United States v. Celaya Valenzuela, No. 16-1009 (1st Cir. 2017)Annotate this Case
After a jury trial, Defendant was convicted of conspiracy to distribute and possess with intent to distribute controlled substances. Defendant was sentenced to 210 months imprisonment. Defendant appealed, challenging both his conviction and sentence. The First Circuit affirmed, holding (1) the government provided sufficient evidence that the conspiracy in question had the required “jurisdictional nexus” to the United States; (2) venue in the District of New Hampshire was proper, and the manufactured venue doctrine is hereby rejected; (3) there was no error in the district court’s failure to instruct the jury on jurisdictional nexus and manufactured venue; and (4) Defendant’s sentence was substantively reasonable.