Justia Criminal Law Opinion Summaries

After a bench trial, Defendant was convicted of thirteen counts of child pornography. The First Circuit vacated Defendant’s conviction on six of those counts and remanded. Defendant subsequently fled the state of Maine in violation of a court order. When he was apprehended, Defendant pled guilty to one count of criminal contempt. The district court sentenced Defendant to 165 months’ imprisonment for the seven remaining child-pornography counts and twenty-four months for the contempt charge. Defendant appealed from his sentence for the child-pornography counts. The First Circuit affirmed, holding that the sentence was both procedurally and substantively reasonable. View "United States v. Cameron" on Justia Law

Defendant entered a conditional guilty plea to conspiracy to distribute and possess with intent to distribute twenty-eight grams or more of cocaine base and possession of a firearm in furtherance of a drug trafficking crime. Defendant appealed, arguing that the district court erred in denying his motion to suppress evidence obtained by law enforcement officers while executing a warrant for his arrest. The First Circuit agreed with Defendant and reversed the denial of his motion to suppress, holding that the officers had insufficient grounds to justify entering Defendant’s girlfriend’s apartment without consent to execute the arrest warrant. Remanded. View "United States v. Young" on Justia Law

After a jury trial, Appellant, a citizen of the Dominican Republic who entered the United States illegally, was found guilty of theft of public money, use of a falsely obtained social security number to obtain benefits, and aggravated identity theft. The First Circuit affirmed on direct appeal, holding (1) the district court did not err in rejecting Appellant’s attempts to suppress evidence; (2) the evidence was sufficient to convict Appellant of theft of public funds and aggravated identity theft; and (3) the district court did not abuse its discretion in instructing the jury. View "United States v. De La Cruz" on Justia Law

After a jury trial, Defendant was convicted of one count of possession of cocaine with intent to distribute. The district court sentenced Defendant to a term of imprisonment of forty-one months. The First Circuit affirmed, holding (1) the district court did not err in denying Defendant’s pre-trial motion to suppress evidence obtained upon the seizure of the car Defendant was driving; (2) the district court did not abuse its discretion in permitting the prosecution to use in its rebuttal a piece of evidence that the government delayed in disclosing, and the government did not act in bad faith in disclosing the evidence when it did; (3) the prosecutor did not commit plain error by questioning Defendant about facts not in evidence; and (4) Defendant’s challenges to his sentence were without merit. View "United States v. Mercer" on Justia Law

Defendant pleaded guilty to three counts of distributing cocaine, one count of possession with intent to distribute cocaine, and one count of felon in possession of a firearm. The district court sentenced Defendant to a term of imprisonment of seventy months and to a term of supervised release of three years to run concurrently on all counts. Defendant appealed, challenging both his conviction and his sentence. The First Circuit affirmed, holding (1) the district court did not err in denying Defendant’s request for a Franks hearing; and (2) any error in the district court’s calculation of Defendant’s criminal history was harmless. View "United States v. Magee" on Justia Law

After a joint jury trial, Alexis Candelario-Santana (Candelario) and David Oquendo-Rivas (Oquendo) (together, Defendants) were found guilty of numerous crimes stemming from a drug-related mass shooting carried out in furtherance of a Racketeer Influenced and Corrupt Organizations Act. Both defendants received life sentences. The First Circuit affirmed Oquendo’s convictions but vacated and remanded as to Candelario, holding (1) the district court’s closure of the courtroom to facilitate a reluctant witness’s testimony constituted a constitutionally impermissible closure, effecting structural error; (2) there was no prejudicial error related to Oquendo’s case; and (3) the evidence was sufficient to support Oquendo’s convictions. View "United States v. Candelario-Santana" on Justia Law

Defendant was convicted in Massachusetts state court of rape and indecent assault and battery on a person over fourteen years of age. After his release from prison, Defendant was arrested for failing to register. Defendant pleaded guilty to failure to register as a sex offender under the Sex Offender Registration and Notification Act. The district court imposed a sentence of eighteen months’ imprisonment, a five-year period of supervised release, and a number of conditions of supervised release. Defendant appealed, challenging three of the conditions of his supervised release. The First Circuit (1) vacated the condition restricting Defendant’s right to associate with children, holding that Defendant met the plain error standard; and (2) affirmed the remaining conditions challenged on appeal. View "United States v. Fey" on Justia Law

Defendant, a school aide for special-needs students, pled guilty to the sexual exploitation of three minors, as well as the transportation, receipt, and possession of child pornography. After a hearing, the judge imposed a below-Guidelines sentence of 780 months - or sixty-five years - in prison. Appellant challenged his sentence on appeal, arguing that the judge erred in applying enhancements in his Guidelines calculation, that the judge failed to adequately explain how the sentence did not violate the parsimony principle, and that the sentence violated the parsimony principle. The First Circuit affirmed, holding that there was no abuse of discretion in the sentencing judge’s determination and that the sentence was neither procedurally nor substantively unreasonable. View "United States v. Arsenault" on Justia Law

Appellant pled guilty to conspiracy to possess with intent to distribute and possession of a firearm in furtherance of a drug trafficking crime. The government filed a complaint for forfeiture in rem against jewelry seized while executing a search warrant on Appellant’s apartment, alleging that the jewelry was subject to civil forfeiture because it was linked to Appellant’s illegal drug activity. The district court granted summary judgment for the government and ordered the jewelry forfeited. The First Circuit vacated the judgment of the district court, holding that the government failed to establish, by a preponderance of the evidence, a link between the jewelry and Appellant’s drug activities. View "United States v. Betancourt-Perez" on Justia Law

Appellant was indicted in three separate criminal cases for his involvement in various drug-related crimes. The parties eventually negotiated a plea deal that resolved the three criminal cases. The plea agreement memorialized a joint sentencing recommendation and contained a provision in which Appellant waived his right to appeal. After he was sentenced, Appellant appealed, arguing that the district court should have accepted the plea agreement’s guideline calculations. The First Circuit dismissed the appeal, holding Appellant’s appeal was barred by the appeal waiver, that the agreement’s sentence recommendation provision was not ambiguous, and that there was no breach of the plea agreement. View "United States v. Betancourt-Perez" on Justia Law