Justia Criminal Law Opinion Summaries

The case concerns an individual who was convicted in Texas state court in 2021 for sexually assaulting a thirteen-year-old child. After serving his sentence, he was deported to Honduras due to his lack of lawful immigration status. He later reentered the United States illegally and, following his detention for immigration violations in 2024, admitted that he had not registered as a sex offender, as required by federal law. He pleaded guilty in federal district court to failing to register as a sex offender under the Sex Offender Registration and Notification Act (SORNA).The United States District Court for the Southern District of Texas classified the defendant as a tier III sex offender—the most serious category under SORNA—and sentenced him to 24 months’ imprisonment followed by five years of supervised release. This classification was based on the court’s determination that his Texas conviction was comparable to the federal offenses of aggravated sexual abuse or sexual abuse. The defendant did not object to the presentence report’s findings at sentencing but appealed, arguing that he should have been classified as a tier I offender, the least severe category.The United States Court of Appeals for the Fifth Circuit reviewed the appeal for plain error, as the argument was raised for the first time on appeal. The court concluded that the Texas statute under which the defendant was convicted criminalizes a broader range of conduct than the comparable federal offenses referenced by SORNA for tier II and tier III classification. Specifically, the Texas law punishes consensual sexual acts with minors under 17, while the federal statutes require nonconsensual conduct or involve narrower age ranges. Therefore, the Fifth Circuit held that the defendant does not qualify as either a tier II or tier III offender and must be classified as a tier I offender. The court vacated the sentence and remanded for resentencing. View "United States v. Quintanilla-Matamoros" on Justia Law

In 1989, a man committed a brutal murder at a Kentucky laundromat, killing a 61-year-old employee after she asked him to leave. After his arrest, he was charged with several crimes, including murder. Five years later, he pleaded guilty to all charges. He sought to have a judge, rather than a jury, decide his sentence, hoping for a more favorable outcome due to the nature of his crimes. After a series of legal maneuvers and a failed attempt to withdraw his guilty plea, a judge ultimately sentenced him to death, despite the presentation of significant mitigating evidence about his abusive childhood and mental health struggles.On direct appeal, the Kentucky Supreme Court affirmed both his conviction and sentence, rejecting his arguments that his guilty plea was not knowing and voluntary and that the sentencing court had failed to consider all mitigating evidence. The court found that while the trial court’s plea colloquy did not specifically enumerate every right waived by pleading guilty, it was sufficient to show that the defendant understood the consequences. The court also concluded that the sentencing judge had considered all mitigating evidence, even if he found it unpersuasive.After exhausting state postconviction remedies, the petitioner filed a federal habeas corpus petition in the United States District Court for the Eastern District of Kentucky, raising multiple grounds for relief. The district court denied relief and declined to issue a certificate of appealability. The United States Court of Appeals for the Sixth Circuit granted a limited certificate and reviewed two claims de novo: whether the plea was knowing and voluntary, and whether the trial court failed to consider mitigating evidence.The Sixth Circuit held that the Kentucky Supreme Court had not unreasonably applied clearly established federal law in either respect. The record affirmatively demonstrated the petitioner’s understanding of his rights, and the sentencing court’s consideration of mitigation evidence was constitutionally adequate. Accordingly, the Sixth Circuit affirmed the district court’s denial of habeas relief. View "Johnson v. Plappert" on Justia Law

