United States v. Pilson

── United States v. Pilson ── Court: Court of Appeals for the First Circuit Date: June 01, 2026 Category: General United States Court of Appeals For the First Circuit No. 24-1356 UNITED STATES OF AMERICA, Appellee, v. STEPHEN PILSON, Defendant, Appellant. APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MAINE [Hon. Jon D. Levy, U.S. District Judge] Before Barron, Chief Judge, Howard and Thompson, Circuit Judges. Emmett E. Robinson, with whom Robinson Law Firm LLC was on brief, for appellant. Linday B. Feinberg, Assistant United States Attorney, with whom Darcie N. McElwee, United States Attorney, was on brief, for appellee. June 1, 2026  THOMPSON, Circuit Judge. This appeal arises out of a series of lamentable events -- dire ones that led to Stephen Pilson's federal convictions for kidnapping his then-girlfriend, Rilka Stefanov, and for an interstate violation of a protective order. Those events began in October 2019 and continued through December 2019 -- some three days after Pilson's release from a Massachusetts jail following his conviction for similar offenses in the Commonwealth (against the same victim). Pilson now raises a few claims of error to the goings-on below, one alleging insufficient evidence to sustain the 18 U.S.C. § 1201(a)(1) federal kidnapping conviction, another asserting jury instructional error premised on the district court's purported misunderstanding of the scope of 18 U.S.C. § 2262(a)(1)'s protections as it applies to state issued domestic violence "stay- away" orders. Pilson also challenges the district court's application of a sentencing enhancement for obstruction of justice, U.S.S.G. § 3C1.1, which is (as you will see below) essentially a challenge aimed at the procedural reasonableness of that enhancement. For the reasons we discuss below, we affirm. I. Background We provide most of the basic facts here in the light most flattering to the verdict, "reserving additional details for our discussion of the specific issues raised in this appeal." See, - 2 - e.g., United States v. Ayala-Vazquez, 751 F.3d 1, 7 (1st Cir. 2014). a. Pilson's Massachusetts Conviction Pilson first crossed paths with Stefanov in 2018 at a rehab center known as "Dexter House," where he was admitted following injuries he suffered in a traffic accident. Stefanov was the center's director of social services and, while there, she and Pilson developed a close relationship. After spending nearly three months at Dexter House, Pilson left and, shortly thereafter, moved in with Stefanov.1 Pilson and Stefanov continued their relationship, but the good times quickly turned bad. So bad, in fact, that on October 15, 2019, a calamitous domestic violence episode ensued: after kicking, striking, and forcing Stefanov into a vehicle, Pilson held her captive while driving erratically from New Hampshire into Massachusetts. Throughout the ordeal, Pilson repeatedly yelled threats at her, such as: "You are going to die, bitch. You deserve it. You put me in jail for three months, and now you think you can leave me . . . You're going to die today." Stefanov was in tears and pleading with him to stop the car, but instead (that is, instead of adhering to her pleas), Pilson slowed the vehicle to turn around, and she was "able to free herself from 1 Stefanov's employment with Dexter House ended in No