Justia Criminal Law Opinion Summaries

Defendant pled guilty to one count of being a prohibited person in possession of a firearm. The district court sentenced Defendant to an upwardly variant sentence of seventy-two months’ imprisonment followed by a three-year term of supervised release. Defendant challenged his sentence on appeal. The First Circuit affirmed, holding (1) there was no plain error in the district court’s finding that at least one of Defendant’s prior convictions was for a “crime of violence,” and therefore, Defendant’s guidelines sentence range was properly calculated; (2) Defendant’s sentence was procedurally reasonable; and (3) Defendant’s sentence was substantively reasonable. View "United States v. Delgado-Sanchez" on Justia Law

Defendant was convicted of possession of heroin with intent to distribute and conspiracy to distribute heroin. The district court sentenced Defendant to a term of imprisonment of sixty-six months. Defendant appealed, raising several allegations of error. The First Circuit affirmed, holding (1) the district court did not err in its pretrial rulings; (2) the district court did not err in its rulings made during trial; and (3) Defendant’s challenge to his sentence failed because the district court’s findings justified its determination that Defendant was responsible for conspiring to distribute between 400 and 700 grams of heroin. View "United States v. Arias" on Justia Law

Defendant pled guilty to participating in a conspiracy to defraud the federal government. Defendant appealed, arguing that the district court erred in denying his motion to dismiss the indictment with prejudice based on violations of the Speedy Trial Act, the Speedy Trial Clause of the Sixth Amendment, and the Due Process Clause of the Fifth Amendment. The First Circuit vacated the district court’s decision on Defendant’s Sixth Amendment claim and remanded for reconsideration of that claim, holding that the district court was led astray by dicta in one of this Court’s prior opinions in calculating the length of delay relevant to evaluating the alleged Sixth Amendment violation. View "United States v. Irizarry-Colon" on Justia Law

After a jury trial, Defendant was convicted of conspiracy to rob a postal worker, assault on a federal employee, and related offenses. The sentencing judge sentenced Defendant to 235 months in prison, plus ten years. Defendant appealed, raising several allegations of error. The First Circuit affirmed Defendant’s conviction but remanded the case to the district court for reconsideration of Defendant’s sentence at a new sentencing hearing, holding (1) the district court applied an erroneously-inflated Guidelines range, which compromised the fairness and integrity of Defendant’s sentencing; and (2) the remainder of Defendant’s arguments on appeal were unavailing. View "United States v. Taylor" on Justia Law

Defendant pled guilty to being a felon in possession of a firearm. Defendant’s plea agreement recommended a total offense level under the U.S. Sentencing guidelines of seventeen. Defendant objected to the recommended total offense level, arguing that it should instead be twelve under the Guidelines. Relying on an untranslated Spanish document, the district court concluded that Defendant’s total offense level was seventeen. The district court proceeded to sentence Defendant to forty-six months’ imprisonment even though the Guidelines’ recommended sentence was twenty-seven to thirty-three months in prison. The First Circuit vacated Defendant’s sentence and remanded for resentencing, holding that the district court erred in relying on an untranslated document in calculating Defendant’s offense level. View "United States v. Roman-Huertas" on Justia Law

After a jury trial, Defendant was convicted of conspiracy, willful violation of the Investment Advisers Act, wire fraud, and corruptly impeding the administration of internal revenue laws. Defendant was sentenced to eighty-four months in prison, a below-guidelines sentence. Defendant appealed, arguing that the trial court’s reasonable doubt instructions were deficient and claiming sentencing error. The First Circuit affirmed Defendant’s convictions and sentence, holding (1) Defendant’s claims of instructional error ultimately failed; and (2) the district court’s decision refusing to grant a downward departure on two alternative bases was reasonable. View "United States v. Herman" on Justia Law

After a jury trial, Defendant was convicted of possession of crack cocaine with intent to distribute. The First Circuit affirmed, holding (1) Defendant waived any argument regarding the district court’s denial of his motion to suppress text messages that the police obtained from Defendant’s cell phone pursuant to a search warrant; (2) the district court did not err in admitting evidence of Defendant’s prior drug conviction; (3) the district court did not err in allowing a police officer to provide expert testimony; and (4) the district court did not err in failing to instruct the jury on the lesser included offense of simple possession. View "United States v. Henry" on Justia Law

Defendant pled guilty to possession of child pornography and was sentenced to seventy-eight months’ imprisonment and ten years of supervised release. Defendant appealed, arguing that the district court erred in denying his motion to suppress because the search and seizure of computers and other items from his apartment violated the Fourth Amendment. The First Circuit affirmed, holding that the district court did not err in finding (1) FBI agents did not violate the curtilage of Defendant’s home; (2) Defendant consented to the search, and the FBI agents did not exceed the scope of that consent; and (3) the temporary seizure of Defendant’s apartment did not violate the Fourth Amendment. View "United States v. Perez-Diaz" on Justia Law

Defendant was convicted of conspiring to possess cocaine with the intent to distribute and aiding and abetting others to posses cocaine with the intent to distribute. Defendant appealed, arguing that he was entitled to a new trial of the prosecutor’s improper questioning that compelled him to comment on the veracity of two cooperating government witnesses, a problem that was compounded by improper judicial intervention in support of the prosecutor’s questions. The First Circuit vacated Defendant’s conviction and remanded for a new trial, holding that the government’s questions were extensive and improper, and the preserved errors were not harmless. View "United States v. Pereira" on Justia Law

Defendant, a police officer acting under color of state law, took Plaintiff into protective custody, handcuffed him, transported him to a police station, and jailed him after attempting to evaluate whether Defendant was incapacitated by his consumption of alcohol. Plaintiff sued in federal district court, arguing that Defendant lacked probable cause to take him into protective custody. The district court granted Defendant’s motion for summary judgment on qualified immunity grounds, concluding that the law was not clearly established as to the need for probable cause. The First Circuit vacated the entry of summary judgment and remanded for further proceedings, holding (1) the state of preexisting law established that a reasonable officer must have probable cause to take an individual into protective custody, handcuff him, transport him to a police station, and confine him in a jail cell; (2) an objectively reasonable officer in this case would not have had adequate reason to believe that Plaintiff, though intoxicated, was incapacitated; and (3) therefore, the qualified immunity defense was not available to Plaintiff. View "Alfano v. Lynch" on Justia Law