Justia Criminal Law Opinion Summaries

David Wright was indicted for conspiracy to provide material support to a designated foreign terrorist organization, conspiracy to obstruct justice, obstruction of justice, and aiding and abetting. Superseding indictments added a count for conspiracy to commit acts of terrorism transcending national boundaries and an additional count for obstruction of justice. A jury convicted Wright on all counts, and the district court sentenced him to 28 years' imprisonment and lifetime supervised release. On appeal, the United States Court of Appeals for the First Circuit affirmed Wright's convictions on all counts except for the material-support count, which was overturned due to an error in the jury instructions. The case was remanded to the district court for further proceedings.Upon remand, the government dismissed the material-support count, and an amended judgment was issued. After a resentencing hearing before a different judge, Wright was sentenced to 30 years' imprisonment, two years more than before, and lifetime supervised release. Wright appealed his sentence, arguing that it was procedurally and substantively unreasonable. He claimed that the sentencing court made a "grouping" error that affected his sentence and that the court failed to adequately explain its upwardly variant sentence.The Court of Appeals found that any grouping error had no impact on Wright's sentence and that the court provided an adequate explanation for its variant sentence. The court affirmed Wright's 30-year sentence and lifetime supervised release. View "United States v. Wright" on Justia Law

The case involves Miguel F. Ramirez-Ayala, who pleaded guilty to illegal possession of firearms and controlled substances in 2015. After serving his federal prison sentence, he began a three-year supervised-release term. However, within a year, Ramirez-Ayala violated his supervised-release conditions by possessing controlled substances and a firearm, among other violations. This led to a revocation sentence of eighteen months, after which he began another supervised-release term. During this second term, Ramirez-Ayala committed multiple violations, including drug and firearm possession, and evaded police in a high-speed car chase. In 2021, he pleaded guilty to these most recent drug and firearm possession charges, leading to another round of revocation proceedings.The district court sentenced Ramirez-Ayala to twenty-four months' imprisonment, the maximum revocation sentence, to be served consecutively to his new conviction. He appealed, arguing that the district court sentenced him in a procedurally and substantively unreasonable manner.The United States Court of Appeals for the First Circuit found no error in the district court's decision. The court noted that the district court had considered the relevant factors, including the seriousness of Ramirez-Ayala's violations, his repeated violations of supervised-release conditions, and his disregard for the law and public safety. The court concluded that the district court's upward variance in sentencing was reasonable given these circumstances. Therefore, the court affirmed the district court's decision. View "US v. Ramirez-Ayala" on Justia Law

The plaintiff, John Deaton, was arrested and charged with assault, battery, and disorderly conduct following an altercation at a youth football game. Although the charges were later dismissed, Deaton filed state and federal claims against the Town of Barrington and several individuals, including police officers and the town manager. The case was removed from state court to the United States District Court for the District of Rhode Island. The district court granted summary judgment in favor of the defendants on most counts and remanded three counts to the state court for resolution. Deaton appealed, arguing that the district court improperly found that probable cause to arrest him existed, improperly denied his post-judgment motion, and should have abstained and remanded to state court to allow the state claims to be resolved.The district court had granted summary judgment in favor of the defendants, finding that there was probable cause for Deaton's arrest. The court also denied Deaton's post-judgment motion for relief. Deaton appealed these decisions, arguing that the district court had improperly found probable cause for his arrest, improperly denied his post-judgment motion, and should have abstained from hearing the case and remanded it to state court.The United States Court of Appeals for the First Circuit affirmed the district court's decisions. The court found that the district court had correctly determined that there was probable cause for Deaton's arrest. The court also found that the district court had not erred in denying Deaton's post-judgment motion for relief. Finally, the court determined that abstention was not appropriate in this case, as resolution of the state law question would not avoid the need to resolve a significant federal constitutional question. View "Deaton v. Town of Barrington" on Justia Law

