Justia Criminal Law Opinion Summaries

In this case, the petitioner was convicted by a jury in New Hampshire state court for the first-degree murder of Larry Lemieux. The petitioner admitted to shooting Lemieux but claimed he acted in self-defense or in defense of another, arguing he did not act with premeditation. After his conviction, the prosecution disclosed a proffer letter recommending a suspended sentence for drug charges against Jose Gomez, a key prosecution witness. The petitioner argued that the failure to disclose this letter violated his due process rights under Brady v. Maryland.The state trial court denied the petitioner's motion for a new trial, finding that the nondisclosure of the proffer letter did not prejudice the petitioner. The New Hampshire Supreme Court affirmed this decision, holding that the petitioner was not prejudiced under New Hampshire law, which sets stricter standards than Brady. The court found that the undisclosed evidence would not have altered the defense strategy or the trial's outcome, given the overwhelming additional evidence of premeditation presented by other witnesses.The United States Court of Appeals for the First Circuit reviewed the case, focusing on whether the New Hampshire Supreme Court's decision involved an unreasonable application of clearly established federal law under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). The First Circuit affirmed the denial of habeas relief, concluding that the New Hampshire Supreme Court reasonably determined that the petitioner was not prejudiced by the nondisclosure of the proffer letter. The court noted the overwhelming evidence of premeditation from multiple witnesses, which supported the jury's verdict independent of Gomez's testimony. View "Etienne v. Edmark" on Justia Law

The case involves Lucas Sirois and Alisa Sirois, who were indicted for conspiracy to distribute and possess with intent to distribute marijuana under the Controlled Substances Act (CSA). They sought to enjoin the Department of Justice (DOJ) from prosecuting them, arguing that their conduct was in substantial compliance with the Maine Medical Use of Cannabis Act, which allows for the use, distribution, possession, and cultivation of medical marijuana under state law. The defendants claimed that the DOJ's prosecution violated the Rohrabacher-Farr Amendment, which prohibits the DOJ from using funds to prevent states from implementing their medical marijuana laws.The United States District Court for the District of Maine denied the defendants' request for injunctive relief. The court held a hearing where the government presented evidence that the defendants' operations, particularly a grow operation known as the "Shoe Shop," violated Maine's medical marijuana laws by operating as a collective and engaging in black-market sales. The court found that the government had met its burden of production, showing a substantial evidentiary basis for the prosecution. However, the defendants failed to meet their burden of persuasion to demonstrate that the prosecution lacked a substantial evidentiary basis or was arbitrary or irrational.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the District Court's decision. The appellate court held that the defendants did not show by a preponderance of the evidence that they were in substantial compliance with Maine's medical marijuana laws. The court noted significant evidence that the Shoe Shop operated as a collective and that Lucas Sirois engaged in black-market sales. The court concluded that the defendants failed to demonstrate that the DOJ's prosecution would prevent Maine from giving practical effect to its medical marijuana laws, as required under the Rohrabacher-Farr Amendment. Therefore, the denial of the motion to enjoin the prosecution was affirmed. View "United States v. Sirois" on Justia Law

In this case, the defendants, Aurea Vázquez Rijos, Marcia Vázquez Rijos, and José Ferrer Sosa, were involved in a murder-for-hire plot that resulted in the death of Adam Anhang Uster in Old San Juan, Puerto Rico, in 2005. Adam, a Canadian entrepreneur, was attacked and killed by a man hired by the defendants while walking with his wife, Aurea. The motive was financial gain from a prenuptial agreement that favored Aurea significantly more in the event of Adam's death than in the case of a divorce.The United States District Court for the District of Puerto Rico tried the defendants. A federal jury convicted Aurea of murder for hire and all three defendants of conspiring to commit murder for hire. Each received a life sentence. The defendants appealed, raising numerous issues related to the trial, sentencing, and post-trial phases.The United States Court of Appeals for the First Circuit reviewed the case. The court addressed various claims, including the sufficiency of the evidence, the denial of severance, the admission of certain evidence, judicial bias, and the handling of post-trial motions related to the mental health of a key witness, Alex Pabón Colon. The court found that the evidence presented at trial was sufficient to support the convictions and that the district court did not abuse its discretion in its rulings on severance, evidentiary matters, and judicial conduct.The court also examined the defendants' claims regarding the mental health of Pabón, who testified that he was hired by the defendants to kill Adam. The court concluded that the district court did not err in its handling of Pabón's competency and the related post-trial motions. The court affirmed the district court's decisions across the board, upholding the convictions and sentences of the defendants. View "United States v. Vazquez-Rijos" on Justia Law

