Justia Criminal Law Opinion Summaries

The First Circuit vacated the judgment of the district court convicting Defendant on federal drug- and gun-related charges, holding that the district court erred by failing to suppress incriminating statements Defendant made to law enforcement because the government failed to satisfy its burden to show that Defendant validly waived his rights under Miranda v. Arizona, 384 U.S. 436 (1966).Defendant was charged with conspiracy to distribute and to possess with intent to distribute heroin, cocaine, cocaine base, and fentanyl; possession with intent to distribute those drugs; and being a felon in possession of a firearm. Defendant filed a motion to suppress statements he made to law enforcement immediately following his arrest, arguing that the statements were obtained in violation of his Miranda rights. The district court denied the motion to suppress, concluding that Defendant understood his Miranda rights and knowingly, intelligently and voluntarily waived them. The First Circuit reversed, holding that the government failed to show that Defendant validly waived his Miranda rights, and this error was not harmless. View "United States v. Donald" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant, following a jury trial, of four counts of wire fraud, in violation of 18 U.S.C. 1343, and one count of making false statements to a financial institution, in violation of 18 U.S.C. 1014, holding that Defendant was not entitled to relief on his claims of error.Specifically, the First Circuit held (1) there was sufficient evidence presented to the jury of Defendant's intent to defraud for his wire convictions; (2) there was sufficient evidence of Defendant's intent to influence a financial institution; and (3) there was no adequate record with which to determine the effectiveness of counsel's decisions, and therefore, Defendant's ineffective assistance of counsel claims were dismissed without prejudice. View "United States v. Buoi" on Justia Law

The First Circuit granted the government's petition for rehearing en banc in these consolidated appeals regarding Defendants' 2016 convictions for violating the Maritime Drug Law Enforcement Act, 46 U.S.C. 70501 et seq. (MDLEA), holding that 46 U.S.C. 70503(e)(1) does not limit the subject matter jurisdiction of federal courts under Article III of the United States Constitution.Defendants pleaded guilty unconditionally to the underlying charges, but a panel of the First Circuit vacated the convictions and ordered the underlying charges dismissed. The government petitioned for rehearing en banc. The First Circuit granted the petition, vacated the panel's ruling, and affirmed Defendant's convictions, holding that section 70503(e)(1) merely limits the substantive reach of the MDLEA and that Defendants' claims on appeal failed. View "United States v. Davila-Reyes" on Justia Law

The First Circuit vacated the judgment of the district court denying Defendant's prisoner-initiated motion for compassionate release, holding that because the district court did not undertake an evaluation of the 18 U.S.C. 3553(a) factors remand was necessary.Defendant was found guilty by a jury of conspiracy to distribute five kilograms or more of heroin, cocaine, cocaine base and marijuana. The district court sentenced Defendant to a term of life imprisonment. After Congress passed the First Step Act amending the compassionate-release statute Defendant moved for either compassionate release or a sentence reduction. The district court denied relief. The First Circuit vacated the judgment below, holding (1) the district court abused its discretion in concluding that Defendant's compassionate-release motion could not proceed as a matter of law; and (2) this Court declines Defendant's request to grant his motion for compassionate release. View "United States v. Quiros-Morales" on Justia Law

The First Circuit vacated the decision of the federal district court revoking Defendant's term of supervised release and ordering him to return to prison for an additional two years, holding that resentencing was required on the proper record.Defendant was convicted of a drug crime, sentenced, and placed on supervised release. The district court later revoked Defendant's supervised release term on ordered him returned to prison for two years, finding that Defendant made unlawful death threats in violation of a condition of his release. The First Circuit affirmed the order revoking Defendant's term of supervision but vacated Defendant's revocation sentence and remanded the case for resentencing, holding that the district court erred by admitting certain testimony and that the error may have affected the court's decision to impose an upwardly variant sentence. View "United States v. Navarro-Santisteban" on Justia Law

