Justia Criminal Law Opinion Summaries

The First Circuit affirmed the judgment of the district court revoking Defendant's supervised release on the underlying conviction of failing to register as a sex offender, in violation of federal law, holding that Defendant's challenges on appeal were unavailing.In revoking Defendant's supervised release, the district court found that Defendant, upon his release from prison, once again failed to register as a sex offender, thus violating the conditions of his release, as well as state and federal law. On appeal, Defendant argued that the district court abused its discretion by not excusing his failure to register and that his sentence was unreasonable. The First Circuit affirmed, holding (1) the district court did not abuse its discretion in finding that Defendant violated the terms of his supervised release; and (2) Defendant's sentence was procedurally and substantively reasonable. View "United States v. Picard" on Justia Law

The First Circuit affirmed Defendant's sentence of sixty months imprisonment for being a felon in possession of a firearm, holding that the district court did not abuse its discretion in sentencing Defendant.Defendant's Guidelines Sentencing Range was thirty-seven to forty-six months in prison. The district court, however, sentenced Defendant to sixty months. The First Circuit affirmed the sentence, holding (1) the district court did not base his sentence on unreliable information in the form of a description in the presentence report of a juvenile burglary conviction in Puerto Rico court; (2) the judge imposed a variance, rather than a departure; and (3) Defendant was not entitled to relief on his remaining claims of error. View "United States v. Ayala-Landor" on Justia Law

The First Circuit affirmed the judgment of the district court sentencing Defendant to eighty-seven months for engaging in firearms trafficking without a license and conspiring to commit an offense against the United States, holding that the sentence was not unreasonable.Defendant's crimes violated the terms of two supervised release sentences, leading to the revocation of both and two consecutive sentences of imprisonment. For his crimes, Defendant was sentenced to eighty-seven months in prison, to be served consecutively to the revocation sentences. On appeal, Defendant argued that the district court erred by viewing the Sentencing Guidelines as mandatory. The First Circuit affirmed, holding that Defendant's claims on appeal were without merit. View "United States v. Zayas-Burgos" on Justia Law

The First Circuit affirmed Defendant's conviction of unlawful reentry into the United States, in violation of 8 U.S.C. 1326(a), holding that Defendant's claims of error were without merit.On appeal, Defendant challenged the government's introduction into evidence under Fed. R. Evid. 803(8) of a so-called I-296 form. The First Circuit affirmed, holding (1) Defendant failed to demonstrate that the district court committed plain error in admitting the I-296 document into evidence; and (2) the record adequately supported a finding that the "previously removed" element of the statute of conviction was met, and therefore, Defendant's motion for judgment of acquittal was properly denied. View "United States v. Fuentes-Lopez" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's petition for a writ of habeas corpus, holding that Appellant was not entitled to relief.Appellant was convicted in Massachusetts of murder in the first degree. The Massachusetts Supreme Judicial Court affirmed. In his habeas petition, Appellant argued that testimony was erroneously introduced at trial that he had given to a grand jury without being advised of his privilege against self-incrimination. Appellant presented this same argument in his challenge to his conviction on appeal and in his appeal of the denial of his motion for a new trial, all without success. The district court denied Appellant's habeas petition. The Supreme Judicial Court affirmed, holding that Appellant's Fifth Amendment rights were not violated by the admission of his grand jury testimony. View "Woods v. Medeiros" on Justia Law

The First Circuit vacated Defendant's convictions on six counts relating to public corruption in the Commonwealth, holding that the district court's refusal to sever Defendant's trial from that of one of her codefendants was an abuse of discretion.Defendant worked as the administrator of the Puerto Rico Workforce Development Administration (ADL) for two years before she was charged with various federal offenses relating to public corruption. Defendant was tried jointly with three other individuals who were also charged in the indictment and convicted of all six counts that she faced. The First Circuit vacated the convictions, holding (1) there was sufficient evidence in the record supporting the convictions; but (2) the district court abused its discretion in declining to sever Defendant's trial from that of her codefendant, and the resulting prejudice was such that the matter must be remanded for a new trial. View "United States v. Lopez-Martinez" on Justia Law

The First Circuit affirmed Defendant's conviction for conspiring to commit drug trafficking offenses but remanded the case for resentencing, holding that the district court erred in imposing a two-level enhancement to Defendant's base offense level.A jury convicted Defendant of conspiracy to possess with intent to distribute a controlled substance and conspiracy to import narcotics into the United States, and the district court imposed a sentence of approximately 224 months, reflecting a sentence at the lowest end of the recommended range. The First Circuit affirmed, holding (1) the trial court erred in permitting the government to solicit "overview" testimony and in allowing the government to present evidence relating to a previous cocaine seizure, but both errors were harmless; and (2) while Defendant's claim that there was an unwarranted disparity between his sentence and those of his codefendants lacked merit, the district court erred by imposing a supervisory role enhancement without identifying evidence that Defendant played a supervisory role in the conspiracy. View "United States v. Garcia-Sierra" on Justia Law

The First Circuit affirmed the order of the district court imposing a sanction against Appellant under Fed. R. Civ. P. 11, holding that the district court did not abuse its discretion.Appellant was a Massachusetts lawyer who brought suit on behalf of Gerald Alston, a black man who formerly worked as a firefighter. Defendant Stanley Spiegel eventually moved to dismiss and for sanctions. The magistrate judge recommended that the district court dismiss the claims against Spiegel with prejudice and ruled that sanctions were in order. The First Circuit affirmed, holding that because Appellant persisted in pursuing claims against Spiegel without an adequate basis in law or fact and despite a warning from the magistrate judge, sanctions were in order. View "Ames v. Spiegel" on Justia Law

The First Circuit affirmed Defendant's conviction of one count of possession with intent to distribute various controlled substance and one count of possession of a firearm in furtherance of a drug-trafficking crime, holding that the district court did not err in denying Defendant's motion to suppress.Defendant sought to suppress drug evidence and a firearm seized pursuant to a search warrant for the car he was driving when he was arrested on an outstanding federal warrant. In his motion, Defendant argued that the search warrant for the car was invalid because it was issued based on an unlawful inventory search. The First Circuit affirmed the denial of Defendant's motion to suppress, holding that the district court did not err in concluding that (1) the officers had an objectively reasonable non-investigatory purpose; and (2) the inventory search of the car was unlawful. View "United States v. Sylvester" on Justia Law

The First Circuit affirmed the sentence imposed on Defendant after he pled guilty to unlawfully possessing a machine-gun, 18 U.S.C. 922(o), and being a felon in possession of a firearm, 18 U.S.C. 922(g)(1), holding that the sentence was reasonable.Defendant's Guidelines Sentencing Range was sixty-three to seventy-eight months. The district judge, however, sentenced Defendant to 100 months' imprisonment and two years of supervised release. The First Circuit affirmed the sentence, holding (1) where it was ambiguous whether the district court imposed a variance or departure, any error was harmless; and (2) the court's focus on Defendant's past convictions did not take the sentence out of the range of reasonable sentences, and the court did not consider Defendant's history of drug use. View "United States v. Laboy-Nadal" on Justia Law