Justia Criminal Law Opinion Summaries

Edison Burgos-Montes, serving a life sentence, sought compassionate release due to serious medical conditions, including severe hypertension and obstructive sleep apnea. He argued that the Bureau of Prisons (BOP) failed to provide adequate treatment for these conditions. Burgos filed a motion with the district court in late 2021, presenting evidence of his ongoing severe hypertension and lack of treatment for his sleep apnea. The district court found that Burgos was receiving adequate medical care and denied his motion without prejudice.Burgos appealed, contending that the district court's finding was clearly erroneous. He pointed to evidence that, nearly a year after his sleep apnea diagnosis, the BOP had not provided him with a CPAP machine, the standard treatment for sleep apnea. The district court had relied on a letter from Dr. Gary Venuto, Clinical Director at FCC Coleman, stating that Burgos was receiving adequate care. However, Burgos argued that this assessment overlooked significant evidence of inadequate treatment.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the district court clearly erred in concluding that Burgos was receiving adequate treatment for his sleep apnea. The appellate court noted that Burgos had not received a CPAP machine or any other treatment for his sleep apnea, despite a diagnosis and a recommendation from an outside cardiologist. The court vacated the district court's order and remanded the case for further proceedings to determine if Burgos had demonstrated an "extraordinary and compelling" reason for compassionate release under 18 U.S.C. § 3582(c)(1)(A). View "United States v. Burgos-Montes" on Justia Law

Martin Flanagan, a former employee of Fresenius Medical Care Holdings, Inc., filed a qui tam lawsuit under the False Claims Act (FCA) against his former employer. He alleged that Fresenius engaged in a fraudulent kickback scheme to induce referrals to its dialysis clinics, violating the Anti-Kickback Statute (AKS). Flanagan claimed that Fresenius offered below-cost contracts to hospitals, overcompensated medical directors, and provided other benefits to secure patient referrals, which were then billed to Medicare and Medicaid.The U.S. District Court for the District of Maryland initially handled the case, which was later transferred to the U.S. District Court for the District of Massachusetts. The district court dismissed Flanagan's complaint for failing to meet the heightened pleading standard under Rule 9(b) of the Federal Rules of Civil Procedure. The court found that the amended complaint did not adequately allege specific false claims or provide representative examples. Additionally, the court ruled that some of Flanagan's claims were barred by the FCA's public-disclosure and first-to-file rules. The district court also denied Flanagan's motion to amend his complaint, citing undue delay and potential prejudice to Fresenius.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's dismissal, agreeing that Flanagan failed to plead the alleged fraud with the required particularity. The appellate court also upheld the denial of the motion to amend, noting that Flanagan had ample time to address the deficiencies in his complaint but failed to do so. The First Circuit concluded that the district court did not abuse its discretion in its rulings. View "Flanagan v. Fresenius Medical Care Holdings, Inc." on Justia Law

In this case, the defendant, Xavier O. Maldonado-Negroni, was appealing a sentence imposed for violations of his supervised release conditions. Maldonado had a history of supervised release violations following his 2013 conviction for drug trafficking. His most recent violations included testing positive for drugs and committing domestic violence, for which he received a six-year sentence under Commonwealth law.The United States District Court for the District of Puerto Rico determined that Maldonado's violations fell within the most serious category of supervised-release violations, classified as Grade A, and sentenced him to the statutory maximum of thirty-six months' imprisonment, to run consecutively to his Commonwealth sentence. Maldonado appealed, arguing that the district court's error in classifying his violations as Grade A rather than Grade B influenced the sentencing determination.The United States Court of Appeals for the First Circuit reviewed the case and agreed with Maldonado. The court found that the district court's brief statement that it would have imposed the same sentence regardless of the violations' category was inadequate to satisfy the government's burden to show harmless error. The appellate court noted that the district court's explanation did not make clear that the erroneous Guidelines range did not influence the sentence. Consequently, the First Circuit vacated the sentence and remanded the case for resentencing, emphasizing the need for a clear and unmistakable record that the Guidelines error did not affect the sentencing decision. View "United States v. Maldonado-Negroni" on Justia Law

