Justia Criminal Law Opinion Summaries

A veteran special agent with Homeland Security Investigations was convicted after a jury trial of accepting bribes from individuals connected to organized crime. In exchange, he misused a confidential government database to assist these individuals and attempted to fraudulently facilitate the entry of an inadmissible foreign national into the United States through immigration parole. The indictment charged him with conspiracy to commit bribery, accepting a bribe as a public official, money laundering, and filing false tax returns. The criminal conduct involved accessing sensitive information and attempting to manipulate immigration processes for personal gain.Previously, the United States District Court for the Central District of California sentenced him to 121 months in prison, applying a four-level sentencing enhancement under U.S.S.G. § 2C1.1(b)(3) for holding a “high-level decision-making or sensitive position.” On his first appeal, the United States Court of Appeals for the Ninth Circuit affirmed his convictions but vacated the sentence, remanding for resentencing because the district court had relied on guideline commentary without first finding the guideline text ambiguous, as required by United States v. Castillo.Upon remand, the district court found the guideline text ambiguous and again applied the enhancement, referencing the commentary which includes law enforcement officers as holding “sensitive positions.” The court imposed an 85-month sentence after a downward departure. On appeal, the United States Court of Appeals for the Ninth Circuit held that the guideline's text is ambiguous regarding whether a “sensitive position” must also be “high-level,” and that it is ambiguous as to what constitutes a “sensitive position.” The court held that deference to the guideline commentary was warranted, finding it reasonable to include law enforcement officers as holding “sensitive positions.” The Ninth Circuit also held that the district court’s sentencing explanation was sufficient. The sentence was affirmed. View "USA V. CISNEROS" on Justia Law

A woman was arrested in Delaware for selling drugs from a motel room, and police recovered heroin and fentanyl in labeled packets from her possession. After her arrest, she cooperated with police and identified her supplier as a man who would be delivering more drugs to the motel. Police surveilled the motel and, after a series of monitored calls, arrested Philip Epps when he arrived in a white SUV, matching the description provided. Evidence seized included two iPhones (one linked to the supplier), large amounts of cash, firearms, and more drugs with the same identifying labels. Forensic evidence further tied Epps to the operation, and the government presented this at trial. Epps offered no evidence in his defense.The United States District Court for the District of Delaware conducted the jury trial. After deliberating for a few hours, the jury indicated it was deadlocked. The court provided a supplemental instruction, which incorrectly stated, “you have to” reach a unanimous verdict. Neither party objected at the time. The jury subsequently returned guilty verdicts on all counts. Two weeks later, Epps moved for a new trial under Federal Rule of Criminal Procedure 33, arguing the supplemental instruction was unduly coercive. The District Court initially denied the motion, but upon reconsideration, it granted a new trial, concluding that justice required it due to the problematic instruction. The government appealed.The United States Court of Appeals for the Third Circuit reviewed the case. It held that while the District Court’s supplemental instruction misstated the law by suggesting the jury was required to reach a verdict, this error, when considered in the context of the entire jury charge, was not unduly coercive and did not prejudice Epps. Therefore, the Third Circuit reversed the District Court’s order granting a new trial and remanded for further proceedings. View "USA v. Epps" on Justia Law

