Justia Criminal Law Opinion Summaries

Gerardo Martinez was convicted of first-degree murder in Rhode Island for the 2005 killing of Lindsay Ann Burke, with evidence at trial showing a troubled relationship and a violent altercation that ended in Lindsay’s death by stabbing. Martinez’s defense attorney, Mark Smith, obtained a PTSD diagnosis from a forensic psychiatrist but chose not to present this expert testimony at trial. Instead, Smith argued that Martinez lacked premeditation and should be convicted of second-degree murder. The jury found Martinez guilty of first-degree murder, and he was sentenced to life without parole. On direct appeal, the Rhode Island Supreme Court affirmed the conviction and sentence.Martinez then sought post-conviction relief in the Rhode Island Superior Court, claiming ineffective assistance of counsel for Smith’s decision not to present the PTSD-based diminished capacity defense at trial. After a three-day evidentiary hearing, the Superior Court found that Smith’s choices were strategic and not constitutionally deficient, and therefore did not address the issue of prejudice. The Rhode Island Supreme Court denied Martinez’s petition for writ of certiorari. Martinez subsequently filed a federal habeas petition in the United States District Court for the District of Rhode Island, which was dismissed, but a certificate of appealability was granted.The United States Court of Appeals for the First Circuit reviewed whether the Rhode Island court’s denial of post-conviction relief was an “unreasonable application” of Strickland v. Washington under 28 U.S.C. § 2254(d). The First Circuit held that the state court’s decision was reasonable, emphasizing the strategic nature of Smith’s choices and the deference required under federal habeas review. The court affirmed the district court’s dismissal of Martinez’s habeas petition, finding no constitutional deficiency in counsel’s performance. View "Martinez v. Salisbury" on Justia Law

In this case, the defendant was involved in a Boston-based drug trafficking organization that distributed fentanyl from March 2020 to March 2021. He played a leadership role, coordinating large drug sales and organizing the movement of proceeds to Mexico, where he resided for much of the relevant period. The organization operated out of a specific apartment, used vehicles with hidden compartments to transport drugs and cash, and relied on encrypted communications. Law enforcement conducted extensive surveillance, culminating in searches and seizures of drugs, cash, and related paraphernalia. The defendant was arrested in the Dominican Republic and extradited to the United States.A federal grand jury in the District of Massachusetts indicted the defendant and several co-defendants for conspiracy to distribute fentanyl and conspiracy to commit money laundering. The defendant moved to dismiss the indictment, arguing that his arrest abroad constituted outrageous government conduct, but the United States District Court for the District of Massachusetts denied the motion. At trial, the defendant challenged various evidentiary rulings, alleged prosecutorial misconduct, and objected to aspects of the jury instructions and sentencing. The jury found him guilty on both counts, and he was sentenced to 25 years in prison. His co-defendant, who cooperated with the government, later received a significantly shorter sentence.On appeal, the United States Court of Appeals for the First Circuit reviewed the defendant’s claims, including the denial of his motion to dismiss, evidentiary objections, allegations of prosecutorial misconduct, jury instruction issues, and sentencing challenges. The court held that the arrest did not constitute outrageous government conduct, the evidentiary rulings and jury instructions were not reversible error, and there was no plain error or prosecutorial misconduct warranting a new trial. The court also found the sentence procedurally and substantively reasonable. Accordingly, the First Circuit affirmed the conviction and sentence. View "United States v. Castillo" on Justia Law

