Justia Criminal Law Opinion Summaries

The First Circuit affirmed Defendant's convictions and sentence for three counts of perjury and two counts of fraud and misuse of visas, permits, and other documents, holding that there was no reversible error in the proceedings below.Defendant's convictions were based on his alleged failure to disclose to immigration authorities the role he played in the Rwandan genocide. The First Circuit affirmed the convictions, holding (1) Defendant's challenges to certain statements made at trial by a government expert witness were unavailing; and (2) the district court did not err in calculating Defendant's sentencing range under the U.S. Sentencing Guidelines by applying a two-level, obstruction-of-justice enhancement. View "United States v. Teganya" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendants - James Stewart-Carrasquillo and Harold Esquilin-Montanez - of various narcotics offenses, holding that the evidence was sufficient to support the verdicts and that there was no prejudicial error.Specifically, the First Circuit held (1) the evidence was sufficient to sustain Defendants' convictions for, inter alia, aiding and abetting the possession with intent to distribute a controlled substance onboard a vessel subject to the jurisdiction of the United States; (2) the district court did not commit reversible error by excluding a demonstrative aid in the form of a videotaped "reenactment"; and (3) a misstatement made by the prosecutor during closing argument did not constitute reversible error. View "United States v. Stewart-Carrasquillo" on Justia Law

The First Circuit affirmed the judgment of the district court ruling that Appellant, a state prisoner, had not satisfied the good cause requirement for his failure to have exhausted his claim in state court, holding that the district court acted within the bounds of its discretion.Appellant was convicted in a Massachusetts superior court of assault and battery with a dangerous weapon and assault and battery with a dangerous weapon causing serious bodily injury. The Massachusetts Appeals Court affirmed, concluding that Appellant's claim that the trial court abused its discretion in excluding his proffered witness was waived. Appellant eventually filed a habeas petition in the federal district court. The district court denied Appellant's motion for a stay in abeyance and dismissed his habeas petition. The First Circuit affirmed, holding that Petitioner failed to satisfy the good cause requirement. View "Sena v. Kenneway" on Justia Law

The First Circuit summarily affirmed Appellant's sentence for possessing a firearm as a convicted felon, holding that the forty-eight-month sentence represented a defensible result.On appeal, Defendant argued that the upwardly variant sentence was substantively unreasonable because the district court imposed a sentence based on an incorrect statement of a material fact concerning Defendant's criminal history. The district court in this case, however, corrected its misstatement before imposing the sentence. The First Circuit summarily affirmed the sentence, holding that where the district court's brief mischaracterization of Defendant's prior offense was promptly corrected, the district court's sentencing rationale was plausible. View "United States v. Rodriguez-Cruz" on Justia Law

The First Circuit affirmed Defendant's conviction of Hobbs Act robbery, murdering a person through the use of firearm during a crime of violence, possessing a firearm in furtherance of a crime of violence, and being a convicted felon in possession of a firearm, holding that there was no error in the proceedings below.Specifically, the First Circuit held (1) under the circumstances of this case, the district court did not err in denying Defendant's motion to suppress identification evidence; (2) the evidence was sufficient to support Defendant's convictions; and (3) the district court did not err in determining that Hobbs Act robbery qualifies as a "crime of violence" under 18 U.S.C. 924(c). View "United States v. Seary-Colon" on Justia Law

The First Circuit affirmed the the district court's denial of Petitioner's petition filed pursuant to 28 U.S.C. 2255 to vacate, set aside, or correct his sentence, holding that the district court did not err in denying the motion.Petitioner pled guilty to one count of possession of a firearm and entered into a plea agreement with the government that included a sixty-month sentencing recommendation. At sentencing, the district court imposed a 120-month sentence. The First Circuit affirmed. Thereafter, Petitioner filed this petition asserting ineffective assistance of counsel. The district court denied relief. The First Circuit affirmed, holding that Petitioner was not prejudiced by counsel's failure to object to the discrepancy between two versions of events contained in the presentence investigation report. View "Fernandez-Garay v. United States" on Justia Law

The First Circuit affirmed the sentences imposed on Defendant after he pleaded guilty to one count of illegally possessing a firearm in violation of 18 U.S.C. 922(g)(1), holding that the sentences were substantively and procedurally reasonable.The district court sentenced Defendant to a within-guidelines sentence of forty-six months' imprisonment for violating section 922(g)(1), to be served consecutively with a sentence of eighteen months for violating the terms of his supervised release. Defendant appealed, arguing that the sentences were procedurally and substantively unreasonable. The First Circuit affirmed, holding that the sentences were both substantively and procedurally reasonable. View "United States v. Ayala-Lugo" on Justia Law

The First Circuit affirmed Defendant's conviction of conspiracy to commit various financial crimes, conspiracy to commit money laundering, and converting government property, holding that Defendant was not entitled to relief as to any of his assignments of error.This case arose from Defendant's participation, along with several coconspirators, in a scheme to defraud the federal government by falsifying tax returns. A jury convicted him of multiple counts, and the judge sentenced him to eighty-four months in jail. The First Circuit affirmed, holding (1) Defendant's claims of error in the trial judge's evidentiary rulings were unavailing; and (2) the judge properly applied two sentencing enhancements. View "United States v. Grullon" on Justia Law

The First Circuit affirmed the judgment of the district court sentencing Defendant in connection with his plea of guilty to the federal crime of carjacking, 18 U.S.C. 2119, holding that the sentence was reasonable.Prior to Defendant's guilty plea he entered into a plea agreement with the government stipulating a total offense level (TOL) but not a criminal history category (CHC). At sentencing, the district court calculated a higher TOL than the one in the plea agreement. Together with the court's CHC calculation, the calculated TOL resulted in a higher sentencing range than that set out in the plea agreement. The First Circuit affirmed the sentence, holding (1) the district court committed no procedural errors during sentencing; and (2) Defendant's sentence was substantively reasonable. View "United States v. Pupo" on Justia Law

The First Circuit affirmed Defendant's sentence of 135 months' imprisonment imposed in connection with his plea of guilty to conspiracy to possess with intent to distribute five kilograms or more of cocaine on board a vessel subject to the jurisdiction of the United States and other drug-related crimes, holding that Defendant's sentence was not unreasonable.On appeal, Defendant argued that the district court procedurally erred by failing to apply an adjustment for his role in the offense and a departure based on his family responsibilities. The First Circuit affirmed, holding that the district court (1) did not err in refusing to grant a reduction to Defendant's offense based on his allegedly minor role in the crime; and (2) did not err in refusing to grant a departure based on Defendant's family ties and responsibilities. View "United States v. Castillo-Vazquez" on Justia Law