The First Circuit vacated Defendant's new sentence after concluding that it could sua sponte consider a claim of error not timely raised by Defendant, holding that the district court committed plain error during sentencing.Defendant pled guilty to two carjacking offenses and a firearm count. The district court varied upward and imposed concurrent sentences of eighty-seven months on the carjacking counts and a consecutive sentence of 108 months on the firearm count. The First Circuit remanded for resentencing. The district court ultimately imposed concurrent sentences of 132 months' imprisonment on the carjacking counts and a consecutive sentence of 108 months' imprisonment on the firearm count. The First Circuit vacated the sentence, holding (1) this Court may sua sponte raise an error that constitutes a violation of the mandate rule; and (2) the resentencing court in this case committed plain error under this Court's holding in United States v. Ticchiarelli, 171 F.3d 24 (1st Cir. 1999). View "United States v. Cheveres-Morales" on Justia Law

The First Circuit vacated Defendant's conviction for possession of a machine-gun in furtherance of a drug trafficking crime and remanded the case for a new trial as to that count, holding that the jury should have been instructed about Defendant's knowledge of the characteristics of the firearm he possessed.After a jury trial, Defendant was convicted of possession with intent to distribute controlled substances, possession of a firearm in furtherance of a drug trafficking crime, and possession of a machine-gun in furtherance of a drug trafficking crime. The First Circuit vacated the convictions in part, holding (1) the evidence was sufficient to support the convictions; (2) Defendant was not entitled to relief on his claims for pretrial and trial error; and (3) the district court improperly instructed the jury that the government was not required to prove that Defendant knew the firearm he possessed was a machine-gun. View "United States v. Perez-Greaux" on Justia Law

The First Circuit affirmed the 194-month sentence imposed upon Defendant after he pled guilty to using, carrying, brandishing, and discharging a firearm in furtherance of a crime of violence, holding that the sentence was neither procedurally or substantively unreasonable.On appeal, Defendant argued, among other things, that the district court erred by making conflicting statements about his applicable guidelines sentence and that his sentence was substantively unreasonable because it was "unmoored from any particular factor." The First Circuit affirmed, holding that Defendant's 194-sentence was both procedurally and substantively reasonable. View "United States v. Melendez-Hiraldo" on Justia Law

The First Circuit affirmed in part and reversed in part the order of the district court ordering A.R., who was adjudicated delinquent in a proceeding under the Federal Juvenile Delinquency Act (FJDA), 18 U.S.C. 5031-5042, detained in a juvenile institution until he reached the age of twenty-one, followed by a term of juvenile delinquent supervision, holding that remand was required.A.R., who was born in 2003, was adjudicated delinquent pursuant to his admission of aiding and abetting an attempted robbery of a motor vehicle and five carjackings, each of which would have been a violation of 18 U.S.C. 2119 had A.R. been an adult. On appeal, A.R. primarily challenged the district court's order of a detention period rather than a probationary one. The First Circuit affirmed as to the court's imposition of detention but reversed and remanded as to two other matters, holding (1) A.R.'s disposition was both procedurally and substantively reasonable; (2) the district court erred in failing to recommend that A.R. be placed in a local detention facility; and (3) the district court erred in imposing a term of detention and supervision that together exceeded the applicable statutory maximum. View "United States v. A.R." on Justia Law

The First Circuit vacated Defendant's statutory maximum thirty-six-month sentence that the district court imposed following a revocation of supervised release, holding that the district court's failure adequately to justify the sentence was procedural error.After a revocation hearing, the district court revoked Defendant's supervised release term for violations of the conditions of his release. The district court sentenced Defendant to thirty-six months' imprisonment, the statutory maximum for Defendant's violation. The First Circuit vacated the sentence and remanded the case for resentencing, holding that none of court's rationales explained why Defendant's case was so distinct from other such revocation cases that he deserved a 400 percent increase over the guidelines sentencing range. View "United States v. Reyes-Correa" on Justia Law