Two fourteen-year-old girls residing in a group home in Dayton, Ohio, contacted Kelly Richards, a man they knew as “Scorpio,” and asked him to pick them up. Richards transported the girls to his apartment in Cincinnati, where he facilitated their drug use, sexually assaulted them, and coerced them into prostitution over several days. He controlled their movements, threatened them with weapons, and advertised them online for sex. The girls eventually escaped, and authorities began an investigation that uncovered substantial evidence connecting Richards to their exploitation, including digital communications and photographs.The United States District Court for the Southern District of Ohio reviewed the evidence and denied Richards’s suppression motion, finding probable cause supported the search warrants. Richards proceeded to a jury trial, which resulted in convictions on two counts of sex trafficking minors, two counts of sexually exploiting children, and one count of possessing a firearm as a felon. He was sentenced to 480 months in prison and a life term of supervised release. Richards raised several legal challenges before and during trial, including claims regarding the Speedy Trial Act, search warrant validity, denial of self-representation, limits on cross-examination, and the substantive reasonableness of his sentence.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The Sixth Circuit held that Richards’s trial occurred within the statutory and constitutional limits for a speedy trial, the search warrants were supported by probable cause and did not require a Franks hearing, the district court did not abuse its discretion in denying mid-trial self-representation, and limiting cross-examination of the government’s agent did not violate Richards’s rights. The court also found Richards’s below-Guidelines sentence substantively reasonable and denied his motion to file a supplemental pro se brief. The judgment and sentence were affirmed. View "United States v. Richards" on Justia Law

In this case, a federal prisoner pleaded guilty in 2008 to charges including conspiracy and attempted Hobbs Act robbery, as well as using a firearm during a “crime of violence” under 18 U.S.C. §924(c). The firearm conviction carried a mandatory 10-year consecutive sentence. After later Supreme Court decisions—United States v. Davis (which invalidated the residual clause of §924(c) as unconstitutionally vague) and United States v. Taylor (which held that attempted Hobbs Act robbery does not qualify as a “crime of violence” under the elements clause)—the validity of the petitioner’s §924(c) conviction was called into doubt.The petitioner first sought relief in federal district court in 2016, but was denied because at that time, Eleventh Circuit precedent still considered attempted Hobbs Act robbery a crime of violence under the elements clause. After Davis, the petitioner sought authorization from the United States Court of Appeals for the Eleventh Circuit to file a second or successive motion under 28 U.S.C. §2255(h), but the court denied authorization, finding he could not make a prima facie case for relief based on then-current precedent. After Taylor, he again sought authorization, but the Eleventh Circuit denied or dismissed his requests, relying on 28 U.S.C. §2244(b)(1) to bar claims previously presented and holding that Taylor did not announce a new constitutional rule. The petitioner’s efforts for rehearing and for certification of the controlling question to the Supreme Court were also denied.The Supreme Court of the United States held that the certiorari bar in §2244(b)(3)(E) does not apply to federal prisoners seeking leave to file a second or successive motion under §2255(h), so the Court had jurisdiction. The Court further held that §2244(b)(1)’s bar on previously presented claims applies only to state prisoners’ habeas applications under §2254, not to federal prisoners’ §2255 motions. The Court vacated the Eleventh Circuit’s decision and remanded for further proceedings. View "Bowe v. United States" on Justia Law

Ali Al-Timimi, a respected lecturer at an Islamic center in Virginia, became acquainted with a group of young Muslim men who engaged in activities including paintball, which some saw as preparation for “jihad in the form of combat.” While Al-Timimi did not directly participate in these preparations, he offered advice on discretion after FBI attention. Following the September 11, 2001 attacks, Al-Timimi attended a gathering where he urged attendees to repent, leave the United States, and join militant groups abroad, including Lashkar-e-Taiba (LET) in Pakistan. His statements inspired several individuals to make concrete plans to travel overseas for training, though he did not provide operational details or set timelines. Some group members subsequently traveled to Pakistan but did not engage in combat.The United States District Court for the Eastern District of Virginia indicted and convicted Al-Timimi on multiple counts, including conspiracy, solicitation, and aiding terrorist groups. He was sentenced to life imprisonment and other consecutive terms. Over two decades, his case saw numerous appeals and remands, including vacatur of certain counts based on changes in law regarding “crimes of violence” (as in Johnson v. United States and United States v. Davis). Ultimately, Al-Timimi appealed his remaining convictions (Counts 2–6, 9, and 10), asserting First Amendment protection for his speech.The United States Court of Appeals for the Fourth Circuit reviewed de novo whether Al-Timimi’s speech constituted unprotected incitement, solicitation, or facilitation of criminal acts. The court held that his speech, though inflammatory and disturbing, did not incite imminent lawless action nor did it intentionally solicit or assist a specific crime. As his advocacy did not meet the narrow exceptions to First Amendment protection, the court vacated Al-Timimi’s remaining convictions and remanded for judgments of acquittal. View "US v. Al-Timimi" on Justia Law

