Justia Criminal Law Opinion Summaries

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

After a jury trial, Defendant was convicted of conspiracy to rob a postal worker, assault on a federal employee, and related offenses. The sentencing judge sentenced Defendant to 235 months in prison, plus ten years. Defendant appealed, raising several allegations of error. The First Circuit affirmed Defendant’s conviction but remanded the case to the district court for reconsideration of Defendant’s sentence at a new sentencing hearing, holding (1) the district court applied an erroneously-inflated Guidelines range, which compromised the fairness and integrity of Defendant’s sentencing; and (2) the remainder of Defendant’s arguments on appeal were unavailing. View "United States v. Taylor" on Justia Law

Defendant pled guilty to being a felon in possession of a firearm. Defendant’s plea agreement recommended a total offense level under the U.S. Sentencing guidelines of seventeen. Defendant objected to the recommended total offense level, arguing that it should instead be twelve under the Guidelines. Relying on an untranslated Spanish document, the district court concluded that Defendant’s total offense level was seventeen. The district court proceeded to sentence Defendant to forty-six months’ imprisonment even though the Guidelines’ recommended sentence was twenty-seven to thirty-three months in prison. The First Circuit vacated Defendant’s sentence and remanded for resentencing, holding that the district court erred in relying on an untranslated document in calculating Defendant’s offense level. View "United States v. Roman-Huertas" on Justia Law

After a jury trial, Defendant was convicted of conspiracy, willful violation of the Investment Advisers Act, wire fraud, and corruptly impeding the administration of internal revenue laws. Defendant was sentenced to eighty-four months in prison, a below-guidelines sentence. Defendant appealed, arguing that the trial court’s reasonable doubt instructions were deficient and claiming sentencing error. The First Circuit affirmed Defendant’s convictions and sentence, holding (1) Defendant’s claims of instructional error ultimately failed; and (2) the district court’s decision refusing to grant a downward departure on two alternative bases was reasonable. View "United States v. Herman" on Justia Law

After a jury trial, Defendant was convicted of possession of crack cocaine with intent to distribute. The First Circuit affirmed, holding (1) Defendant waived any argument regarding the district court’s denial of his motion to suppress text messages that the police obtained from Defendant’s cell phone pursuant to a search warrant; (2) the district court did not err in admitting evidence of Defendant’s prior drug conviction; (3) the district court did not err in allowing a police officer to provide expert testimony; and (4) the district court did not err in failing to instruct the jury on the lesser included offense of simple possession. View "United States v. Henry" on Justia Law