Justia Criminal Law Opinion Summaries

The First Circuit affirmed Defendant’s sentence for the crime of possession of stolen government property with intent to convert. The district court imposed an above-the-range sentence of thirty months’ imprisonment. The First Circuit held (1) the district court did not clearly err in refusing to find that Defendant’s criminal conduct was attributable to his substance abuse; (2) the district court made no finding that the offensive conduct involved identity fraud; (3) the district court adequately explained its reasons for imposing an upwardly variant sentence; and (4) Defendant’s sentence was substantively reasonable. View "United States v. Fields" on Justia Law

After a trial, Defendant was convicted of conspiracy to possess with intent to distribute and possession with intent to distribute at least fifteen kilograms but less than fifteen kilograms of cocaine. On appeal, Defendant argued that the evidence was insufficient to support his conspiracy conviction and that there were trial irregularities and errors. The First Circuit affirmed, holding (1) because the entire drug deal was captured on video and audio showing Defendant inspecting the drugs, there was sufficient evidence to convict Defendant; and (2) Defendant’s claims of trial error were without merit. View "United States v. Martinez-Lantigua" on Justia Law

Defendant entered a conditional guilty plea to possession with intent to distribute alpha-PHP and obstruction of justice, reserving the right to appeal the denial of four of his five motions to suppress. On appeal, Defendant challenged the district court’s denial of his four motions to suppress and claimed sentencing error. The First Circuit affirmed, holding (1) the district court did not commit clear error in denying Defendant’s four motions to suppress incriminating evidence; and (2) the district court did not err in fashioning Defendant’s sentences, which were substantively reasonable. View "United States v. Coombs" on Justia Law

Alvin Houston and Shawna Calhoun pleaded guilty to transporting Minor A from Maine to Massachusetts and back to Maine over an eight-day period with the intent that Minor A engage in prostitution. In these consolidated appeals, the defendants challenged their sentences of 108 months’ imprisonment each. The First Circuit affirmed, holding (1) the district court did not err in applying sentencing enhancements for undue influence and computer use; (2) the government did not breach the terms of a proffer agreement in its sentencing memorandum; and (3) the district court adequately weighed the 18 U.S.C. 3553(a) factors when fashioning Calhoun’s sentence. View "United States v. Houston" on Justia Law

Defendant pleaded guilty, without a plea agreement, to several federal firearms offenses. Defendant already had a long criminal record, including Massachusetts convictions for unarmed robbery, assault with a dangerous weapon, distribution of a controlled substance, and armed assault with intent to murder. Relying on the first three convictions, the district judge sentenced Defendant as an armed career criminal to fifteen years prison. The First Circuit affirmed, holding that Defendant’s convictions for unarmed robbery, assault with a dangerous weapon, and armed assault with intent to murder provided the necessary three predicates for his Armed Career Criminal Act sentence. View "United States v. Edwards" on Justia Law

The First Circuit affirmed Defendant’s conviction for conspiracy to commit access-device fraud. Before trial, Defendant and his co-defendant filed motions to suppress evidence and statements that had been obtained in the previous months in connection with three traffic stops. The district court denied the motions to suppress. The First Circuit affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress concerning a traffic stop in Kittery, Maine because the police had reasonable suspicion to justify the investigative stop as of 1:55 a.m. and the seizure was not unreasonably long; and (2) the district court did not err in denying the motion to suppress evidence obtained from a traffic stop in Ohio because there was reasonable suspicion to justify the detention. View "United States v. Ramdihall" on Justia Law

The First Circuit affirmed Defendant’s conviction for conspiracy to commit access-device fraud. Before trial, Defendant and his co-defendant filed motions to suppress evidence and statements that had been obtained in the previous months in connection with three traffic stops. The district court denied the motions to suppress. The First Circuit affirmed, holding (1) the district court did not err in denying the motion to suppress evidence obtained from a traffic stop in Ohio because there was no unlawful seizure, and therefore, the evidence Defendant sought to suppress did not constitute the fruits of an unlawful seizure; and (2) the district court did not err in concluding that the warrantless swiping of credit cards from in the trunk of a rental car through a card reader was constitutional. View "United States v. Hillaire" on Justia Law

Defendant appealed his conviction for carjacking in violation of 18 U.S.C. 2119. The First Circuit affirmed, holding (1) Defendant’s actions were sufficient to allow a rational jury to conclude beyond a reasonable doubt that Defendant actually intended to cause harm if that were necessary to steal the car; (2) the district court did not err by admitting Defendant’s confession and finding that it was voluntarily given; (3) the district court did not abuse its discretion in refusing to give a proposed supplemental jury instruction; and (4) Defendant failed to preserve his challenge to the admission of an in-court witness identification. View "United States v. Diaz-Rosado" on Justia Law

First Circuit rejects Double Jeopardy challenge to second indictment for cocaine smuggling. On August 15, 2013, Díaz was indicted in the Southern District of Florida for his role in planning and organizing a maritime smuggling operation involving over 1,000 kilograms of cocaine. Five days later, Díaz was indicted in the District of Puerto Rico -- for his role in planning and organizing a maritime smuggling operation involving over 1,000 kilograms of cocaine. The First Circuit rejected his argument that the Double Jeopardy Clause barred his prosecution on the Puerto Rico charges because the Florida charges already encompass the conduct for which he was indicted in Puerto Rico. While the places involved and the two statutory provisions under which Díaz was charged were the same, the lower court concluded that the conspiracies charged in the two indictments were separate ones insofar as the conduct charged in the two indictments involved distinct time periods, personnel, and evidence. View "United States v. Diaz-Rosado" on Justia Law

Defendant appealed from the revocation of his supervised release and the imposition of a term of imprisonment of twenty-four-months. During Defendant’s period of supervised release for his conviction of conspiracy to bring unauthorized aliens into the United States without going through an authorized port of entry, U.S. Coast Guard personnel interdicted Defendant’s boat off the coast of the Dominican Republic and discovered cocaine. Defendant was then charged with importing and conspiracy to import and possess, with intent to distribute, controlled substances on board a vessel subject to United States jurisdiction. The First Circuit affirmed, holding that the district court (1) did not abuse its discretion in admitting hearsay evidence in the form of two Coast Guard officers’ statements; and (2) did not err in finding that Defendant violated his supervised release terms. View "United States v. Bueno-Beltran" on Justia Law