Police in Milwaukee searched Michael Yumang’s car and home in 2019 and 2022, finding distribution quantities of methamphetamine, a handgun, and ammunition. Before the 2022 search, a postal inspector intercepted a package containing a quarter pound of meth addressed to Yumang’s residence from California. Yumang admitted to regularly obtaining meth from California and reselling it in Wisconsin. He was charged with three drug-trafficking offenses related to each meth seizure and the intercepted shipment, as well as unlawful possession of a firearm in furtherance of a drug crime.After an indictment and pretrial proceedings, Yumang waived his right to a jury trial and had a bench trial in the United States District Court for the Eastern District of Wisconsin. The government called multiple witnesses, including three forensic chemists who analyzed the seized meth, confirming its purity and quantity. Prior to trial, the government disclosed—subject to a protective order—that the DEA chemist who tested the 2019 meth had been placed on a performance improvement plan in 2023. At trial, Yumang’s attorney sought to cross-examine the chemist about the plan, but the judge ruled the information irrelevant since the performance issues arose years after the chemist’s work on the case. The judge found Yumang guilty on all counts and imposed a sentence of 180 months.On appeal to the United States Court of Appeals for the Seventh Circuit, Yumang argued that briefly closing the courtroom to make a record of the sidebar discussion about the chemist’s performance plan violated his Sixth Amendment right to a public trial, and that the exclusion of the proposed cross-examination was both evidentiary error and a Confrontation Clause violation. The Seventh Circuit held that the five-minute courtroom closure was too trivial to constitute a Sixth Amendment violation and that excluding the cross-examination was neither an evidentiary nor constitutional error. The court affirmed the judgment. View "USA v Yumang" on Justia Law

Charles Cui was charged with bribery and related offenses after he attempted to secure the assistance of Edward Burke, a powerful Chicago alderman, in reversing a permit denial by the Chicago Department of Buildings (CDOB) regarding a pole sign at his commercial property. Cui’s financial interests were jeopardized by the permit denial, which threatened both a lucrative lease with Binny’s Beverage Depot and tax increment financing from the City. To influence Burke, Cui offered to retain Burke’s law firm for property tax appeal work, explicitly seeking Burke’s intervention in the CDOB matter.The United States District Court for the Northern District of Illinois, Eastern Division, presided over a six-week trial in which a jury convicted Cui on all counts: bribery under 18 U.S.C. § 666(a)(2), violations of the Travel Act, and making false statements to the government. The district court admitted evidence over Cui’s objections, including a photoshopped photograph sent to the CDOB, and denied Cui’s post-trial motions for acquittal and a new trial. The court sentenced Cui to 32 months’ imprisonment and applied an obstruction-of-justice enhancement for failing to produce key emails in response to a grand jury subpoena.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed Cui’s challenges to the sufficiency of evidence, jury instructions, evidentiary rulings under Federal Rule of Evidence 404(b), and sentencing. The court held that sufficient evidence supported the convictions, that the jury instructions correctly conveyed the law’s requirements—including the quid pro quo element and the definition of “corruptly”—and that the admission of the photoshopped photograph was not an abuse of discretion. The court also found that the sentencing enhancement and the disparity between Cui’s and Burke’s sentences were justified. The Seventh Circuit affirmed the judgment of the district court. View "USA v Cui" on Justia Law

