Justia Criminal Law Opinion Summaries

Joseph Dwayne Matt was a passenger in Levi Gadaire’s vehicle when it was stopped by law enforcement for erratic driving. Both Matt and Gadaire were probationers, and Matt was flagged as an absconder with an active warrant for his arrest. During the stop, Gadaire admitted to recent methamphetamine use, which led to a search of the vehicle. Officers discovered multiple bags of methamphetamine and drug paraphernalia in the center console. Matt was charged with criminal possession of a dangerous drug with intent to distribute by accountability, and criminal possession of drug paraphernalia.The case proceeded to trial in the Montana First Judicial District Court, Broadwater County. The State’s evidence included testimony from the reporting driver, law enforcement officers, body cam footage, surveillance video, and phone records. Gadaire, who had given multiple inconsistent statements during the investigation, testified that Matt was present during the drug pick-up but later recanted aspects of his testimony. At the close of the State’s case, Matt moved for a directed verdict, arguing that the State’s evidence was insufficient because it relied on uncorroborated accomplice testimony. The District Court denied the motion, and the jury found Matt guilty of criminal possession of a dangerous drug, but not guilty of possession of drug paraphernalia.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court erred in denying Matt’s motion for a directed verdict due to insufficient corroborating evidence. The Supreme Court held that the State failed to provide independent evidence connecting Matt to the crime, apart from Gadaire’s testimony. Mere presence in the vehicle did not meet the statutory requirement for corroboration. The Supreme Court reversed Matt’s conviction, remanded the case, and ordered the District Court to vacate the judgment and dismiss the charges. View "State v. Matt" on Justia Law

Craig Medoff, after a history of violating federal securities laws and failing to comply with prior court orders and penalties, was subject to a 2016 consent judgment in the District of Massachusetts that barred him and any entity he controlled from participating in the issuance, offer, or sale of any security for ten years. Despite this, Medoff continued to control Nova Capital International LLC and engaged in securities-related activities, using an alias and receiving substantial fees in violation of the judgment. The SEC initiated civil contempt proceedings, but the district court, concerned about the futility of further civil sanctions given Medoff’s history and financial situation, instead initiated criminal contempt proceedings under 18 U.S.C. § 401(3) and Federal Rule of Criminal Procedure 42(a).The United States District Court for the District of Massachusetts appointed the U.S. Attorney to prosecute the criminal contempt case. Medoff’s counsel moved for the judge’s recusal under 28 U.S.C. § 455(a), arguing that the judge’s impartiality might reasonably be questioned due to his comments and conduct during the proceedings. The district court denied the recusal motion, finding no reasonable basis for doubting its impartiality, and proceeded with the criminal case. Medoff ultimately pleaded guilty to criminal contempt and was sentenced to twenty months in prison, a variance above the guideline range, and thirty-six months of supervised release, along with a fine.On appeal to the United States Court of Appeals for the First Circuit, Medoff challenged the denial of the recusal motion and the reasonableness of his sentence. The First Circuit held that the district court did not abuse its discretion in denying recusal, as the judge’s actions did not display deep-seated antagonism or favoritism. The court also found the sentence both procedurally and substantively reasonable, affirming the district court’s judgment. View "United States v. Medoff" on Justia Law

In this case, the defendant applied for U.S. citizenship in 2011 and, on his application and during an interview, denied ever having committed a crime for which he was not arrested. However, in 2013, he pleaded guilty in North Carolina state court to attempted statutory rape for conduct that occurred in 2008, admitting to engaging in a sexual act with a minor. He did not disclose this conduct on his naturalization application. Years later, a federal grand jury indicted him for naturalization fraud, alleging he knowingly concealed his criminal history to obtain citizenship.The United States District Court for the Western District of North Carolina denied the defendant’s motion to dismiss the indictment for unconstitutional preindictment delay, finding he had not shown actual prejudice from the delay. The court also denied his motion to suppress evidence of his state guilty plea, ruling that he could not collaterally attack the validity of his state conviction in federal court except for a deprivation of counsel, which did not apply here. At trial, the court limited the testimony of the defendant’s expert witness regarding his cognitive abilities, excluding certain opinions about his capacity to understand the application question. The jury convicted the defendant, finding he knowingly made a false statement, and the court sentenced him to six months in prison and revoked his citizenship.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that the defendant failed to demonstrate substantial actual prejudice from the preindictment delay, that the district court properly refused to suppress the state guilty plea, and that while the limitation of the expert’s testimony was error under recent Supreme Court guidance, the error was harmless given the other evidence presented. The conviction and sentence were therefore affirmed. View "US v. Palmer" on Justia Law

