Justia Criminal Law Opinion Summaries

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

Defendant pleaded guilty in federal court to a single count of wire fraud. A judge sentenced Defendant to a term of imprisonment, thirty-six months of supervised release, and restitution. After Defendant was released from custody, probation asked the court to revoke his supervised release for violating the conditions of his probation. After a hearing, the judge found that Defendant had violated the conditions of his probation by committing two new crimes and tampering with electronic-monitoring equipment probation installed in his house. The judge then revoked Defendant’s supervised release and sentenced him to twelve months in prison followed by two years of supervised release. The First Circuit affirmed the judgment in all respects, holding that the district court did not err in its judgment. View "United States v. Marino" on Justia Law

Pursuant to a plea agreement, Defendant pled guilty to carjacking and possessing a firearm. After a sentencing hearing, the judge imposed a within-guidelines prison sentence of seventy months for the carjacking crime and a consecutive prison sentence of eighty-four months for the firearm crime. Defendant appealed, challenging his sentence. The First Circuit affirmed Defendant sentence on the carjacking count, vacated his sentence on the firearm count, and remanded for resentencing, holding (1) there was no procedural error in Defendant’s carjacking sentence; and (2) because Defendant pled guilty to possessing a firearm rather than brandishing a firearm, the judge plainly erred in sentencing Defendant for brandishing a firearm. View "United States v. Garay-Sierra" on Justia Law

Petitioner pleaded guilty to two counts of carjacking resulting in death. The jury sentenced Petitioner to death under the Federal Death Penalty Act (FDPA). Due to jury taint, Petitioner’s sentence was vacated and his case remanded for further proceedings. The government subsequently filed an amended notice of intent to seek the death penalty, as required by the FDPA. The amended notice listed the factors that the government believed justified the death penalty, largely tracking the original notice. Petitioner filed a motion in limine to dismiss or strike two non-statutory aggravating factors the prosecutor intended to present in a second penalty-phase proceeding under the FDPA. The district court denied the motion. Petitioner appealed, arguing that because the jury in his first penalty-phase proceeding did not find unanimously that the government proved these two aggravating factors beyond a reasonable doubt, their introduction at the new penalty-phase proceeding was barred by double jeopardy principles. The First Circuit affirmed, holding that the Double Jeopardy Clause did not bar the government from alleging those non-statutory aggravating factors again at Petitioner’s new penalty-phase proceeding. View "Sampson v. United States" on Justia Law

Pursuant to a non-binding plea agreement, Appellant pled guilty to knowingly possessing a firearm and ammunition after having been convicted of a felony. The presentence investigation report resulted in a guidelines sentencing range of thirty to thirty-seven months. Despite the parties’ joint recommendation for a mid-range guideline sentence, the court varied upward and imposed a term of sixty months of incarceration, to be followed by a three-year term of supervised release. The First Circuit affirmed, holding (1) Appellant’s sentence was not substantively unreasonable; and (2) the district court did not plainly err err in attaching a financial disclosure condition to Appellant’s supervised release term. View "United States v. Colon-de Jesus" on Justia Law