Justia Criminal Law Opinion Summaries

After a jury trial, Petitioner was found guilty of second degree murder and unlawful possession of a firearm. Petitioner appealed his conviction, contending that the Commonwealth used its peremptory challenges to exclude young African Americans in violation of the equal protection principles laid down in Batson v. Kentucky. The Massachusetts Appeals Court (MAC) concluded that Petitioner had failed to make a prima facie showing that the Commonwealth’s use of peremptory challenges was likely motivated by the jurors’ race. Petitioner failed to obtain relief on appeal in the Massachusetts courts and subsequently sought a writ of habeas corpus from the United States District Court. The district court denied the petition. The First Circuit vacated the judgment of the district court, holding that the MAC’s application of the first Batson prong was clear error and represented an objectively unreasonable application of clearly established federal law. Remanded to the district court to conduct an evidentiary hearing and to complete the Batson inquiry. View "Sanchez v. Roden" on Justia Law

Defendant was charged with several drug trafficking crimes. Defendant engaged in several pre-trial antics in an apparent effort to put off the trial, including seeking continuances of the trial and ostensibly firing his attorney. Because of Defendant’s continued complaints about his attorney, Defendant ended up representing himself at trial. The jury ultimately convicted Defendant on all counts. The First Circuit affirmed Defendant’s convictions, holding (1) the trial judge did not deprive Defendant of his Sixth Amendment right to counsel of his choice when she allowed Defendant to represent himself at trial; and (2) the district judge did not err in refusing Defendant’s motions to continue. View "United States v. Robinson" on Justia Law

Petitioner was convicted as an accessory before the fact to George Carpenter’s murder. The Massachusetts Supreme Judicial Court (SJC) reversed the conviction, concluding that the indictment charging Petitioner improperly defined the offense on which he was tried. The Commonwealth subsequently indicted Petitioner for the murder of Carpenter. Petitioner moved to dismiss the indictment, arguing that the second prosecution was barred by double jeopardy as incorporated against the states. The SJC affirmed the trial judge’s denial of Petitioner’s motion, concluding that its earlier reversal had been based on a variance between the crime charged and the crime proved at trial under state law, and a second prosecution under these facts did not give rise to a double jeopardy problem. Petitioner filed a petition for habeas relief, claiming that his pending prosecution was barred by double jeopardy. The district court granted the petition. The First Circuit reversed, holding that under Tibbs v. Florida, the SJC’s interpretation of its earlier reversal and the requirements of Massachusetts law bound the Court, and therefore, Petitioner’s double jeopardy argument necessarily failed. View "Marshall v. Bristol Superior Court" on Justia Law

Defendant, a former police officer with the Puerto Rico Police Department (PRPD), was caught providing armed protection for sham drug transactions through a sting operation controlled by the FBI. After a jury trial, Defendant was found guilty on multiple counts of conspiracy to possess with intent to distribute a controlled substance, attempt to possess with intent to distribute a controlled substance, and possession of a firearm in relation to a drug trafficking scheme. The First Circuit affirmed, holding (1) the evidence was sufficient to support Defendant’s convictions; (2) the district court did not err in denying Defendant the opportunity to present entrapment, derivative entrapment or duress defenses; (3) the prosecutor’s statements during closing argument were not improper; and (4) Defendant’s conviction and sentences were not improperly multiplicitous. View "United States v. Diaz-Castro" on Justia Law

Defendant was prosecuted in federal court for possession of child pornography, in violation of 18 U.S.C. 2252(a)(4)(B), after police officers took several digital devices from his home, including a thumb drive that contained child pornography. To establish that the pornography was “produced using materials which have been…shipping or transported” in interstate commerce, the prosecution relied on an inscription on the thumb drive stating, “Made in China.” The First Circuit affirmed Defendant’s conviction, holding (1) copying pornography onto a thumb drive is “producing” pornography under the statute, and the Court’s interpretation of the law did not put it beyond Congress’s authority to regulate interstate commerce; (2) the district court did not err by admitting as evidence the drive’s inscription over Defendant’s hearsay objection; and (3) the warrant to search Defendant’s home and the devices inside it was constitutional. View "United States v. Burdulis" on Justia Law

