Justia Criminal Law Opinion Summaries

The case involves a defendant who, in 2012, pled guilty to a federal drug conspiracy charge and was sentenced in 2013 to a 120-month prison term followed by five years of supervised release. At sentencing, the district court orally imposed four special conditions of supervised release but did not mention any standard, non-mandatory conditions. However, the written judgment issued later that day included both the special conditions and fourteen standard conditions. Years later, after his release from prison, the defendant was accused of violating several of these standard conditions, specifically those requiring notification of changes in residence or employment and permitting home visits by a probation officer.After allegations of these violations, the United States District Court for the District of Maryland held a revocation hearing. The defendant admitted to violating the standard conditions regarding home visits, and the government agreed to dismiss the other violations. The court revoked supervised release and imposed a new sentence of 90 days’ imprisonment and an additional 42 months of supervised release with the same conditions as previously imposed. The defendant appealed, arguing that, under United States v. Rogers, the standard conditions were invalid because they were not orally pronounced at his sentencing.The United States Court of Appeals for the Fourth Circuit reviewed whether the defendant’s appellate waiver barred the claim, whether the appeal was procedurally proper, and whether there was plain error. The court held that the appellate waiver did not bar the challenge because the defendant was not appealing the original sentence but the revocation based on conditions never validly imposed. The court found the appeal timely and procedurally proper under recent circuit precedent. Applying plain error review, the court ruled that revocation based on unpronounced, discretionary conditions was error, affected substantial rights, and undermined the integrity of the proceedings. The Fourth Circuit vacated the district court’s revocation judgment and remanded for resentencing. View "United States v. McLaurin" on Justia Law

Deputies from the St. Tammany Parish Sheriff’s Office responded to a late-night call reporting suspicious activity at a local automotive business. On arrival, they found Michael Steven White at the scene, with several vehicle doors and hoods open. White admitted to opening some of the vehicles, explaining he was either looking for parts to sell or searching for a car for his mother. He was subsequently charged with six counts of simple burglary. At trial, the jury was instructed verbally that they could find White guilty of simple burglary, guilty of attempted simple burglary, or not guilty on each count. However, the written verdict form given to the jury omitted “not guilty” as an option and instead listed only guilty-related verdicts.White was convicted on all six counts, adjudicated as a fourth-felony offender, and sentenced to twenty years on each count, to be served concurrently. On appeal, he argued the evidence was insufficient and that the omission of a “not guilty” option on the written verdict form constituted reversible error. The Louisiana Court of Appeal, First Circuit, found the evidence sufficient and, relying on State v. Craddock, determined the omission did not amount to reversible error, especially since the trial court gave correct oral instructions and there was no timely objection.The Supreme Court of Louisiana reviewed whether the failure to include a “not guilty” option on the written verdict form was reversible error. The court held that this omission was a patent error touching on the fundamental right to a fair trial and the presumption of innocence, and that it was not harmless under the circumstances. The Supreme Court of Louisiana found that the error could have caused juror confusion, undermined the fairness of the proceedings, and was not subject to harmless error analysis. Therefore, the court reversed the convictions, habitual offender adjudication, and sentences, and remanded the case for further proceedings. View "STATE OF LOUISIANA VS. WHITE" on Justia Law

The defendant was convicted of armed robbery and his conviction was affirmed on appeal. He later filed a collateral attack on his conviction, alleging ineffective assistance of counsel and claiming that his defense attorney prevented him from testifying at trial. In support of his post-conviction claims, the defendant submitted several affidavits, but did not provide testimony or an affidavit from his trial counsel to substantiate his allegations.The trial court granted the defendant’s application for post-conviction relief, finding that defense counsel’s prevention of the defendant's testimony constituted structural error, which required automatic reversal of his conviction. The Louisiana Court of Appeal, Fourth Circuit, reversed this decision, relying on State v. Hampton and concluding that such collateral attacks must be supported by testimony or an affidavit from defense counsel acknowledging they prevented the defendant from testifying. The defendant sought review by the Supreme Court of Louisiana, which granted certiorari.The Supreme Court of Louisiana addressed whether the trial court properly granted post-conviction relief. The court held that, on collateral review, a claim that defense counsel prevented a defendant from testifying is reviewed under the Strickland v. Washington standard, requiring the defendant to show both constitutionally deficient performance and resulting prejudice. The court overruled Hampton to the extent it required automatic reversal for such claims on collateral review and to the extent it required substantiating evidence exclusively from defense counsel. The court found the record insufficient to determine whether the Strickland standard was met and remanded to the trial court for a hearing to make such findings. The disposition was reversed and remanded. View "STATE OF LOUISIANA VS. TURNER" on Justia Law

