Justia Constitutional Law Opinion Summaries

Defendant was indicted on a single count of possessing cocaine with intent to distribute. That same day, law enforcement officers interviewed Defendant at a proffer session, which was held pursuant to a written proffer agreement. The government promised Defendant it would not use against him any "statements made or other information" disclosed at the proffer session. After the proffer session failed, Defendant proceeded to trial. Despite its earlier assurances, the government presented at trial voice identification testimony from a police officer based on what the officer had heard at the proffer session. The testimony linked Defendant to an incriminating recorded telephone conversation. The jury found Defendant guilty. The First Circuit Court of Appeals vacated Defendant's conviction, holding (1) admission of the testimony violated the proffer agreement and Defendant's due process rights; and (2) the error was not harmless beyond a reasonable doubt. Remanded. View "United States v. Melvin" on Justia Law

After losing his job as a stockbroker and financial advisor and his accompanying health insurance, Appellant applied for and received subsidized health insurance for several years. Russell represented on each application that he had no income to report and was unemployed, but Appellant was working under the table during those years. After a government investigation and an ensuing jury trial, Appellant was convicted of making false statements in connection with the payment of health care benefits. The First Circuit Court of Appeals affirmed, holding (1) the jury instruction on the definition of willfulness was not error; (2) the government presented sufficient evidence that Appellant's false statements were material to support the conviction; (3) the district court did not err in excluding certain testimony as state-of-mind hearsay; and (4) neither the prosecutor's statements during closing arguments nor his questions in eliciting testimony from a witness necessitated reversal. View "United States v. Russell" on Justia Law

After a jury trial, Defendants Salvatore DiMasi, the former Speaker of the Massachusetts House of Representatives, and Richard McDonough, a lobbyist, were convicted of several crimes, including honest-services fraud and conspiracy to commit honest-services fraud, resulting from a scheme to funnel money to DiMasi in exchange for political favors. The district court sentenced DiMasi to ninety-six months' imprisonment and McDonough to eight-four months' imprisonment. The First Circuit Court of Appeals affirmed the convictions and sentences, holding (1) the evidence was sufficient to support Defendants' convictions; (2) the trial court did not prejudicially err in instructing the jury; (3) the trial court did not err in its challenged evidentiary rulings; and (4) the trial court did not err in sentencing Defendants. View "United States v. McDonough" on Justia Law

The parties in this case were a group of chess players and their opponent, the Puerto Rico Chess Federation. The chess players filed suit against the chess federation in Puerto Rico court, alleging violations of their rights under the United States and Puerto Rico constitutions and Puerto Rico law. The chess federation successfully removed the case to federal court. The chess players subsequently filed a second case, again in Puerto Rico court, excluding any claims under federal law. The federation also removed this case. The district court consolidated the two cases and declared jurisdiction over the second case under the All Writs Act. Ultimately, the district court granted summary judgment in favor of the federation on all claims. The First Circuit Court of Appeals affirmed in part and reversed in part, holding (1) the district court had federal subject matter jurisdiction over the first case but did not have subject matter jurisdiction over the second case; and (2) the district court incorrectly granted summary judgment to the federal on some of the chess players' Commonwealth law claims. View "Ortiz-Bonilla v. Federacion de Ajedrez de P.R., Inc." on Justia Law

After a jury trial, Defendant, a corrections officer, was convicted of drug and weapons charges for providing security for a drug transaction orchestrated by the FBI as part of a sting operation. The First Circuit Court of Appeals affirmed subject to a limited remand, holding (1) the district court did not err in refusing to instruct the jury on entrapment, as the evidence was insufficient to raise a jury issue of entrapment; and (2) the sentence imposed by the district court was procedurally sound and substantively reasonable. Remanded for correction of a reference in the written judgment that caused no prejudice to Defendant. View "United States v. Diaz-Maldonado" on Justia Law

