Justia Criminal Law Opinion Summaries

Humana, a health insurance company and Medicare Part C and Part D sponsor, filed a lawsuit against Biogen, a drug manufacturer, and Advanced Care Scripts, Inc. (ACS), a specialty pharmacy, in the District of Massachusetts. Humana alleged that Biogen and ACS engaged in fraudulent schemes involving three multiple sclerosis drugs, violating the civil RICO statute. Humana claimed that Biogen "seeded" the market with these drugs, funneled patients into Medicare, and indirectly funded patient copays through third-party patient-assistance programs (PAPs). Humana also alleged that ACS aided Biogen's scheme by steering patients and acting as an intermediary between Biogen and the PAPs, causing the submission of false certifications to Humana.The district court dismissed the case, ruling that Humana lacked standing to bring RICO claims because it was an indirect purchaser and failed to plead the RICO claims with particularity as required by Federal Rule of Civil Procedure 9(b). The court found that Humana did not specify the time, place, and content of the alleged fraudulent communications and failed to detail the false certifications' language, timing, and context. Humana's motion for leave to amend the complaint was also denied.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's dismissal, agreeing that Humana failed to meet the heightened pleading standard of Rule 9(b) for its RICO claim. The court held that Humana did not provide specific details about the fraudulent certifications or the use of mail or wire communications in furtherance of the scheme. The court also upheld the denial of leave to amend, citing undue delay and the inefficiency of seeking amendment after dismissal. View "Humana Inc. v. Biogen, Inc." on Justia Law

In 2012, three people were shot and killed outside a nightclub in Houston, Texas. Feanyichi E. Uvukansi was identified by an eyewitness, Jeresano, who picked him out of a photo array. Uvukansi was convicted of capital murder and sentenced to life without parole. At trial, Jeresano testified that he had no agreement with prosecutors regarding his testimony, but it was later revealed that he did have an agreement that could reduce his federal drug sentence in exchange for his testimony.Uvukansi did not raise the issue of false testimony on direct appeal but did so in state habeas proceedings. The state district court found that Jeresano's testimony was false but deemed it immaterial because the jury was aware of parts of the agreement through other testimony. The Texas Court of Criminal Appeals denied Uvukansi’s application without a written order. Uvukansi then filed a Section 2254 application in federal district court, which was dismissed on the grounds that the state court's decision was not contrary to, or an unreasonable application of, clearly established Supreme Court precedent.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the state district court applied the correct "reasonable likelihood" standard for materiality and did not impose a higher burden of proof on Uvukansi. The court also found that the state district court did not err in considering the false testimony's impact on Jeresano's credibility rather than the identification itself. The Fifth Circuit concluded that the state court's decision was not contrary to, or an unreasonable application of, clearly established Supreme Court precedent and affirmed the dismissal of Uvukansi's Section 2254 application. View "Uvukansi v. Guerrero" on Justia Law

Aqudre Quailes and Ayinda Harper were separately charged with being felons in possession of a firearm in violation of 18 U.S.C. § 922(g)(1). Harper was on Pennsylvania state probation and parole when his probation officer discovered photographs of him holding firearms on social media. During a home visit, officers found a semiautomatic pistol in his residence. Harper had thirteen prior felony convictions. Quailes, on parole for one of his six prior felony convictions, was arrested for absconding from parole. Authorities found firearms and ammunition in his girlfriend’s apartment, where he had been staying.The United States District Court for the Middle District of Pennsylvania dismissed both indictments, ruling that § 922(g)(1) was unconstitutional under the Second Amendment. The court reasoned that the defendants' status as parolees or probationers did not negate their Second Amendment rights. The Government appealed, arguing that § 922(g)(1) is constitutional as applied to state parolees and probationers.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that § 922(g)(1) is constitutional as applied to Quailes and Harper because neither had completed their criminal sentences. The court referenced its en banc decision in Range v. Attorney General, which held that § 922(g)(1) was unconstitutional for a felon who had completed his sentence, and United States v. Moore, which upheld the constitutionality of § 922(g)(1) for felons still serving their sentences. The court concluded that historical practices support disarming convicts who are still serving their sentences, including those on state parole or probation. Consequently, the Third Circuit reversed the District Court’s orders and remanded the cases for further proceedings. View "USA v. Quailes" on Justia Law