The defendant was charged with first-degree rape and aggravated crime against nature, with allegations that he sexually abused his eight-year-old son while giving him a bath. The child was taken to the hospital on the night of the alleged incident, but no physical evidence of abuse was found. About a month later, the child was evaluated by a psychiatric mental health nurse practitioner at a children’s hospital, who subsequently diagnosed the child with “child sexual abuse.” The State gave notice of its intent to offer the nurse practitioner as an expert witness at trial.After a Daubert hearing, the Criminal District Court for the Parish of Orleans found the nurse practitioner qualified as an expert in pediatric child abuse medicine and ruled that she could testify about her diagnosis at trial. The defendant sought supervisory review, but the Louisiana Fourth Circuit Court of Appeal denied the writ. The appellate court cited prior precedent permitting such expert testimony, reasoning that a nurse practitioner’s diagnosis did not usurp the jury’s role in determining the defendant’s guilt.Upon review, the Supreme Court of Louisiana held that the trial court erred in allowing the expert to testify regarding her diagnosis of child sexual abuse. The court found the methodology underlying the diagnosis insufficiently reliable under Louisiana Code of Evidence article 702(A), particularly because the diagnosis was based almost entirely on the child’s statements, which the jury would be able to hear and assess directly. The Supreme Court also determined that such expert testimony would improperly bolster the credibility of the complaining witness, potentially prejudicing the defendant. The court reversed the lower court’s ruling, holding that under these circumstances, the expert’s diagnosis was inadmissible. View "STATE OF LOUISIANA VS. CLOUDIE" on Justia Law

A man was indicted and tried for three counts of abusive sexual contact involving his niece, who was twelve years old at the time and lived with her grandmother, sisters, and several uncles, including the defendant. The charges stemmed from two incidents in which the niece reported that her uncle had touched her inappropriately on multiple parts of her body. At trial, the niece testified in detail about the first incident, describing how the defendant entered her room, massaged her back, and then touched her buttocks, breasts (over her bra), and genital area (over her clothes). She also described a second incident, but the defendant was acquitted of the charge relating to that event.A federal grand jury returned a superseding indictment charging the defendant with three counts, but the jury convicted him only on two counts—one for touching the genitalia and one for touching the breasts during the first incident. The United States District Court for the District of New Mexico denied the defendant’s post-trial motions for judgment of acquittal and to merge the two convictions, finding sufficient evidence for the convictions and holding that each touching constituted a separate offense under the statute.Upon appeal, the United States Court of Appeals for the Tenth Circuit reviewed de novo the questions of multiplicity under the Double Jeopardy Clause and sufficiency of the evidence. The court held that the convictions were not multiplicitous because the relevant statute, 18 U.S.C. §§ 2244(a)(3) and 2246(3), defines abusive sexual contact as a separate-act offense, allowing for separate punishment for each intentional touching of an enumerated body part. The court also determined that sufficient evidence supported the jury’s verdict, as a rational juror could find the requisite sexual intent based on the victim’s testimony. The judgment of conviction was affirmed. View "United States v. Aguilar" on Justia Law

The case involves a defendant who, while guarding a cache of drugs and money, opened fire on law enforcement officers, wounding one but not fatally due to protective gear. He was indicted by a federal grand jury on several charges, including attempted murder of federal officers and using a firearm during a crime of violence under 18 U.S.C. § 924(c). Under a plea agreement, he pleaded guilty to two counts of attempted murder, one § 924(c) count (with attempted murder as the predicate crime of violence), and a firearm possession charge, waiving most rights to appeal or collaterally attack his conviction. In exchange, the government dropped other charges and agreed not to prosecute his son.After his conviction, the defendant pursued multiple post-conviction relief motions under 28 U.S.C. § 2255, all unsuccessful. Following the Supreme Court’s decision in United States v. Davis, which invalidated the “residual clause” of § 924(c)’s definition of “crime of violence” as unconstitutionally vague, he sought authorization to file a successive § 2255 motion. The United States Court of Appeals for the Tenth Circuit granted authorization, and the District of Utah considered the merits. The district court denied relief, concluding the plea waiver barred relief and, alternatively, that the defendant failed to show the sentencing court relied on the residual clause.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the denial of the § 2255 motion. The court held that the defendant did not prove by a preponderance of the evidence that the sentencing court relied on the now-invalid residual clause when applying § 924(c). The court further affirmed that attempted murder qualifies as a “crime of violence” under the still-valid “elements clause” of § 924(c). The Tenth Circuit affirmed the district court’s denial of post-conviction relief. View "United States v. Sandoval-Flores" on Justia Law

Andrew Butler was arrested after his ex-girlfriend reported to police that he broke into her apartment with a gun and then left in a car registered to him. Officers, knowing Butler was a convicted felon on probation with a waiver permitting warrantless searches and with outstanding misdemeanor arrest warrants, went to his workplace, Altium Packaging. There, they located his vehicle but did not see a gun inside. Upon entering the workplace, officers encountered Butler, who then fled, and during their pursuit, they saw him pick up a gun. After a brief chase, Butler was apprehended near the gun, which was recovered by police.The United States District Court for the Eastern District of Arkansas denied Butler’s motion to suppress the gun and related fingerprint evidence, ruling that he did not have a basis to challenge the officers’ entry into his workplace and, alternatively, that his search waiver justified the entry. Butler then pleaded guilty to being a felon in possession of a firearm, reserving the right to appeal the denial of his suppression motion. The district court sentenced him to 60 months in prison, a sentence above the advisory guidelines range.On appeal, the United States Court of Appeals for the Eighth Circuit held that Butler could not challenge the officers’ entry under the Fourth Amendment because he could not assert greater privacy rights than the property owner, and Steagald v. United States did not extend a right to object to entry into a third party’s property to the subject of an arrest warrant. The appellate court also found that the district court did not abuse its discretion in imposing an above-guidelines sentence, as it reasonably considered the relevant sentencing factors. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Butler" on Justia Law

