Justia Criminal Law Opinion Summaries

The First Circuit affirmed the judgment of the district court sentencing Appellants to terms of imprisonment and imposing conditions of supervised release on all Appellants, including "Standard Condition of Supervised Release Number 12," holding that Appellants' constitutional challenges to Standard Condition 12 failed on the merits.Appellants - Akeem Cruz, Taylor Lovely, and Jeremiah Mitchell - pleaded guilty to drug-related crimes and were each sentenced to a term of imprisonment followed by supervised release. The district courts imposed conditions of supervised release on all Appellants, including Standard Condition 12. For the first time on appeal, Appellants argued that Standard Condition 12 was unconstitutionally vague and an unconstitutional delegation of judicial authority. The First Circuit affirmed, holding that the Standard Condition 12 is neither unconstitutionally vague, nor does it unconstitutionally delegate judicial authority to a probation officer. View "United States v. Cruz" on Justia Law

The First Circuit affirmed Defendant's conviction for drug-trafficking and firearms charges, holding that the district court did not err in denying Defendant's motion to suppress or in finding Defendant eligible for a mandatory minimum sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924 (e).Reports of a parking-lot confrontation following a road-rage incident led law enforcement to stop Defendant in his vehicle the next day. The ensuing searches of Defendant's car and motor home led to the discovery of evidence supporting drug-trafficking and firearms charges. Defendant pleaded guilty. The First Circuit affirmed Defendant's conviction and sentence, holding (1) there was no error in the district court's denial of Defendant's motion to suppress; and (2) Defendant's sentence under the ACCA was lawfully imposed. View "United States v. Mulkern" on Justia Law

The First Circuit affirmed Defendant's conviction, entered upon his guilty plea, for one count of being a felon in possession of a firearm and sentence of fifteen years of incarceration followed by three years of supervised release, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant failed to establish plain error on his argument that his plea colloquy was facially invalid because of an omission that rendered his guilty plea unknowing and involuntary; (2) Defendant waived his right challenge the sufficiency of the indictment by pleading guilty; (3) although Defendant's challenge to the government's failure to file substantial assistance motions fell outside the scope of the appeal waiver, this Court nevertheless holds that the district court did not err in declining to hear evidence before sentencing; (4) Defendant's prior convictions under the Massachusetts drug distribution statute were properly characterized as Armed Career Criminal Act predicates; and (5) the district court did not err in deciding to proceed with sentencing despite argument from defense counsel that the government had failed to honor the terms of a cooperation agreement. View "United States v. Doe" on Justia Law

The First Circuit affirmed the convictions of Appellants Edilio Benjamin-Hernandez (Benjamin) and Johanni Balbuena-Hernandez (Balbuena) on multiple charges stemming from a conspiracy to transport cocaine from the Dominican Republic to Puerto Rico, holding that Appellants were not entitled to relief on their claims of error.On appeal, Appellants challenged the district court's denial of their motion to dismiss and argued that the evidence presented at trial was insufficient to support the convictions. Benjamin also raised two evidentiary challenges. The First Circuit affirmed, holding (1) there was no violation of the Speedy Trial Act's seventy-day limit; (2) no Sixth Amendment violation occurred in this case; and (3) there was sufficient evidence supporting Appellants' convictions. View "United States v. Benjamin-Hernandez" on Justia Law

The First Circuit affirmed the judgment of a federal district judge in Maine sentencing Defendant on drug-distribution and communications-device counts, holding that the sentence was neither procedurally nor substantively unreasonable.In 2019, a Maine federal grand jury indicted Defendant for possessing drugs (crack and heroin) with intent to distribute and for using a communications device to commit a drug crime. Defendant pled guilty. The Maine federal judge varied downwards to 137 months and structured his term to run concurrently with the remainder of a Connecticut sentence. The First Circuit affirmed the sentence imposed, holding that nothing Defendant argued on appeal persuaded the Court that his below-guidelines sentence was implausible or indefensible. View "United States v. Perry" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motion to withdraw his guilty plea and sentencing him to consecutive sentences of life imprisonment for discharging a firearm during and in relation to a crime of violence resulting in death and attempted carjacking, holding that there was no error or abuse of discretion.On appeal, Defendant argued that the district court abused its discretion in denying his motion to withdraw his guilty plea and that his sentence was neither procedurally nor substantively reasonable. The First Circuit disagreed and affirmed, holding (1) the district court did not abuse its discretion in denying Defendant's motion to withdraw his guilty plea; and (2) there was no significant procedural or substantive error. View "United States v. Bruzon-Velazquez" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's latest request to withdraw his guilty plea to conspiring to import Cocaine into the United States and money laundering to promote this conspiracy, holding that the district court did not err in denying Defendant's motion to withdraw his guilty plea.Multiple times before he was sentenced Defendant filed motions to withdraw his guilty plea. As to Defendant's most recent withdrawal motion, the magistrate judge recommended that the district court grant the motion. The district court disagreed and denied Defendant's request to withdraw his plea. The First Circuit affirmed, holding (1) the district court's analysis of the plea withdrawal motion was flawed in two respects, but the district court did not abuse its discretion in denying Defendant's motion to withdraw the guilty plea; and (2) the district court did not err in exercising jurisdiction over Defendant. View "United States v. Fonseca" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant of one count of possession with intent to distribute fentanyl and cocaine base after a traffic stop near Wells, Maine, holding that the district court did not commit plain error in accepting Defendant's guilty plea.On appeal, Defendant argued that the district court impermissibly failed to advise him that he was giving up the right to file pretrial motions at his Rule 11 hearing and that this Court should reverse the denial of his motion to withdraw his guilty plea. The First Circuit affirmed, holding that Defendant's claim on appeal was meritless. View "United States v. Williams" on Justia Law

On the government's appeal from the district court's grant of Appellant's motion for compassionate release the First Circuit reversed, holding that remand was required for further review.Nearly thirty years ago, Appellant was convicted of several crimes stemming from his role in a 1991 car bombing and sentenced to life imprisonment. The district court later concluded that a sentencing error constituted an "extraordinary and compelling" reason to grant compassionate release and reduced Appellant's sentence to forty-one years, crediting time served. The First Circuit reversed, holding that remand was required for further proceedings with the benefit of guidance of United States v. Ruvalcaba, 46 F.4th 14 (1st Cir. 2022). View "United States v. Trenkler" on Justia Law

The Supreme Court remanded this immigration case to the Boards of Immigration Appeals (BIA) after it affirmed an immigration judge's (IJ) decision to deny Petitioner's applications for relief from removal based on two marijuana offenses found by the IJ and the BIA to be "particularly serious" pursuant to 8 U.S.C. 1158(b)(2)(A)(ii) and 1231(b)(3)(B)(ii), holding that remand was required.The IJ found Petitioner removable based on two Massachusetts state court convictions involving marijuana. The BIA upheld the IJ's determination that Petitioner was ineligible for asylum and withholding of removal for having been convicted of a particularly serious crime. The Supreme Court granted Petitioner's petition for review, holding that there was not a sufficient rational explanation to explain the BIA's conclusion that Petitioner's minor marijuana offenses were particularly serious crimes and that remand was required. View "Dor v. Garland" on Justia Law