Justia Criminal Law Opinion Summaries

Defendants - Rivera-Ruperto, Salinas-Acevedo, and Santiago-Cardero - were found guilty of various federal drug and firearms-related crimes. Each was sentenced to multiple years of imprisonment. For Rivera-Ruperto, this was the second of two trials. The First Circuit separately addressed Rivera-Ruperto’s challenges from the first trial in a decision also released today. Here the First Circuit addressed all three defendants’ appeals as to the second trial. The First Circuit affirmed, holding (1) each of Rivera-Ruperto’s challenges failed in this second appeal; (2) the district court did not err in preventing Salinas-Acevedo from presenting an entrapment defense at trial; and (3) as to Santiago-Cordero, the judge did not err in refusing to give an entrapment jury instruction and in denying his post-verdict motion for acquittal. View "United States v. Rivera-Ruperto" on Justia Law

After two trials, Appellant was found guilty of various federal drug and firearms-related crimes for his participation in six “Operation Guard Shack” drug deals orchestrated by the FBI. Each trial was presided over by a different district judge. Thus, there were two cases on appeal. In this present appeal from the first trial, Appellant argued that the district court committed several reversible errors. The First Circuit affirmed, holding that the district court (1) did not err when it denied Appellant’s claim for ineffective assistance of counsel during the plea-bargaining stage; (2) did not commit obvious error in failing to instruct the jury that it was required to find drug quantity beyond a reasonable doubt; (3) did not clearly err in denying Appellant’s sentencing manipulation claim; and (4) did not sentence Appellant to a grossly disproportionate sentence in violation of the Eighth Amendment. View "United States v. Rivera-Ruperto" on Justia Law

Defendant pled guilty to being a felon in possession of a firearm. Prior to the sentencing hearing, the government submitted a motion requesting that the district court apply the sentencing enhancement for trafficking in firearms under section 2K2.1(b)(5) of the United States Sentencing Guidelines. The district court found that the sentencing enhancement applied and sentenced Defendant to a term of imprisonment of seventy-one months. Defendant appealed the trafficking enhancement. The First Circuit affirmed, holding that the district court did not plainly err in finding that the trafficking enhancement applied. View "United States v. Taylor" on Justia Law

After a jury trial, Appellant was found guilty of one count of conspiracy to possess with intent to distribute cocaine base and three specific-offense counts of distribution of that controlled substance. Appellant was sentenced to an eighteen-year term of immurement to be followed by a five-year term of supervised release. After Appellant began serving his supervised release term, he was charged in a Massachusetts state court with attempted murder and assault with a dangerous weapon. A federal district court subsequently found that Appellant had violated the conditions of his supervised release and sentenced Appellant to a four-year incarcerate term. The First Circuit affirmed, holding (1) Appellant’s challenges to the evidentiary rulings made in the course of the revocation of his supervised release were unavailing; and (2) Appellant’s claim of sentencing error was baseless. View "United States v. Fontanez" on Justia Law

Appellant pled guilty to one count of committing a Hobbs Act robbery. The court sentenced Appellant to a prison term of 120 months. Appellant appealed, arguing that his sentence was procedurally unreasonable - because the court relied on clearly erroneous facts - and substantively unreasonable. The First Circuit vacated the sentence and remanded for resentencing, holding that the district court committed clear error when it insisted without factual support that Appellant was more culpable for the commission of the robbery than his co-defendants, and therefore, the sentence was procedurally unreasonable because it was premised on factual findings that were not supported by any evidence in the record. View "United States v. Cotto-Negron" on Justia Law

Defendant pleaded guilty to robbery of a controlled substance from a pharmacy by use of a dangerous weapon. After conducting a sentencing hearing, the district court sentenced Defendant to 120 months’ imprisonment. Defendant appealed, arguing that his sentence was both procedurally and substantively unreasonable. The First Circuit affirmed, holding (1) the district court did not err in applying a two-level enhancement, the basis of which was a finding of obstruction of justice; (2) the district court provided sufficient support for finding that Defendant failed to establish that this was a case where an acceptance of responsibility reduction should be granted to a defendant who has obstructed the government’s efforts to prosecute him; and (3) the sentencing court gave the evidence of Defendant’s drug addiction the weight and effect that Defendant claimed it warranted; and (4) the duration of Defendant’s sentence was not substantively unreasonable. View "United States v. Stile" on Justia Law

Erasmo Rodriguez-Vazquez (Rodriguez) successfully worked to obtain the reversal of several wrongfully convicted individuals. Those individuals and/or their heirs or assigns brought two suits, consolidated into this case, against the police officers and prosecutors who were involved in their prosecutions. The parties reached a settlement. The district court issued a report that the parties and the district court have treated as a gag order barring the parties from disclosing the terms and conditions of the settlement. Rodriguez subsequently made statements about the settlement to the press. The district court held Rodriguez in contempt and referred him to the Commonwealth of Puerto Rico’s Supreme Judicial Court for disciplinary review. The First Circuit reversed the district court’s decision and vacated the contempt and sanctions order, holding that the district court’s contempt finding and sanction were based on clearly erroneous findings of fact because Rodriguez did not violate what the parties all treat as a confidentiality order issued by the district court. View "Rodriguez-Vazquez v. Solivan Solivan" on Justia Law

In 2010, Petitioner pleaded guilty to several charges in connection with a drug-trafficking enterprise. The district court sentenced Petitioner to a ten-year term of immurement. Thereafter, Petitioner moved to correct the sentence. The district court denied the motion, ruling that the charges to which Petitioner had pleaded guilty barred him from receiving a shorter sentence. In 2012, Petitioner filed a pro se motion to vacate, set aside, or correct his sentence pursuant to 28 U.S.C. 2255 on the basis of ineffective assistance of counsel. The magistrate judge set an evidentiary hearing limited to Petitioner’s claim that his then-attorney never told him about a nine-year plea offer. During the hearing, the magistrate judge heard conflicting testimony. The judge found the attorney’s version of events to be generally “consistent and credible” and, based on these findings, denied the section 2255 motion. The First Circuit affirmed, holding that the magistrate judge’s determination was not clearly erroneous. View "Rivera-Rivera v. United States" on Justia Law

In the 1945 case Crespo v. United States, the First Circuit held that 18 U.S.C. 2421(a), which prohibits transportation of an individual “in interstate or foreign commerce, or in any Territory or Possession of the United States” for purposes of prostitution or other unlawful sexual activity, applies to transportation that occurs solely within Puerto Rico. Since that case was decided, Puerto Rico has transformed from a United States territory to a self-governing Commonwealth. Defendant, who transported a woman within Puerto Rico with the intent to engage in sexual activity that was criminal under Puerto Rico law, dismissed the indictment against him, arguing that transportation occurring solely within Puerto Rico no longer violates section 2421(a). The district court agreed with Defendant and dismissed the indictment. The First Circuit affirmed the dismissal of the indictment, holding that section 2421(a) does not extend to illicit transportation that occurs solely within Puerto Rico and instead reaches only transportation “in interstate or foreign commerce” with respect to the island. View "United States v. Maldonado-Burgos" on Justia Law

After a jury trial, Defendant was convicted of making false statements in a passport application, aggravated identity theft, and use of a falsely-obtained Social Security account number to obtain benefits. The district court sentenced Defendant to an aggregated sentence of thirty-six months of imprisonment. Defendant appealed, challenging his sentence. The First Circuit affirmed, holding (1) the district court properly applied the four-level enhancement as to the making false statements in a passport application count; and (2) Defendant’s argument challenging his conviction for aggravated identity theft is foreclosed by binding circuit precedent. View "United States v. Nolte" on Justia Law