United States v. Paladin
748 F.3d 438
| 1st Cir. | 2014Background
- Paladin convicted on multiple drug counts; mandatory life sentence triggered by prior felonies and total cocaine quantities.
- Trial evidence centered on FBI Agent Alford and informant Vega's controlled buys and statements.
- Vega testified to a long drug-dealing history with Paladin and to ceasing activity in 2009 to cooperate with police.
- Defense discovered an Andino proffer (Nov. 2010) suggesting Vega lied about stopping in 2009 and that Andino supplied Vega.
- Paladin moved for a new trial under Brady; district court denied after an August 2012 hearing.
- On appeal, court held the Andino proffer immaterial and affirmed the denial of Paladin’s Brady motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Brady materiality of the Andino proffer | United States argues immateriality of Andino proffer. | Paladin contends undisclosed evidence could impeach Vega’s credibility. | Proffer immaterial; suppression not prejudicial. |
| Is the Andino proffer cumulative evidence? | United States maintains proffer overlaps existing impeachment. | Paladin argues it would add distinct impeachment avenues. | Impeachment value was cumulative; not sufficient to undermine verdict. |
| Collateral nature of impeachment issues? | United States asserts impeachment topics were collateral to guilt. | Paladin contends impeachment on credibility matters could affect outcome. | Impeachment topics deemed collateral; harmless error. |
| Almendarez-Torres/Alleyne implications for prior convictions | Almendarez-Torres precedent allows use of prior convictions for sentencing without jury findings. | Alleyne requires jury finding for sentencing-enhancing facts; prior convictions still excepted. | Almendarez-Torres remains valid; no fifth/sixth amendment error. |
| Alleyne and jury findings on drug quantity | Alleyne requires jury finding for quantities increasing mandatory minimums. | District court instructions adequately tied conspiracy to the five-kilogram minimum. | No plain-error requiring reversal; substantial corroboration supports the verdict. |
Key Cases Cited
- Strickler v. Greene, 527 U.S. 263 (1999) (materiality requires reasonable probability of a different outcome)
- Conley v. United States, 415 F.3d 183 (1st Cir. 2005) (impeachment evidence must be material; cumulative evidence limits impact)
- United States v. Hall, 557 F.3d 15 (1st Cir. 2009) (abuse-of-discretion standard for Brady rulings; deference to trial judge)
- United States v. Avilés-Colón, 536 F.3d 1 (1st Cir. 2008) (impeachment evidence and materiality under Brady analysis)
- Dumas, 207 F.3d 11 (1st Cir. 2000) (collateral impeachment evidence and materiality framework)