A man with two prior felony convictions for carrying a pistol without a license in the District of Columbia was sentenced in 2022 to a period of supervised probation in lieu of imprisonment for his second offense. While still under this court-ordered supervision, he knowingly possessed a firearm, which was reportedly stolen and modified for automatic firing, and was alleged to have brandished it during a shootout. He was indicted by a federal grand jury under 18 U.S.C. § 922(g)(1), the federal felon-in-possession statute.In the United States District Court for the District of Columbia, the defendant moved to dismiss the indictment, arguing that § 922(g)(1) violated the Second Amendment both facially and as applied to him, particularly in light of the Supreme Court’s decision in New York State Rifle & Pistol Association v. Bruen, which emphasized historical tradition over means-end scrutiny in Second Amendment cases. The district court rejected his arguments, holding that earlier circuit precedent (Medina v. Whitaker) upholding § 922(g)(1) remained good law, and denied the motion to dismiss. The defendant then pleaded guilty while preserving his right to appeal the constitutional issue.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The court held that, even assuming prior precedent did not control and that § 922(g)(1) implicated conduct covered by the Second Amendment, there exists a widespread historical tradition of temporarily disarming felons while they are serving their criminal sentences, including during periods of noncustodial supervision such as probation or supervised release. Therefore, § 922(g)(1) is constitutional as applied to individuals still serving their sentences, and is not facially unconstitutional. The court affirmed the judgment of the district court. View "USA v. Richardson" on Justia Law

Three individuals were indicted for participating in a string of ten armed robberies targeting businesses in the District of Columbia, Maryland, and Virginia in January 2018. The robberies followed a consistent pattern: two of the men would enter a store masked and armed, threatening employees and collecting cash and valuables, while the third waited nearby. In one instance, all three entered and used physical violence against staff. Security footage and other evidence linked the defendants to the crimes. Several weeks after the robberies, police responded to an unrelated home invasion, arresting two of the men and discovering a car registered to one of them nearby, which contained clothing and items connected to the earlier robberies.The United States District Court for the District of Columbia conducted a joint trial, after which a jury found all three defendants guilty on all counts, including conspiracy to commit Hobbs Act robbery, and for two defendants, additional counts of completed Hobbs Act robbery and brandishing a firearm during a crime of violence. The district court imposed sentences ranging from 166 to 234 months. The defendants appealed, challenging, among other things, the admission of evidence from a subsequent Missouri traffic stop, the search of the car, the admission of evidence from a cell phone, jury instructions, and the sufficiency of evidence for firearm-related charges. They also raised claims of ineffective assistance of counsel.The United States Court of Appeals for the District of Columbia Circuit reviewed each challenge. The court held that evidence from the Missouri traffic stop was properly admitted to show association among co-conspirators and was not unduly prejudicial. It found the seizure and search of the car lawful under the automobile exception and rejected claims that mistakes in the warrant affidavit required suppression. The court concluded that Hobbs Act robbery qualifies as a "crime of violence" under 18 U.S.C. § 924(c), supporting the firearm-related convictions. It also held that the claims of ineffective assistance of counsel lacked merit because no prejudice was shown. Accordingly, the Court of Appeals affirmed the convictions and sentences in full. View "USA v. Onyewu" on Justia Law

The case concerns an individual who was convicted of first-degree murder after he entered a home with several gang members and shot the victim, Michael Rhodes, multiple times as Rhodes sat on a couch next to his young daughter. The events stemmed from a gang dispute involving other individuals, but Rhodes was not the intended target and was caught in the crossfire. After the incident, the defendant and his accomplices fled the scene.The trial took place in an Oklahoma state court, where the defendant requested an instruction for the jury on the lesser-included offense of second-degree murder, arguing that the evidence could support a conviction for that crime rather than for first-degree murder. The trial court denied this request, concluding there was insufficient evidence to support the lesser charge. The defendant also requested an evidentiary hearing to determine whether he was intellectually disabled and therefore ineligible for the death penalty; this was denied because one of his IQ scores was above the statutory cutoff. The jury convicted him of first-degree murder and found aggravating circumstances, resulting in a death sentence. On direct appeal, the Oklahoma Court of Criminal Appeals (OCCA) affirmed both the conviction and the sentence, finding no error in the trial court’s refusal to give the lesser-included instruction or to conduct an intellectual disability hearing. The defendant’s requests for post-conviction relief and for certiorari to the United States Supreme Court were denied.The United States Court of Appeals for the Tenth Circuit reviewed the case after the federal district court denied habeas relief. The Tenth Circuit held that the OCCA did not unreasonably apply clearly established Supreme Court precedent regarding either the necessity of a lesser-included offense instruction under Beck v. Alabama or the requirement for an intellectual disability hearing under Atkins v. Virginia and its progeny. The court affirmed the district court’s denial of habeas relief. View "Fuston v. Quick" on Justia Law