The case involves Andy G. Morales-Veléz, who appealed two rulings related to his guilty plea for possessing a firearm in furtherance of a drug trafficking crime. Morales argued that his 120-month sentence was both procedurally and substantively unreasonable because the district court did not provide adequate justification for imposing a higher sentence than that recommended by the U.S. Sentencing Guidelines. He also contended that the district court erred by refusing to consider his motion to return $20,000 in cash the government seized from his vehicle during his arrest.The district court had denied Morales's motion to return the seized cash, arguing that a separate civil forfeiture proceeding against the money had already commenced. At the sentencing hearing, the court imposed a sentence of 120 months, higher than the parties' proposed ninety-six-month sentence, based on the fact that Morales possessed not only a machine gun but four magazines, two of which were high capacity, and 125 rounds of radically invasive projectiles.The United States Court of Appeals for the First Circuit affirmed the district court's rulings. The court found that the district court provided an adequate explanation for the upward variance in Morales's sentence, considering the nature of the machine gun and the amount of ammunition found with the gun. The court also concluded that Morales's claims regarding the return of the seized cash were moot because he had reached a settlement with the government over the seized $20,000. View "United States v. Morales-Velez" on Justia Law

The case involves Maximiliano Fígaro-Benjamín, a co-conspirator in a multi-defendant drug conspiracy case. Fígaro-Benjamín was part of a crew that transported cocaine between Puerto Rico and St. Thomas on a vessel named the Black Wolfpack. The crew was intercepted by federal agents in January 2018. Fígaro-Benjamín was charged with conspiracy to possess with intent to distribute controlled substances and conspiracy to import controlled substances into the U.S. He pleaded guilty and was sentenced to 292 months in prison.Fígaro-Benjamín appealed his sentence, arguing that the district court relied on unreliable evidence at sentencing and incorrectly calculated his sentence. He also claimed that the court did not adequately explain its sentence. His arguments were based on the testimony of a co-conspirator, José Javier Resto Miranda, who testified at the trial of Fígaro-Benjamín's co-defendants.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court found that Fígaro-Benjamín's arguments did not hold up. It ruled that the sentencing court did not err in considering Resto's testimony, which was reliable and corroborated by other evidence. The court also found that the sentencing court correctly calculated Fígaro-Benjamín's guidelines sentencing range and did not err in finding that he was a supervisor in the trafficking operation. Lastly, the court found that the sentencing court adequately explained its sentence. View "US v. Figaro-Benjamin" on Justia Law

The case involves Joel Dudley, who was appealing the 2023 revocation of his supervised release and his sentence of two terms of two years of incarceration, to be served consecutively, followed by supervised release for life. The revocation was the second one from his prior convictions in 2014 for possession of child pornography and making a false declaration before the court. The revocation was based on the district court's finding that he had violated five conditions of his supervised release, including by sharing images of himself sexually abusing his daughter when she was approximately four years old and engaging in sexual contact with, exchanging sexually explicit messages with, and receiving and possessing pornographic video of his daughter when she was seventeen years old.Previously, Dudley had been found guilty on both counts at two separate jury trials. His supervised release was first revoked in 2019 after he violated the conditions of his release by failing to update his sex offender registration and having other individuals access the internet on his behalf. His supervised release was again revoked in 2020 after he had unapproved contact with his daughter, exchanged sexually explicit messages with her, and used an unreported cell phone number and Facebook account under a false name.The United States Court of Appeals for the First Circuit held that the district court judge did not err or abuse his discretion in revoking Dudley's supervised release and that Dudley's sentence is procedurally and substantively reasonable. The court affirmed the decision of the lower court. View "United States v. Dudley" on Justia Law

The case involves Hassan Abbas, who was convicted on several counts of wire fraud and money laundering. Abbas was found guilty of participating in an email-based fraud scheme that targeted citizens of Massachusetts. He appealed his conviction on several grounds, including the appropriateness of Massachusetts as the venue for his trial.In the lower courts, Abbas challenged the venue for his trial, arguing that the wire fraud and money laundering activities did not occur in Massachusetts. The district court denied his motion, determining that the issue of when the wired funds became "proceeds" was not capable of resolution before the trial.Upon review, the United States Court of Appeals for the First Circuit affirmed Abbas's convictions for wire fraud but vacated his convictions for money laundering. The court found that the money sent from the victims did not become "proceeds" until it reached Abbas's bank accounts in Illinois and California. Therefore, Abbas did not "participate in the transfer of proceeds" from Massachusetts, making Massachusetts an improper venue for the money laundering charges. The court remanded the case for resentencing and recalculation of restitution. View "US v. Abbas" on Justia Law

