Justia Criminal Law Opinion Summaries

Several plaintiffs, including the founder of a religious group called Singularism, used psilocybin as part of their religious ceremonies in Utah, where the drug is classified as a controlled substance. Authorities seized a large quantity of psilocybin from them and notified Singularism’s landlord that the drug use constituted a nuisance. Shortly after, the plaintiffs initiated a state lawsuit, which was removed to the United States District Court for the District of Utah. The federal court issued a temporary restraining order requiring the return of seized items and, after state authorities filed criminal charges, enjoined state prosecution against the religious leader to prevent a potential First Amendment violation.On appeal, the state authorities argued that the federal district court should have abstained from interfering with ongoing state criminal proceedings under the Younger abstention doctrine, and that prosecution did not violate the First Amendment. The United States Court of Appeals for the Tenth Circuit reviewed the district court’s refusal to abstain de novo and found the requirements for abstention were satisfied. The court concluded that the state authorities had not waived the abstention argument through their litigation conduct. The plaintiffs failed to show that the prosecution was brought in bad faith, was harassing, or created a threat of irreparable injury, as required for exceptions to abstention.On the merits, the Tenth Circuit held the district court erred in finding a likely First Amendment violation. The court found Utah law’s regulatory scheme for secular, supervised medical use of psilocybin was not comparable to the unsupervised religious use, and thus did not treat secular activity more favorably than religious activity. The court vacated the injunction and the denial of the motion to dismiss as to preferential treatment for secular use, remanding the issue of individualized exemptions for further district court proceedings, and dismissed the appeal regarding the Fourth Amendment claim for lack of jurisdiction. View "Jensen v. Utah County" on Justia Law

A man convicted of murder in Texas and sentenced to death sought to halt his execution, scheduled for October 7, 2026. He argued that newly developed clinical standards for diagnosing intellectual disability, which became available after his first federal habeas petition, would now classify him as intellectually disabled and therefore constitutionally ineligible for execution. He maintained that these new clinical guidelines constituted either a new rule of constitutional law or a new factual predicate, justifying a second federal habeas petition under 28 U.S.C. § 2254. As an alternative, he requested a stay of execution pending a potential relevant decision by the United States Supreme Court.After his 2001 conviction, the Texas Court of Criminal Appeals rejected his Eighth Amendment claim that his mental illness barred execution. His first state and federal habeas petitions were denied, with the federal courts determining in 2017 that he was not intellectually disabled. He later abandoned his initial Atkins v. Virginia claim after the Supreme Court faulted Texas’s standards for such claims in Moore v. Texas. In 2019, the United States District Court for the Eastern District of Texas denied his remaining federal habeas claims, and the United States Court of Appeals for the Fifth Circuit denied a Certificate of Appealability in 2020.Reviewing the case, the United States Court of Appeals for the Fifth Circuit held that the petitioner’s second federal habeas application was barred by the one-year statute of limitations and that he was not entitled to equitable tolling. The court further found that his renewed claim of intellectual disability had already been presented in his prior habeas petition, barring reconsideration under § 2244(b)(1). The court also denied his request for a stay of execution, finding no likelihood of success on the merits and no justification for equitable relief. Both motions were denied. View "In re Howard" on Justia Law

