Justia Juvenile Law Opinion Summaries

In January 2018, Nycole Amaury Rosario Sánchez, then fifteen years old, and six accomplices committed a series of violent crimes in Puerto Rico, including three robberies, two carjackings, and four murders. Rosario brandished and discharged firearms during these crimes, resulting in multiple injuries and deaths. He was arrested on January 25, 2018, and agreed to be prosecuted as an adult. Rosario pleaded guilty to six counts, including interference with commerce by robbery, carjacking, and using a firearm during a crime of violence causing murder.The United States District Court for the District of Puerto Rico sentenced Rosario to 480 months' imprisonment. Rosario appealed, arguing that the district court failed to consider mitigating factors such as his age, mental and emotional condition, and the sentencing disparity between him and his co-defendants. He also claimed that his sentence was both procedurally and substantively unreasonable.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the district court had considered Rosario's age, mental and emotional condition, and other mitigating factors, as evidenced by the sentencing transcript and the Presentence Investigation Report (PSR). The court also noted that Rosario's co-defendants were sentenced by a different judge and that Rosario had not provided sufficient information to establish an unwarranted sentencing disparity.The First Circuit held that the district court did not commit procedural error in its consideration of the section 3553(a) factors or in addressing the sentencing disparity. The court also found that Rosario's sentence was substantively reasonable, given the seriousness of his offenses and his behavior while incarcerated. Consequently, the First Circuit affirmed Rosario's 480-month sentence. View "United States v. Rosario Sanchez" on Justia Law

The government filed a juvenile information against Y.C.T. alleging two acts of delinquency. The government filed a motion for a discretionary transfer of Y.C.T. to the district court’s criminal jurisdiction. A magistrate judge issued a written report recommending that Y.C.T. be transferred to adult status for criminal prosecution. The district court adopted the recommendation after conducting a de novo review, concluding that the transfer best served the interest of justice. The First Circuit affirmed the transfer order, holding that the district court’s reliance on the record, as developed by the magistrate judge, to conduct its de novo review was not an abuse of discretion and did not violate Y.C.T.’s right to due process. View "United States v. Y.C.T." on Justia Law