United States v. Padilla-Galarza

── United States v. Padilla-Galarza ── Court: Court of Appeals for the First Circuit Date: May 06, 2026 Category: General United States Court of Appeals For the First Circuit No. 22-1950 UNITED STATES, Appellee, v. JOSE PADILLA-GALARZA, a/k/a "Joey", Defendant, Appellant. APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO [Hon. Silvia L. Carreño-Coll, U.S. District Judge] Before Aframe, Hamilton,* and Thompson, Circuit Judges. Rafael F. Castro Lang for appellant. Ann O'Connell Adams, with whom W. Stephen Muldrow, United States Attorney, Mariana E. Bauzá-Almonte, Assistant United States Attorney, Chief, Appellate Division, Ricardo A. Imbert-Fernández, Assistant United States Attorney, and Thomas F. Klumper, Assistant United States Attorney, Senior Appellate Counsel, were on brief, for appellee. May 6, 2026 * Of the Seventh Circuit, sitting by designation.  AFRAME, Circuit Judge. Following a bench trial, the district court convicted Jose Padilla-Galarza ("Padilla") of several counts related to a scheme to steal firearms from a Puerto Rico police compound.1 The court sentenced Padilla to twenty-five years in prison. On appeal, Padilla argues that two of his convictions were time-barred and that several unjustified discretionary rulings prejudicially tainted the remaining convictions. We affirm. I. Padilla's convictions arose from an October 2010 robbery of a shooting range located within a Puerto Rico police compound. During the robbery, two police officers were taken hostage, and 125 firearms were stolen. On October 15, 2015, shortly before the expiration of the statute of limitations, a grand jury indicted Padilla for masterminding the robbery and committing several related crimes. The original indictment charged five counts: (1) conspiracy to commit Hobbs Act robbery; (2) brandishing and possessing a firearm in furtherance of a crime of violence; (3) stealing firearms; (4) unlicensed dealing in firearms; and 1 The counts of conviction are conspiracy to interfere with commerce by robbery, 18 U.S.C. § 1951 ("Hobbs Act conspiracy"); interference with commerce by robbery, id. ("Hobbs Act robbery"); carrying a firearm during and in relation to the Hobbs Act robbery, 18 U.S.C. §§ 924(c)(1)(A)(i), 2; stealing firearms, 18 U.S.C. §§ 924(1), 924(a)(2), 2; and being a convicted felon in possession of firearms, 18 U.S.C. § 922(g)(1). - 2 - (5) being a convicted felon in possession of a firearm. The indictment also charged three co-defendants, all of whom pleaded guilty before Padilla's trial. Although the grand jury indicted Padilla in October 2015, he did not face trial until almost seven years later, in April 2022. The proceedings were initially delayed because of multiple changes in Padilla's representation between 2015 and 2018. A second delay occurred after the district court allowed a March 2020 motion for a continuance to an unspecified future date. During this period, Padilla filed numerous motions and discovery requests. Eventually, the court set a December 1, 2021, trial date. The last major delay, until February 2022, occurred when a new trial judge inherited the case. After Padilla obtained a few more short continuances, trial was set for April 21, 2022. Two weeks before trial, the government filed a superseding indictment based on a change in the law. Count Two of the original indictment charged Padilla with possessing and