United States v. Fernandez-Santos

CourtCourt of Appeals for the First Circuit
DecidedMay 15, 2026
Docket25-1090
StatusPublished

This text of United States v. Fernandez-Santos (United States v. Fernandez-Santos) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Fernandez-Santos, (1st Cir. 2026).

Opinion

United States Court of Appeals For the First Circuit

No. 25-1090

UNITED STATES,

Appellee,

v.

DIEGO FERNÁNDEZ-SANTOS,

Defendant, Appellant.

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

[Hon. Francisco A. Besosa, U.S. District Judge]

Before

Gelpí, Thompson, and Rikelman, Circuit Judges.

Samuel P. Carrion, Assistant Federal Public Defender, with whom Rachel Brill, Federal Public Defender, District of Puerto Rico, Franco L. Pérez-Redondo, Assistant Federal Public Defender, Supervisor, Appellate Division, and Kevin E. Lerman, Assistant Federal Public Defender, were on brief, for appellant. Maarja T. Luhtaru, Assistant United States Attorney, with whom W. Stephen Muldrow, United States Attorney, and Juan Carlos Reyes-Ramos, Assistant United States Attorney, Chief, Appellate Division, were on brief, for appellee.

May 15, 2026 RIKELMAN, Circuit Judge. Diego Fernández-Santos

("Fernández") appeals his sentence for violating the terms of his

supervised release. He argues that the government failed to prove

the critical fact that drove his sentence, leading the district

court to commit a procedural error by looking outside the

revocation record to justify the sentence. We agree with Fernández

that a procedural error occurred and thus vacate and remand for

resentencing.

I. BACKGROUND

In 2014, Fernández pleaded guilty to multiple federal

criminal charges, including possession of a firearm (a compact

pistol) by a prohibited person. See 18 U.S.C. § 922(g)(1). The

district court sentenced him to over six years in prison for these

crimes, followed by three years of supervised release.

In February 2023, after Fernández completed his prison

sentence but while he was still on supervised release, he was

arrested again. At the time of his arrest, the police seized a

rifle and ammunition from a bedroom closet in the house where

Fernández was living, as well as a pistol and a gun magazine from

a bag that an officer testified he saw Fernández discard outside

the house. The officers did not see Fernández near the rifle nor

is there any evidence in the record that he had ever handled it.

Fernández's probation officer promptly notified the

district court of the arrest and alleged that Fernández had

- 2 - violated several conditions of his supervised release. One of

those conditions prohibited Fernández from "possess[ing] a

firearm, ammunition, destructive device, or any other dangerous

weapon." After Fernández waived his preliminary revocation

hearing, a magistrate judge found probable cause for the alleged

violations and referred the case to the district court for a final

revocation hearing.

Meanwhile, the government charged Fernández with new

criminal conduct based on the arrest -- possession of a firearm by

a prohibited person and possession of a machine gun. See 18 U.S.C.

§ 922(g)(1), (o).1 As part of his defense against these new

criminal charges, Fernández moved to suppress the evidence seized

at his arrest. The district court granted his motion in part: It

ordered the suppression of the pistol, and other items found in

the discarded bag, but not the rifle the police found in a bedroom

of the house.

The trial on the new firearm charges against Fernández

began in December 2024. At the trial, the government introduced

an "expert in the identification of machine guns," Homeland

Security Investigations Agent Ariel Pérez-Nieves ("Pérez"). Agent

Pérez testified that the rifle seized during Fernández's arrest

1The initial indictment only charged Fernández with a violation of § 922(g)(1), but in May 2024, a grand jury returned a superseding indictment that also included the § 922(o) charge.

- 3 - was an "AK-47 style" rifle that functioned as a machine gun,

meaning that someone operating the gun could fire multiple rounds

with one pull of the trigger. He also explained that the gun had

a visible "lever" and three small, unmarked dash lines. According

to Agent Pérez, the lever and dash lines indicated that the gun

had three possible settings: safety, automatic, and semiautomatic.

He pointed out, however, that the rifle would not function as a

machine gun unless an automatic sear was installed inside it and

a sear pin held that sear in place. He also testified that the

sear pin was small but visible, that he could not identify one of

the other pins in the rifle, and that all the pins looked

"similar." Finally, Agent Pérez explained that the only way he

was able to conclude with certainty that the firearm was a machine

gun was by firing it.

Five days into the trial, the district court dismissed

the new firearm charges against Fernández with prejudice due to

discovery violations by the government. With these new charges

wiped away, the court scheduled Fernández's final revocation

hearing to determine whether he had violated the terms of his

supervised release for his 2014 convictions.

In advance of the final revocation hearing, the

government filed an Informative Motion with the district court.

It contended that Fernández had committed a Grade A violation of

his supervised release terms by possessing a "destructive

- 4 - device" -- a machine gun -- despite his prior felony conviction.

See U.S. Sent'g Guidelines Manual ("U.S.S.G.")

§ 7B1.1(a)(1)(A)(iii) (U.S. Sent'g Comm'n 2024) (defining a

Grade A violation as "a federal, state, or local offense punishable

by a term of imprisonment exceeding one year that . . . involves

possession of a . . . destructive device," such as a machine gun).

It then requested that the court impose the statutory maximum

sentence of 60 months.

The government submitted six exhibits, which it attached

to the Informative Motion, as evidence of the violations. The

exhibits contained excerpts of witness testimony from the

suppression hearing and the jury trial on the dismissed § 922(g)(1)

and § 922(o) charges against Fernández. The government even

highlighted portions of the testimony that it viewed as critical.

Exhibit Six is particularly important. That exhibit

consisted of excerpts from the trial testimony of two government

experts: Alcohol Tobacco and Firearms Agent Jorge Escribano, an

expert in the "identification of firearms," and Agent Pérez. The

government included four pages of trial testimony by Agent

Escribano. In that testimony, he identified the firearm that was

seized during Fernández's arrest as "an AK-type rifle" that

"qualif[ies] as a firearm under [f]ederal law" and was "not

manufactured in the Commonwealth of Puerto Rico." The government

- 5 - included only one page of trial testimony by Agent Pérez. That

testimony reads:

Q: Special Agent P[é]rez, showing you Government's Exhibit 22, what is that?

A: It is a rifle, an AK-47 style.

Q: Have you seen that rifle before?

A: Yes, sir.

Q: How do you know?

A: Ah, this rifle was inspected, examined by me. It has the engraving that we did the testing on it.

Q: What was your conclusion once you tested it?

A: It was found to be a -- to operate as a machine gun.

Beyond the exhibits attached to the Informative Motion,

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