United States v. Roszkowski, No. 11-1456 (1st Cir. 2012)Annotate this Case
After a three-day trial, a jury convicted Defendant of being a felon in possession of a firearm and knowingly possessing a firearm with an altered serial number. Defendant appealed, claiming (1) the district court erroneously precluded his proposed entrapment defense and improperly admitted certain evidence at trial, and (2) because the Commerce Clause does not endow Congress with the requisite authority to regulate the conduct covered by the underlying statutes of conviction, those statutes were invalid and unenforceable. The First Circuit Court of Appeals affirmed, holding (1) the district court's denial of Defendant's pretrial motions to unveil and subpoena an alleged confidential informant did not deprive Defendant of his constitutional right to present a complete defense; (2) the district court's admission of the disputed evidence was not error; and (3) the underlying statutes of conviction were valid and constitutional.