United States v. Boyrie-Laboy, No. 22-1354 (1st Cir. 2024)
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The case revolves around Carlos Rubén Boyrie-Laboy, a Puerto Rico Police officer, who was convicted under 18 U.S.C. §§ 1951, 371, and 641 for his involvement in a conspiracy to commit robbery and theft of government property. Boyrie-Laboy was part of the Humacao Drugs Division, responsible for seizing illegal weapons, drugs, and other contraband. In 2015, Officer Gabriel Maldonado-Martínez joined the division and began working with Boyrie-Laboy. Maldonado-Martínez later became an undercover FBI informant to identify corrupt police officers. Boyrie-Laboy was involved in two thefts of fireworks and was present during two FBI operations designed to catch corrupt officers. However, he did not accept any stolen goods or money from these operations.
The government indicted Boyrie-Laboy and three other officers based on these activities. Boyrie-Laboy was charged with conspiracy to commit robbery, conspiracy to steal and convert government property, and theft and conversion of government property. He proceeded to a five-day jury trial, where the jury found him guilty on all counts. Boyrie-Laboy appealed the convictions, arguing that there was insufficient evidence to support them.
The United States Court of Appeals for the First Circuit reviewed the case. Boyrie-Laboy's counsel had declined the opportunity to move for a judgment of acquittal twice during the trial and did not make a post-trial motion for judgment of acquittal. As a result, the court applied the "clear and gross injustice" standard of review. The court found that the evidence sufficiently supported the jury's findings and that upholding Boyrie-Laboy's convictions did not result in a clear and gross injustice. Therefore, the court affirmed the convictions.
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