A former U.S. Navy Reserve officer, after serving in Afghanistan, maintained contact with an Afghan businessman who had provided interpreters to U.S. forces. In 2018, the businessman asked the officer to write letters of recommendation for Afghan nationals seeking Special Immigrant Visas (SIVs) to the United States, offering payment in return. The officer agreed, negotiating a price and ultimately producing multiple letters that attested to his personal knowledge of the applicants’ character and service, despite not actually knowing or remembering them. The letters were used in SIV applications, and the officer received payment, which he attempted to disguise as consulting fees through a false invoice.A grand jury in the United States District Court for the District of New Hampshire indicted the officer on four counts: conspiracy to commit bribery and false writing, bribery, false writing, and conspiracy to commit concealment money laundering. At trial, the officer moved for acquittal on the basis of insufficient evidence of falsity in the letters, but the district court denied the motion. The jury convicted him on all counts, and the district court later denied a renewed motion for acquittal, finding sufficient evidence for the jury to conclude the letters contained false statements and that the government was not required to prove falsity for all charges. The court sentenced the officer to thirty months’ imprisonment.On appeal, the United States Court of Appeals for the First Circuit reviewed the sufficiency of the evidence de novo and affirmed the convictions. The court held that there was sufficient evidence for a rational jury to find the letters contained false statements about the applicants’ character and the officer’s personal knowledge. The court also rejected challenges to the bribery and money laundering convictions, finding no clear or obvious error and no impermissible merger of offenses. The convictions and sentence were affirmed in full. View "United States v. Pittmann" on Justia Law

In late 2020 and early 2021, Massachusetts law enforcement investigated a suspected drug trafficking organization operating in the South Shore area. The investigation focused on two apartments believed to be used for storing and distributing drugs, and a blue Jeep Grand Cherokee linked to the organization. On January 11, 2021, officers executed state search warrants at both apartments, recovering large quantities of narcotics, cash, firearms, and drug-trafficking equipment. Earlier that day, officers conducted a warrantless stop of the Jeep, driven by Aderito Patrick Amado, and found additional drugs and cash. Amado was charged with conspiracy to possess with intent to distribute fentanyl, fentanyl analogue, and cocaine; three counts of possession with intent to distribute those substances; two counts of being a felon in possession of firearms; and one count of possessing firearms in furtherance of drug trafficking.The United States District Court for the District of Massachusetts denied Amado’s motion to suppress evidence from the Jeep, finding that officers had reasonable suspicion for the stop. After a nine-day trial, a jury convicted Amado on all counts except one firearm-in-furtherance charge. The district court sentenced him to a total of 384 months’ imprisonment, within the advisory Guidelines range, and ten years of supervised release. Amado appealed, challenging the denial of his suppression motion, the application of an obstruction-of-justice enhancement, his designation as a career offender, and the substantive reasonableness of his sentence compared to a co-defendant’s shorter term.The United States Court of Appeals for the First Circuit affirmed the district court’s rulings. The court held that reasonable suspicion supported the stop of the Jeep, the obstruction-of-justice enhancement was warranted due to Amado’s perjury at trial, and the career-offender designation was proper and did not affect the advisory range. The court also found no substantive sentencing error, noting material differences between Amado and his co-defendant. The convictions and sentence were affirmed. View "United States v. Amado" on Justia Law

Víctor Miguel Duluc-Méndez was convicted for his role in a 2013 carjacking in Puerto Rico that resulted in the death of the vehicle’s driver. Duluc and a juvenile accomplice forcibly took a car, detained the driver, withdrew money from his account, and later, the juvenile fatally shot the driver. Duluc was apprehended shortly after and admitted to the carjacking, though he denied knowledge of the juvenile’s intent to kill. He pleaded guilty to the carjacking charge, and the United States District Court for the District of Puerto Rico sentenced him to 240 months in prison.After serving about ten years, Duluc moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing his mother’s deteriorating health and his siblings’ inability to care for her, supported by letters from his family. He also emphasized his substantial post-conviction rehabilitation, including completion of over a thousand hours of programming, leadership roles, and strong recommendations from prison staff and fellow inmates. The government opposed the motion, arguing that Duluc had not shown he was the only available caregiver and that rehabilitation alone was insufficient for compassionate release. The district court denied the motion in a brief order, finding Duluc’s family circumstances unconvincing and citing his criminal record, without addressing his rehabilitation arguments.The United States Court of Appeals for the First Circuit reviewed the denial. The court held that the district court abused its discretion by failing to consider Duluc’s argument that his rehabilitation, combined with his family circumstances, could constitute “extraordinary and compelling reasons” for release. The appellate court vacated the district court’s order and remanded the case for further proceedings, instructing the lower court to consider Duluc’s rehabilitation in its analysis. View "United States v. Duluc-Mendez" on Justia Law

