United States v. Casellas-Toro, No. 14-1933 (1st Cir. 2015)
Annotate this CaseAfter a jury trial, Defendant was convicted of the murder of his wife. Eight days later, Defendant was indicted by a federal grand jury on three counts of making false statements to a federal officer. One week later, a Puerto Rico Commonwealth court sentenced Defendant to 109 years’ imprisonment for the murder. Defendant moved to transfer the federal trial to another venue, arguing that the pretrial publicity about his murder conviction prevented a fair and impartial jury in Puerto Rico. The trial court overruled the motion to change venue. After a trial, the jury convicted Defendant of all three false-statement counts, but the court granted a motion of acquittal on two counts. The First Circuit reversed, holding that the district court abused its discretion by denying Defendant’s motion to change venue, as there was a significant risk that the level of prejudice permeating the trial was so high that Defendant could not possibly have received an impartial trial. Remanded.
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