Federal officials learned in December 2015 about a scheme to launder $5 million from South Korea to the United States for the purpose of bribing General Motors executives. The aim was for Woo Kyung M.I.T., a South Korean automotive supplier, to secure a lucrative GM contract. After a first payment, further funds were transferred through hawala brokers. Following an airport search, the bribe was delivered to Hyoung Nam “Brian” So. Shortly after, Woo Kyung M.I.T. was awarded the GM contract, but later withdrew due to profitability concerns and the ongoing investigation. Most of the bribe money was eventually returned, and South Korean officials arrested Lee, who pleaded guilty and cooperated with U.S. authorities.A formal request for evidence under the Mutual Legal Assistance Treaty (MLAT) was made to South Korea in July 2017, seeking documents and certifications relevant to the investigation. Several responses followed, with South Korean officials continuing efforts to provide requested certifications until October 2021. In September 2020, the government sought to toll the statute of limitations under 18 U.S.C. § 3292, citing ongoing requests for evidence. The U.S. District Court for the Central District of California issued a tolling order, suspending the statute of limitations for offenses described in the government’s application. On March 23, 2022, So was indicted for conspiracy to commit federal funds bribery. So moved to dismiss the indictment as untimely, but the district court found the offense covered by the tolling order and denied the motion. The court also refused to instruct the jury on the statute-of-limitations issue, ruling it was a question for the judge.On appeal, the United States Court of Appeals for the Ninth Circuit held that the tolling order applied to conspiracy to commit federal funds bribery, even though the offense was not specifically cited by statute. The panel concluded the indictment was timely, as final action by South Korean authorities occurred after the natural limitations period. The court also held that the district court properly resolved the statute-of-limitations issue without submitting it to the jury. The conviction and district court decisions were affirmed. View "USA V. SO" on Justia Law

A hunter discovered human remains in Park County, Wyoming, later identified as Angela Elizondo. Joseph Underwood, a person of interest, was apprehended after attempting to flee law enforcement and holding a handgun during a standoff. Underwood was initially charged in both Park and Laramie Counties for offenses related to the death, including concealing a felony, firearm possession, interference with an officer, fleeing police, and more serious charges in Laramie County. Extensive evaluations determined Underwood had a mild neurocognitive disorder, impairing his ability to participate in legal proceedings but potentially manageable with accommodations.After the Laramie County District Court dismissed charges due to permanent incompetency, Park County refiled charges. The Park County Circuit Court conducted further competency evaluations, some finding Underwood competent if reasonable accommodations were provided, such as slowing proceedings and using plain language. Underwood requested specific accommodations under the Americans with Disabilities Act (ADA), including an informed assistant, but this was denied by the Wyoming Judicial Branch as not mandated by the ADA. The circuit court bound the case over to the Park County District Court, which adopted the circuit court’s competency findings and proceeded with arraignment and plea hearings. During these proceedings, accommodations such as breaks, plain language, and opportunities to confer with counsel were implemented.On appeal to the Supreme Court of Wyoming, Underwood argued his Alford pleas were involuntary due to the district court’s failure to provide an informed assistant or specific accommodations for his intellectual disability. Applying plain error review, the Supreme Court of Wyoming found no clear mandate requiring an informed assistant and concluded the district court implemented approved ADA accommodations and provided ample opportunities for Underwood to understand and consult with counsel. The Court held that, under the totality of circumstances, Underwood’s pleas were knowing and voluntary and affirmed the district court’s acceptance of the pleas and imposition of sentence. View "Underwood v. The State of Wyoming" on Justia Law

David Koan pled guilty in federal court to two counts of producing child pornography, offenses that arose from the same conduct underlying his prior Texas state conviction for aggravated sexual assault of a child. For the state offenses, Koan had already been sentenced to 35 years in prison and had served nearly 40 months in custody by the time of his federal sentencing. The federal presentence report recognized that the state and federal offenses were related and recommended that Koan's federal sentence be adjusted under U.S.S.G. § 5G1.3(b) to account for the time already served on his undischarged state term.In the United States District Court for the Northern District of Texas, Koan was sentenced to 60 years in prison—30 years on each count, to run consecutively—but the court ordered the federal sentence to run concurrently with the remaining state sentence. When defense counsel requested that Koan be given credit for the time already served in state custody, the district court stated it lacked authority to do so and deferred the issue to the Bureau of Prisons. The district court did not address the relevant Guideline provision or make clear reference to the statutory sentencing factors.The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that Koan had properly preserved his challenge concerning the application of U.S.S.G. § 5G1.3(b). The court held that the district court erred by failing to consider its authority under § 5G1.3(b) to adjust Koan’s sentence to account for time served on the related state conviction, mistakenly believing that only the Bureau of Prisons could award such credit. The Fifth Circuit vacated the sentence and remanded the case for resentencing so that the district court could properly consider and apply § 5G1.3(b). View "USA v. Koan" on Justia Law

