United States v. Maldonado-Maldonado

── United States v. Maldonado-Maldonado ── Court: Court of Appeals for the First Circuit Date: June 08, 2026 Category: General United States Court of Appeals For the First Circuit No. 25-1607 UNITED STATES, Appellee, v. HÉCTOR MALDONADO-MALDONADO, Defendant, Appellant. APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO [Hon. María Antongiorgi-Jordán, U.S. District Judge] Before Barron, Chief Judge, Lipez and Rikelman, Circuit Judges. José David Rodríguez, Assistant Federal Public Defender, with whom Rachel Brill, Federal Public Defender, and Franco L. Pérez-Redondo, Assistant Federal Public Defender, Supervisor, Appellate Unit, were on brief, for appellant. Maarja T. Luhtaru, with whom W. Stephen Muldrow, United States Attorney, Juan Carlos Reyes-Ramos, Assistant United States Attorney, Chief, Appellate Division, and Julia M. Meconiates, Assistant United States Attorney, were on brief, for appellee. June 8, 2026  RIKELMAN, Circuit Judge. For the second time, Héctor Maldonado-Maldonado ("Maldonado") appeals his sentence for assaulting a corrections officer. He lodges several procedural challenges to his revised sentence. We agree with Maldonado that the district court legally erred when it relied on information outside the record, without any notice to him, in determining his sentence. Thus, we vacate the judgment and remand for resentencing. I. BACKGROUND1 A. Relevant Facts In August 2020, while he was incarcerated at the Metropolitan Detention Center in Guaynabo, Maldonado assaulted a senior corrections officer (SCO). See United States v. Maldonado-Maldonado (Maldonado I), 134 F.4th 32, 33-34 (1st Cir. 2025). During the assault, Maldonado punched the SCO multiple times and placed him in a headlock, all with the help of his cellmate, Miguel Santana-Aviles ("Santana"). See id. at 34. The SCO suffered injuries to his head and neck and experienced headaches for months after the attack. See id. A grand jury eventually charged both Maldonado and Santana with assaulting, 1Because this appeal follows a guilty plea, we draw the relevant facts from the plea agreement, the unobjected-to portions of the Presentence Investigation Report, and the transcript of the sentencing hearing. See United States v. Colón-Cordero, 91 F.4th 41, 45 (1st Cir. 2024). - 2 - resisting, or impeding a federal officer. See 18 U.S.C. § 111(a)(1), (b). B. Procedural History 1. The Initial Sentencing and Appeal Although Santana proceeded to trial, Maldonado eventually pleaded guilty to the charge against him. See Maldonado I, 134 F.4th at 34. As part of his plea deal, Maldonado and the government agreed to propose to the district court a sentencing calculation that hinged on applying the "[o]bstructing or [i]mpeding [o]fficers" guideline in the United States Sentencing Guidelines. See U.S. Sent'g Guidelines Manual ("U.S.S.G.") § 2A2.4 (U.S. Sent'g Comm'n 2021).2 Given Maldonado's criminal history category and various adjustments, the agreed-upon calculation would have yielded a sentencing range of 18 to 24 months in prison. Separately, the U.S. Probation Office submitted a Presentence Investigation Repo