Justia Criminal Law Opinion Summaries

Defendant was convicted in a federal court of being a felon in possession of a firearm and criminal contempt. Only a few years after his supervised release started, Defendant was arrested for theft and admitted to violating the terms of his release. Once out on release a second time, Defendant used drugs and engaged in conduct leading to his arrest. Defendant was subsequently charged with aggravated assault under Maine law. The government filed petitions to revoke Defendant’s supervised release on grounds of use of narcotics and violation of state law. The district court ordered revocation, finding that Defendant had violated the Maine aggravated assault statute. The court sentenced Defendant to thirty months’ imprisonment after classifying criminal contempt as a Class A felony, which carries a maximum sixty-month term of imprisonment. The First Circuit affirmed, holding (1) the district court did not err in determining that Defendant violated state law; and (2) the district court properly classified Defendant’s underlying conviction for criminal contempt as a Class A felony, rather than a Class C felony. View "United States v. Wright" on Justia Law

Defendant pleaded guilty to conspiracy to two counts of conspiracy to possess and aiding and abetting the possession of cocaine on a vessel subject to the jurisdiction of the United States, in violation of Maritime Drug Law Enforcement Act (MDLEA), and one count of aiding and abetting a failure to heave. On appeal, Defendant challenged only his MDLEA convictions, arguing that Congress exceeded the scope of its Article I powers in enacting that statute, and therefore, his MDLEA convictions must be reversed. The First Circuit affirmed Defendant’s convictions, holding that Defendant waived his right to assert his argument when he pled guilty. View "United States v. Diaz-Doncel" on Justia Law

Defendant pleaded guilty to illegal possession of a machine gun. The presentence report calculated Defendant’s Guidelines range as twenty-seven to thirty-three months’ imprisonment. After a sentencing hearing, the district court sentenced Defendant to sixty months’ imprisonment. Defendant appealed, arguing that his sentence was both procedurally and substantively unreasonable. The First Circuit affirmed, holding that, given the nature of Defendant’s offense in combination with his personal characteristics and his near-immediate recidivism for a similar offense, Defendant’s sixty-month sentence was within the range of reasonable sentences the district court could impose. View "United States v. Vazquez-Martinez" on Justia Law

Defendant was convicted of possession with intent to distribute cocaine base. Prior to trial, Defendant moved unsuccessfully to suppress evidence found in the car in which Defendant was riding before he was arrested. After Defendant pleaded guilty, the district court sentenced Defendant as a career offender, imposing a below-guidelines sentence of 200 months. The First Circuit affirmed, holding (1) the district court did not err in denying Defendant’s suppression motion, as Defendant did not failed to show he had an expectation of privacy in the evidence; and (2) the district court did not err when it sentenced Defendant as a career offender, as Defendant’s prior conviction for criminal threatening with a dangerous weapon qualified as a crime of violence under the sentencing guidelines. View "United States v. Collins" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to illegally possessing a firearm and ammunition. The district judge sentenced Defendant to 108 months’ imprisonment, determining that Defendant should be sentenced as a Career Offender because he committed a “crime of violence” as defined by the United States Sentencing Guidelines. Defendant appealed, arguing that the district court erred in treating him as a Career Offender. The First Circuit vacated Defendant’s sentence and remanded the matter to the district court for resentencing, holding that Defendant’s crime of conviction does not fall within the Guidelines’ definition of “crime of violence,” and therefore, Defendant may not be sentenced as a Career Offender. View "United States v. Soto-Rivera" on Justia Law

After a jury trial, Defendant was convicted of aiding and abetting a convicted felon in possession of a firearm. Defendant appealed, arguing that the district court erred in denying his motion for acquittal. Specifically, Defendant contended that the evidence was insufficient to support his conviction in light of the advance knowledge requirement articulated in Rosemond v. United States. The First Circuit affirmed, holding (1) the evidence was sufficient to support Defendant’s conviction under Rosemond; and (2) Defendant’s argument that the jury instructions did not sufficiently instruct as to the knowledge requirement under Rosemond was waived for lack of development. View "United States v. Manso-Cepeda" on Justia Law

After a jury trial, Defendant was convicted of mail fraud. At the sentencing hearing, the district court ordered Defendant to pay restitution to his victims in an amount of over $2 million. Defendant appealed, challenging both his conviction and the amount of restitution awarded. The First Circuit affirmed, holding (1) the government properly alleged a single scheme, and its proof at trial did not unfairly vary from what was alleged; (2) the evidence was sufficient to support the conviction; (3) there were no other errors made during, or shortly after the close of, Defendant’s trial; and (4) Defendant’s waived his challenge to the restitution award. View "United States v. Prieto" on Justia Law

After a jury trial in a Massachusetts court, Appellant was convicted of murder in the first degree and other crimes. On appeal to the Massachusetts Supreme Judicial Court (SJC), Appellant, who is African-American, argued that the superior court erred by allowing the prosecutor’s peremptory challenge of juror No. 10-10, an African-American woman. The SJC ruled that the superior court did not abuse its discretion in allowing the peremptory challenge to Juror No. 10-10 because defense counsel did not object to the argument that three African-American jurors had already been seated. Thereafter, Appellant filed a petition for a writ of habeas corpus under 28 U.S.C. 2254, arguing that his state court convictions constituted an unreasonable application of federal law in Batson v. Kentucky. The district court denied the petition. The First Circuit affirmed, holding that the SJC reasonably concluded that the trial judge found that Appellant had not met his burden to make out a prima facie case of discrimination. View "Scott v. Gelb" on Justia Law

After a jury trial, Defendant was convicted of six counts of aiding and abetting the making of material false statements in connection with the acquisition of firearms. Following a sentencing hearing, the district court varied upward and imposed a thirty-six-month term of immurement. Defendant appealed, raising claims of both trial and sentencing error. The First Circuit affirmed, holding (1) the prosecutor’s statements during closing argument during trial did not misstate the evidence, comprise an improper comment on Defendant’s failure to testify, or improperly shift the burden of proof; and and (2) the district court did not abuse its discretion in imposing a variant sentence above the guideline sentencing range. View "United States v. Madsen" on Justia Law

Pursuant to a plea agreement, Defendant pled guilty to conspiracy to distribute a controlled substance and aiding and abetting possession of a firearm in furtherance of a drug crime. The parties agreed to a total recommended sentence of sixty to seventy-two months’ imprisonment. After a sentencing hearing, the district court imposed a total sentence of 366 months’ imprisonment. Defendant appealed, arguing, inter alia, that the sentence was substantively unreasonable due to its length. The First Circuit vacated Defendant’s sentence and remanded, holding that because the varied upward from the guidelines range by such a great extent and the district court failed to prove an adequate explanation for the sentence, the district court’s imposition of the sentence was obvious error. View "United States v. Rivera-Gonzalez" on Justia Law