In 2006, the defendant acted as a lookout during an attempted robbery committed by his associate, who shot and killed an off-duty Los Angeles County Sheriff’s deputy. The defendant was charged with first degree murder and attempted robbery. At trial in the Superior Court of Los Angeles County, the jury was instructed on the felony-murder rule and convicted him on both counts. The court sentenced him to 29 years to life, later reduced to 26 years to life after the sentence for attempted robbery was stayed.Years later, following legislative changes to the felony-murder rule under Senate Bill No. 1437, the defendant petitioned for resentencing under Penal Code section 1172.6, which allows relief for certain felony-murder convictions. However, the statute excludes defendants if the victim was a peace officer killed in the course of duty and the defendant knew or should have known the victim’s status. After a series of appeals, the California Court of Appeal, Second Appellate District, directed the trial court to hold evidentiary hearings to determine whether the slain deputy was acting as a peace officer within the meaning of the statute at the time of her death.After further hearings, the trial court found that the deputy was not a “modified” custodial deputy with limited authority but rather a fully trained deputy sheriff under section 830.1, subdivision (a), who retained peace officer authority, including while off duty. The California Court of Appeal, Second Appellate District, Division One, affirmed this finding, holding that section 830.1, subdivision (c) applies only to deputies hired, trained, and utilized exclusively or initially as modified custodial deputies, not to regular deputies assigned to custodial duties. Substantial evidence supported that the victim was a regular deputy with full peace officer authority. Therefore, the defendant was ineligible for resentencing relief under section 1172.6, and the trial court’s order denying the petition was affirmed. View "People v. Flint" on Justia Law

A group of medical students attended the University of Science, Arts and Technology (USAT), an international medical school based in Montserrat. USAT was licensed in Montserrat and, for years, was listed in the International Medical Education Directory, allowing its graduates to seek U.S. medical licensure. After a volcanic eruption in 2007, USAT began offering classes online and at alternative sites in the United States and Puerto Rico. In 2018, the Educational Commission for Foreign Medical Graduates (ECFMG) changed its policy, restricting certification to students educated in the country where the school was authorized. USAT students who took courses outside Montserrat after 2018 were no longer eligible for ECFMG certification, affecting their ability to obtain U.S. medical licenses. The students alleged that USAT misrepresented its accreditation and educational legitimacy, leading them to pay substantial tuition under false pretenses.The students filed suit in the United States District Court for the District of Puerto Rico, asserting federal RICO claims, as well as Puerto Rico law claims for fraudulent inducement, breach of contract, and unjust enrichment. The district court granted summary judgment in favor of the defendants, holding that the students failed to establish a “pattern of racketeering activity” as required under RICO, and dismissed the federal claims with prejudice. The court declined to exercise jurisdiction over the Puerto Rico law claims.On appeal, the United States Court of Appeals for the First Circuit reviewed the grant of summary judgment de novo. The court held that the students did not present sufficient evidence of closed- or open-ended continuity to establish a pattern of racketeering activity under RICO. As a result, the First Circuit affirmed the district court’s dismissal of the RICO claim and its decision not to exercise supplemental jurisdiction over the remaining claims. View "Pena-Torres v. University of Science, Arts and Tech" on Justia Law

