Justia Criminal Law Opinion Summaries

The First Circuit affirmed the judgment of the district court denying Defendant's motion to withdraw his guilty plea and motions related to his sentencing, holding that the record withstood Defendant's multiple claims of error.Defendant entered a straight guilty plea to forty-eight counts of an indictment charging him with fraud-based crimes. The district court denied Defendant's subsequent motion to withdraw his guilty plea and other sentencing-related motions and sentenced Defendant to 132 months' imprisonment and ordered him to make restitution in the amount of $7,737,486.10. The First Circuit affirmed, holding (1) the district court did not abuse its discretion in refusing to allow Defendant to retract his guilty plea; (2) the district court did not err in applying a two-level enhancement for crimes involving ten or more victims; (3) the district court did not err in calculating the amount of loss attributable to the offenses of conviction; (4) the district court did not abuse its discretion in denying Defendant's motion to compel production of materials three days before his scheduled sentencing; (5) the district court did not err in denying Defendant's motion for an evidentiary hearing at sentencing; (6) Defendant's due process rights were not violated during sentencing; and (7) there was no plain error in the district court's restitution order. View "United States v. Flete-Garcia" on Justia Law

The First Circuit reversed the district court's dismissal of Petitioner's petition for postconviction relief, holding that trial counsel's failure to consult with Petitioner about an appeal deprived Petitioner of an appeal that he otherwise would have taken.This appeal required the First Circuit to apply the presumption of prejudice set forth in Roe v. Flores-Ortega, 528 U.S. 470 (2000), in circumstances in which a defense attorney violates his or her duty to consult with a client about an appeal when the defendant reasonably demonstrated that he or she was interested in appealing or when a rational defendant would want to appeal. In the instant case, Petitioner previously executed a plea agreement containing a waiver-of-appeal provision. Petitioner filed a pro se petition to vacate his sentence pursuant to 28 U.S.C. 2255, claiming that trial counsel was ineffective for failing to file a notice of appeal. The district court held that Flores-Ortega's presumption of prejudice was inapposite because Petitioner had executed an appeal waiver. The First Circuit reversed, holding that trial counsel did not properly discharge his duty to consult and that counsel's constitutionally deficient performance prejudiced Petitioner by depriving him of an appeal that he otherwise would have taken. View "Rojas-Medina v. United States" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Appellant's habeas petition under 28 U.S.C. 2254, holding that the district court did not err in determining that the Massachusetts Supreme Judicial Court (SJC) acted reasonably in concluding that the evidence was sufficient to support the conviction.Appellant was convicted in state court of first-degree murder. The SJC affirmed Appellant's convictions and found that the evidence was constitutionally sufficient to support the first-degree murder conviction. Appellant later filed a petition for a writ of habeas corpus in a federal district court, challenging the sufficiency of the evidence grounding his murder conviction. The district court denied the petition. The First Circuit affirmed, holding that the SJC's rejection of Appellant's sufficiency claim was objectively reasonable. View "Roman v. Mitchell" on Justia Law

The First Circuit affirmed the sentence imposed by the district court in connection with Appellant's plea of guilty to sex trafficking crimes pursuant to a plea agreement, holding that Appellant's claims on appeal failed.Appellant pleaded guilty pursuant to a plea agreement and was sentenced to 216 months of imprisonment. Appellant appealed, seeking a new sentencing hearing partially on the grounds that the prosecution breached the plea agreement by providing information to Probation and the court regarding victims of sex trafficking who were either covered by counts that were dismissed as part of the plea agreement or who were never included in any counts in the indictment. The First Circuit affirmed, holding (1) Appellant's breach claim fell within the plain language of the exemption from the appellate waiver in the plea agreement; (2) the government did not breach the plea agreement; and (3) the appellate waiver in the plea agreement barred Appellant's appeal on the issue of inadequate notice regarding victim statements presented at the sentencing hearing. View "United States v. Davis" on Justia Law

The First Circuit affirmed Defendant's conviction of possessing child pornography and transporting a minor with the intent to engage in criminal sexual activity, holding that there was sufficient evidence to support the conviction of possessing child pornography and that Defendant waived his argument that the prosecutor committed misconduct during closing argument.On appeal, Defendant argued that that the government did not adequately prove that he possessed images of minors and that the photos could be not considered child pornography because the the government failed to show they were "lascivious." The First Circuit disagreed, holding (1) with the evidence presented, a rational jury could find, beyond a reasonable doubt, that the images admitted into evidence contained minors, and a jury reasonably could deem the photos were "lascivious"; and (2) Defendant waived his argument that the prosecutor's comments during summation were so improper and prejudicial as to require a new trial. View "United States v. Charriez-Rolon" on Justia Law

