June 8, 2026·25-1607·Panel Decision·RIKELMAN·By James Taylor
The First Circuit vacated the sentence of Héctor Maldonado-Maldonado for assaulting a corrections officer, finding that the district court erred by relying on extra-record information without notice. The case has been remanded for resentencing before a different judge.
Background
Héctor Maldonado-Maldonado appealed his sentence for assaulting a corrections officer, challenging the reliance on information not included in the record during sentencing.
The court’s reasoning
The court found that the district court erred by considering extra-record materials, specifically recent disciplinary violations, without providing notice to the defense, which constituted a procedural error.
The district court must have learned about the newer violations during an ex parte communication with the probation officer.
What it means going forward
Maldonado will be resentenced by a different judge, ensuring a fairer process.
