgment of acquittal; and (2) the district court did not err in admitting Defendant's statements about the robbery scheme and his handling of the revolver at the cookout, as the evidence was relevant and not unfairly prejudicial. View "United States v. Williams" on Justia Law

Defendant was sentenced to eight years' incarceration after she pled guilty to various crimes committed during her sixteen years on the run with wanted fugitive, James "Whitey" Bulger. Defendant challenged her sentence on appeal, claiming that the court erroneously calculated her base offense level on the conspiracy to harbor a fugitive count, incorrectly applied a firearm enhancement, wrongly utilized an obstruction of justice enhancement, and erred in allowing family members of Bulger's alleged victims to speak during sentencing. The First Circuit Court of Appeals affirmed, holding that the district court did not err in (1) finding that Defendant's conduct was not limited to harboring Bulger and refusing to cap her offense level accordingly; (2) applying the firearm enhancement and the obstruction of justice enhancement; and (3) deciding to let the family members speak. View "United States v. Greig" on Justia Law

Appellant received a life sentence for his role in a large-scale drug operation that sold heroin, crack, cocaine, and marijuana at a public housing project in Puerto Rico. Appellant pled guilty to several drug offenses at the end of the first day of testimony. The First Circuit Court of Appeals vacated Appellant's sentence and remanded for resentencing before a different judge, holding (1) the imposition of a general sentence of life imprisonment on all counts when none of the crimes of conviction supported that penalty was improper, and the life term of imprisonment did not survive the plain error test; and (2) the district court erred in fixing Appellant's sentence by considering information obtained during an ex parte meeting with the probation department. View "United States v. Zavala-Marti" on Justia Law

After a jury trial, Defendant was found guilty of conspiracy to possess with the intent to distribute fifty grams or more of cocaine base, five kilograms or more of cocaine, one or more kilograms of heroin, and an undetermined quantity of marijuana, and possession with intent to distribute cocaine base, cocaine, heroin, and marijuana. Defendant received a thirty-year incarcerative sentence. Defendant subsequently filed a motion for reduction of sentence. The district court denied the motion. The First Circuit Court of Appeals vacated and remanded because the court's conclusion was not self-evident on the face of the record. In remanding, the First Circuit directed that Defendant could only be held responsible for those drugs he personally handled as well as "those that were reasonably foreseeable to him." The district court reaffirmed its ruling on remand, finding that the quantity of heroin distributed by the conspiracy was reasonably foreseeable to Defendant and in itself sufficient to support Defendant's sentence. The First Circuit reversed, holding that the district court's foreseeability finding and the drug quantity determinations underlying it were clearly erroneous. View "United States v. Candelaria-Silva" on Justia Law

After a jury trial, Defendant was convicted in the District of Massachusetts of aiding and abetting the making of a false claim against the United States in connection with his 2008 federal income tax return. Defendant appealed. The First Circuit Court of Appeals affirmed, holding (1) the district court's aiding and abetting instruction was legally correct in that it accurately conveyed the appropriate legal elements; (2) the aiding and abetting instruction did not constructively amend the indictment in violation of the Fifth Amendment; and (3) the evidence adduced at trial was sufficient to sustain Defendant's aiding and abetting conviction. View "United States v. Davis" on Justia Law