Justia Criminal Law Opinion Summaries

Articles Posted in US Court of Appeals for the First Circuit
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The case involves the defendant-appellant, Augusto Valdez, who appealed from his guilty plea and conviction for which he received 120 months' imprisonment, followed by a five-year term of supervised release. Valdez raised two issues: firstly, he asserted that the district court should have granted his motion to withdraw his guilty plea because he conspired only with a confidential source and not a co-conspirator, and that the court did not ensure that he knew he couldn't conspire illegally with a government agent. Secondly, he sought to vacate his sentence because the district court should have, on its own initiative, verified his eligibility for the safety valve under U.S.S.G. § 5C1.2.The United States Court of Appeals for the First Circuit affirmed the decision of the district court. The court found that Valdez knowingly and voluntarily entered his guilty plea and was not misled about the nature of the conspiracy charge, thereby rejecting his argument that his plea was not knowing, voluntary, and intelligent. His argument that he could not be convicted for conspiring only with a government agent was rejected because the facts revealed two true conspirators: Valdez and a Texas source. The court also found that Valdez waived his right to argue for the application of the safety valve because he failed to object to the PSR and requested the mandatory minimum sentence, which was inconsistent with his later argument for the application of the safety valve. View "United States v. Valdez" on Justia Law

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In this case, Ángel Menéndez-Montalvo, while serving a term of supervised release arising from his conviction for a federal firearm offense, violated the conditions of his release by breaching Article 3.1 of Puerto Rico's Domestic Violence Law. The United States Court of Appeals for the First Circuit had to determine whether a violation of Article 3.1 is a "crime of violence" as used in section 7B1.1(a)(1) of the United States Sentencing Guidelines. The court found that it is not because Puerto Rico courts have applied the law to encompass less-than-violent force. As such, the court vacated Menéndez's sentence because the district court had held to the contrary in calculating a sentencing range that was higher than it should have been. The court further clarified that its decision does not prevent the district court from considering Menéndez's conduct while on supervised release as it bears on the factors specified in 18 U.S.C. § 3583(e). The case was remanded to the district court for further proceedings consistent with this opinion. View "US v. Menendez-Montalvo" on Justia Law

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In a drug trafficking case, the defendant, Amanda Cowette, appealed the district court's denial of her motion to suppress statements she made to law enforcement officers on July 16 and 17, 2018. Cowette argued that she unequivocally invoked her Fifth Amendment right to counsel and any subsequent questioning by law enforcement officers was in violation of that right. She contended that the district court's ruling to the contrary was in error. The United States Court of Appeals for the First Circuit agreed with Cowette and held that she properly invoked her Fifth Amendment right to counsel. The court found that the phrase "I guess" used by Cowette did not create any ambiguity in her clear invocation of her right to counsel. The court vacated the decision of the district court in part, affirmed in part, and remanded for proceedings consistent with this opinion. View "US v. Cowette" on Justia Law

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The United States Court of Appeals for the First Circuit affirmed the convictions of Rafael Cardona Sr. and Isaac Cardona for conspiracy to distribute and possess with intent to distribute cocaine and heroin. Isaac Cardona was also convicted of conspiracy to commit money laundering with intent to promote the carrying on of unlawful activity. The defendants raised several arguments on appeal.Rafael Cardona Sr. argued that his two convictions were multiplicitous in violation of the Double Jeopardy Clause. The court concluded that this argument was not reviewable because it was raised for the first time on appeal and not supported by good cause, as required under Federal Rules of Criminal Procedure 12(b)(3) and 12(c)(3).Isaac Cardona argued that the money laundering statute under which he was charged is unconstitutionally vague. The court determined that this argument was not reviewable because it was not raised before trial, as required by Rule 12(b)(3). Isaac Cardona also argued that there was insufficient evidence to support his money laundering conviction and that the court gave erroneous jury instructions on this charge. The court found sufficient evidence to support the conviction and concluded that the erroneous instructions did not affect his substantial rights.The case arose from surveillance footage, recorded communications between the defendants and other co-conspirators, and other evidence showing that the defendants conspired to distribute cocaine and heroin and that Isaac Cardona conspired to commit money laundering by using the proceeds of cocaine distribution to procure and resell heroin. View "US v. Cardona" on Justia Law

