Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was convicted of conspiring to possess and aiding and abetting to possess with intent to distribute five kilos or more of cocaine. Defendant was sentenced to 240 months in prison and ten years of supervised release. Defendant appealed, arguing that the government failed to present sufficient evidence that Defendant knowingly joined a conspiracy or knowingly aided and abetted other individuals in committing a crime. The First Circuit affirmed, holding that there was sufficient evidence in the record to allow a rational factfinder to conclude beyond a reasonable doubt that Defendant committed the charged crime. View "United States v. Maymi-Maysonet" on Justia Law

Defendant was convicted of possession of child pornography. Defendant appealed, arguing that the district court erred in refusing to suppress evidence that had been gathered in a police search of his home and computer. The search was conducted pursuant to a warrant issued by a magistrate, who found probable cause based on the affidavit of a state trooper that relied on information obtained from an informant. The First Circuit withheld and final ruling on the denial of the motion to suppress and remanded the case for further findings, holding that the district court erred in ruling as a matter of law that a police officer affiant never has a duty to make further inquiry into the credibility of an informant before presenting to a magistrate a warrant application. After conducting further proceedings on remand, the district court made additional findings and again denied Defendant’s motion to suppress, concluding that the warrant affidavit established probable cause. The First Circuit affirmed, holding that the showing of probable cause was not vitiated when the district court further reformed the trooper’s affidavit. View "United States v. Tanguay" on Justia Law

After a jury trial, Defendant was convicted of the first-degree murder of his wife. The Massachusetts Supreme Judicial Court (SJC) affirmed. Thereafter, Defendant filed a petition for a writ of habeas corpus in federal district court, alleging that the evidence was insufficient to support the conviction and that the admission of statements that the victim made to her father violated Defendant’s rights under the Confrontation Clause. The district court denied the petition. The First Circuit affirmed, holding that Defendant did not prove that the SJC acted “contrary to” or unreasonably applied “clearly established Federal law” under the Antiterrorism and Effective Death Penalty Act. View "Linton v. Saba" on Justia Law

Defendant pleaded guilty to one count of conspiracy to possess with intent to distribute narcotics. Defendant was sentenced to seventy months in prison and eight years of supervised release. While Defendant was on supervised release, he violated the terms of his release by engaging in conduct that would warrant a Grade C violation of his conditions of supervised release. The government countered that Defendant had also engaged in more serious offenses which would constitute a Grade A violation. The district court concluded that there was sufficient evidence to find a Grade A violation but nonetheless classified Defendant’s conduct as a Grade C violation, which entitles a district court to exercise its discretion to revoke supervised release. The court subsequently imposed a three-year term of imprisonment. The First Circuit affirmed, holding (1) the district court did not commit plain error in admitting hearsay testimony at the show cause hearing; (2) the district court did not err in revoking the term of Defendant’s supervised release; and (3) Defendant’s three-year sentence was reasonable. View "United States v. Mulero-Diaz" on Justia Law

Richard Schiffmann and Stephen Cummings were officers of ICOA, Inc. (ICOA), a corporation that struggled to stay current on federal trust fund tax - or payroll tax - obligations. After Schiffmann and Cummings were fired, the Internal Revenue Service (IRS) made trust fund recovery penalty assessments against Schiffmann and Cummings. Schiffman filed suit seeking to recover the sums previously seized from him and to nullify the assessments. The government counterclaimed against Schiffman, Cummings, and others seeking to recover the remainder of the overdue taxes and penalties. Cummings, in turn, counterclaimed against the government seeking to nullify the assessments against him. The district court entered summary judgment for the government on its counterclaims and on the claims asserted by Schiffmann and Cummings, concluding that, as a matter of law, Schiffmann and Cummings were responsible persons who had acted willfully in not paying ICOA’s trust fund taxes. The First Circuit affirmed, holding that the district court did not err in concluding that Schiffmann and Cummings were responsible persons who had willfully caused ICOA to shirk its payroll tax obligations. View "Schiffmann v. United States" on Justia Law

Defendant was the mastermind of a Ponzi scheme that defrauded more than 230 investors out of over $22 million. Defendant pled guilty to bank fraud and to conspiracy to commit wire fraud. The district court sentenced Defendant to concurrent terms of sixty months’ imprisonment on the wire fraud conspiracy count and 242 months on the bank fraud count. Restitution was also ordered in the amount of $10,629,021. Defendant appealed, arguing that his 242-month sentence was too high. The First Circuit affirmed, holding that the 242-month sentence was both procedurally and substantively reasonable. View "United States v. Reyes-Rivera" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, armed assault with intent to murder, assault and battery with a dangerous weapon, and the unlicensed possession of a firearm. The Supreme Judicial Court of Massachusetts affirmed the convictions. Defendant subsequently filed a petition for a writ of habeas corpus in a federal district court, claiming, inter alia, that evidence provided by an expert witness who relied on and tendered work done by a non-testifying witness violated his right to confrontation under the Sixth Amendment. The First Circuit affirmed, holding (1) the admission of the expert witness’s opinion did not provide a basis for habeas corpus relief; and (2) the admission of the disputed evidence provided by the expert witness violated clearly established law under the Confrontation Clause, but the error was harmless because the evidence was cumulative and because the properly admitted evidence against Defendant was overwhelming. View "Barbosa v. Mitchell" on Justia Law

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