A priest residing in the rectory of St. Mary's Catholic Church in Providence, Rhode Island, was found to have over 12,000 images and 1,300 videos of child pornography on his laptop and external hard drive. The government obtained a search warrant for the rectory, which led to the seizure of these devices. Subsequently, a federal grand jury charged the priest with receipt and possession of child pornography. The priest entered a conditional guilty plea, reserving the right to appeal the district court's denial of his motion to suppress the evidence obtained from the search.The United States District Court for the District of Rhode Island denied the motion to suppress, finding that the rectory was best characterized as a single-family residence, thus validating the warrant's description. The court also held that even if the warrant lacked sufficient particularity, the good-faith exception to the exclusionary rule would apply, as the officers reasonably relied on the warrant.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court concluded that the warrant was sufficiently particular regarding the premises and the items to be seized. Even if it were not, the good-faith exception applied because the officers acted reasonably based on the detailed affidavit provided by Detective Evans. The court also noted that the appellant waived his right to appeal the denial of his motion for reconsideration by not reserving it in his conditional plea agreement. Thus, the judgment of the district court was affirmed. View "US v. Jackson" on Justia Law

Brian Watson was convicted in 2017 by a jury for the felony sale of a controlled drug (fentanyl) resulting in death. The prosecution's evidence included testimony from Dr. Daniel Isenschmid, a forensic toxicologist, who discussed toxicology tests conducted by his colleagues, revealing fentanyl and its metabolites in the victim's blood. Watson appealed, arguing that the trial court erred by allowing Dr. Isenschmid to testify about tests he did not perform. The New Hampshire Supreme Court affirmed the conviction, finding that Dr. Isenschmid's involvement in the case was sufficient to satisfy the Confrontation Clause.Watson then filed a habeas corpus petition under 28 U.S.C. § 2254 in the United States District Court for the District of New Hampshire, claiming that his Confrontation Clause rights were violated by Dr. Isenschmid's testimony. The warden moved for summary judgment, which the district court granted, concluding that the state court's decision was neither contrary to nor an unreasonable application of Supreme Court precedent.The United States Court of Appeals for the First Circuit reviewed the case and upheld the district court's decision. The court found that Watson did not provide clear and convincing evidence to show that the state court's factual findings were incorrect. The court also determined that the state court's decision was not contrary to or an unreasonable application of clearly established federal law. The First Circuit noted that Dr. Isenschmid had personally reviewed all relevant documentation, data, and test results, and had issued and signed the toxicology report, making his testimony permissible under the Confrontation Clause. The court affirmed the district court's grant of summary judgment in favor of the warden. View "Watson v. Edmark" on Justia Law

In 2020, a federal grand jury indicted David DeQuattro, an architect, and Cedric Cromwell, Chairman of the Mashpee Wampanoag Tribal Council and President of the Mashpee Wampanoag Gaming Authority. They were charged with various federal offenses, including bribery and extortion, related to Cromwell allegedly soliciting and DeQuattro allegedly providing checks and other items of value to protect a contract between DeQuattro's firm and the Gaming Authority for building a casino on tribal land.The United States District Court for the District of Massachusetts held a jury trial where DeQuattro was convicted of one count of federal-program bribery, and Cromwell was convicted of two counts of federal-program bribery and multiple counts of Hobbs Act extortion. However, the District Court later entered a judgment of acquittal on the Hobbs Act-related counts, determining that the Hobbs Act did not clearly abrogate tribal immunity. Both defendants appealed their § 666 convictions, and the government cross-appealed the judgment of acquittal on the Hobbs Act counts.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed both the § 666 convictions and the judgment of acquittal. The court found that the evidence did not suffice to show that the RGB contract was "business" of the Tribe, as required under § 666, because the Gaming Authority, which entered the contract, was a separate legal entity from the Tribe and received almost all its funding from a third party. The court also reversed the District Court's judgment of acquittal on the Hobbs Act convictions, holding that tribal officials do not enjoy immunity from federal criminal prosecution and that the evidence was sufficient to show Cromwell's intent to engage in a quid pro quo arrangement. The case was remanded for further proceedings consistent with this opinion. View "United States v. Dequattro" on Justia Law

The defendant pleaded guilty to one count of coercion and enticement of a minor. The plea agreement included a joint recommendation for a 120-month sentence, which is the statutory minimum, despite the calculated Guidelines sentencing range being significantly higher. The government did not provide an explanation for this recommendation at the sentencing hearing. The district court sentenced the defendant to 292 months in prison, imposed a condition of supervised release prohibiting unsupervised contact with any minor, including his children, and ordered a special assessment and restitution.The defendant appealed, arguing that the government breached the plea agreement by not adequately supporting the recommended sentence and that the sentence and conditions imposed were unreasonable. The United States Court of Appeals for the First Circuit reviewed the case. The court agreed that the government breached the plea agreement by failing to provide a minimal explanation for the recommended sentence, which was necessary given the significant downward variance from the Guidelines range. However, the court concluded that this breach did not constitute plain error and affirmed the length of the sentence as reasonable.The court also upheld the restriction on the defendant's unsupervised contact with his children, finding it reasonably related to the nature of the offense and necessary to protect the community and minors. However, the court vacated the special assessment and restitution orders, remanding these issues to the district court for further consideration. The special assessment was vacated because the district court did not make a finding regarding the defendant's indigency, and the restitution order was vacated because the district court did not find that the victim's mother was a victim within the statutory definition. View "United States v. Acevedo-Osorio" on Justia Law