Edwin Otero operated a violent drug trafficking organization across Cape Cod, Massachusetts, and Rhode Island, distributing heroin and engaging in brutal acts to maintain control. In April 2019, suspecting a member of his group was cooperating with authorities, Otero orchestrated a kidnapping and assault in Pawtucket, Rhode Island, where the victim was beaten, stripped, and sexually exploited. Otero recorded the attack and boasted about it to others. A month later, he was involved in another violent incident, ordering a crew member to shoot a drug debtor. Otero was arrested in May 2019 after a DEA investigation uncovered his extensive criminal activities.Otero was charged in the United States District Court for the District of Massachusetts with multiple counts related to drug trafficking, kidnapping, firearms offenses, and obstruction of justice. He pleaded guilty to eight counts without a plea agreement. The presentence investigation report calculated a total offense level of 43, including a six-level enhancement for sexual exploitation during the kidnapping, resulting in a guideline range of life imprisonment. The district court sentenced Otero to 456 months’ imprisonment, with 336 months for most counts served concurrently and 120 months for a firearms count served consecutively. Otero objected to the sexual exploitation enhancement and the substantive reasonableness of his sentence, preserving these issues for appeal.The United States Court of Appeals for the First Circuit reviewed Otero’s procedural and substantive challenges for abuse of discretion. The court held that the district court did not err in applying the sexual exploitation enhancement, finding sufficient evidence that Otero’s conduct met the relevant statutory definitions. The appellate court also found the sentence substantively reasonable, noting it fell within the guidelines and was supported by a plausible rationale. The First Circuit affirmed the district court’s judgment. View "United States v. Otero" on Justia Law

Over a period of 35 years, the defendant operated a dogfighting enterprise known as Stone City Kennel, where he bred, trained, and sold dogs for fighting, mentored others in the practice, and participated in over 150 dogfights across the Americas and the Caribbean. He was known as a prominent figure in the dogfighting world. After admitting incriminating information to an undercover agent, he was indicted in the District of Puerto Rico for conspiracy to violate the Animal Welfare Act (AWA) and for possession of dogs for use in animal fighting. A search of his property revealed four dogs in poor condition, leading to a superseding indictment with additional possession counts. He ultimately pleaded guilty to one conspiracy count and two possession counts.The United States District Court for the District of Puerto Rico grouped the offenses and calculated a Sentencing Guidelines Range (GSR) of 12 to 18 months. However, the Presentence Investigation Report and the government argued for a much higher sentence, citing the exceptional scale and cruelty of the defendant’s conduct. At sentencing, the court heard expert testimony and considered the defendant’s extensive involvement, the cruelty involved, and the need for deterrence. The court imposed an 84-month sentence: 36 months for conspiracy and 24 months for each possession count, to be served consecutively, and described the sentence as an upward variance based on the statutory sentencing factors.On appeal, the United States Court of Appeals for the First Circuit reviewed the defendant’s challenges, including claims of double jeopardy, inadequate explanation, and substantive unreasonableness. The court held that consecutive sentences for conspiracy and possession did not violate double jeopardy, that the statutory text allowed separate punishment for each dog possessed, and that the district court adequately explained and justified the upwardly variant sentence. The First Circuit affirmed the judgment of the district court. View "United States v. Casillas-Montero" on Justia Law

