Justia Criminal Law Opinion Summaries
Articles Posted in US Court of Appeals for the First Circuit
United States v. Contreras-Delgado
The First Circuit affirmed the decision of the district court sentencing Defendant to forty-six months’ imprisonment in connection with Defendant’s plea of guilty to a charge of possessing a machine gun, holding that the sentence was neither procedurally flawed nor substantively unreasonable.Defendant’s guilty plea placed him in a federal guideline sentencing range (GSR) of twenty-four to thirty months’ imprisonment. After considering the facts of Defendant’s offense as well as other sentencing factors set forth in 18 U.S.C. 3553(a), the district court determined that a sentence above the GSR was appropriate and sentenced Defendant to forty-six months’ imprisonment and three years’ supervised release. The First Circuit affirmed, holding that the forty-six-month variant incarceration was neither procedurally nor substantively unreasonable. View "United States v. Contreras-Delgado" on Justia Law
United States v. Calderon-Lozano
The First Circuit affirmed the sentence imposed by the district court in connection with Defendant’s conviction of conspiracy to launder monetary instruments, holding that the sentence was both procedurally and substantively reasonable.Defendant received a guideline sentence of forty-six months of imprisonment for his conviction. On appeal, Defendant argued, among other things, that the district court abused its discretion by applying a six-level enhancement pursuant to U.S.S.G. 2S1.1(b)(1) when it was not proven that he knew his crime involved drug trafficking proceeds. The First Circuit affirmed, holding (1) there was ample evidence to establish by a preponderance of the evidence that Defendant knew that laundered funds were drug-trafficking proceeds; and (2) Defendant’s sentence was procedurally and substantively reasonable. View "United States v. Calderon-Lozano" on Justia Law
United States v. Ponzo
The First Circuit affirmed the judgment of the district court convicting Defendant on twelve federal criminal counts, including conspiracy to commit murder in aid of racketeering, Defendant’s lengthy prison sentence, and the $2.25 million money judgment forfeiture entered by the district court, holding that Defendant’s arguments on appeal were unavailing.Specifically, the Court held that the district court (1) did not manifestly abuse its discretion in denying Defendant’s motion for a new trial under Fed. R. Crim. P. 33 on the basis of what Defendant claimed was newly discovered evidence; and (2) did not abuse its discretion in ordering the forfeiture of a gold ring in partial satisfaction of the previously ordered money judgment forfeiture. View "United States v. Ponzo" on Justia Law
United States v. Aybar-Ulloa
The First Circuit affirmed Defendant’s convictions of two counts of drug trafficking in international waters while aboard a stateless vessel in violation of the Maritime Drug Law Enforcement Act (MDLEA), 46 U.S.C. 70501-08, holding that Defendant’s challenges to his convictions failed but that the district court erred in denying Defendant a minor participant reduction under section 3B1.2(b) of the Sentencing Guidelines.Specifically, the Court held (1) in light of prior precedent concerning Defendant’s assertion about the content of international law, the Court must reject Defendant’s constitutional contention regarding the scope of Congress’s power to criminalize his conduct that he argued lacked any nexus to the United States; and (2) because Amendment 794 to the Sentencing Guidelines, which added five factors to the application note, applies retroactively, this case must be remanded for resentencing so that the district court can have an opportunity to apply the new factors. View "United States v. Aybar-Ulloa" on Justia Law
Blue v. Medeiros
The First Circuit affirmed the dismissal of Petitioner’s petition for habeas corpus relief as time-barred under the one-year statute of limitations set forth in the Antiterrorism and Effective Death Penalty Act (AEDPA), 28 U.S.C. 2244(d)(1), holding that Petitioner was not entitled to relief based on his two tolling theories.As grounds for reconsideration of the dismissal of his habeas petition, Petitioner argued (1) the statute of limitations should be statutorily tolled during the pendency of his motion to stay the execution of his sentence because that motion constituted an application for collateral review under section 2244(d)(2); and (2) the circumstances surrounding his conviction justified equitable tolling of the time between the finality of his Massachusetts convictions and the filing of his habeas petition. The First Circuit disagreed, holding (1) Petitioner’s motion to stay the execution of his sentence was not a request for collateral review and therefore did not toll the one-year statute of limitations; and (2) there was no reason to disrupt the district court’s discretionary ruling on equitable tolling. View "Blue v. Medeiros" on Justia Law
