Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's 2019 sentence in the District of Maine for one count of conspiracy to distribute and to possess with intent with distribute forty grams or more of fentanyl, holding that the sentence was not unreasonable.Defendant pled guilty pursuant to a plea agreement. Under the plea agreement, Defendant and the government agreed that they would both recommend a base offense level (BOL) under the Guidelines of twenty-eight. The district court, however, adopted the presentence investigation report's calculation of Defendant's guidelines sentencing range (GSR), which was based on a BOL of thirty. The Supreme Court affirmed the sentence, holding that the sentence was neither procedurally nor substantively unreasonable. View "United States v. Ayala" on Justia Law

The First Circuit affirmed the judgment of the district judge imposing three special conditions of supervised release after the revocation of Defendant's supervised release, holding that the special conditions were not unreasonable.On appeal, Defendant argued that the imposition of the conditions was procedurally unreasonable because the judge's explanation for the special conditions was insufficient and that the contested special conditions were substantively unreasonable. The First Circuit disagreed, holding (1) the special conditions were procedurally reasonable; and (2) Defendant's substantive unreasonableness challenge failed. View "United States v. McCullock" on Justia Law

The First Circuit denied Petitioners' petition for a writ of mandamus claiming that the district court erred in denying their bail application despite the ongoing COVID-19 pandemic, holding that the petition was without merit.Petitioners, immigration detainees held primarily at the Bristol County House of Correction, brought this petition for a writ of mandamus against Respondents, state immigration officials and federal United States Immigration and Customs Enforcement officials who secured Petitioners' detention after they were picked up and found to be in the United States illegally. Petitioners had all been denied bail and claimed that the district court erred in denying their bail applications. The First Circuit denied relief, holding that, under the circumstances of this case, there was no basis for either supervisory or advisory mandamus relief. View "Da Graca v. Souza" on Justia Law

The First Circuit affirmed the district court's order denying Defendant's motion for resentencing, holding that the district court did not abuse its discretion in denying the motion.In 2008, Defendant pleaded guilty to possession with intent to distribute and distribution of cocaine base. While Defendant was serving his 228-month term of immurement Congress passed the Fair Sentencing Act, Pub. L. No. 111-220, 124 Stat. 2372, which reduced the penalties for most federal crimes involving crack cocaine. Thereafter, Defendant filed his motion for resentencing. The district court denied the motion. The First Circuit affirmed, holding that the sentencing court weighed the proper factors and made a reasonable judgment. View "United States v. Concepcion" on Justia Law

The First Circuit denied Defendant's appeal of his conviction for unlawful possession of a firearm by a prohibited person in violation of 18 U.S.C. 922(g) and 924(a)(2), holding that the district court did not commit plain error by accepting Defendant's guilty plea and in denying his motion to suppress.Following Defendant's plea, the Supreme Court decided Rehaif v. United States, 139 S. Ct. 2191 (2019), under which the government must prove that the defendant knew he had the relevant status prohibiting possession. On appeal, Defendant argued (1) under Rehaif, the district court committed plain error during his plea colloquy by failing to inform him that the government was required to prove that he knew he was prohibited from possessing firearms; and (2) the district court erred by denying his motion to suppress. The First Circuit affirmed, holding (1) the search warrant issued for Defendant's residence was supported by probable cause; and (2) the district court did not plainly err by accepting Defendant's guilty plea. View "United States v. Austin" on Justia Law

The First Circuit affirmed Defendant's eighteen-month sentence imposed for violating the conditions of his supervised release by committing a new crime, holding that Defendant had not suffered any prejudice from the delay in his supervised release revocation hearing.The revocation hearing concluded thirty months after the the United States Probation Office petitioned the district court to revoke supervised release and eight months after Defendant was taken into federal custody. On appeal, Defendant argued that his revocation hearing was unreasonably delayed in violation of his rights under Fed. R. Crim. P. 32.1 and the due process clause of the United States Constitution. The First Circuit affirmed, holding that Defendant's claim failed on the prejudice prong. View "United States v. Torres-Santana" on Justia Law

The First Circuit dismissed this appeal of the district court's order sentencing Defendant to a seventy-eight-month term of immurement to be followed by five years of supervised release, holding that the court did not err by denying Defendant's request that the incarcerative portion of the sentence be ordered to run concurrently with any period of incarceration that might thereafter be imposed by the Puerto Rico courts in consequence of Defendant's violation of probation.Pursuant to a plea agreement, Defendant pleaded guilty to possession of child pornography. The agreement contained a waiver-of-appeal provision stipulating that, if the imprisonment sentence imposed was seventy-eight months, Defendant waived the right to appeal any aspect of the court's judgment and sentence. After Defendant was sentenced he challenged the district court's failure to run his sentence concurrently with any sentence that any Puerto Rico court might impose for the probation violation. The First Circuit affirmed, holding that there was no miscarriage of justice granting Defendant an exception to the enforcement of his appeal waiver. View "United States v. O'farrill-Lopez" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motion to strike the federal government's notice of intent to seek the death penalty (Death Notice) that was untimely filed, holding that the district court did not err in denying Defendant's motions to strike the Death Notice.Under the Local Rules for the United States District Court for the District of Puerto Rico the federal government, if seeking the death penalty, must file a Death Notice within 180 days of an indictment containing a death-eligible offense. A Puerto Rico federal grand jury returned a five-count indictment charging Defendant with three offenses punishable by death. The government, however, did not file a Death Notice until after the 180-day deadline had expired. After Defendant unsuccessfully moved to strike the death penalty he appealed. The First Circuit affirmed, holding that the district court did not abuse its discretion by denying the motion to strike without an evidentiary hearing because the purpose of the Local Criminal Rule was satisfied and the untimely filed Death Notice did not prejudice Defendant. View "United States v. Pedro-Vidal" on Justia Law

The First Circuit affirmed the judgment of the trial court convicting Defendants - Rolando Millan-Machuca, Roberto Casado-Berrios, Miguel Rivera-Calcano, and Giordano Santana-Meledez - of racketeering and drug trafficking conspiracies, holding that Defendants' claims on appeal were unavailing.Specifically, the First Circuit held (1) the evidence was sufficient to support the convictions; (2) there was no merit to Defendants' claims of error in the admission of certain evidence; (3) Defendants' sentences were reasonable; and (4) Rivera-Calcano's claims of ineffective assistance of counsel at his sentencing hearing is dismissed without prejudice. View "United States v. Millan-Machuca" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant of conspiracy to commit bank robbery, armed bank robbery, conspiracy to commit Hobbs Act robbery, and other offenses, holding that there was no prejudicial error in the proceedings below.Specifically, the First Circuit held (1) the district court did not err in denying Defendant's pretrial motion for severance; (2) the district court did not abuse its discretion in granting a protective order relating to certain discovery materials; (3) the district court did not abuse its discretion by declining to order the government to produce notes taken by law enforcement agents who interviewed a cooperating witness; and (4) Defendant was not entitled to relief on his remaining claims of error. View "United States v. Padilla-Galarza" on Justia Law