Missouri state police linked James Darrick Beeler to an IP address sharing child pornography in 2022. A search warrant led to the seizure of several electronic devices from Beeler’s residence, which, after forensic analysis, were found to contain numerous images of child pornography. Beeler subsequently pled guilty to possession of child pornography in federal court. He had a previous 2007 conviction in Missouri for abuse of a child, based on recording two nude minor children for sexual gratification.The United States District Court for the Eastern District of Missouri determined that Beeler’s prior conviction triggered the 10-year mandatory minimum sentence under 18 U.S.C. § 2252A(b)(2). The court found that the Missouri statute, although overbroad on its face, was divisible and that Beeler’s conviction under the relevant subsection “related to” child pornography as contemplated by the federal enhancement statute. Beeler was sentenced to 120 months’ imprisonment and lifetime supervised release. He appealed, arguing both that his prior conviction did not qualify and that the sentencing statute was unconstitutionally vague.The United States Court of Appeals for the Eighth Circuit reviewed the statutory interpretation and constitutional challenge de novo. The court held that the Missouri statute was divisible, and Beeler’s conviction under Mo. Rev. Stat. § 568.060.1(2) was sufficiently related to the offenses enumerated in 18 U.S.C. § 2252A(b)(2) to trigger the mandatory minimum. The court also held that the “relating to” language in the statute was not unconstitutionally vague, as it provided adequate notice and did not permit arbitrary enforcement. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Beeler" on Justia Law

Jerron Williams was involved in an altercation with a United States Postal Service letter carrier in Gary, Indiana. After a brief dispute, Williams fired several shots into the carrier's vehicle as she attempted to leave, causing her physical injuries. A grand jury indicted Williams on three counts: assaulting a federal employee with a deadly weapon causing bodily injury, discharging a firearm during a crime of violence, and unlawful possession of a firearm by a felon. Williams entered into a plea agreement, admitting guilt to the first two counts and waiving his right to appeal.The United States District Court for the Northern District of Indiana, Hammond Division, held a change of plea hearing where the magistrate judge explained the charges and their elements. Williams, with his attorney’s agreement, confirmed his understanding and acceptance of the facts and the charges. Prior to sentencing, Williams changed attorneys and sought to withdraw his plea, alleging ineffective assistance of counsel. The district court held an evidentiary hearing, denied the motion to withdraw the plea, and sentenced Williams to 153 months in prison.On appeal, Williams argued for the first time that his conviction under 18 U.S.C. § 924(c) was invalid because the predicate offense under 18 U.S.C. § 111(b) was not a “crime of violence.” The United States Court of Appeals for the Seventh Circuit reviewed the case for plain error and determined that Williams had waived this argument multiple times: by pleading guilty, by waiving his right to appeal, and by not raising the argument in his motion to withdraw the plea. The court also found that the magistrate judge properly explained the charges and ensured Williams’s understanding. As a result, the Seventh Circuit dismissed the appeal. View "USA v JWilliams" on Justia Law

In this case, the defendant was stopped by law enforcement officers in Seward County, Nebraska, after officers observed his vehicle turn without signaling and swerve as it drove. The officers approached the vehicle and observed signs of intoxication, including the smell of alcohol and the defendant’s slurred speech. The defendant admitted to drinking and was arrested for driving under the influence (DUI) and transported to the county detention center, where he submitted to a breath test. His blood alcohol content was measured at .131 grams per 210 liters of breath. After the breath test, an officer informed the defendant, incorrectly, that he could seek an independent chemical test only after being released, when in fact he had the statutory right to do so while still in custody.The County Court for Seward County denied the defendant’s motion to suppress the breath test results, finding that the officers had probable cause to stop the vehicle based on a traffic violation and did not hamper or prevent the defendant from obtaining an independent test. A bench trial resulted in a conviction for DUI and an open container violation. Upon appeal, the District Court for Seward County affirmed, concluding that the officer’s incorrect statement did not amount to a refusal or denial of the defendant’s statutory right to an independent test.The Nebraska Supreme Court reviewed the case and affirmed the district court’s decision. It held that the officer’s mistaken or incomplete advisement regarding the timing of the independent test did not constitute a refusal to permit such a test under Neb. Rev. Stat. § 60-6,199. The court found the officers had probable cause for the initial stop, and the defendant’s statutory and constitutional rights were not violated. The judgment of the district court was affirmed. View "State v. Weber" on Justia Law