On July 3, 2021, a group of young women in Topeka, Kansas, were involved in escalating physical and verbal altercations. The confrontation ended with Daisha Butler firing a gun, resulting in the death of 17-year-old N.M., who was shot in the head while running away. Butler had previously purchased the firearm legally, and ballistic evidence linked the shell casing at the scene to her weapon. Witnesses described various fights between two groups and Butler’s eventual admission to firing the gun, allegedly for self-defense and to protect her daughter, though she denied intentionally shooting anyone.The District Court of Shawnee County presided over Butler’s trial. The jury convicted Butler of first-degree felony murder, based on the inherently dangerous felony of aggravated endangering a child, and of aggravated endangering a child itself. The court merged the murder convictions and sentenced Butler to life in prison without parole for 25 years, plus a consecutive prison term. Butler appealed directly to the Kansas Supreme Court, arguing insufficient evidence, errors regarding the admission of prior crimes evidence, improper jury instructions (including self-defense and lesser-included offenses), and cumulative error.The Supreme Court of the State of Kansas affirmed the convictions. It held that the evidence was sufficient for a rational factfinder to convict Butler of aggravated endangering a child and felony murder, clarifying that the State is not required to prove the defendant knew the victim was a minor; only the fact of the victim’s age must be shown. The court found no abuse of discretion in denying a mistrial after a fleeting reference to marijuana possession. Instructional errors regarding lesser-included offenses and self-defense were deemed harmless, and the cumulative error doctrine did not apply, as there was only a single, non-prejudicial error. View "State v. Butler " on Justia Law

The defendant faced fourteen serious federal charges, including multiple counts related to methamphetamine distribution and a firearms offense, which exposed him to the possibility of life imprisonment and asset forfeiture. He, his attorney, and the government negotiated a plea agreement under which the defendant would plead guilty to a single count of methamphetamine distribution in exchange for dismissal of the remaining charges. However, at the scheduled change-of-plea hearing, the defendant hesitated and expressed a need for further information before deciding to enter a guilty plea. His attorney, citing a breakdown in their relationship, requested to withdraw from the case.The United States District Court for the District of Kansas held an ex parte discussion with the defendant and his attorney to address the attorney’s request. During this conversation, the court explained possible consequences if the attorney withdrew, including potential delays and the government’s ability to withdraw its plea offer. The defendant ultimately decided to proceed with the plea agreement. The district court then conducted the plea colloquy but failed to explicitly inform the defendant of his right to appointed counsel if he could not afford one, as required by Federal Rule of Criminal Procedure 11(b)(1)(D). The defendant did not object to this omission at the time.On appeal, the United States Court of Appeals for the Tenth Circuit considered whether the district court improperly participated in plea negotiations and whether the failure to explicitly advise the defendant of his right to appointed counsel warranted reversal. The Tenth Circuit held that the district court did not participate in plea negotiations by merely advising the defendant about the status of the plea offer and available options regarding representation. The court further held that the omission regarding the right to appointed counsel did not affect the defendant’s substantial rights because he had previously been informed of this right and demonstrated an understanding of it. The conviction was affirmed. View "United States v. Eckstein" on Justia Law

The defendant faced four criminal charges in separate cases—three for theft (shoplifting) and one for interference with official acts following an arrest. As part of a single plea agreement, he pled guilty to two theft charges; in return, the State dismissed the remaining two cases, with the defendant agreeing to pay costs in the dismissed cases. The Iowa District Court for Polk County sentenced the defendant in the two theft cases, dismissed the other two, and ordered him to pay costs for the dismissed cases, including indigent defense recoupment and filing fees.After the district court’s dispositional orders, the defendant appealed, challenging the court’s authority to assess costs in the dismissed cases. The Iowa Supreme Court granted discretionary review to address this issue. The State conceded that no statute authorized the district court to impose costs in dismissed criminal cases. The Supreme Court examined relevant statutory provisions, noting that neither Chapter 815 nor Chapter 910 of the Iowa Code allows for assessment of costs against a defendant when a case is dismissed, as such authority was repealed in 2012.The Iowa Supreme Court held that parties cannot confer statutory authority on the court through a plea agreement for a disposition not authorized by statute. Accordingly, the district court’s orders assessing costs in the dismissed cases were ultra vires and invalid. The Supreme Court vacated the convictions, sentences, and dispositional orders, and remanded the cases. On remand, the State may elect either to vacate only the unauthorized cost orders while enforcing the remainder of the plea bargain, or to vacate the entire plea agreement and all resulting orders, with the option to reinstate any dismissed charges. View "State of Iowa v. Pagliai" on Justia Law