The First Circuit affirmed the district court's grant of a preliminary injunction compelling Defendants to provide Plaintiff with medication while she is incarcerated, holding that the district court properly found that a preliminary injunction was warranted under the circumstances of this case.Plaintiff, who was due to be incarcerated for forty days in the county jail, was informed that she was not to receive her twice daily dose of buprenorphine prescribed for an "opioid use disorder" while incarcerated. Plaintiff brought this suit seeking injunctive relief compelling Defendants to provide her medication while she was incarcerated. The district court found a sufficient likelihood of success combined with both a strong balance of harms and a public interest in favor of Plaintiff so as to warrant a preliminary injunction. The First Circuit affirmed, holding that the district court did not abuse its discretion in its preliminary assessment of the issues that must be balanced in deciding a request for preliminary injunctive relief. View "Smith v. Aroostook County" on Justia Law

The First Circuit affirmed the district court's grant of summary judgment to the Puerto Rico Ports Authority (the PRPA) on Plaintiffs' suit alleging that the PRPA violated the First Amendmen and Puerto Rico law by terminating Plaintiff's employment, holding that Plaintiffs' claims were barred by res judicata.Daniel Grajales, his wife, their children brought this suit under 42 U.S.C. 1983 and Puerto Rico law against the PRPA alleging that Grajales was transferred to a new job location and subsequently terminated from his employment because of both his political affiliation and his reporting of alleged safety violations by PRPA employees. Just before Grajales filed his federal complaint, the Secretary of Labor and Human Resources of Puerto Rico filed a civil complaint against the PRPA in the Puerto Rico Court of First Instance, which entered judgment for the PRPA. The PRPA moved for summary judgment in the federal case on res judicata grounds in light of the Court of First Instance's ruling. The district court ruled in favor of the PRPA. The First Circuit affirmed, holding (1) the district court properly found that the two actions shared a "common nucleus of operative fact"; (2) Grajales's claims were barred by res judicata; and (3) the derivative claims of Grajales's family members necessarily failed. View "Grajales v. Puerto Rico Ports Authority" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motions to suppress evidence and to dismiss his indictment for outrageous government conduct, holding that the district court did not err in its judgment.Defendant was identified as a user of Playpen, an online forum that allowed users to upload, download, and distribute child pornography, and indicted for possession and receipt of child pornography. Defendant moved to suppress evidence resulting from an Network Investigative Technique warrant and also sought to dismiss the indictment on the grounds that the government engaged in outrageous conduct by running Playpen for two weeks after seizing its control. The district court denied the two motions. Defendant subsequently pled guilty to both charges. The First Circuit affirmed, holding (1) the district court correctly denied Defendant's motion to suppress for lack of probable cause; and (2) under the totality of the circumstances, there were no grounds to reverse the district court's denial of Defendant's motion to dismiss the indictment. View "United States v. Anzalone" on Justia Law

The First Circuit affirmed the judgment of the district court sentencing Appellant to a prison term of 240 months after Appellant pleaded guilty to transporting a minor with the intent to engage in criminal sexual activity, holding that there was no plain error in the judgment below.On appeal, Appellant claimed that the prosecutor engaged in various incidents of an alleged breach of the plea agreement during the disposition hearing. The First Circuit disagreed, holding (1) the waiver-of-appeal provision in the plea agreement did not apply to the sentence actually imposed by the district court; (2) the government's statement that it made a "sweetheart deal" to avoid exposing the victim to the rigors of trial did not breach the agreement; (3) the prosecutor did not breach the agreement by recounting the offense characteristics and explaining why those characteristics justified the prosecutor's recommended sentence; and (4) the prosecutor did not breach the agreement by undermining the foundation on which the the prosecutor's proposed sentence rested. View "United States v. Colon-Rosario" on Justia Law

The First Circuit affirmed Defendant's sentence of sixty months' imprisonment imposed after Defendant pleaded guilty to illegal possession of a machine gun and to being a felon in possession of three firearms and ammunition, holding that there was no plain error in the imposition of the sentence.On appeal, Defendant argued that the district court committed procedural error when it chose not to, before imposing its sentence, definitively determine whether the guidelines sentencing range (GSR) proposed in the presentence report or the guidelines calculation agreed to in the plea agreement was correct. Instead, the district court based its sentence on the other sentencing factors listed in 18 U.S.C. 3553(a). The First Circuit affirmed, holding that, in light of the district court's statements that the sentence would have been the same under any of the proposed GSRs, there was no prejudice. Further, the district court's rationale was plausible and led to a defensible sentence, and therefore, the sentence was not substantively flawed. View "United States v. Ortiz-Alvarez" on Justia Law