Luis Javier Matta Quiñones was convicted of possession of firearms and ammunition as a prohibited person and possession of a machinegun. Matta claimed he was wrongfully accused by police officers who found contraband nearby. He attempted to discredit the officers' testimony that he threw a feed sack containing guns and ammunition onto a roof while fleeing. Matta argued on appeal that the district court hindered his defense in several ways, including allowing the government's case agent to be present during jury deliberations.The United States District Court for the District of Puerto Rico oversaw Matta's trial. The jury found Matta guilty on both charges. Matta moved for a judgment of acquittal and a new trial, arguing insufficient evidence and improper jury contact by the case agent. The district court denied both motions, reasoning that Matta had waived objections to the case agent's presence and that the contact was brief and non-prejudicial. Matta was sentenced to 96 months' imprisonment, with an additional 18 months for revocation of supervised release.The United States Court of Appeals for the First Circuit reviewed the case. The court found sufficient evidence to support Matta's convictions but agreed that the district court erred by allowing the case agent to be present during jury deliberations without proper investigation into potential juror misconduct. The appellate court vacated Matta's convictions and remanded for a new trial. The court also vacated the revocation of supervised release sentence and remanded for resentencing. Additionally, the court addressed evidentiary issues likely to recur, ruling that Matta should have been allowed to cross-examine Officer Vidal about prior statements and that the Receipt Form could be admissible under the business records exception. View "United States v. Matta-Quinones" on Justia Law

In the 1990s, José A. Vega-Figueroa was involved in a drug-trafficking operation in Puerto Rico. He was charged in 1994 with multiple offenses, including first-degree murder, but was acquitted by a jury in 1995. In 1997, a federal grand jury indicted him for his role in a criminal enterprise involving the distribution of various drugs and related violent acts. After a thirty-day trial, he was found guilty on all counts and sentenced to multiple life sentences. Vega has since made several unsuccessful attempts to challenge his conviction and sentence.In February 2021, Vega filed a motion for compassionate release in the District of Puerto Rico, citing his health conditions and the risk of COVID-19 complications. He also argued that his rehabilitation efforts and the double jeopardy of being tried for the same conduct warranted his release. The district court denied his motion, finding that the Bureau of Prisons had taken adequate measures to protect inmates from COVID-19 and that Vega's health conditions did not meet the criteria for compassionate release. The court also determined that Vega remained a danger to the community, given his criminal history and prison infractions.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's decision, agreeing that Vega's health conditions and the measures taken by the Bureau of Prisons did not constitute extraordinary and compelling reasons for release. The appellate court also upheld the district court's assessment that Vega continued to pose a danger to the community, thus justifying the denial of his motion for compassionate release. View "United States v. Vega-Figueroa" on Justia Law

José Luis Meléndez-Rivera and an associate committed a carjacking in Bayamón, Puerto Rico, during which Meléndez shot one of the victims in the face. Meléndez was arrested and charged with multiple offenses, including carjacking resulting in serious bodily injury and firearm-related charges. He initially pled not guilty but later negotiated a plea agreement with the government, agreeing to plead guilty to the carjacking charge in exchange for the dismissal of other charges.The United States District Court for the District of Puerto Rico did not accept the initial plea agreement, prompting Meléndez to withdraw his plea. A new plea agreement was reached, recommending a 180-month sentence for the carjacking charge. At sentencing, the court considered the presentence investigation report (PSR), the plea agreement, and Meléndez's sentencing memorandum, which detailed his difficult upbringing and history of recidivism. The court ultimately imposed a 198-month sentence, citing Meléndez's extensive criminal history and the need for deterrence and punishment.On appeal to the United States Court of Appeals for the First Circuit, Meléndez argued that the government breached the plea agreement by failing to meaningfully advocate for the recommended 180-month sentence and that the sentence was procedurally unreasonable because the court did not consider his mitigation arguments. The First Circuit found no plain error in the government's conduct, concluding that the prosecutor fulfilled her obligation by requesting the agreed-upon sentence. The court also held that the sentence was procedurally reasonable, as the district court had considered the relevant factors and Meléndez's mitigation arguments, even if it did not explicitly address each one. The First Circuit affirmed the district court's judgment. View "United States v. Melendez-Rivera" on Justia Law

Lester Aceituno was convicted of conspiracy to commit bank fraud and two counts of aggravated identity theft. The fraudulent scheme involved using stolen identification information to open bank accounts, change addresses to rented mailboxes, deposit fraudulent checks, and withdraw funds using debit cards. Aceituno opened accounts in New Hampshire and Massachusetts using stolen identities and signed documents attesting to the accuracy of the information. He also created a mailbox using a stolen identity. The scheme was led by a man known as "Abby," who provided the stolen information.The United States District Court for the District of New Hampshire denied Aceituno's Rule 29 motion, which argued insufficient evidence to prove he knew he was using real persons' identifying information. The court also rejected his claim of prosecutorial misconduct during the government's closing argument and rebuttal. Aceituno was sentenced to 30 months in prison.The United States Court of Appeals for the First Circuit reviewed the case. The court held that sufficient evidence supported the jury's finding that Aceituno knew the identification information belonged to real people. The evidence included Aceituno's repeated use of stolen identities, the bank's verification process, and testimony from a co-conspirator. The court also found that the prosecution's statements during closing arguments were fair inferences from the evidence and did not constitute misconduct. The court affirmed Aceituno's conviction. View "United States v. Aceituno" on Justia Law