United States v. Miller
The First Circuit affirmed Defendant’s conviction and sentence without prejudice to his right to raise his claim of ineffective assistance of counsel in a collateral proceeding brought pursuant to 28 U.S.C. 2255, holding that Defendant’s ineffective assistance of counsel claim ought not to be aired for the first time on direct appeal.Defendant pleaded guilty to violating the Mann Act, 18 U.S.C. 2423(a) and was sentenced to a 327-month term of immurement. On appeal, Defendant argued for the first time that he received ineffective assistance of counsel. The First Circuit affirmed, holding that this case did not qualify for an exception to the general rule that an ineffective assistance of counsel claim must first be raised in the district court. View "United States v. Miller" on Justia Law
United States v. Montanez-Quinones
The Supreme Court affirmed Defendant’s 109-month sentence for possession of child pornography, holding that the government did not violate the plea agreement in this case and that the district court did not err in applying an enhancement for knowingly distributing child pornography.Defendant entered a guilty plea to the charge of possession of child pornography. The district court sentenced Defendant to a 109-month term of immurement. On appeal, Defendant argued that the government breached the terms of the plea agreement by failing to advocate for the bargained-for sentence and that the district court’s finding that he knowingly distributed child pornography was in error. The First Circuit affirmed, holding (1) the district court did not err when it included a two-level enhancement for knowing distribution in its calculation of the guideline sentencing range; and (2) there was no breach of the plea agreement. View "United States v. Montanez-Quinones" on Justia Law
Walker v. Medeiros
The First Circuit affirmed the district court’s dismissal of Appellant’s federal petition for writ of habeas corpus filed pursuant to 28 U.S.C. 2254, holding that the district court did not err in dismissing the petition.In his petition, Appellant challenged his convictions under Massachusetts law for murder and other offenses, arguing that he received ineffective assistance of counsel, in violation of the Sixth Amendment to the United States Constitution. The district court denied relief. Because Appellant’s case was adjudicated on the merits in state court, the Antiterrorism and Effective Death Penalty Act’s (AEDPA) highly deferential standard of review applied. See 28 U.S.C. 2254(d). The First Circuit affirmed the district court’s denial of habeas relief, holding that any error on the part of counsel was not unsustainable under AEDPA’s deferential review standard. View "Walker v. Medeiros" on Justia Law
United States v. Sostre-Cintron
The First Circuit affirmed Defendant’s convictions and sentence for conspiring to defraud the United States and stealing government property in violation of 18 U.S.C. 371, 641, holding that there was sufficient evidence to support Defendant’s convictions and that the sentence was procedurally reasonable.Specifically, the First Circuit held (1) there was ample evidence from which a jury could have reasonably determined that Defendant was a knowing and willing participant in a fraudulent scheme of claiming eligibility for Social Security benefits and receiving nearly $100,000 in disability insurance disbursements to which he was not entitled; and (2) the district court’s imposition of Defendant’s sentence was procedurally sound. View "United States v. Sostre-Cintron" on Justia Law
Leite v. Goulet
In this 42 U.S.C. 1983 case, the First Circuit affirmed the judgment of the district court granting summary judgment in favor of Kathy Bergeron, a corrections officer, holding that no reasonable juror could conclude that Bergeron was deliberately indifferent to the health and safety of Plaintiff, an inmate, under the Eighth Amendment based on the facts presented by Plaintiff.Plaintiff was severely beaten by other inmates in a cell at a medium-security prison. In his complaint, Plaintiff alleged that Bergeron was deliberately indifferent while doing a round, leading to a delay in his being provided with medical treatment, which exacerbated his injuries. The district court granted summary judgment for Bergeron. The First Circuit affirmed, holding that Plaintiff failed to produce enough evidence for a jury to conclude that Bergeron had the requisite culpable state of mind of deliberate indifference to Plaintiff’s need for medical care. View "Leite v. Goulet" on Justia Law