Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was convicted of conspiracy, manufacturing over 100 marijuana plants, maintaining a residence for marijuana manufacturing, and possessing a firearm as a felony. The district court sentenced Defendant to 120 months’ imprisonment followed by eight years of supervised release. The First Circuit affirmed, holding (1) even if the superseding indictment violated the principles outlined in Alleyne v. United States, the error was harmless beyond a reasonable doubt; (2) the district court erred in admitting hearsay testimony under the exception for statements in furtherance of a conspiracy, but this error did not warrant reversal; (3) any error in the admission of other testimony was harmless; and (4) Defendant’s sentence did not violate the Eighth Amendment. View "United States v. Ford" on Justia Law

After a jury trial, Defendant was convicted of one count of manufacturing marijuana. Defendant was sentenced to twelve months and one day of imprisonment. Defendant appealed, raising several procedural challenges and arguing that there was insufficient evidence presented to prove that the marijuana found by the police belonged to him. The First Circuit affirmed, holding (1) the Government’s evidence was strong enough for a rational jury to conclude beyond a reasonable doubt that the marijuana at issue belonged to Defendant; (2) the district court did to err in denying Defendant’s suppression motion without an evidentiary hearing; (3) the Government did not violate Defendant’s right to a speedy trial; and (4) the trial court did not err in denying Defendants’ motions for mistrial. View "United States v. Apicelli" on Justia Law

In 2014, four residents of the City of Cranston, Rhode Island, and the American Civil Liberties Union of Rhode Island filed a complaint against the City under 42 U.S.C. 1983 for declaratory and injunctive relief, alleging that Cranston’s 2012 Redistricting Plan violated the Equal Protection Clause. The district court entered an injunction prohibiting Cranston from holding elections, concluding that the inclusion in the Redistricting Plan of 3,433 inmates of the Adult Correctional Institutions (ACI) in the population count of Cranston’s Ward Six diluted the votes of voters in the City’s other five wards. The First Circuit reversed and instructed the district court to enter summary judgment in favor of Cranston, holding that the United States Constitution does not require Cranston to exclude the ACI inmates from its apportionment process and gives no power to the federal courts to interfere with Cranston’s decision to include them. View "Davidson v. City of Cranston, R.I." on Justia Law

Defendant pleaded guilty to participating in a conspiracy to possess illegal drugs with intent to distribute and with using or carrying a firearm in furtherance of the conspiracy. Defendant was sentenced to thirty-three months’ imprisonment for the drug count and sixty consecutive months for the weapons count. Here Defendant sought to vacate his guilty plea and his sentence, raising two claims of error. The First Circuit affirmed, holding (1) Defendant’s plea on the weapons charge was both knowing and rooted in a factual basis; and (2) the district court did not err in calculating Defendant’s Guidelines sentencing range. View "United States v. Delgado-Lopez" on Justia Law

After a jury trial, Defendant was convicted of using a means of interstate commerce to entice a minor to engage in illegal sexual activity. Defendant was sentenced to ten years in prison to be followed by five years of supervised release. The First Circuit affirmed Defendant’s conviction and Defendant’s sentence, with the exception of two conditions of Defendant’s supervised release, holding (1) the evidence supported a finding that the government did not wrongly induce Defendant to engage in criminal conduct; (2) the district court did not err in its jury instruction on entrapment; (3) there was not prejudicial error in the court’s evidentiary rulings; but (4) two conditions of Defendant’s supervised release were either unreasonable or too broad and ambiguous. View "United States v. Hinkel" on Justia Law

After a jury trial, Defendant was convicted of conspiracy to commit bank fraud and conspiracy to pass counterfeit currency. Defendant appealed, alleging five purported evidentiary errors that he failed to raise below, two arguably preserved evidentiary challenges, and an unpreserved claim of prosecutorial misconduct. The First Circuit affirmed, holding (1) Defendant’s unpreserved evidentiary challenges did not rise to the level of plain error; (2) the remaining evidentiary rulings were not an abuse of the district court’s discretion; and (3) assuming that the prosecutor acted improperly, there was no plain error. View "United States v. Alcantara" on Justia Law

After a jury trial, Defendant was found guilty of one count of possession of child pornography. Defendant appealed, arguing that the district court committed reversible error when it declined to view a limited number of images and videos found on Defendant’s computers that Defendant had sought to exclude from evidence on the basis that the images were of minimally probative value because Defendant was willing to stipulate that his computers contained child pornography. The First Circuit affirmed, holding that the district court did not abuse its discretion under Fed. R. Crim. P. 403 when it declined to view the challenged evidence before admitting these materials for the purpose of demonstrating Defendant’s knowledge. View "United States v. Ross" on Justia Law

Defendant entered into a plea agreement pursuant to Fed. R. Crim. P. 11(c)(1)(C) (a “C-type plea agreement”), which binds the district court to a pre-agreed sentence if the court accepts the defendant’s plea. Under C-type plea agreements, a defendant is eligible for a sentence reduction based on a retroactive amendment to the United States Sentencing Guidelines only if the term of imprisonment in the agreement is “based on” a Guidelines sentencing range. In 2013, Defendant imposed the stipulated sentence of fifty-seven to seventy-one months’ imprisonment. In 2014, the United States Sentencing Commission retroactively reduced the base offense level for several drug offenses. Because many of his convictions were for controlled substance offenses, Defendant filed a motion to modify his sentence. The district court denied the motion. The First Circuit affirmed, holding that Defendant was not eligible for a sentencing reduction because his sentence was not “based on” a Guidelines sentencing range. View "United States v. Negron" on Justia Law

After a jury trial in the Commonwealth of Massachusetts, Petitioner was convicted of first-degree murder, armed home invasion, and unlawful possession of a firearm. The Supreme Judicial Court (SJC) reversed Petitioner’s conviction for armed home invasion and upheld the remaining conditions. Thereafter, Petitioner sought federal habeas corpus relief in a federal court, asserting three claims. The district court denied the petition. The First Circuit affirmed, holding (1) Defendant’s trial counsel did not provide constitutionally deficient representation; (2) Petitioner’s waiver of his right to testify was not invalid based on erroneous legal advice or Petitioner’s misunderstanding of counsel’s advice; and (3) the SJC did not act contrary to clearly established federal law when it imposed on Petitioner the obligation to show that his waiver was invalid. View "Smith v. Dickhaut" on Justia Law

After a jury trial, Defendant was convicted of possessing drugs with intent to distribute and possessing a firearm in furtherance of a drug trafficking crime. Defendant appealed his conviction and sentence, asserting that judicial misconduct, inadequate preparation time, and ineffective assistance of counsel denied him a fair proceeding. The First Circuit affirmed Defendant’s conviction but remanded the action for further proceedings, holding (1) the trial judge’s conduct of the trial did not prejudice Defendant; (2) the district court did not abuse its discretion in denying Defendant’s motion to continue the trial date; and (3) there were sufficient signs of attorney ineffectiveness to remand for an evidentiary hearing. View "United States v. Marquez-Perez" on Justia Law