Dana A. Pullman, a former Massachusetts State Police trooper and president of the State Police Association of Massachusetts (the Union), and Anne M. Lynch, head of the lobbying firm Lynch Associates, were involved in a kickback scheme. Pullman hired Lynch Associates to assist with a grievance negotiation, initially agreeing to a $200,000 fee. Later, Pullman verbally agreed to increase the fee to $350,000. After the Union received reimbursement from the Commonwealth, Pullman pressured the Union treasurer to issue a $250,000 check to Lynch Associates. Lynch then paid $20,000 to Pullman's wife. Both Pullman and Lynch were convicted of honest-services wire fraud, among other charges.The United States District Court for the District of Massachusetts convicted Pullman and Lynch of honest-services wire fraud, wire fraud, obstruction of justice, conspiracy to defraud the United States, and a racketeering conspiracy. Pullman and Lynch challenged the sufficiency of the evidence and the jury instructions, particularly regarding the honest-services wire fraud convictions. They argued that the evidence did not support a quid pro quo arrangement and that the jury instructions improperly suggested Pullman owed a fiduciary duty to the Commonwealth.The United States Court of Appeals for the First Circuit reviewed the case. The court found sufficient evidence to support the honest-services wire fraud convictions, noting the jury could reasonably infer a quid pro quo arrangement. The court also held that any instructional error regarding Pullman's fiduciary duty to the Commonwealth was harmless, as the evidence overwhelmingly showed he breached his fiduciary duty to the Union. The court reversed the wire fraud convictions and one of Lynch's tax fraud convictions based on the government's concession. The court affirmed the other convictions, including those for honest-services wire fraud, obstruction of justice, and the RICO conspiracy. The case was remanded for resentencing. View "United States v. Pullman" on Justia Law

The case involves Jovan Vavic, a former head coach of the men's and women's water polo teams at the University of Southern California (USC), who was implicated in the "Varsity Blues" college admissions scandal. Vavic was accused of facilitating the admission of students as fake athletic recruits in exchange for payments from Rick Singer, a college consultant orchestrating the scheme. The payments were allegedly made to benefit Vavic's water polo program and his sons' private school tuition.In the lower court, the United States District Court for the District of Massachusetts presided over the case. A jury convicted Vavic on three counts: conspiracy to commit mail and wire fraud and honest services mail and wire fraud, conspiracy to commit federal programs bribery, and wire fraud and honest services wire fraud. However, the district court granted Vavic a new trial, concluding that certain statements made by the government during its rebuttal closing amounted to prosecutorial misconduct. The court found that the government's statements misrepresented the law and facts, particularly regarding the payments to USC and the alleged $100,000 bribe for Agustina Huneeus's recruitment.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's order for a new trial on the honest services fraud charge (Count Sixteen) due to a Yates error, as it was impossible to determine if the jury's verdict rested on an invalid legal theory following the decision in United States v. Abdelaziz. However, the appellate court reversed the new trial order for the federal programs bribery conspiracy charge (Count Three), concluding that the government's statements did not constitute plain error and that there was no prejudicial variance or Napue error. The case was remanded for further proceedings consistent with the appellate court's opinion. View "US v. Vavic" on Justia Law

In this case, the defendant, Admilson Pires, was convicted by a jury of conspiracy to commit sex trafficking of a minor and sex trafficking of a minor. The case began when the Norwood Police Department received a tip about a missing sixteen-year-old girl, Daisy, who was found at an apartment in Norwood, Massachusetts. Daisy revealed that she had been engaging in commercial sex. During the investigation, it was discovered that Pires and another individual, Sandro Rosa (known as Eli), were involved in trafficking Daisy.The United States District Court for the District of Massachusetts conducted the trial, where Pires was found guilty on both counts. He was sentenced to 132 months' imprisonment for each count, to be served consecutively. Pires appealed, arguing that the evidence was insufficient to support his conspiracy conviction and that there were errors in the trial, including the admission of expert testimony and statements made by the prosecution during summation.The United States Court of Appeals for the First Circuit reviewed the case. The court found that there was sufficient evidence to support the conspiracy conviction, noting that Eli's involvement went beyond merely providing shelter and included actions that indicated a tacit agreement to traffic Daisy. The court also held that the expert testimony about typical patterns of sex trafficking was admissible and relevant to the case, and that the prosecutor's statements during summation did not amount to misconduct that would warrant a reversal of the conviction.The First Circuit affirmed the district court's judgment, upholding Pires's convictions and sentences. View "U.S. v. Pires" on Justia Law