United States v. Walker-Couvertier, No. 15-1261 (1st Cir. 2017)Annotate this Case
After a jury trial, Defendants Abraham Walker-Couvertier (Walker) and Dean Lugo-Diaz (Lugo) were found guilty of numerous drug-related crimes. The trial court sentenced Walker to concurrent 192-month terms of immurement on the drug counts and a consecutive sixty-month term of immurement on a firearms count. The court sentenced Lugo to concurrent 121-month terms of immurement on the various counts of conviction. The First Circuit affirmed, holding (1) Defendants’ belated challenge to the requirement, as applied in the District of Puerto Rico, that jurors be proficient in English failed; (2) Walker’s challenge to the propriety of a traffic stop was not preserved for appellate review; (3) contrary to Defendants’ arguments, several statements made by the prosecutor during closing argument were not prejudicial; (4) there was no plain error in the challenged jury instructions; (5) the evidence was sufficient to support Lugo’s conspiracy conviction; and (6) Defendants’ claims of sentencing error were unavailing.