Three individuals, all Cameroonian Americans, participated in a secretive group dedicated to sending firearms and ammunition from Maryland to Anglophone fighters in Cameroon. The group, known as the “Peanut Project,” operated out of a basement in Baltimore County, where they assembled, modified, and packaged weapons and ammunition for overseas shipment. Their concealment methods included obliterating serial numbers from firearms and hiding the items within compressor tanks and other cargo. In 2019, law enforcement intercepted a shipping container en route to Nigeria containing over 35,000 rounds of ammunition and 39 firearms, many with defaced serial numbers. A subsequent search of the group’s base revealed a full-scale operation for manufacturing and preparing firearms for export.A federal grand jury in the United States District Court for the District of Maryland indicted the defendants on five counts, including conspiracy, illegal exportation, transportation of firearms with obliterated serial numbers, and smuggling. After a ten-day jury trial, the defendants were convicted of conspiracy, transporting firearms with obliterated serial numbers, and smuggling, but acquitted on the exportation counts. The district court denied post-trial motions challenging the sufficiency of the evidence and various trial rulings. At sentencing, the court applied enhancements for the number of firearms involved and for trafficking, sentencing each defendant to 63 months’ imprisonment and two years of supervised release.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the convictions and sentences. The court held that the evidence was sufficient to support the jury’s findings, the district court did not abuse its discretion in evidentiary or instructional rulings, and the sentencing enhancements were properly applied. The court also found no error in the oral and written pronouncement of supervised release conditions. The judgments of the district court were affirmed. View "US v. Nji" on Justia Law

Several individuals associated with the Reccless Tigers, a Northern Virginia-based drug gang, were charged with a range of offenses, including drug trafficking, racketeering, kidnapping, and murder. The gang was involved in distributing marijuana and cocaine, and members targeted those who failed to pay drug debts or cooperated with law enforcement. The case centered on the murder of Brandon White, who owed a drug debt and had testified against a gang member. Evidence showed that gang members, including the defendants, orchestrated White’s abduction and murder, with some directly participating in the killing.The United States District Court for the Eastern District of Virginia presided over a joint trial. The court denied several pretrial motions, including requests for continuances, motions to substitute counsel, and a motion to dismiss based on alleged violations of the Speedy Trial Act and the Sixth Amendment. The jury convicted three defendants—Lamborn, Yoo, and Peter—of racketeering conspiracy, murder in aid of racketeering, kidnapping conspiracy, kidnapping resulting in death, drug conspiracy, and killing while engaged in drug trafficking, with Lamborn also convicted of using a firearm resulting in death. Tony was convicted of racketeering and drug conspiracy but acquitted of destructive device charges. The court sentenced Lamborn, Yoo, and Peter to life imprisonment and Tony to 312 months.The United States Court of Appeals for the Fourth Circuit reviewed the case. It affirmed the convictions and most sentences, finding no abuse of discretion in the denial of continuances or substitution of counsel, and sufficient evidence supported the convictions. The court also upheld the district court’s application of sentencing enhancements and rejected the Speedy Trial Act and Sixth Amendment claims. However, it vacated the sentences of Lamborn, Yoo, and Peter due to inconsistencies between the oral pronouncement and written judgments regarding supervised release conditions, remanding for resentencing on that issue. View "US v. Lamborn" on Justia Law

A commercial truck driver was stopped by police in Rankin County, Mississippi, for speeding and following too closely. During the stop, the officer noticed the driver was using paper logs instead of the electronic logs typically required for commercial vehicles, and observed inconsistencies in the logs. The driver, after initial denials, admitted to having over $100,000 in the vehicle, later specifying it was $225,000, which he claimed was for truck repairs or his life savings. The officer obtained consent to search the vehicle and found the cash packaged in multiple envelopes. Further investigation linked phone numbers provided by the driver to ongoing federal drug-trafficking investigations, and a trained narcotics dog showed interest in the cash. The State initiated civil forfeiture proceedings, alleging the money was connected to illegal drug activity.The Circuit Court of Rankin County held a bench trial, heard testimony from law enforcement and an expert in drug trafficking, and issued an order of forfeiture, finding by a preponderance of the evidence that the cash was connected to drug trafficking. The driver appealed, and the Mississippi Court of Appeals, in a split decision, reversed the trial court, concluding the State had not met its burden of proof under the relevant forfeiture statute.The Supreme Court of Mississippi reviewed the case on certiorari. Applying the substantial evidence/clearly erroneous standard, the court found that the trial court’s findings were supported by sufficient circumstantial evidence, including the manner of cash packaging, travel patterns, phone records, and the narcotics dog’s alert. The Supreme Court of Mississippi reversed the judgment of the Court of Appeals and reinstated and affirmed the judgment of the Circuit Court, holding that the State had met its burden to show the currency was more likely than not connected to illegal drug activity and thus subject to forfeiture. View "Chung v. State of Mississippi" on Justia Law

Carlos Jones, Jr. was convicted of attempted aggravated assault after an incident in which he became angry when a neighbor’s visitor honked a car horn, waking him from sleep. Jones confronted his neighbor, Niesha Russell, and after a verbal argument, retrieved a gun from a car, pointed it at Russell, and fired two shots as she fled toward her house. Russell testified that she saw Jones point the gun at her and heard the shots as she ran, though she was not injured. Jones left the scene immediately after the shooting. He later told police that he had fired into the air rather than at Russell.The case was tried in the Circuit Court of Coahoma County, where the State charged Jones with attempted aggravated assault. At trial, the jury heard testimony from Russell and law enforcement. Jones moved for a directed verdict, arguing that the evidence did not show he intended to harm Russell, but the motion was denied. The jury found Jones guilty, and he was sentenced to five years’ imprisonment, with three years to serve and two years of supervised probation. After his motion for a new trial was denied, Jones appealed.The Supreme Court of Mississippi reviewed the conviction. The court held that, when viewing the evidence in the light most favorable to the State, a rational juror could have found beyond a reasonable doubt that Jones intended to shoot Russell, based on the circumstantial evidence that he pointed the gun at her and fired. The court also found that the verdict was not against the overwhelming weight of the evidence, as the jury was entitled to resolve conflicting testimony regarding Jones’s intent. The Supreme Court of Mississippi affirmed the conviction and sentence. View "Jones v. State of Mississippi" on Justia Law

