Justia Criminal Law Opinion Summaries

After a trial in 2003, Petitioner was convicted of rape in a Massachusetts state court. The Supreme Judicial Court (SJC) affirmed. In 2008, Petitioner sought a new trial claiming that his counsel on appeal had been ineffective for failing to argue that Petitioner’s speedy-trial rights had been violated. The superior court denied the motion, and the SJC affirmed. In 2013, Petitioner filed a petition for habeas corpus in federal district court, claiming that his Sixth Amendment rights to a speedy trial and effective assistance of counsel were violated during his trial. The district court denied the petition. The First Circuit affirmed, holding the SJC’s conclusion that Petitioner’s constitutional speedy-trial rights had not been violated and that Petitioner had not received ineffective assistance of counsel did not violate the standards of the Antiterrorism and Effective Death Penalty Act. View "Butler v. Mitchell" on Justia Law

Defendant, an employee with the Massachusetts Registry of Motor Vehicles (RMV), was convicted of two counts of mail fraud and one count of conspiracy to interfere with interstate commerce by threats or violence. The convictions arose from a scheme to sell RMV licenses to automotive service station owners in order to perform state-mandated vehicle inspections. The First Circuit affirmed Defendant’s convictions, holding (1) the evidence was sufficient to support the convictions; (2) the district court did not err by denying Defendant’s motion for a new trial; and (3) because there was no error in the district court’s rulings, Defendant’s argument that his convictions must be vacated pursuant to the doctrine of cumulative error cannot succeed. View "United States v. Gaw" on Justia Law

After a jury trial, fugitive James “Whitey” Bulger, the former head of an organized crime syndicate in Boston, was found guilty of racketeering, the murder of eleven individuals, multiple instances of extortion and money laundering, and narcotics distribution and conspiracy. Bulger was sentenced to life in prison. Bulger appealed, alleging that he was deprived of his right to a fair trial when the trial court and the government erred in various ways both prior to and during trial. The First Circuit affirmed, holding that Bulger received a fair trial and that none of the court’s or government’s alleged errors warranted reversal of Bulger’s conviction. View "United States v. Bulger" on Justia Law

After a jury trial, Defendant was convicted of being a felon in possession of a firearm. The district court sentenced Defendant to seventy-four months of imprisonment. Defendant appealed, challenging primarily the denial of his pretrial motion to bar a government witness from identifying him at trial. The Supreme Court affirmed the conviction but vacated the sentence, holding (1) the admission of the identification evidence did not violate Defendant’s due process rights, as the existence of the video recording of the witness’s pretrial identification of Defendant in a photo array guarded against the harm that the district court might have otherwise guarded against by excluding the identification; (2) the record is not fully developed to establish Defendant’s claim of ineffective assistance in relation to sentencing, and so Defendant’s sentence must vacated to allow consideration of the Stickland v. Washington issue on remand; and (3) there was no merit to Defendant’s remaining claims. View "United States v. Constant" on Justia Law

Appellant pleaded guilty to one count of possession of child pornography. Appellant was sentenced to ten years’ imprisonment followed by fifteen years of supervised release. The terms of Appellant’s supervised release included multiple conditions. Appellant did not object to any of these conditions at the sentencing hearing. Appellant appealed, arguing that the waiver of appeal provision in his plea agreement did not cover an appellate challenge to his supervised release conditions, and challenging four categories of his supervised release conditions. The First Circuit vacated one condition and affirmed the rest, holding (1) this appeal falls within the scope of Appellant’s waiver, and the waiver is valid; and (2) the condition that subjects Appellant to penile plethysmograph testing is plain error, but the remainder of the conditions challenged on appeal are affirmed. Remanded. View "United States v. Velez-Luciano" on Justia Law

