Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was convicted of first degree murder based on extreme atrocity or cruelty. The jury rejected Defendant's insanity defense. After unsuccessfully filing a motion for a new trial and a motion to consider, Defendant filed this habeas corpus petition, alleging several errors on the part of the motion judge. The district court denied the petition. The First Circuit Court of Appeals affirmed, holding that the motion judge did not err in ruling (1) the trial court did not need to hold a competence hearing sua sponte; (2) trial counsel was not constitutionally deficient; (3) the trial court did not need to inquire into Defendant's waiver of his right to testify; and (4) appellate counsel was not constitutionally deficient. View "Rosenthal v. O'Brien" on Justia Law

After a jury trial, four defendants (Defendants) were convicted of one count of conspiracy to possess with intent to distribute narcotics and one count of conspiracy to use or carry firearms in furtherance of a drug trafficking crime. After considering all of the evidence, including evidence of seven murders committed in furtherance of the narcotics conspiracy, the district court sentenced each Defendant to life imprisonment on the first count and ten years' imprisonment on the second count, to be served consecutively. The First Circuit Court of Appeals affirmed, holding (1) the evidence was sufficient to support the guilty verdicts as to each defendant; (2) the district court did not err in imposing the life sentences as to three of the defendants; and (3) the court did not err in denying severance as to the fourth defendant. View "United States v. Rodriguez-Reyes" on Justia Law

Defendant was a Marine Corps veteran who worked as a civilian employee with the U.S. Department of Veterans Affairs. Defendant was convicted of fraud in connection with his own receipt of veterans benefits. Defendant appealed, contending (1) statements he made during an interview with a Criminal investigator for the Veterans Administration Office of the Inspector General were coerced because they forced him to choose between losing his job or surrendering his right to remain silent under the Fifth Amendment, and (2) the restitution he was ordered to pay as part of his sentence should have been offset by other benefits he might have claimed from the Veterans Administration. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in refusing to suppress statements Defendant made to the Veterans Administration investigator; and (2) the court's restitutionary order was proper. View "United States v. Palmquist" on Justia Law

A federal grand jury indicted Defendant of being a felon in possession of a firearm. Defendant moved to suppress the gun on the ground that the search that resulted in the discovery of the gun derived from an unlawful seizure. The district court granted the motion to suppress, finding that Defendant's encounter with law enforcement officers was at first consensual, but by the time it became a Terry stop, the officers lacked reasonable suspicion to permit the detention. The First Circuit Court of Appeals affirmed, holding that the district court did not err in concluding that the totality of the circumstances did not provide a reasonable suspicion to support Defendant's continuing detention at the time of the search that produced the firearm. View "United States v. Dapolito" on Justia Law

Defendant, who had a 1994 conviction for criminal sexual assault, failed to register as required under the Sex Offender Registration and Notification Act (SORNA) when he moved to Puerto Rico in 2010. Defendant also had two prior failures to register as a sex offender in New Jersey and Florida, and he had an extensive criminal record, including a recent assault on an adult female. Defendant pled guilty to the federal charge of failure to register in this case. In sentencing Defendant, the district court imposed a particular condition of supervised release: that Defendant participate in a sex offender treatment and/or mental health treatment program arranged by the probation officer. The First Circuit Court of Appeals affirmed, holding that the district court did not abuse its discretion in imposing the sex-offender treatment, which was reasonably related to Defendant's present offense as well as to his criminal history. View "United States v. Morales-Cruz" on Justia Law

Defendant purchased a stolen handgun. Two days later, Defendant returned the gun in exchange for the money he paid. Based on the time he possessed the weapon, Defendant was indicted and convicted of one count of possession of a stolen firearm and was sentenced to a $100 special assessment, a one-month jail term, and a two-year term of supervised release. The First Circuit Court of Appeals vacated Defendant's conviction and remanded the case for a new trial, holding that the district court erred when it declined to instruct the jury on "innocent possession," which would have allowed Defendant to make out a defense of innocent possession of the stolen weapon. View "United States v. Baird" on Justia Law

