United States v. Pilson

CourtCourt of Appeals for the First Circuit
DecidedJune 1, 2026
Docket24-1356
StatusPublished

This text of United States v. Pilson (United States v. Pilson) 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. Pilson, (1st Cir. 2026).

Opinion

United States Court of Appeals For the First Circuit

No. 24-1356

UNITED STATES OF AMERICA,

Appellee,

v.

STEPHEN PILSON,

Defendant, Appellant.

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MAINE

[Hon. Jon D. Levy, U.S. District Judge]

Before

Barron, Chief Judge, Howard and Thompson, Circuit Judges.

Emmett E. Robinson, with whom Robinson Law Firm LLC was on brief, for appellant. Linday B. Feinberg, Assistant United States Attorney, with whom Darcie N. McElwee, United States Attorney, was on brief, for appellee.

June 1, 2026 THOMPSON, Circuit Judge. This appeal arises out of a

series of lamentable events -- dire ones that led to Stephen

Pilson's federal convictions for kidnapping his then-girlfriend,

Rilka Stefanov, and for an interstate violation of a protective

order. Those events began in October 2019 and continued through

December 2019 -- some three days after Pilson's release from a

Massachusetts jail following his conviction for similar offenses

in the Commonwealth (against the same victim).

Pilson now raises a few claims of error to the goings-on

below, one alleging insufficient evidence to sustain the 18 U.S.C.

§ 1201(a)(1) federal kidnapping conviction, another asserting jury

instructional error premised on the district court's purported

misunderstanding of the scope of 18 U.S.C. § 2262(a)(1)'s

protections as it applies to state issued domestic violence "stay-

away" orders. Pilson also challenges the district court's

application of a sentencing enhancement for obstruction of

justice, U.S.S.G. § 3C1.1, which is (as you will see below)

essentially a challenge aimed at the procedural reasonableness of

that enhancement. For the reasons we discuss below, we affirm.

I. Background

We provide most of the basic facts here in the light

most flattering to the verdict, "reserving additional details for

our discussion of the specific issues raised in this appeal." See,

- 2 - e.g., United States v. Ayala-Vazquez, 751 F.3d 1, 7 (1st Cir.

2014).

a. Pilson's Massachusetts Conviction

Pilson first crossed paths with Stefanov in 2018 at a

rehab center known as "Dexter House," where he was admitted

following injuries he suffered in a traffic accident. Stefanov

was the center's director of social services and, while there, she

and Pilson developed a close relationship. After spending nearly

three months at Dexter House, Pilson left and, shortly thereafter,

moved in with Stefanov.1

Pilson and Stefanov continued their relationship, but

the good times quickly turned bad. So bad, in fact, that on

October 15, 2019, a calamitous domestic violence episode ensued:

after kicking, striking, and forcing Stefanov into a vehicle,

Pilson held her captive while driving erratically from New

Hampshire into Massachusetts. Throughout the ordeal, Pilson

repeatedly yelled threats at her, such as: "You are going to die,

bitch. You deserve it. You put me in jail for three months, and

now you think you can leave me . . . You're going to die today."

Stefanov was in tears and pleading with him to stop the car, but

instead (that is, instead of adhering to her pleas), Pilson slowed

the vehicle to turn around, and she was "able to free herself from

1 Stefanov's employment with Dexter House ended in November of 2018.

- 3 - the vehicle [and thereafter, she] began yelling for help and for

someone to call the police." After screaming to her, "[y]ou'll be

sorry, bitch," Pilson fled the scene, but, after the police

gathered more details from Stefanov, he was apprehended and jailed.

Eventually, Pilson pleaded guilty in a Massachusetts

court to multiple charges, including kidnapping, witness

intimidation, assault and battery on a household member, and more.

At his consolidated change of plea and sentencing hearing, the

Commonwealth's prosecutor asked the judge to impose a "stay-away,

no contact" provision ("No Contact Order") against Pilson to

prevent him from interacting with Stefanov upon his release. While

acknowledging that Stefanov did not join in the Commonwealth's

request, the prosecutor pressed for the No Contact Order based on

the history of physical abuse between the couple and the extremely

volatile nature of their relationship.2 Troubled by the thought

of Pilson's incarceration, Stefanov chose to testify on his behalf,

proclaiming that she felt safe around him and that she did not

want him to be prohibited from communicating with her. Pilson's

attorney also asked the court to refrain from imposing the No

2 The Commonwealth's prosecutor also explained during its summation of the case that Stefanov "told police . . . there had been a past incident in January in Woburn, Massachusetts[,] where [Pilson] had been charged with strangulation threats and domestic [violence offenses]," resulting in a "three month[]" period in jail. Pilson did not protest those allegations.

- 4 - Contact Order, stating that "they clearly want to be together,"

and "[s]he clearly feels safe with him."

After accepting Pilson's guilty plea and meting out a

fifty-six-day, time-served prison sentence (along with two years'

probation), the court sided with the Commonwealth and granted the

request for the No Contact Order. In imposing that Order, the

court succinctly reasoned that it had "some concerns that

[Stefanov] really could have been killed that day [of the October

kidnapping]," and after considering the couple's history of

violence, that "[i]t doesn't sound like them being together is a

good thing."

b. The December Incident

And then, déjà vu.

On December 13, 2019, one day after Pilson's sentencing

hearing, and notwithstanding the No Contact Order, Stefanov went

to retrieve Pilson from jail. That night and through the next

morning, the two stayed holed up in a hotel room with no reported

incidents.

Fast forward two days later to December 15 where Pilson

and Stefanov could be found in Stefanov's car, parked near the

Beverly, Massachusetts beach with Pilson behind the wheel and

Stefanov voluntarily situated in the front passenger seat. After

some (unimportant) chit-chat, Pilson began to drive away. They

were headed to Canada, he said, and going for the ride of their

- 5 - lives. Moments later, he started belting down a large bottle of

Grey Goose Vodka and spewing a stream of threatening comments

towards Stefanov. Pilson told Stefanov that she wouldn't "need

[her seatbelt] because today is the day that [she] will be dying."

He said that he planned to bury her in Canada and that she wouldn't

be able to see her kids. Stefanov began to sob and pleaded with

Pilson, but her actions seemed only to fuel his anger. He called

her a "bitch" and told her she was "going to get what [she]

deserve[s]." Stefanov described Pilson's driving that day as

erratic and very fast, reaching speeds of 110 miles per hour. In

her telling, Pilson was in a trance-like state, appearing both

intoxicated and enraged.

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United States v. Pilson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-pilson-ca1-2026.