A man and his wife experienced a tumultuous marriage marked by frequent conflict and the issuance of mutual protection orders. The couple eventually separated, and the wife, along with their children, moved out. During and after their separation, the husband violated a modified protection order that restricted his contact with his wife to matters relating to their children and prohibited any abuse or conduct likely to cause her fear. The state filed two sets of criminal charges against the husband, including witness intimidation, stalking, and multiple counts of violating a protection order. The cases were joined for trial. Evidence presented at trial included numerous communications from the husband to his wife, some of which the wife described as threatening or emotionally distressing.The District Court of Uinta County presided over the trial. The court excluded certain evidence regarding the wife’s past conduct, deeming it irrelevant or more prejudicial than probative, and limited the admissibility of other evidence on similar grounds. A jury acquitted the husband on two counts of violating a protection order but convicted him on all remaining charges. The district court orally sentenced the husband to specific jail terms but entered written sentencing orders that were inconsistent with the oral pronouncement, including indeterminate sentences for misdemeanors and conflicting statements about the order in which sentences would be served.The Supreme Court of Wyoming reviewed the case. It held that the district court did not abuse its discretion by excluding most evidence of the wife’s conduct, finding such evidence irrelevant to the husband’s specific intent or the elements of the crimes charged, and that the exclusion did not violate his constitutional rights. The court also held that the evidence was sufficient to support the witness intimidation conviction, as the husband's statements constituted threats under the statute. However, it found that the written sentencing orders imposing indeterminate misdemeanor sentences were illegal and that the chronological order of sentences was unclear. The court affirmed the convictions but reversed and remanded for correction and clarification of the written sentencing orders. View "Walker v. The State of Wyoming" on Justia Law

Two children, John and Jane, lived primarily with their maternal grandfather under an informal arrangement, while their parents, Nicole Roy and Harrison Dudley, Sr., retained responsibility for their medical care. Medical professionals discovered severe health issues: Jane, age two, suffered from life-threatening anemia and a scalp infection, while John, age six, had significant developmental delays and both children had untreated head lice. Roy and Dudley repeatedly failed to follow through with prescribed treatments, missed follow-up appointments, and did not address the children's medical and hygiene needs, despite receiving explicit instructions and assistance from healthcare providers.A grand jury indicted Roy and Dudley for felony child neglect and felony child endangerment under the Major Crimes Act, alleging the offenses occurred on the Red Lake Indian Reservation. After a trial in the United States District Court for the District of Minnesota, a jury convicted both defendants on all counts. The district court sentenced Roy to twelve months and one day and Dudley to four months of imprisonment, with both receiving three years of supervised release and special assessments. Roy’s appeal became moot due to her death, while Dudley appealed, challenging the sufficiency of the evidence and the legality of his sentence.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that sufficient evidence supported Dudley’s convictions, finding that a rational jury could conclude he willfully deprived the children of necessary care and recklessly endangered their health. The court also held that Dudley’s term of supervised release and the imposition of special federal assessments were lawful under the Major Crimes Act and relevant federal statutes. The Eighth Circuit affirmed the judgment as to Dudley and vacated the judgment as to Roy, remanding with instructions to dismiss her indictment. View "United States v. Roy" on Justia Law