Kaiser Foundation Health Plan and Kaiser Foundation Hospitals (together, Kaiser), Aetna, Inc. and Guardian Life Insurance Company (Guardian) filed a coordinated complaint against Pfizer, Inc. and Warner-Lambert Company (together, Pfizer). The coordinated plaintiffs asserted violations of, inter alia, the Racketeer Influenced and Corrupt Organizations Act (RICO) and the California Unfair Competition Law (UCL). Ultimately, Kaiser prevailed, and Aetna and Guardian's claims were dismissed on summary judgment. After a jury trial, the district court entered judgment in favor of Kaiser on its RICO and state UCL claims. The court subsequently denied Pfizer's motion for a new trial or, in the alternative, to alter or amend judgment. The court awarded Kaiser damages and ordered Defendants to pay restitution. Finding no error, the First Circuit Court of Appeals affirmed the verdicts for Kaiser. View "Kaiser Found. Health Plan v. Pfizer, Inc." on Justia Law

This appeal by Harden Manufacturing Corporation and others (together, Harden plaintiffs) arose from multidistrict litigation concerning the off-label marketing of Neurontin, an anticonvulsant drug manufactured by Pfizer, Inc. The Harden plaintiffs, representing a putative class of third-party payors (TPPs), alleged that Pfizer engaged in a fraudulent off-marketing campaign that caused the TPPs to pay for Neurontin prescriptions that were ineffective for the off-label conditions at issue and that the plaintiffs suffered injury when they paid for those prescriptions. The district court granted summary judgment to Pfizer and denied class certification on the plaintiffs' claims under the Racketeer Influenced and Corrupt Organizations Act (RICO) and the New Jersey Consumer Fraud Act, and state common law claims of fraud and unjust enrichment. The First Circuit Court of Appeals (1) reversed the grant of summary judgment as to the plaintiffs' RICO claim, as the Harden plaintiffs presented evidence to survive summary judgment; (2) vacated the grant of summary judgment as to the state law claims; and (3) vacated the denial of class certification. View "Harden Mfg. Corp. v. Pfizer, Inc." on Justia Law

Aetna, Inc. filed a coordinated complaint with Kaiser Foundation Health Plan and Kaiser Foundation Hospitals (together, Kaiser) and Guardian Life Insurance Company (Guardian) against Pfizer, Inc. and Warner-Lambert Company (together, Pfizer). The coordinated plaintiffs asserted that they had suffered injury from the fraudulent marketing of Neurontin for off-label uses, and alleged violations of, inter alia, the Racketeer Influenced and Corrupt Organizations Act (RICO) and the Pennsylvania Insurance Fraud Statute (PIFS). The district court dismissed the claims of Guardian and Aetna but denied summary judgment as to Kaiser's claims. The court then entered judgment against Guardian and Aetna and in favor of Pfizer. The First Circuit Court of Appeals (1) reversed the dismissal of Aetna's RICO claim, as Aetna presented evidence of causation and damages sufficient to survive summary judgment; and (2) vacated the district court's dismissal of Aetna's claim under the PIFS. Remanded. View "Aetna, Inc. v. Pfizer, Inc." on Justia Law

After a jury trial, Appellants were each convicted under 18 U.S.C. 1347 and 1349 for making fraudulent claims to, and obtaining payment from, insurance companies participating in Massachusetts' no-fault automobile insurance program. The First Circuit Court of Appeals affirmed Appellants' convictions, holding that the district court (1) correctly determined that the defrauded insurance companies constituted "health care benefit programs" within the jurisdictional reach of section 1347; (2) did not err in concluding that Appellants' scheme affected interstate commerce as is required for a constitutionally valid application of section 1347; and (3) did not violate Appellants' Fifth and Sixth Amendment rights in denying proposed voir dire questions concerning the ethnic minority group to which they belonged. View "United States v. Gelin" on Justia Law