United States v. González-Román

MEMORANDUM IN SUPPORT OF VARIANCE

JOSE ANTONIO FUSTE, District Judge.

I

Introduction

It is undeniable that violent crime is rampant in Puerto Rico. See Watchtower *273Bible and Tract Society of New York, Inc. v. Sagardia De Jesus, 634 F.3d 3 (1st Cir.2011) (“Watchtoiver I”). In Watchtower I, the First Circuit examined the constitutionality of Puerto Rico’s Controlled Access Law, which allowed neighborhoods to close off access to public streets. Id. The Court recognized that “[t]he Controlled Access Law [ ] was prompted by and adopted against a background of endemic violent crime.” Id. at 6. “Puerto…