Defendant pleaded guilty to conspiracy to import a hundred grams or more of heroin. At the time, Defendant had pending criminal charges in the Northern District of Georgia. The district court in Puerto Rico sentenced Defendant to 120 months of imprisonment, to be served consecutively to the anticipated Northern District of Georgia sentence. Defendant filed a motion for reconsideration seeking to eliminate the portion of the sentence ordering his term of imprisonment to be consecutive to the sentence in the pending case. The district court denied the motion. Defendant appealed. Defendant subsequently pleaded guilty in the North District of Georgia to one count of conspiracy to commit money laundering. The North District of Georgia sentenced Defendant to eighty-seven months of imprisonment to be served concurrently with the sentence at issue in this case. The First Circuit reversed, holding that, under 18 U.S.C. 3584(a), a federal sentencing court does not have the authority to determine that a sentence should be consecutive to a federal sentence that has not yet been imposed. Remanded for resentencing. View "United States v. Almonte-Reyes" on Justia Law

Defendant was indicted for failure to register as a sex offender. Defendant filed a motion to dismiss the indictment, claiming that Sex Offender Registration and Notification Act was unconstitutional (the SORNA motion). No hearing was requested on the motion, and none was held until after Defendant had filed a second dismissal motion in which he asserted a violation of the Speedy Trial Act (the STA motion). After a hearing, the district court denied both the SORNA motion and the STA motion. Defendant pleaded guilty, reserving his right to appeal the denials of both motions. The First Circuit (1) summarily affirmed the district court’s rejection of the constitutional challenges to SORNA; (2) held that the district court did not abuse its discretion in determining that a hearing on the SORNA motion was required; and (3) affirmed the dismissal of Defendant’s STA motion. View "United States v. Ibrahim" on Justia Law

Defendant was arrested for driving under the influence. Shortly after he was brought by Puerto Rico Police Department officers to the police station, he died in a holding cell. Defendant’s family members and estate filed suit, alleging that Defendants - Officer Perez, Sergeant Rodriguez, and Superintendent Toledo - used excessive force against Defendant and denied him needed medical care in violation of 42 U.S.C. 1983. The district court granted summary judgment in favor of Defendants on the grounds of sovereign immunity and insufficient evidence. Plaintiffs appealed, challenging only the district court’s decisions on the excessive force and denial of medical care claims and supervisory liability. The First Circuit (1) reversed and remanded for trial Plaintiffs’ claims against Perez and Rodriguez, holding (i) Perez and Rodriguez were not entitled to qualified immunity on the excessive force claim or the denial of medical care claim; and (2) affirmed the district court’s grant of summary judgment on Plaintiffs’ claims against Toledo, holding that Plaintiffs did not adequately plead facts going to Toledo’s liability. View "Miranda-Rivera v. Toledo-Davila" on Justia Law

After a jury trial, Defendant was convicted of smuggling narwhal tusks into the United States, conspiracy to illegally import narwhal tusks into the United States, money laundering, and conspiracy to commit money laundering. On appeal, Defendant argued that the district court erred (1) by allowing, then failing to cure, a series of comments and questions by the prosecutor, which Defendant alleged unconstitutionally drew the jury’s attention to his decision not to testify; and (2) in admitting records of vehicular border crossings between the United States and Canada, which the government used to establish that the illegally imported tusks had originated in Canada. The First Circuit affirmed, holding (1) the government’s comments and questions either constituted harmless error or did not result in plain error; and (2) the district court properly admitted the vehicular border crossings reports pursuant to Fed. R. Evid. 803(8) as admissible, non-adversarial public records. View "United States v. Zarauskas" on Justia Law

After a jury trial, Defendant was found guilty of two counts of possession with intent to distribute a controlled substance within one thousand feet of a school and one count of conspiracy to do the same. Defendant later filed a 28 U.S.C. 2255 petition for post-conviction relief, arguing that his trial counsel provided ineffective assistance at sentencing. The district court denied the petition. The First Circuit affirmed, holding that Defendant failed to established that his counsel’s failure to challenge the quantity determination in the presentence report resulted from an unreasonably deficient judgment. View "Vargas-De Jesus v. United States" on Justia Law