The defendant, Antonio Santonastaso, was convicted of making a false statement to federal investigators and attempted witness tampering. The charges stemmed from a 2018 investigation by the Federal Aviation Administration (FAA) into allegations that Santonastaso was flying a helicopter without the necessary certifications. During the investigation, Santonastaso falsely claimed that he had the requisite certifications to fly and that his previous involvement in a 2000 helicopter theft was part of an undercover operation.The case was first heard in the United States District Court for the District of Massachusetts, where Santonastaso was found guilty. He appealed the decision, arguing that the government's evidence was insufficient to prove his guilt and that the district court erred by not giving a materiality instruction based on the Supreme Court's decision in Maslenjak v. United States.The United States Court of Appeals for the First Circuit affirmed the lower court's decision. The court found that the evidence was sufficient for the jury to find Santonastaso guilty of making a false statement to federal investigators and attempted witness tampering. The court also ruled that the district court did not commit instructional error in rejecting Santonastaso's proposed materiality instruction. The court held that the law-of-the-circuit doctrine foreclosed the application of the Maslenjak materiality standard to § 1001(a) prosecutions, and that the district court's instruction correctly stated the controlling law on materiality. View "United States v. Santonastaso" on Justia Law

The case involves Reynaldo Rosa-Borges, who was sentenced to 72 months for unlawful firearm possession and 36 months for violating the terms of his supervised release from a previous conviction. The firearm and ammunition were discovered during two separate incidents. The first incident occurred when Rosa-Borges was found with a firearm during a police patrol at a beach. The second incident happened the following day when police searched Rosa-Borges' residence and found additional ammunition. Rosa-Borges' brother, Naim, claimed that the ammunition belonged to Rosa-Borges.In the lower courts, Rosa-Borges pleaded guilty to the charges. However, he disputed the claim that he possessed the additional 100 rounds of ammunition found at his residence, arguing that the information was derived from unreliable hearsay from his brother, who had a motive to avoid his own criminal liability. Despite these objections, the district court sentenced Rosa-Borges to a total of 108 months in prison.On appeal, the United States Court of Appeals for the First Circuit vacated and remanded the case for resentencing. The appellate court found that the district court had relied on unreliable hearsay evidence from Rosa-Borges' brother to extend Rosa-Borges' sentence. The court concluded that the brother's statement was self-serving and inconsistent with the government's version of events, and therefore, it was an abuse of discretion for the district court to find the statement reliable. The court did not address Rosa-Borges' argument that his limited confrontation right under Rule 32.1(b)(2)(C) was violated. View "United States v. Rosa-Borges" on Justia Law

Lashaun Casey was sentenced to life imprisonment after being found guilty by a jury of carjacking and murdering an undercover police officer. Casey sought a writ of habeas corpus, claiming that his trial attorney failed to seek exclusion of inculpatory statements he made during a period of improper delay in bringing him before a magistrate judge following his arrest and detention. The district court rejected this claim, concluding that while a delay occurred, it was reasonable and necessary for legitimate law enforcement purposes.The United States Court of Appeals for the First Circuit disagreed with the district court's conclusion that Casey's presentment was justifiably delayed. However, the court agreed with Casey that admission at trial of one of the two contested sets of statements was improper. Despite this, the court concluded that Casey had not demonstrated that his trial counsel's failure to press that error constituted ineffective assistance of counsel because his showing of prejudice fell short of the Sixth Amendment standard. Therefore, the court affirmed the district court's judgment denying the writ of habeas corpus. View "Casey v. US" on Justia Law