United States v. Middleton

── United States v. Middleton ── Court: Court of Appeals for the First Circuit Date: May 08, 2026 Category: General United States Court of Appeals For the First Circuit No. 24-1421 UNITED STATES, Appellee, v. RICARDO MIDDLETON, Defendant, Appellant. APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MAINE [Hon. Jon D. Levy, U.S. District Judge] Before Gelpí, Thompson, and Dunlap, Circuit Judges. Charles W. Rankin, with whom Rankin & Sultan was on brief, for appellant. Brian S. Kleinbord, Assistant United States Attorney, with whom Andrew B. Benson, United States Attorney, was on brief, for appellee. May 8, 2026  THOMPSON, Circuit Judge. A nightmarish four-day stretch of abuse and forced prostitution led to the arrest and indictment of defendant-appellant Ricardo Middleton for sex trafficking in violation of 18 U.S.C. § 1591(a)(1) and (b)(1). A series of inculpatory phone calls Middleton made from prison tacked on a second charge for obstruction of a sex trafficking prosecution in violation of 18 U.S.C. § 1591(d). After an unforgettable four-day trial (the reader will soon learn what made certain aspects so memorable) in the United States District Court for the District of Maine, a jury found Middleton guilty of both offenses, and the court followed up by sentencing him to thirty years in prison followed by ten years of supervised release. This appeal followed. Middleton challenges the use of expert testimony at his trial, the sufficiency of the evidence used to prove his obstruction conviction, the reasonableness of his thirty-year sentence, and the effectiveness of his trial counsel. For reasons we'll explain, we affirm Middleton's convictions and sentence, and we dismiss his ineffective assistance of counsel claim as premature. I A The following facts related to Middleton's sufficiency challenge are brought to the reader in the light most favorable to the prosecution; facts relevant to Middleton's other appellate - 2 - claims are presented in equipoise, with further exposition coming soon when we address those claims themselves. See United States v. Díaz-Rosado, 857 F.3d 116, 117 (1st Cir. 2017). It all began one fall morning in November 2015. Adrienne Rush and her friend Julie Deschaine needed a fix to alleviate their withdrawal sickness from a shared heroin addiction. Deschaine contacted her dealer, Matt Thatcher, who agreed to deliver drugs to Deschaine's room at the Knights Inn in South Portland, Maine. Thatcher showed up with two companions -- Middleton and his future co-defendant, Sherry Jones. Thatcher apparently proposed that Rush and Deschaine find customers for his drugs in exchange for the heroin the friends craved. The two accepted Thatcher's offer, but their efforts proved less than fruitful. After failing to find buyers, the group relocated to Rush's friend's apartment nearby. During the drive over, Middleton asked Rush if she wanted to make money providing "company," but Rush didn't fully grasp the meaning of his words. Rush and Deschaine smoked crack together at the apartment before Middleton told the group it was time to return to the Knights Inn. Back at the Knights Inn, only Rush and Middleton made their way to Deschaine's room. Once inside, Middleton placed a phone and a condom on a table and told Rush a man would arrive soon. Middleton instructed Rush to let the man in and to do whatever he told her. At this point, Rush realized Middleton