Defendants, Jimmy Carrasquillo-Rodriguez (Carrasquillo) and Jesus Pabellon Rodriguez (Pabellon), were convicted on drug and gun charges arising from a reverse sting operation set up by Drug Enforcement Administration (DEA) agents seeking to reduce the flow of illegal narcotics from the Dominican Republic to Puerto Rico. With one exception, the First Circuit Court of Appeals affirmed both Defendants' convictions and Carrasquillo's sentence, holding (1) Carrasquillo's conviction for possession of a firearm with an obliterated serial number was not supported by sufficient evidence; (2) the evidence was sufficient to sustain the remaining convictions challenged by Defendants; (3) the language in the verdict form did not constitute plain error sufficient to warrant a new trial; (4) the district court did not plainly err in its instructions to the jury; and (5) the district court did not err in sentencing Carrasquillo. View "United States v. Pabellon-Rodriguez" on Justia Law

Puerto Rico law operated to cause hundreds of thousands of motor vehicle owners to pay twice for liability insurance. Commonwealth law declared motor vehicle owners to be entitled to a refund of the excess premiums paid, but large amounts of unclaimed refunds accumulated. The Commonwealth subsequently placed the unclaimed refunds with its Treasury Secretary with the condition that, if not claimed within five years, the funds escheated to the Commonwealth without notice to the vehicle owners. In Garcia-Rubiera II, the First Circuit Court of Appeals held that the Commonwealth's failure to notify vehicle owners of their reimbursement rights violated their procedural due process rights. On remand, the district court ordered the Commonwealth to notify vehicle owners of their reimbursement rights, to publish notices in two newspapers alerting the owners of their rights, and to give owners a 120-day grace period for them to claim reimbursement. The First Circuit again remanded for the district court to craft with "the benefit of further guidance" an injunction that more fittingly remedied the Commonwealth's constitutional violations and ordered no duplicate premiums to escheat to the Commonwealth until it established and complied with a reimbursement procedure meeting the requirements of due process. View "Garcia-Rubiera v. Fortuno" on Justia Law

Defendant pleaded guilty to conspiring to possess with intent to distribute heroin, possessing with the intent to distribute heroin, conspiring to import heroin, and importing heroin into the United States. Defendant was sentenced to twenty-four months' imprisonment and two years of supervised release. Defendant appealed, arguing that her sentence was procedurally and substantively flawed. The First Circuit Court of Appeals affirmed, holding that the district court (1) did not err in denying Defendant's request for a continuance of the sentencing hearing; (2) did not abuse its discretion in choosing to impose a term of imprisonment; and (3) afforded Defendant an adequate opportunity to allocute. View "United States v. Pacheco" on Justia Law

A New Hampshire court issued a warrant to search Defendant's home after a state trooper submitted a supporting affidavit detailing the trooper's suspicion that Defendant's home contained a marijuana grow operation. Based on the items seized from Defendant's home, Defendant was charged with manufacturing marijuana, possessing marijuana with the intent to distribute, and possessing a firearm in furtherance of a drug trafficking crime. Defendant moved to suppress the evidence, arguing that the search warrant lacked probable cause. The district court suppressed the evidence, finding that the trooper recklessly omitted from his affidavit information material to a probable cause determination. The First Circuit Court of Appeals affirmed, holding that the search warrant at issue contained reckless material omissions, and the omitted information, when included back into the affidavit, failed to establish probable cause. View "United States v. Gifford" on Justia Law

Plaintiff, a Massachusetts corporation engaged in international asset recovery operations, filed a complaint against Defendants, the Republic of Ukraine and some of its agents and instrumentalities, for, inter alia, breach of contract after Plaintiff performed asset recovery work for which Defendants allegedly did not compensate Plaintiff. Defendants filed a motion to dismiss on the grounds that they were entitled to immunity under the Foreign Sovereign Immunities Act (FSIA). The district court denied the motion in regard to the breach of contract claim, concluding that jurisdiction could be asserted over that claim under the commercial activity exception to the FSIA. The First Circuit Court of Appeals affirmed the district court's exercise of jurisdiction over Plaintiff's breach of contract claim, holding that Defendants' transactions with Plaintiff constituted commercial activity exempt from immunity under FSIA. View "Universal Trading & Inv. Co. v. Bureau for Representing Ukrainian Interests" on Justia Law