In 1998, Defendant was convicted of the Massachusetts crime of indecent assault and battery of a child under the age of fourteen. Defendant was notified of his obligation to register as a sex offender under the Sex Offender Registration and Notification Act (SORNA) but failed to do so. In 2012, a federal grand jury indicted Defendant of failing to register under SORNA. In 2013, the state district court vacated Defendant’s sex crime. Defendant subsequently moved to dismiss his federal charges on the basis that he no longer had a predicate sex offense to support a SORNA violation. The district court denied Defendant’s motion to dismiss and convicted him of failing to register as a sex offender under SORNA. The First Circuit affirmed, holding that SORNA’s registration requirement applies to defendants who are convicted of a sex offense, regardless of whether that conviction is later vacated, when federal charges have been brought for conduct before the vacation of conviction. View "United States v. Roberson" on Justia Law

Petitioner was convicted in Massachusetts state court of drug distribution and trafficking. While Petitioner’s appeal was pending in the Supreme Judicial Court (SJC), the U.S. Supreme Court decided Melendez-Diaz v. Massachusetts. On appeal, Petitioner argued that his conviction must be reversed because the trial proceedings violated his federal Confrontation Clause rights as articulated in Melendez-Diaz. The SJC decided that there was a Melendez-Diaz error in this case but that the error was harmless beyond a reasonable doubt. Petitioner petitioned for habeas review in federal district court, arguing that the state proceedings had violated his Sixth Amendment rights under Melendez-Diaz. The district court denied the petition, concluding that Petitioner could not show sufficient injury under the Brecht v. Abrahamson standard of review. The First Circuit affirmed, holding that under the highly deferential standard announced in Brecht, Petitioner failed to show the “substantial and injurious effect or influence” on the verdict required to set aside the SJC’s affirmance of his conviction. View "Connolly v. Roden" on Justia Law

After a jury trial, Appellant was convicted of one count of conspiracy to make false statements on a federal firearms application, three counts of gun possession by a previously convicted felon, and one count of marijuana possession. At sentencing, Appellant argued against the imposition of the four-level enhancement under the federal sentencing guidelines for possessing a firearm “in connection with” another felony. The district court imposed the enhancement, finding that Appellant had possessed a gun in connection with what the court described as felony “drug trafficking” rather than marijuana possession. The First Circuit Court of Appeals affirmed, holding that the district court did not err (1) in denying Appellant a judgment of acquittal on the marijuana possession count; and (2) in finding that Appellant possessed a firearm “in connection with” the drug-dealing offense. View "United States v. Matthews" on Justia Law

After a jury trial, Appellant was convicted of conspiracy to distribute cocaine, distribution of cocaine, and possession of cocaine with intent to distribute. Before Appellant’s sentencing, he learned of the existence of certain evidence that the government had failed to disclose to him. Appellant filed a motion to set aside the verdict and for a new trial, contending that the government had failed to disclose exculpatory evidence that could have been used to impeach the credibility of the key government witness against him at trial. The district court denied the motion. Appellant was subsequently sentenced to life imprisonment, which was “legally required” by the quantities of cocaine at issue and by virtue of this being Appellant’s third felony drug conviction. The First Circuit Court of Appeals (1) affirmed the denial of Appellant’s motion, holding that the suppression did not result in prejudice to Appellant; and (2) rejected the constitutional challenges Appellant raised to the district court’s imposition of a life sentence. View "United States v. Paladin" on Justia Law

Defendants, Geovanny Ramirez-Negron and Obed Alvarado-Merced pled guilty to aiding and abetting possession with intent to distribute at least one kilogram of heroin, five kilograms of cocaine, fifty grams of cocaine base, and one hundred kilograms of marijuana, all within 1000 feet of a public school, and related conspiracy charges. The district court sentenced each defendant to a Guidelines sentence. Defendants appealed, challenging the district court’s findings at sentencing as to drug quantity. After oral argument, the First Circuit Court of Appeals ordered the parties to submit additional briefs on the issue of whether the Supreme Court’s decision in Alleyne v. United States impacted this appeal. The First Circuit affirmed, holding (1) there was no Alleyne error because all elements of Defendants’ crimes of conviction were admitted as part of the guilty pleas and neither Defendant was sentenced based on a mandatory minimum sentence; and (2) the evidentiary base for the district court’s findings of fact in support of its Guidelines sentences was adequate. View "United States v. Ramirez-Negron" on Justia Law