United States v. Reyes-Correa, No. 19-1003 (1st Cir. 2020)
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The First Circuit reversed the decision of the district court denying Defendant's motion to dismiss his indictment under the Double Jeopardy Clause of the United States Constitution based on his prior conviction in a Commonwealth court for a local drug offense, holding that Defendant met his burden to make a prima facie case that he had been prosecuted twice for the same conduct under equivalent criminal laws.
On March 15, 2016, Defendant pleaded guilty to a violation of Article 406 of the Puerto Rico Controlled Substances Act. About sixteen months later, Defendant was named in a federal indictment charging him with five drug-related federal offenses, including conspiracy to possess with intent to distribute controlled substances, in violation of 21 U.S.c. 846. Defendant moved to dismiss the section 846 conspiracy count on double jeopardy grounds, alleging that his prior Article 406 conviction was for the same criminal conduct that the section 846 count charged him with committing. The district court denied the motion. The First Circuit reversed, holding that Defendant met his burden of presenting evidence to establish a prima facie non frivolous double jeopardy claim, and the government failed to meet its burden to rebut it.
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