Justia Criminal Law Opinion Summaries

In 1999, Petitioner admitted to a single count of shoplifting in Massachusetts state court. In 2012, Petitioner admitted to an amended charge of larceny by inducement. The following year, Petitioner was charged with removability as an alien who has been convicted of or admits to having committed "a crime involving moral turpitude.” Petitioner applied for special rule cancellation, arguing that he fell within the petty offense exception because his shoplifting conviction was not a crime involving moral turpitude. The Immigration Judge denied Petitioner’s application. The Board of Immigration Appeals dismissed Petitioner’s appeal, concluding that the IJ properly found that Petitioner’s shoplifting conviction was, in addition to the larceny conviction, a crime involving moral turpitude, making him ineligible for the petty offense exception. The First Circuit granted Petitioner’s petition for review, holding that the BIA did not provide a comprehensive analysis to support its conclusion Petitioner’s shoplifting conviction was also a crime involving moral turpitude, and therefore, the case must be remanded to the BIA for further proceedings. View "Mejia v. Holder" on Justia Law

After a jury trial in federal district court, Petitioner was convicted of child pornography and sentenced to 180 months’ imprisonment. The First Circuit Court of Appeals affirmed Petitioner’s conviction and sentence. Petitioner subsequently filed a petition under 28 U.S.C. 2255 collaterally attacking his conviction on four grounds. The district court rejected the petition. The First Circuit affirmed the district court’s denial of Petitioner’s petition for collateral relief, holding (1) because Petitioner did not show any prejudice, his ineffective assistance of counsel claim failed; (2) any error that the district court made in excluding certain testimony did not have a substantial and injurious effect on the jury’s verdict; (3) the conduct underlying Petitioner’s conviction was not constitutionally protected; and (4) Petitioner’s argument that he was actually innocent failed. View "Ortiz-Graulau v. United States" on Justia Law

After a jury trial in Massachusetts state court, Appellant was convicted of the first-degree murder of his estranged wife under both the theory of deliberate premeditation and extreme atrocity or cruelty. The Massachusetts Supreme Judicial Court (SJC) affirmed on appeal. Appellant subsequently filed a petition for a writ of habeas corpus in the federal district court, alleging (1) his constitutional right to confrontation was violated when the testimony of the chief medical examiner in Massachusetts was admitted, and (2) his attorney provided ineffective assistance by failing to introduce certain mental health related evidence. The district court denied the petition. The First Circuit Court of Appeals affirmed, holding (1) the SJC’s rejection of Appellant’s Confrontation Clause argument was not contrary to governing Supreme Court precedent; and (2) the SJC did not unreasonably apply Strickland or commit clear factual error when it concluded that Appellant’s attorney’s performance was not deficient. View "Hensley v. Roden" on Justia Law

This case arose from the misconduct of Annie Dookhan, a chemist at a Massachusetts state testing laboratory, who falsely certified drug testing results. Appellant was indicted for possession of crack cocaine with intent to distribute. Appellant pleaded guilty to the charge, but when news broke about Dookhan’s perfidy, Appellant moved to withdraw his plea. The district court denied relief, concluding that Appellant had not shown that Dookhan’s misconduct was material to his guilty plea. The First Circuit Court of Appeals affirmed, holding that the district court did not abuse its discretion in finding no fair and just reason for allowing Appellant to withdraw his guilty plea. View " United States v. Merritt" on Justia Law

After a jury trial, Defendant was convicted for being a felon in possession of a firearm and for possession of a firearm in a school zone. Defendant was sentenced to sixty months imprisonment on both counts. The First Circuit affirmed the conviction and sentence as to the felon in possession count but reversed the conviction and sentence as to the possession of a firearm in a school zone count, holding that the prosecution’s evidence was insufficient to prove the requisite element that Defendant knew or reasonably should have known he was in a school zone while possessing a firearm. View "United States v. Guzman-Montanez" on Justia Law

Appellant pled guilty to robbery and brandishing a firearm during a robbery and was sentenced to prison sentences of seventy-two months and eighty-four months, to be served consecutively. Following the imposition of sentence, Appellant argued that the district court improperly departed upward from the applicable Guidelines sentencing range. The district court’s responded that the sentence was not a departure, but rather, the sentence was a variance. Appellant raised the same argument on appeal. The First Circuit affirmed, holding that Appellant received a sentence that in fact varied from the applicable Guidelines range, rather than an upward departure under the Guideliens, and there was no plain error in the variance. View "United States v. Aponte-Vellon" on Justia Law

The United States sought extradition of Alexander Hilton, a U.S. citizen, to face an attempted murder charge in Scotland. A magistrate judge found Hilton extraditable despite Hilton’s arguments that extradition would increase his risk of suicide and that trial under the Scottish jury system would violate his U.S. Constitutional rights because Scotland requires only a simple majority for conviction. Hilton subsequently sought habeas corpus relief seeking to block extradition. The district court denied relief. The First Circuit affirmed, holding that Defendant’s claim that his extradition would violate his right to due process because of his high risk of suicide and his claim that extradition would violate his constitutional rights because Scotland allows simple majority jury verdicts were both barred by the rule of non-inquiry, which precludes the judicial system from evaluating the fairness and humaneness of another country’s criminal justice system. View "Hilton v. Kerry" on Justia Law

Appellant had worked for twenty-six years with the United States Postal Service as a letter carrier when he was charged with obstructing the mails in violation of 18 U.S.C. 1701. The statute provides that a defendant who “knowingly and willfully obstructs or retards the passage of mail” shall be fined or imprisoned. After a bench trial, the magistrate judge found Appellant guilty as charged. The district court affirmed. The First Circuit Court of Appeals affirmed, holding (1) even if the trial court’s definition of the term “willfully” was error, any error was harmless beyond a reasonable doubt; (2) the evidence of willful obstruction was sufficient; and (3) the magistrate judge did not deny Appellant due process by continuing the trial date. View "United States v. Marshall" on Justia Law

In 2011, drugs found in Appellant’s possession were sent to a Massachusetts testing laboratory, where Annie Dookhan, a chemist, certified that the drugs were crack cocaine. Appellant was subsequently indicted in federal court for possessing crack cocaine with the intent to distribute. Appellant pleaded guilty to the offense and went to prison. In 2012, it was discovered that Dookhan had falsely certified countless drug-test results. Although there was no direct evidence that Dookhan had committed misconduct in this case, Appellant filed a motion to set aside his conviction and vacate his guilty plea based on the scandal. The district court denied Appellant’s motion. The First Circuit affirmed, holding that Appellant did not meet his burden of proving that there was a reasonable probability that he would not have pleaded guilty had he known of Dookhan’s transgressions. View "Wilkins v. United States" on Justia Law

Appellant pleaded guilty to two counts related to his involvement in a drug ring. After a plea colloquy, the district judge sentenced Appellant to 327 months on count one and life imprisonment on count two, to run consecutively. Thereafter, the district judge twice resentenced Appellant. The last sentence imposed on Appellant was a total aggregate sentence of 405 months. Appellant appealed, contending that his first judgment should be vacated because of flaws in the initial plea colloquy and because the district court lacked authority for actions taken after entry of the first sentence. The First Circuit affirmed the initial guilty plea and original sentence and vacated all subsequent judgments and orders of the district court, holding (1) the first sentence was not unreasonable, and although the initial plea colloquy was flawed, the imperfections did not justify setting aside the first judgment; and (2) the district judge lacked statutory authority to act after he entered the original sentence, and therefore, the first and most severe sentence imposed by the district judge stands. View "United States v. Sevilla-Oyola" on Justia Law