The case involves William Castillo, who was convicted and sentenced to death for the murder of Isabelle Berndt in Las Vegas, Nevada. Castillo used a key he found while working as a roofer at Berndt’s home to later enter her residence with an accomplice, steal items, and fatally attack Berndt with a tire iron. Subsequently, he returned to the home to set it on fire. Evidence recovered from Castillo’s apartment linked him to the crime. He confessed to the robbery, murder, and arson during police interrogation and was convicted by a jury on multiple counts, including first-degree murder. The penalty phase included testimony regarding his abusive childhood and mental health, but the jury imposed a death sentence.After his conviction, Castillo appealed to the Nevada Supreme Court, which affirmed both the conviction and sentence. His state post-conviction relief (PCR) petition was denied by the trial court and affirmed by the Nevada Supreme Court. Castillo then filed a federal habeas corpus petition in the United States District Court for the District of Nevada. He voluntarily dismissed the petition, but later moved to reopen it. His subsequent amended petitions were dismissed by the district court as untimely or procedurally defaulted. The district court granted a certificate of appealability for four claims and denied it for two others.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that Castillo’s first and second amended habeas petitions were untimely and equitable tolling was not warranted. The court affirmed denial of relief on most claims, including ineffective assistance of trial counsel and the as-applied Eighth Amendment challenge to Nevada’s lethal injection protocol. However, the court reversed the district court’s ruling on two claims, finding that attorney error in state PCR proceedings could excuse procedural default under Martinez v. Ryan and Hogan v. Bean. Those claims were remanded for further proceedings. The court affirmed denial of certificates of appealability for the remaining claims. View "CASTILLO V. BEAN" on Justia Law

Federal agents suspected that an individual was using his auto garage as a front for narcotics distribution. After two controlled purchases of cocaine and ongoing surveillance, agents obtained a warrant to search his house and the surrounding grounds for evidence of drug crimes. The warrant did not specifically list vehicles among the items to be seized. Upon executing the warrant, agents found a blue minivan and a red truck parked in the driveway. Although a search of the vehicles initially revealed no contraband, the agents seized them for civil asset forfeiture, believing the minivan was used to facilitate drug sales and the truck was purchased with drug proceeds. Later, after receiving a tip, agents obtained a separate warrant to search the minivan and discovered cocaine and a firearm hidden in a secret compartment.The United States District Court for the District of Connecticut denied the defendant’s motion to suppress the evidence found in the minivan. The court reasoned that, under Florida v. White, law enforcement does not need a warrant to seize forfeitable vehicles from places where officers are lawfully present, even private driveways. The defendant subsequently pleaded guilty while preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Second Circuit reviewed the case. The Court held that the warrantless seizure of the minivan from the private driveway was reasonable under the Fourth Amendment since the agents had a warrant authorizing them to be present on the property and search its grounds. The Court explained that such a seizure did not constitute an invasion of privacy. The Court distinguished this case from United States v. Lasanta, finding Lasanta inapposite because the agents here had a search warrant for the property, unlike in Lasanta. The judgment of the district court was affirmed. View "United States v. Acevedo" on Justia Law

The defendant was transporting a large mobile home on a rural county road in Gage County, Nebraska, when an axle broke and the mobile home became stuck, obstructing the roadway for nearly a week. Despite attempts to remove the obstruction, the defendant was unsuccessful, and the Gage County sheriff’s office ultimately hired an excavation company to clear the road, incurring a $15,000 expense. The obstruction did not cause any physical damage to the road, and the expense was solely for removal and disposal. The defendant pled no contest to obstructing a public road under Nebraska law, and the county court ordered him to pay $15,000 in restitution to the sheriff’s office.Upon appeal to the District Court for Gage County, the defendant challenged the restitution order, arguing that the relevant Nebraska statute did not authorize criminal restitution for such expenses and that the county court had not considered his ability to pay. The district court affirmed the county court’s determination that restitution was authorized under Neb. Rev. Stat. § 29-2280, reasoning that the expenses incurred were a loss sustained by the victim as a direct result of the offense. However, it found merit in the argument regarding ability to pay, vacated the restitution order, and remanded for a hearing on that issue.The Nebraska Supreme Court reviewed the statutory authority for criminal restitution de novo, holding that the restitution statutes must be strictly construed and only authorize restitution for actual physical injury or property damage or loss, as defined by Neb. Rev. Stat. §§ 29-2280 and 29-2282. The Court concluded that the expenses incurred by the sheriff’s office did not constitute property damage or loss within the meaning of the statutes. As a result, the Court affirmed the district court’s vacation of the restitution order, but on the grounds that restitution was not authorized by statute, and remanded with directions to vacate the order in its entirety. View "State v. Carpenter" on Justia Law