Law enforcement identified the defendant as a supplier of methamphetamine and fentanyl in a drug-trafficking conspiracy in Kansas City. After seizing three pounds of methamphetamine from a car en route to the defendant, DEA agents enlisted the driver to continue the delivery to the defendant. The defendant was arrested upon arrival to collect the drugs. During custody, the defendant made incriminating statements and consented to a search of his cell phone. He later moved to suppress these statements and the phone's contents.The United States District Court for the District of Kansas denied the suppression motions. The court ruled that the defendant's pre-Miranda statement about his cell phone number was admissible under the inevitable-discovery doctrine. It also found that the defendant voluntarily and knowingly waived his Miranda rights and that his post-Miranda statements were not coerced. The court concluded that the defendant's consent to the cell phone search was voluntary.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's decision, agreeing that the inevitable-discovery doctrine applied to the pre-Miranda statement. It found that the defendant voluntarily and knowingly waived his Miranda rights, and his statements were not coerced. The court also held that the defendant's consent to the cell phone search was voluntary. The Tenth Circuit concluded that the totality of the circumstances supported the district court's findings and affirmed the denial of suppression. View "United States v. Perez" on Justia Law

Jeffrey Brown, Markus Maly, and Peter Schwartz were tried and convicted by a jury for assaulting police officers on the Capitol grounds on January 6, 2021. They traveled separately to Washington, D.C., and participated in the riot following then-President Trump’s rally. Evidence showed that Maly and Schwartz assaulted officers on the Lower West Terrace, with Schwartz throwing a chair and both using pepper spray. All three later entered the Tunnel, where they used pepper spray against officers and attempted to push through the police line.The United States District Court for the District of Columbia denied Schwartz’s motions to suppress evidence obtained from his cellphone and to sever the trials. The court found that the FBI had compelled Schwartz to unlock his phone but ruled that this act was not testimonial. The jury convicted all three defendants on all counts, and the district court sentenced Schwartz to 170 months, Maly to 72 months, and Brown to 54 months.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court affirmed Brown’s and Maly’s convictions and Brown’s sentence. It vacated Schwartz’s conviction on the 18 U.S.C. § 1512(c)(2) charge and remanded for resentencing. The court also held that compelling Schwartz to unlock his cellphone violated the Fifth Amendment and remanded to the district court to determine which, if any, of Schwartz’s counts of conviction must be vacated due to this error. The court found sufficient evidence to support the jury’s findings that the defendants used pepper spray and, in Schwartz’s case, a chair as deadly or dangerous weapons. The court also upheld the district court’s refusal to give a special unanimity instruction for Maly’s Section 111 counts and found no abuse of discretion in Brown’s sentencing. View "USA v. Brown" on Justia Law

Isaiah Duffield was required to register as a sex offender due to a juvenile adjudication for sexual abuse. In April 2022, he was charged with sexual abuse in the third degree, second or subsequent offense, and failure to comply with the sex offender registry. After the charges were severed and amended, Duffield entered a guilty plea to the lesser offense of failure to register, an aggravated misdemeanor. The district court sentenced him to a term of incarceration not to exceed two years and a fine of $1,025, which was suspended. The court ordered the sentence to be served consecutively to a sentence in a separate sexual abuse case.Duffield appealed to the Iowa Court of Appeals, arguing that the district court abused its discretion in imposing the $1,025 fine and failed to state its reasons for imposing consecutive sentences. The court of appeals upheld the fine, reasoning it was within the statutory range and Duffield did not establish any irregularity. However, the court agreed that the district court erred in failing to state reasons for consecutive sentences and remanded the case to a different judge to decide whether the sentences should be served concurrently or consecutively.The Iowa Supreme Court reviewed the case and focused on the consecutive sentencing issue. The court held that the district court erred in failing to state its reasons for imposing consecutive sentences. The court vacated Duffield’s sentence and remanded the case for a plenary resentencing hearing, emphasizing that the resentencing should not be limited to the consecutive sentencing issue alone. The court also concluded that resentencing before a different judge was not required, as there was no taint in the sentencing process. The decision of the court of appeals was vacated, the conviction was affirmed, the sentence was vacated, and the case was remanded for resentencing. View "State of Iowa v. Duffield" on Justia Law

Lukouxs Brown was charged with first-degree murder after allegedly killing a coworker. Before his arraignment, his counsel observed signs of mental illness, including hearing voices and a history of schizophrenia. The district court found probable cause to believe Brown was not competent to stand trial and ordered a psychiatric evaluation. Dr. Arnold Andersen diagnosed Brown with a schizophrenia-like disorder and substance abuse disorders, concluding he was not competent but could potentially be restored to competency. Brown was committed to the Iowa Medical and Classification Center (IMCC) for treatment.After eight months of treatment, Dr. Andersen reported that Brown remained incompetent and unlikely to be restored to competency within a reasonable time. The district court, however, allowed the State to obtain a separate psychiatric evaluation, which concluded that Brown was competent. The district court found Brown competent to stand trial and reinstated the criminal proceedings. Brown filed an interlocutory appeal, arguing the district court erred in its competency determination and in allowing the State to obtain a separate evaluation.The Iowa Court of Appeals reviewed the case de novo, found Brown was not competent, and remanded the case for further treatment. The State sought further review, challenging the standard of review and the district court's decision to allow a separate evaluation. The Iowa Supreme Court reaffirmed the de novo standard of review for competency determinations, emphasizing the protection of constitutional rights. The court also held that Iowa Code does not permit separate psychiatric evaluations at the dispositional phase of competency proceedings. The court vacated the Court of Appeals decision, reversed the district court order, and remanded the case for further proceedings consistent with its opinion. View "State of Iowa v. Brown" on Justia Law

