⚖ Oral Arguments, with Context

The First Circuit considers whether a Bitcoin prosecution was tainted by references to unrelated fraud. Alan Joseph exchanged cash for Bitcoin. In undercover meetings, an agent presented himself as a seller of counterfeit designer goods who needed Bitcoin to pay a supplier. Prosecutors said Joseph knew what those transactions were meant to support. A jury convicted him of money laundering and operating an unregistered money-transmitting business. The jury acquitted him on one other laundering count. The appeal concerns trial testimony about romance scams and cryptocurrency investment fraud, not charges that Joseph ran those schemes. His lawyer will argue that these references portrayed him as a habitual criminal and denied him a fair trial. This is a propensity concern: treating someone's supposed criminal character as proof of the charged conduct. The government will acknowledge that some fraud references were unnecessary, but will argue that the judge's warnings kept jurors focused on the actual charges. A limiting instruction tells jurors how they may use particular evidence. The government will also point to the undercover evidence and the mixed verdict. Even if testimony should have been excluded, the court must consider whether it affected the verdict. That is the harmless-error question at the heart of this appeal.

United States v. Joseph (No. 25-1610) — U.S. Court of Appeals for the First Circuit, argued November 2, 2026.