Justia Criminal Law Opinion Summaries

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

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