Karsen H. Rezac was involved in a vehicular collision on December 23, 2022, in Lincoln, Nebraska, which resulted in the shooting death of Kupo Mleya. Rezac, who was identified as a suspect based on vehicle debris and witness reports, admitted to firing shots at Mleya's vehicle after the collision. Rezac was charged with second-degree murder and use of a firearm to commit a felony. He later pled no contest to second-degree murder as part of a plea agreement, and the firearm charge was dropped.The district court for Lancaster County, Nebraska, denied Rezac's motion to continue his sentencing hearing, which he requested to allow more time to gather and review his mental health records. The court proceeded with the sentencing, considering the presentence investigation report and supplemental items. Rezac was sentenced to 60 years to life imprisonment. Rezac appealed, arguing that the court abused its discretion in denying the continuance and imposing an excessive sentence, and that his trial counsel was ineffective in several respects.The Nebraska Supreme Court reviewed the case and found that Rezac forfeited his argument regarding the denial of the continuance by failing to raise the issue at the sentencing hearing. The court also found no abuse of discretion in the sentencing, as the district court had considered the relevant mitigating factors. The court rejected Rezac's claims of ineffective assistance of counsel related to the failure to move to suppress his statement to law enforcement and the failure to explain the penalties for second-degree murder, finding that the record refuted these claims.However, the court found the record insufficient to address Rezac's claims that his trial counsel was ineffective for advising him that self-defense was not a viable argument, failing to explain the difference between second-degree murder and involuntary manslaughter, and failing to provide his mental health records to probation or the court. The court affirmed Rezac's conviction and sentence but noted that these claims of ineffective assistance of counsel could not be resolved on direct appeal due to the insufficient record. View "State v. Rezac" on Justia Law

Shawn Lamar Peake-Wright, Jr. was a passenger in a car driven by Kimberly Manney in Kalamazoo, Michigan, when they were stopped by Sgt. Timothy Millard. Sgt. Millard recognized Peake-Wright and knew of his criminal history. During the stop, Peake-Wright exhibited strange behavior, including removing his jacket in freezing weather and repeatedly standing up despite officers' instructions to remain seated. Sgt. Millard, suspecting that Peake-Wright's jacket might contain contraband, searched it and found a loaded 9mm pistol.The United States District Court for the Western District of Michigan denied Peake-Wright's motion to suppress the evidence of the firearm, holding that the search was justified under the automobile exception to the warrant requirement. The court found that Peake-Wright's behavior and criminal history provided probable cause to believe that his jacket contained evidence of a crime.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the duration of the traffic stop was reasonable and that the officers had probable cause to search Peake-Wright's jacket. The court emphasized that the totality of the circumstances, including Peake-Wright's erratic behavior and criminal history, justified the search under the automobile exception. The court concluded that the search was lawful and upheld the district court's judgment. View "United States v. Peake-Wright" on Justia Law

Michael Mills was convicted of being a felon in possession of ammunition after a shootout involving members of the Detroit gang, It’s Just Us (IJU). Mills, armed with a loaded pistol-grip shotgun, fired two shots during the altercation, resulting in the death of IJU member James Matthews Jr. Mills was subsequently arrested and charged. A jury found him guilty, and the district court sentenced him to the statutory maximum of 120 months, applying a sentencing enhancement based on Mills's role in Matthews's death.The United States District Court for the Eastern District of Michigan initially sentenced Mills, but the case was remanded by the United States Court of Appeals for the Sixth Circuit for additional factual findings regarding the sentencing enhancement. On remand, the district court reaffirmed its findings, concluding that Mills caused Matthews's death, had the necessary mental state for second-degree murder, and rejected Mills's justification defense. The district court reimposed the same 120-month sentence.The United States Court of Appeals for the Sixth Circuit reviewed the case again. The court held that the district court did not clearly err in finding that Mills committed second-degree murder with malice aforethought, based on his actions and social media messages indicating a premeditated intent. The court also found no clear error in the district court's rejection of Mills's justification defense, noting that Mills had viable alternatives to engaging in the shootout. Additionally, the appellate court determined that the district court properly considered the sentencing factors, including the need for deterrence and Mills's criminal history.The Sixth Circuit affirmed the district court's judgment, upholding Mills's 120-month sentence. View "United States v. Mills" on Justia Law