Justia Criminal Law Opinion Summaries

Defendant pleaded guilty to six counts of a ten-count indictment, including conspiracy to commit export violations, conspiracy to smuggle goods, and four counts of unlawfully exporting U.S. goods to Iran through the People’s Republic of China. The district court imposed a sentence of 108 months, the upper end of the Guidelines sentencing range. Defendant appealed, arguing that his 108-month incarcerative sentence was unreasonable. Defendant made three different arguments in support of his claim. The First Circuit affirmed, holding that, under the circumstances of this case, imposition of the 108-month sentence was not substantively unreasonable. View "United States v. Cheng" on Justia Law

In a multiple-count indictment, Defendant was charged with conspiring with twenty-nine others to distribute drugs in several Boston area neighborhoods. In pretrial proceedings, Defendant filed a motion to suppress evidence obtained pursuant to wiretaps obtained by the government, claiming, in part, that the government, in bad faith, failed to meet the strict procedural requirements for obtaining wiretaps under 18 U.S.C. 2517-2522. The trial court denied the motion to suppress without a hearing. After a trial, the jury failed to reach a unanimous verdict, and the district court declared a mistrial. Thereafter, Defendant pled guilty solely to conspiracy to distribute marijuana, reserving his right to appeal the denial of his suppression motion. The First Circuit affirmed, holding (1) the district court did not err in finding that Defendant failed to present a credible case of bad faith omissions; (2) the district court properly determined that the facts set forth in the wiretap applications were sufficient to support its grant of wiretap intervention; (3) the lack of strict adherence to statutory sealing requirements did not mandate suppression; and (4) the trial court did not err in denying Defendant a hearing to explore his misrepresentation and bad faith concerns. View "United States v. Rodrigues" on Justia Law

After a jury trial, Defendant was convicted of illegal insider trading. The conviction arose from Defendant’s act of receiving material, nonpublic information about a local bank from a fellow member of the Oakley Country Club and then using that information to make a substantial trading profit. Defendant appealed, arguing, in part, that the district court wrongly instructed the jury on the mens rea element of his offense. Defendant did not object to these instructions at trial. The First Circuit affirmed, holding (1) the government presented sufficient evidence to support the jury’s verdict; and (2) the trial court erred in its instructions to the jury regarding the mens rea element of Defendant’s offense, but Defendant failed to establish that the error was plain error. View "United States v. Bray" on Justia Law

After a bench trial, Defendant was convicted of both conspiracy to commit healthcare fraud and healthcare fraud. The convictions arose from Defendant’s role in an extensive scheme to defraud Medicare by billing the program for services provided to patients falsely presented as eligible to receive them. Defendant was sentenced to thirty-six months of imprisonment to be followed by three years of supervised release. Defendant appealed, arguing that there was insufficient evidence to prove beyond a reasonable doubt that she acted with the required culpable state of mind. The First Circuit affirmed, holding that the evidence was sufficient to permit a reasonable fact-finder to conclude, beyond a reasonable doubt, that Defendant conspired to commit, and committed, healthcare fraud. View "United States v. Troisi" on Justia Law

After a jury trial, Defendant was convicted of conspiracy to distribute and possess with intent to distribute controlled substances. Defendant was sentenced to 210 months imprisonment. Defendant appealed, challenging both his conviction and sentence. The First Circuit affirmed, holding (1) the government provided sufficient evidence that the conspiracy in question had the required “jurisdictional nexus” to the United States; (2) venue in the District of New Hampshire was proper, and the manufactured venue doctrine is hereby rejected; (3) there was no error in the district court’s failure to instruct the jury on jurisdictional nexus and manufactured venue; and (4) Defendant’s sentence was substantively reasonable. View "United States v. Celaya Valenzuela" on Justia Law

Defendant was convicted on two counts of making false statements to federal authorities regarding his possible participation in the Boston Marathon bombing. Defendant appealed, challenging, in part, the district court’s admission into evidence of a signed confession in which Defendant admitted to making the false statements at issue during informal interviews with federal agents. The First Circuit affirmed the convictions, holding that the district court did not err in (1) admitting the confession at trial; (2) excluding testimony from Defendant’s proposed expert on false confessions without first conducting a hearing under Daubert v. Merrell Dow Pharmaceuticals, Inc.; and (3) in denying Defendant’s motion for acquittal. View "United States v. Phillipos" on Justia Law

After a jury trial, Defendant was convicted of conspiracy to commit healthcare fraud, healthcare fraud, and money laundering. Defendant appealed, alleging trial error. The First Circuit affirmed, holding that the district court did not err by (1) failing to sua sponte give a limiting instruction as to testimony by Defendant’s associate that the associate had pled guilty to one count of healthcare fraud arising from the same scheme; (2) permitting witness testimony about Medicare regulations; and (3) denying Defendant’s preferred jury instruction as to the meaning of a particular certification requirement in the relevant Medicare provisions. View "United States v. Galatis" on Justia Law

Defendant pled guilty to one count of being a prohibited person in possession of a firearm. The district court sentenced Defendant to an upwardly variant sentence of seventy-two months’ imprisonment followed by a three-year term of supervised release. Defendant challenged his sentence on appeal. The First Circuit affirmed, holding (1) there was no plain error in the district court’s finding that at least one of Defendant’s prior convictions was for a “crime of violence,” and therefore, Defendant’s guidelines sentence range was properly calculated; (2) Defendant’s sentence was procedurally reasonable; and (3) Defendant’s sentence was substantively reasonable. View "United States v. Delgado-Sanchez" on Justia Law

Defendant was convicted of possession of heroin with intent to distribute and conspiracy to distribute heroin. The district court sentenced Defendant to a term of imprisonment of sixty-six months. Defendant appealed, raising several allegations of error. The First Circuit affirmed, holding (1) the district court did not err in its pretrial rulings; (2) the district court did not err in its rulings made during trial; and (3) Defendant’s challenge to his sentence failed because the district court’s findings justified its determination that Defendant was responsible for conspiring to distribute between 400 and 700 grams of heroin. View "United States v. Arias" on Justia Law

Defendant pled guilty to participating in a conspiracy to defraud the federal government. Defendant appealed, arguing that the district court erred in denying his motion to dismiss the indictment with prejudice based on violations of the Speedy Trial Act, the Speedy Trial Clause of the Sixth Amendment, and the Due Process Clause of the Fifth Amendment. The First Circuit vacated the district court’s decision on Defendant’s Sixth Amendment claim and remanded for reconsideration of that claim, holding that the district court was led astray by dicta in one of this Court’s prior opinions in calculating the length of delay relevant to evaluating the alleged Sixth Amendment violation. View "United States v. Irizarry-Colon" on Justia Law