Crespo-Morales v. Caro-Delgado

── Crespo-Morales v. Caro-Delgado ── Court: Court of Appeals for the First Circuit Date: May 22, 2026 Category: General United States Court of Appeals For the First Circuit No. 23-1638 JUAN M. CRESPO-MORALES, Petitioner, Appellant, v. NICANOR CARO-DELGADO, Respondent, Appellee, CÉSAR R. MIRANDA RODRÍGUEZ, Respondent. APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO [Hon. Pedro A. Delgado Hernández, U.S. District Judge] Before Barron, Chief Judge, Breyer,* Associate Justice, and Gelpí, Circuit Judge. Robert M. Fitzgerald, Assistant Federal Public Defender, with whom Rachel Brill, Federal Public Defender, District of Puerto Rico, and Franco L. Pérez-Redondo, Assistant Federal Public Defender, Supervisor, Appellate Unit, were on brief, for appellant. Francisco J. González-Magaz, with whom Omar Andino Figueroa, Solicitor General of Puerto Rico, was on brief, for appellee. * Hon. Stephen G. Breyer, Associate Justice (Ret.) of the Supreme Court of the United States, sitting by designation. May 22, 2026  BREYER, Associate Justice. In 1996, a jury in the Commonwealth of Puerto Rico convicted Juan Crespo-Morales on four counts of first-degree murder and other related charges. The Commonwealth judge sentenced him to nearly 600 years in prison, and he began to serve his sentence. Around twenty years later, he filed a motion for a new trial in the Commonwealth court. He claimed that Commonwealth prosecutors had violated the holding of Brady v. Maryland, 373 U.S. 83 (1963), because they had failed to give him material evidence that would have proved helpful to his defense. See id. at 87. After the Commonwealth court denied his Brady claim, Crespo petitioned a federal district court for a writ of habeas corpus under 28 U.S.C. § 2254. The district court initially dismissed the § 2254 petition, but it did so before the Commonwealth had produced the record from Crespo's trial and postconviction litigation. On appeal, we vacated and remanded the district court's judgment, explaining that the record before us did not reflect compliance with the rules governing § 2254 proceedings. On remand, the Commonwealth supplemented the record, but certain gaps remained. Most notably, the Commonwealth did not furnish a transcript or narrative summary of the testimony of a key witness named Regino Burgos-Torres. The district court nevertheless denied Crespo's petition. – 3 –  We once again vacate the district court's judgment. We hold that the district court erred because it could not have reasonably evaluated the Commonwealth court's adjudication of Crespo's Brady claim as required under § 2254 without knowing more about the content of Burgos-Torres's testimony. We therefore remand this case back to the district court with instructions to order the production of a transcript of Burgos-Torres's trial testimony (or a narrative summary of that testimony if the transcript is unavailable). I. A. A jury in a Commonwealth court convicted Crespo of murdering (by shooting) four persons: William Curet-Suárez, Ángel Luis Díaz-Cruz, Ramón Bon-Home-Reyes, and Teresa Maldonado-Figueroa. For ease of exposition, we shall call the shooting victims V1, V2, V3, and V4, respectively. The shooting took place in the Piñones Sector of Loíza, and subsequently became known as the "Piñones Massacre." At Crespo's trial, the Commonwe