The plaintiff was indicted by a Rhode Island grand jury, along with several co-defendants, on charges related to an alleged mortgage fraud conspiracy. He filed multiple motions to dismiss the charges in Rhode Island Superior Court, arguing that the indictment was tainted by prosecutorial misconduct and the presentation of misleading or missing evidence. After evidentiary hearings, a Magistrate denied his motions, and an Associate Justice of the Superior Court, on de novo review, adopted the Magistrate’s decision and added that the plaintiff had not shown sufficient prosecutorial misconduct to justify dismissal. The plaintiff did not appeal this ruling. Later, the charges against him were dismissed by the state as part of a plea agreement with a co-defendant.Subsequently, the plaintiff filed a malicious prosecution suit in the United States District Court for the District of Rhode Island against state law enforcement defendants. The defendants moved for summary judgment, arguing that collateral estoppel barred the plaintiff from relitigating whether the indictment was procured by fraud or misconduct, since that issue had already been decided in state court. The plaintiff responded only that the issues were not identical, and did not contest the “final judgment” or “full and fair opportunity to litigate” elements of collateral estoppel.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the plaintiff had waived his arguments regarding the “final judgment” and “full and fair opportunity” elements by failing to raise them in the district court, and that no exceptional circumstances justified excusing this waiver. The First Circuit affirmed the district court’s grant of summary judgment to the defendants, holding that collateral estoppel applied and barred the plaintiff’s malicious prosecution claim. Costs were awarded to the defendants. View "Shabshelowitz v. Rhode Island Department of Public Safety" on Justia Law

A native Spanish speaker with limited English proficiency responded to an online advertisement for commercial sex in November 2022. After exchanging text messages with the poster, who was actually an undercover federal agent, he arranged to meet at a hotel, bringing $200, his phone, and condoms. The agent’s messages indicated that the sex would be with minors, specifically describing two girls as ages 14 and 12. The defendant arrived at the hotel, met the agent, received a room key, and was arrested. During booking, when told he was charged with paying for sex with a minor, he expressed surprise and denied speaking to any minor. In a subsequent interview conducted in Spanish about thirty minutes later, he stated he believed he was arranging sex with an adult.A grand jury indicted him on attempted sex trafficking of a child and attempted coercion and enticement of a child to engage in prostitution. His first trial ended in a hung jury, but the second resulted in convictions on both counts. The defense argued he did not intend to have sex with a minor and misunderstood the agent’s messages due to his limited English. The district court admitted his immediate booking statement as an excited utterance but excluded his later interview statements. The court also gave jury instructions distinguishing motive from intent and explaining the interstate commerce element, using examples that paralleled the government’s evidence.The United States Court of Appeals for the First Circuit reviewed the district court’s evidentiary and instructional rulings. The appellate court held that the exclusion of the post-arrest interview statements was not an abuse of discretion, as the statements were made after a significant time lapse and under circumstances suggesting reflection. The court also found no error in the jury instructions regarding interstate commerce or the distinction between motive and intent. The convictions were affirmed. View "US v. Medina" on Justia Law

The defendant pleaded guilty in 2013 to possessing child pornography, after sharing videos of minors being sexually abused and attempting to arrange sex with a minor. He was sentenced to ten years in prison and 25 years of supervised release, with conditions restricting his access to internet-capable devices. After completing his prison term, he began supervised release in December 2019. His release was revoked three times for violations, including unauthorized internet access and failure to comply with monitoring requirements. The conditions at issue required him to use only devices with court-approved monitoring software and to contribute to the cost of monitoring based on his ability to pay.Following the first revocation, the United States District Court for the District of Puerto Rico imposed new, stricter internet monitoring conditions. After further violations, including possessing unauthorized devices and failing to report employment changes, the court again revoked his supervised release (the “Second Revocation”), sentencing him to time served and a renewed term of supervised release with the same conditions. The defendant objected, arguing that the court improperly relied on ex parte communications from his probation officer and that the internet monitoring conditions were unconstitutional and unlawfully delegated judicial authority to the Probation Office.The United States Court of Appeals for the First Circuit reviewed the appeal. The court held that, although the district court erred by relying on new, significant facts from ex parte communications regarding the defendant’s employment, the error was harmless because other uncontested violations supported the revocation and sentence. The court also held that the challenged internet monitoring conditions were not facially unconstitutional or an unlawful delegation of judicial authority. The court found the defendant’s as-applied constitutional challenges unripe, as they depended on future enforcement. The judgment and sentence from the Second Revocation were affirmed. View "United States v. Negron-Cruz" on Justia Law