In February 2013, a correctional officer named Osvaldo Albarati was murdered while driving home from the federal prison where he worked. Oscar Martínez-Hernández, an inmate at the prison, was convicted and sentenced to life imprisonment for orchestrating the murder. The prosecution argued that Martínez-Hernández, along with another inmate, planned the killing in retaliation for Albarati's efforts to confiscate contraband, including cellphones, from inmates. The defense contended that the evidence was insufficient and that the government had manipulated evidence and allowed false testimony.The United States District Court for the District of Puerto Rico oversaw the trial, which lasted twelve days and included testimony from twenty government witnesses. The defense presented two witnesses. The jury found Martínez-Hernández guilty on all counts, including aiding and abetting the murder of a federal officer, conspiracy to commit murder, murder for hire, and related firearms charges. The defense's motion for a new trial, based on the late disclosure of a prison logbook and other alleged errors, was denied by the district court.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the evidence presented at trial was sufficient to support the jury's verdict. The court also concluded that the late disclosure of the prison logbook did not warrant a new trial, as the logbook's contents did not significantly undermine the overwhelming evidence of Martínez-Hernández's guilt. The court rejected the defense's claims of prosecutorial misconduct and improper admission of hearsay statements, finding no abuse of discretion by the district court. The court affirmed Martínez-Hernández's conviction and the denial of his motion for a new trial. View "United States v. Martinez-Hernandez" on Justia Law

Joseph Segrain, an inmate at Rhode Island's Adult Correctional Institutions, filed a civil lawsuit against the Rhode Island Department of Corrections and several correctional officers, alleging violations of his Eighth Amendment rights and various state laws. Segrain claimed that on June 28, 2018, officers used excessive force by executing a leg-sweep maneuver, spraying him with pepper spray, and delaying his decontamination. The district court granted summary judgment in favor of the officers on all claims, leading Segrain to appeal.The United States District Court for the District of Rhode Island initially reviewed the case. The court found that no reasonable jury could conclude that the officers' conduct constituted an Eighth Amendment violation. It granted summary judgment on the basis that the force used was minimal and necessary to maintain order. The court also dismissed the state law claims, concluding that the officers' actions did not meet the legal standards for battery, intentional infliction of emotional distress, or excessive force under Rhode Island law.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed the district court's judgment regarding the 42 U.S.C. § 1983 claim that Officer Walter Duffy's use of pepper spray violated Segrain's Eighth Amendment rights. It found that a reasonable jury could conclude that Duffy's use of pepper spray was excessive and not in good faith. The court vacated the district court's judgment on the Rhode Island Constitution Article I, Section 8 claim regarding Duffy's use of pepper spray and remanded for further proceedings. However, the court affirmed the district court's judgment on all other claims, including the leg-sweep maneuver and the delayed decontamination, granting qualified immunity to the officers on those issues. View "Segrain v. Duffy" on Justia Law

In this case, the petitioner, a state prisoner, challenged the dismissal of his federal habeas petition, which alleged violations of his constitutional rights under the Fifth, Sixth, and Fourteenth Amendments. The petitioner, along with two accomplices, planned and executed a robbery that resulted in the murder of a pizza delivery driver. The petitioner was convicted of first-degree murder, armed robbery, and breaking and entering, and was sentenced to life in prison without parole.The Massachusetts Supreme Judicial Court (SJC) affirmed the petitioner's conviction, rejecting his claims of insufficient evidence, improper admission of redacted statements from a co-defendant, and errors in jury instructions. The SJC found that the evidence was sufficient to support the petitioner's conviction under theories of felony-murder and extreme atrocity or cruelty. It also held that the redacted statements did not violate the petitioner's Confrontation Clause rights and that the trial court's jury instructions were appropriate.The United States Court of Appeals for the First Circuit reviewed the district court's denial of the habeas petition de novo. The court applied the standards set forth in the Antiterrorism and Effective Death Penalty Act (AEDPA), which requires deference to state court decisions unless they are contrary to or involve an unreasonable application of clearly established federal law, or are based on an unreasonable determination of the facts.The First Circuit affirmed the district court's decision, holding that the SJC's rulings were not unreasonable. The court found that the evidence was sufficient to support the petitioner's conviction, the redacted statements did not violate the Confrontation Clause, and the jury instructions were proper. The court also concluded that any errors in the trial court's rulings were harmless and did not prejudice the petitioner. View "St. Jean v. Marchilli" on Justia Law