Case Explained: UNITED STATES v. JOAN ROSADO MALDONADO

Court: United States Court of Appeals for the First Circuit

Filed: 2026-07-06

The First Circuit vacated Joan Rosado Maldonado’s sixty-month prison sentence and remanded the case to the District Court for resentencing. The court held that the District Court erred in calculating Maldonado’s base offense level under U.S. Sentencing Guidelines § 2K2.1(a)(2) by treating his two prior Massachusetts drug convictions as “controlled substance offenses.” Applying a de novo standard of review, the court determined that the term “controlled substance” within Guideline § 4B1.2(b) encompasses only substances regulated by the federal Controlled Substances Act (CSA), not those defined solely by state law. Because Massachusetts law at the time of sentencing defined “cocaine” to include ioflupane—a substance removed from the federal CSA schedule in 2015—the state convictions were not a categorical match to the federal definition and thus could not serve as predicate offenses for the sentencing enhancement. Consequently, the procedural error required vacatur because the government failed to demonstrate that the District Court would have inevitably imposed the same sentence absent the miscalculation. The court declined to address Maldonado’s separate challenges to his supervised release conditions, noting that any ambiguities regarding those terms would be resolved during resentencing.

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