The federal appeals court in Boston has overturned the prison sentence of an inmate convicted of assaulting a corrections officer, ruling that the trial judge improperly used secret, unlisted disciplinary records to justify a harsher penalty.
It marks the second time the U.S. Court of Appeals for the First Circuit has tossed out a sentence for Héctor Maldonado-Maldonado. The court ordered that his case be sent to a completely different judge for an expedited resentencing hearing.
The case stems from an August 2020 incident at the Metropolitan Detention Center in Guaynabo, Puerto Rico. Maldonado and a cellmate assaulted a senior corrections officer, leaving the guard with head and neck injuries. Maldonado later pleaded guilty.
Under a plea agreement, prosecutors and the defense agreed to recommend a sentence of 18 to 24 months. However, the U.S. Probation Office calculated a much higher recommended range of 63 to 78 months, using evidence from the cellmate’s trial. At the initial 2022 sentencing, the government broke its agreement and advocated for the higher range. The original judge handed down a 78-month sentence.
Maldonado appealed, and the government admitted it breached the deal. The appeals court threw out that sentence and sent the case to a second judge to provide a “clean slate.”
At the May 28, 2025 resentencing, the government kept its promise, asking for a sentence of “time served” because Maldonado had already spent 48 months behind bars.
Instead, the second district judge rejected the deal, adopting a guidelines range of 57 to 71 months and sentencing Maldonado to the maximum 71 months. During the hearing, the judge cited five recent jailhouse disciplinary infractions from October 2022 to March 2025, including refusing a drug test and lying.
Those five violations were never included in the official pre-sentence report, meaning Maldonado’s defense lawyers had no warning or opportunity to challenge them. The judge stated during the hearing that “the record proves him wrong” regarding his rehabilitation “because after he was sentenced in this case, he has committed five other violations.”
Maldonado’s defense immediately objected to the use of outside information. While the judge later claimed the sentence was based strictly on the facts of the case, the judge also stated the infractions were considered to evaluate Maldonado’s “prognosis of rehabilitation.”
The First Circuit ruled Monday that relying on those unlisted violations without notifying the defense was a procedural error.
The appeals court rejected Maldonado’s separate argument that the second judge violated court orders by reviewing transcripts from the first, flawed sentencing. The court ruled that judges have broad discretion to look at their own dockets.
However, the three-judge appellate panel found that the secret inclusion of the five recent prison violations violated the defendant’s right to a fair hearing.
“A convicted defendant has the right to be sentenced on the basis of accurate and reliable information, and implicit in this right is the opportunity to rebut the evidence,” the court stated in its opinion.
The court noted that the judge spoke about the violations right before issuing the 71-month term, showing they directly influenced the longer sentence. Because the information came through an unrecorded communication with the probation officer, the appeals court ruled the process was compromised.
Maldonado is currently scheduled to be released on October 19, 2026. His pending motion for bail was denied as moot because of the order for an immediate resentencing.
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