Late one night, a man called police twice, claiming he was being chased, and was found by officers pounding on a homeowner’s door in Beaumont, Mississippi. The man appeared erratic and admitted to drinking. He gave police permission to search his vehicle, which he referred to as “his” car. Inside, officers found a sunglasses case on the dashboard containing a glass pipe and a bag of methamphetamine. While being transported to jail, the man remarked that he “should have gotten rid of that shit before [he] called” the police. Subsequent testing confirmed the substance was methamphetamine, and he was indicted for possession of more than one-tenth gram but less than two grams of a Schedule II controlled substance.The case was tried in the Perry County Circuit Court, where a jury found the defendant guilty of possession of methamphetamine. The court sentenced him to three years in the custody of the Mississippi Department of Corrections. The defendant appealed, arguing that the evidence was insufficient to prove he constructively possessed the methamphetamine and that the verdict was against the weight of the evidence.The Supreme Court of Mississippi reviewed the case. Applying the standard of viewing evidence in the light most favorable to the State, the court held that a rational juror could find the defendant exercised dominion and control over the vehicle and knew about the methamphetamine, especially given his statements and behavior. The court distinguished this case from Ferrell v. State, 649 So. 2d 831 (Miss. 1995), finding additional incriminating circumstances beyond mere proximity. The court concluded that the evidence was sufficient and the verdict was not against the overwhelming weight of the evidence. The conviction and sentence were affirmed. View "Moody v. State of Mississippi" on Justia Law

An employee at a dental clinic within a correctional facility alleged that she was sexually assaulted by an inmate while working in her office. The incident occurred when the inmate entered her office, closed the door, and, according to her testimony, physically restrained and sexually assaulted her. The victim immediately reported the incident to her supervisor and underwent a forensic examination, which revealed DNA evidence consistent with the inmate being the primary contributor. The inmate claimed the encounter was consensual and that he and the victim had a prior relationship, but no evidence supported this assertion.The Circuit Court of Rankin County presided over the trial, during which the jury found the inmate guilty of sexual battery. The court sentenced him to thirty years’ imprisonment as a habitual offender. The defendant filed post-trial motions for a new trial or judgment notwithstanding the verdict, arguing insufficient evidence and that the verdict was against the overwhelming weight of the evidence. The trial court denied these motions, leading to the present appeal.The Supreme Court of Mississippi reviewed the case, applying a de novo standard to the sufficiency of the evidence and an abuse-of-discretion standard to the weight of the evidence. The court held that the evidence, including the victim’s testimony and supporting forensic findings, was sufficient for a rational jury to find guilt beyond a reasonable doubt. The court also found that the verdict was not so contrary to the weight of the evidence as to constitute an injustice. Accordingly, the Supreme Court of Mississippi affirmed the conviction, sentence, and denial of post-trial motions. View "Mayfield v. State of Mississippi" on Justia Law

In 2003, the defendant was convicted by a jury of armed bank robbery in federal court. At sentencing, the government sought a mandatory life sentence under the federal “three strikes” law, 18 U.S.C. § 3559(c), which requires a life sentence for certain repeat offenders convicted of “serious violent felonies.” The government identified five prior convictions it argued qualified as “serious violent felonies.” The district court imposed a life sentence, finding the defendant had three qualifying strikes, but did not specify which prior convictions or which statutory definitions it relied upon.The United States Court of Appeals for the Tenth Circuit previously affirmed the conviction and sentence on direct appeal. The defendant’s first motion for collateral relief under 28 U.S.C. § 2255 was denied by the United States District Court for the District of Utah, and that denial was affirmed on appeal. In 2020, the Tenth Circuit authorized the defendant to file a second or successive § 2255 motion, based on recent Supreme Court decisions finding similar statutory “residual clauses” unconstitutionally vague. The defendant argued that his life sentence was imposed under the residual clause of § 3559(c), which he claimed was unconstitutional.Reviewing the district court’s denial of relief de novo, the United States Court of Appeals for the Tenth Circuit held that the defendant failed to prove by a preponderance of the evidence that the sentencing court relied on the residual clause to enhance his sentence. The court found that, at the time of sentencing, the legal environment permitted the use of a circumstance-specific approach, allowing the defendant’s California robbery conviction to qualify as a strike under the enumerated clause. As a result, the defendant did not meet the burden required for relief under § 2255. The Tenth Circuit affirmed the district court’s denial of the motion. View "United States v. Cooper" on Justia Law