Justia Criminal Law Opinion Summaries

When the five defendants in this case failed to pass the required exams to obtain their medical licenses, they gained certification by obtaining falsified scores. All five defendants were indicted for conspiracy to commit honest-services mail fraud, money or property mail fraud, and aggravated identity theft. The First Circuit affirmed Defendants’ convictions for honest-services mail fraud conspiracy but reversed the convictions for money or property mail fraud and aggravated identity theft, holding that there was sufficient evidence to support the convictions for conspiracy to commit honest-services mail fraud but insufficient evidence to support both Defendants’ convictions for money or property mail fraud and the identity theft convictions. View "United States v. Berroa" on Justia Law

Appellant appealed the district court’s imposition of a two-year sentence imposed following the revocation of a term of supervised release. Specifically, Appellant argued that the district court erred in (1) stating that it had granted Appellant “two previous opportunities” to “get his act together,” and (2) imposing a substantively unreasonable sentence. The First Circuit affirmed, holding (1) there was no error in the court’s characterization of the outcome of a hearing as an “opportunity” afforded to Appellant; and (2) Appellant’s two-year sentence, though severe, did not fall outside the boundaries of the range of reasonable sentences. View "United States v. Soto-Soto" on Justia Law

Appellant entered a straight plea to illegal possession of a machine gun. The district judge sentenced Appellant to forty-eight months’ imprisonment followed by thirty-six months’ supervised release. On appeal, Appellant challenged the reasonableness of his sentence. The First Circuit affirmed, holding (1) the district court did not err in not applying, sua sponte, an additional one-level reduction to Appellant’s total offense level for acceptance of responsibility; (2) the district court’s decision to impose a forty-eight-month sentence was not in error; and (3) Appellant’s ineffective assistance of counsel claim could not be addressed on direct appeal. View "United States v. Fuentes-Echevarria" on Justia Law

Appellant pleaded guilty to three charges related to his act of possessing guns and drugs while he was on supervised release. The federal district court denied Appellant's motion to withdraw his guilty plea that he filed seven months after he pleaded guilty. The district court sentenced Appellant to a total of seventy-six months for the three charges. The court sentenced Appellant to an additional twenty-four months, to be served consecutively to his seventy-six-month sentence, for violating the conditions of his supervised release. The First Circuit affirmed, holding (1) the district court did not err in denying Appellant’s motion to change his plea; and (2) Appellant’s 100-month sentence was procedurally reasonable. View "United States v. Fernandez-Santos" on Justia Law

Appellant challenged the seventy-month prison sentence he received after pleading guilty in federal district court, pursuant to a plea agreement, to aiding and abetting a convicted felon in the possession of a firearm. The First Circuit affirmed, holding (1) Appellant failed to demonstrate that plain error occurred in the classification of his prior convictions as convictions that trigger the application of U.S.S.G. 2K2.1(a)(1)(B); and (2) no plain error occurred in the district court’s consideration of the mitigating factors under 18 U.S.C. 3553(a). View "United States v. Nieves-Borrero" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to possession of a firearm in furtherance of a drug-trafficking offense (Count 1) and possession with intent to distribute controlled substances (Count 5). The district court sentenced Defendant to eighty-four months’ imprisonment for Count 1 and to forty-one months for Count 5. The sentences were to be served consecutively, for a total of 125 months’ imprisonment. Defendant appealed, arguing that his sentence was both procedurally and substantively unreasonable. The First Circuit affirmed Defendant’s sentence, holding that the sentence “reside[d] within the expansive universe of reasonable sentences.” View "United States v. Vazquez" on Justia Law

In 2010, Appellant pled guilty to participating in a conspiracy to possess with intent to distribute between fifteen and fifty kilograms of cocaine. Consistent with the parties’ joint recommendation, the district court sentenced Appellant to 180 months’ imprisonment. In 2014, Appellant filed a motion to reduce his sentence, citing an April 2014 amendment to the sentencing guidelines that was given retroactive effect. The amendment reduced the base offense level for certain drug crimes by two levels. Five days after the amendment’s effective date, the Puerto Rico District Court issued an administrative directive under which all motions to reduce sentence based on the amendment are automatically referred to a magistrate judge for initial screening. In the instant case, the district judge sua sponte denied Appellant’s motion before the magistrate judge had the opportunity to make an eligibility determination. Appellant appealed, arguing, inter alia, that the district court failed to apply its own administrative directive. The First Circuit vacated the district court’s orders denying Appellant’s motion to reduce sentence, holding that, under the circumstances of this case, remand to the district court for it to apply its administrative directive was the appropriate course. View "United States v. Rodriguez-Rosado" on Justia Law

Pursuant to a written plea agreement, Defendant pleaded guilty to unlawful possession of firearms in furtherance of a drug trafficking crime and possession of crack cocaine with intent to distribute. The plea agreement included a provision titled “Waiver of Appeal.” The district court accepted Defendant’s plea and sentenced him to 132 months in prison. Defendant appealed, challenging the reasonableness of his sentence. With regard to the waiver provision Defendant argued that the provision did not apply to this appeal and, alternatively, that enforcing it “would work a miscarriage of justice.” The First Circuit dismissed the appeal, holding that Defendant’s waiver was both valid and enforceable and, therefore, the Court’s consideration of this appeal on the merits was barred. View "United States v. Morales-Arroyo" on Justia Law

The Armed Career Criminal Act (ACCA) requires mandatory sentences for recidivist criminals with three or more convictions for crimes committed on different occasions that qualify as predicate offenses. Defendant pled guilty to possessing ammunition as a felon. In addition to two ACCA-qualifying Maine burglary convictions, Defendant had on his record a 2001 Maine robbery conviction and a 2004 Maine drug-trafficking conviction. The district judge applied an ACCA enhancement and sentenced Defendant to the statutory minimum of fifteen years in jail. The First Circuit vacated Defendant’s sentence and remanded for resentencing, holding that neither Defendant’s robbery conviction nor his drug-trafficking conviction qualified as an ACCA predicate. Remanded for resentencing without the ACCA enhancement. View "United States v. Mulkern" on Justia Law

Defendant pleaded guilty to conspiracy to distribute and possess with intent to distribute cocaine base. The district court imposed a total prison sentence of forty-six months, at the lower end of the United States Sentencing Guidelines imprisonment range. Defendant appealed, challenging the district court’s application of a two-level enhancement for possession of a dangerous weapon and the substantive reasonableness of his sentence. The Court of Appeals for the First Circuit affirmed, holding (1) the district court did not clearly err by applying the two-level enhancement for the possession of a dangerous weapon, and therefore, Defendant’s guideline sentencing range was properly calculated; and (2) Defendant’s sentence was substantively reasonable. View "United States v. Coleman" on Justia Law