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A plaintiff, Elvin Torres-Estrada, brought claims against several Federal Bureau of Investigation (FBI) agents and the United States under the Federal Tort Claims Act (FTCA) and Bivens, alleging violations of his constitutional and statutory rights. The district court dismissed his complaint, arguing that some of his claims were not filed within the required time frame and that the FTCA's discretionary function exception stripped the court of jurisdiction over his other claims. Torres-Estrada appealed the dismissal, arguing that his claims are timely, the discretionary function exception does not apply, and even if it does, it does not cover the alleged misconduct of the FBI.The United States Court of Appeals for the First Circuit held that the district court erred in its interpretation of the discretionary function exception. The court explained that this exception does not serve as a bar to FTCA tort claims that plausibly allege constitutional violations. In addition, at least two of Torres-Estrada's claims could be subject to the "continuing violation" doctrine, which means the district court erred in dismissing his claims as untimely without considering this doctrine. Given that new facts have emerged throughout the litigation, the court granted Torres-Estrada leave to amend his complaint. Therefore, the court affirmed in part, reversed in part, and remanded the case for further proceedings.The background facts of the case are that Torres-Estrada was detained at the Metropolitan Detention Center (MDC) in Guaynabo, Puerto Rico, pending prosecution for drug and money laundering offenses. During this time, he was investigated by the FBI as a potential suspect in the murder of a correctional officer at the MDC. Torres-Estrada alleges that the FBI violated his rights through various actions, including the use of informants to elicit incriminating statements about the murder, subjecting him to invasive body searches, and maintaining records falsely linking him to the murder. View "Torres-Estrada v. Cases" on Justia Law

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The First Circuit affirmed Defendant's conviction and sentence for one count of transportation of a minor with the intent to engage in criminal sexual activity, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that the trial court erred in admitting hearsay testimony and improper opinion testimony and that his sentence was both procedurally and substantively unreasonable. The First Circuit affirmed, holding that the district court (1) did not abuse its discretion in admitting the hearsay statements under the excited utterance exception; (2) did not abuse its discretion in admitting the opinion testimony; and (3) did not err in sentencing Defendant to 235 months' imprisonment because the sentence was procedurally and substantively reasonable. View "United States v. Irizarry-Sisco" on Justia Law

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The First Circuit affirmed the judgment of the district court dismissing the suit brought by Plaintiff seeking to enjoin the New Hampshire Secretary of State from "accepting or processing" the "ballot access documentation" brought by Donald Trump, the former President of the United States, for the 2024 Republican presidential primary in the state of New Hampshire, holding that Plaintiff lacked standing.Plaintiff, a United States citizen and Republican primary presidential candidate, brought this complaint alleging that section 3 of the Fourteenth Amendment barred Tump from "holding" the office of President of the United States again on the ground that he "engaged in insurrection or rebellion against [the U.S. Constitution], or [gave] aid or comfort to the enemies thereof." The district court dismissed the lawsuit on jurisdictional grounds, concluding that Plaintiff lacked standing under U.S. Const. art. III, 2 and that his section 3 claim presented a nonjusticiable political question. The First Circuit affirmed, holding that Plaintiff failed to show that he could satisfy the "injury-in-fact" component of Article III standing. View "Castro v. Scanlan" on Justia Law

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The First Circuit affirmed the judgment of the district court ruling that the underlying suit was time barred as to all defendants in this action brought by Plaintiff under 42 U.S.C. 1983 on behalf of her late son's estate on the six-year anniversary of his death, holding that the lawsuit was time barred.Plaintiff sued jail staff and a medical contractor (collectively, Defendants), alleging that while her son was detained in the Somerset County Jail, Defendants failed to recognize his serious mental illness, thus leading to his death following a suicide attempt. Defendants moved to dismiss the suit as time barred. The district court granted the motion. The First Circuit affirmed, holding that Plaintiff was not entitled to relief on her allegations of error. View "Martin v. Somerset County" on Justia Law

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The First Circuit affirmed Defendant's conviction for possession of child pornography, holding that the district court did not err in denying Defendant's motion to suppress or to dismiss the indictment and that the government set forth sufficient evidence to support Defendant's conviction.On appeal, Defendant argued, among other things, that the district court erred in denying his motion to suppress the fruits of a warrantless search of his residence and in denying his motion to dismiss the indictment due to inadequate notice of the warrantless search. The First Circuit affirmed, holding (1) assuming that the search of Defendant's home was in violation of the Fourth Amendment, the facts gathered legally provided an independent and adequate source for the warrant application; (2) the district court did not err in denying Defendant's motion to dismiss the indictment or suppress the fruits of the warrant due to insufficient notice; and (3) there was sufficient evidence to sustain Defendant's conviction under 18 U.S.C. 2252A(a)(5)(B). View "United States v. Royle" on Justia Law

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The First Circuit denied Petitioner's petition for review challenging the denial of her application for asylum and withholding of removal, holding that Petitioner failed to establish a connection between her past persecution on account of a statutorily protected ground.Specifically, the First Circuit held (1) Petitioner failed to raise before the Board of Immigration Appeals (BIA) her argument that the BIA's failure to address a procedural error in Petitioner's hearing before the IJ violated her right to due process under the Fifth Amendment, and therefore, this Court was precluded from addressing it now; and (2) the BIA erred by failing to evaluate the severity of Petitioner's mistreatment as a teenager through the eyes of a child, but the error did not warrant remand because Petitioner failed to link her mistreatment to a statutorily-protected ground. View "Varela-Chavarria v. Garland" on Justia Law