United States v. Maldonado-Pena
4 F.4th 1
| 1st Cir. | 2021Background
- Five defendants (Joel Rivera-Alejandro, Carlos Rivera-Alejandro, Juan Rivera-George, Suanette Ramos-Gonzalez, Idalia Maldonado-Peña) appealed convictions arising from a 55-defendant multi-site drug-trafficking indictment (Los Claveles and Villa Margarita, Puerto Rico) charging conspiracy and multiple substantive distribution counts (2006–2009). Many codefendants pled; four cooperated at trial.
- Trial began July 2014 after ~5 years from indictment; ~128 trial days stretched over ~18 months; verdicts in Jan 2016 and sentencing through May 2018. Most appeals contest speedy-trial delay, suppression rulings, evidentiary rulings, confrontation/cross-examination limits, juror/judge/prosecutor conduct, sufficiency of evidence (Suanette, Juan), and drug-quantity findings at sentencing.
- Speedy-trial claims (Joel, Carlos) focused on 5-year pretrial delay; court applied Barker balancing (length, reason, assertion, prejudice) and found both sides substantially contributed to delay and defendants’ assertions were tepid, so no Sixth Amendment violation.
- Suppression: Joel’s motion to suppress a gun found in his father’s car after a traffic stop was denied (officer observed illegal front-window tint; gun observed in plain view). Juan waived suppression challenge to a notebook because he failed to object to magistrate R&R.
- Evidentiary and confrontation disputes (rough notes/Jencks, business records with handwritten annotations, limits on cross-examination, excluded impeachment witnesses, cumulative testimony) were mostly resolved against defendants; one close evidentiary admission (handwritten notations) was deemed harmless given abundant corroborating evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Speedy Trial (Sixth Amendment) | Joel/Carlos: 5-year pretrial delay and long trial violated right; government’s multi-defendant prosecution and government continuances primarily to blame | Government: delays caused substantially by numerous pretrial motions by defendants and many codefendant plea/continuance events; defendants delayed asserting right | Court: Denied dismissal. Barker factors balanced — length favored defendants but reasons diffuse (both parties), defendants’ weak assertion of right and no showing of specific prejudice meant no abuse of discretion. |
| Suppression of gun (Fourth Amendment) | Joel: stop and seizure unlawful (pretext stop; no reasonable suspicion for tint; no hearing) | Govt: officer observed impermissible front-window tint justifying stop; gun in plain view once car door open; no disputed material facts needing hearing | Court: Denied suppression; stop valid under motor-vehicle stop precedent; no abuse in declining evidentiary hearing absent disputed facts. |
| Jencks/Brady and production of rough notes | Suanette/Juan: rough agent notes are Brady/ Jencks material and exculpatory/impeaching; must be produced or inspected in camera | Govt: notes not adopted/verified by witnesses; summaries and DEA reports provided; materials cumulative or immaterial | Court: Denied production. Judge conducted requisite inquiries re: witness adoption; notes not Jencks statements; Brady claim speculative and notes cumulative of other disclosures. |
| Admission of business records with handwritten annotations | Defendants: handwritten notations are double-hearsay/unreliable and should be excluded | Govt: business-record foundation established; limiting instruction limits handwritten notes to association inference | Held: Admitted for limited purpose; even if erroneous, admission harmless given substantial corroborating evidence. |
| Limits on cross-examination / excluded defense witnesses | Defendants: trial court curtailed confrontation rights and excluded witnesses impeaching cooperating witnesses | Govt: limitations were reasonable; collateral impeachment barred; defendants had ample opportunity to impeach witnesses on core points | Court: No Confrontation Clause violation; court allowed sufficient cross-examination; exclusion of collateral impeachment witnesses was within discretion. |
| Juror bias / juror exposure to defendants in restraints / jury notes | Defendants: jurors saw defendants handcuffed or received notes implying encounters; juror who played basketball with a witness biased | Govt: court properly investigated (hearings, video), juror gave credible assurances; newspaper items speculative | Court: No abuse of discretion. Court conducted inquiries (including videorecord review), admonitions and remedies sufficed; juror retained. |
| Judicial demeanor and prosecutorial tactics (fair trial) | Defendants: judge’s tone/demeanor toward defense counsel and alleged prosecutorial misconduct deprived defendants of fair trial | Govt: judge’s admonitions were within courtroom management; prosecutors complied with discovery and corrected mistakes; curative instructions given | Court: No reversible bias or misconduct; judge’s conduct not so prejudicial and jury instruction cured potential effects; asserted prosecutorial tactics lacked merit. |
| Sufficiency of evidence (judgment of acquittal) | Suanette/Juan: testimony from cooperating witnesses was inconsistent, sparse, or not corroborated; insufficient to convict | Govt: testimony from CWs and law enforcement provided direct and corroborative evidence of each defendant’s role; one-witness testimony can suffice | Court: Affirmed convictions. Viewing evidence in prosecution’s favor, rational juries could find guilt beyond reasonable doubt. |
| Sentencing — drug quantity attribution and crack:powder conversion | Joel/Carlos/Juan/Idalia: district court erred in extrapolating drug quantities from CW testimony, or attributing unrelated location sales; Carlos sought 1:1 crack:powder ratio | Govt: PSR used conservative, corroborated extrapolation across CWs; court may attribute foreseeable conspiracy quantity; guideline ratio discretionary but not required to vary | Court: Drug-quantity findings supported by preponderance and reasonable inferences; no clear error. Judge not required to adopt 1:1 ratio; sentences affirmed. |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (constitutional speedy-trial balancing test)
- Doggett v. United States, 505 U.S. 647 (prejudice categories and presumption after long delay)
- Whren v. United States, 517 U.S. 806 (pretextual traffic stop doctrine)
- Maryland v. Wilson, 519 U.S. 408 (officer may order passengers out of vehicle)
- Goldberg v. United States, 425 U.S. 94 (Jencks-like issues and investigatory review)
- United States v. Casas, 425 F.3d 23 (multidefendant prosecution efficiencies; Speedy Trial context)
- United States v. Lara, 970 F.3d 68 (First Circuit treatment of speedy-trial claims)
- United States v. Rivera-Maldonado, 194 F.3d 224 (limits on unreliable pyramided extrapolations for drug-quantity findings)
- United States v. Correa-Alicea, 585 F.3d 484 (attributing foreseeable conspiracy drug quantities for sentencing)
- United States v. Sepulveda, 15 F.3d 1161 (Jencks Act standards for discoverable statements)