Cory Martin was charged with murder-for-hire, conspiracy to commit murder-for-hire, fraud, and identity theft after he killed Brandy Odom in April 2018. Martin’s then-girlfriend, Adelle Anderson, had taken out life insurance policies on Odom and promised Martin the proceeds upon Odom’s death. Following the murder, Anderson attempted to collect on the fraudulent policies but was unsuccessful. Law enforcement discovered Odom’s remains, secured Anderson’s cooperation, and prosecuted Martin based in large part on Anderson’s testimony.The case was heard in the United States District Court for the Eastern District of New York. At trial, Martin argued Anderson was the mastermind and that he was uninvolved, but the jury rejected this, finding Martin guilty on all counts. Anderson, having cooperated, pleaded guilty in a separate proceeding and received probation due to her history of abuse and other mitigating factors. Martin was sentenced to life imprisonment for the murder-for-hire offenses, along with additional sentences for the fraud and identity theft charges. He appealed, challenging the sufficiency of the evidence, the adequacy of the jury instructions, the inclusion of an aiding-and-abetting instruction, and alleging spillover prejudice affecting his other convictions.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that the evidence was sufficient to support the murder-for-hire convictions under 18 U.S.C. § 1958, clarifying that the statute’s “consideration” requirement does not demand a formal employment relationship but rather a reciprocal inducement—an exchange of the murder for a promise of pecuniary value. The Second Circuit also found the jury instructions were proper, the aiding-and-abetting instruction was justified, and no impermissible spillover prejudice had occurred. The district court’s judgment was affirmed in all respects. View "United States v. Martin" on Justia Law

The case concerns a man who was convicted by an Alabama jury of murdering his girlfriend and her mother. The key facts established at trial showed that after the murders occurred in the victims’ home, the defendant left the state with the children, the victims’ car, and their checks, traveling to Cleveland, Ohio. Witness testimony placed him at the scene around the time of the murders, and his fingerprints were found on duct tape used to bind one of the victims. Additional evidence included his efforts to obtain cash using the victims’ checks, his lies about needing money for a child’s medical care, and his subsequent standoff with police in Cleveland. Family members of the defendant, including his aunt and uncle, were involved in alerting police to possible trouble at the victims’ home before the bodies were discovered.The Alabama Court of Criminal Appeals, reviewing the conviction and death sentence, agreed that the trial court erred in admitting testimony from a police investigator about a statement the defendant allegedly made to his aunt (“I hurt them girls”) without proper impeachment procedure. However, the appellate court held that this error was harmless beyond a reasonable doubt, given the overwhelming evidence of guilt.After unsuccessful state postconviction proceedings, the defendant sought federal habeas relief in the United States District Court for the Northern District of Alabama, arguing that admission of his alleged statement violated his federal due process rights. The district court denied relief, ruling that any error was not prejudicial in light of the full record. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed, holding that admission of the statement did not violate due process because it was not a crucial or highly significant factor in the conviction, and any error was harmless under both state and federal standards. View "Brown v. Commissioner, Alabama Department of Corrections" on Justia Law

The case involved allegations that the defendant sexually abused his stepson, J.M., on multiple occasions between 2019 and 2022. The prosecution charged the defendant with two counts of first degree sexual assault of a child and one count of third degree sexual assault of a child. A key issue arose regarding the age of the victim at the time of one incident. Initially, the charge alleged the victim was between 12 and 15 years old, but testimony at trial indicated the victim was younger than 12. The prosecution successfully moved to amend the information during trial to reflect the victim’s correct age at the time of the offense.Prior to the appeal, the District Court for Douglas County allowed the State to amend the information to align with the evidence presented. The jury found the defendant guilty on all three counts, and the court convicted and sentenced him, also concluding that he committed an aggravated offense requiring lifetime sex offender registration. The defendant, now represented by different counsel, appealed, raising several assignments of error including challenges to the amendment of the information, exclusion of certain evidence, his absence during trial proceedings, and claims of ineffective assistance of trial counsel.The Nebraska Supreme Court held that the statute defining first degree sexual assault of a child creates a single offense that can be committed in two distinct ways, based on the age of the victim and the age of the defendant. The Court found no abuse of discretion in allowing the amendment of the information, determined that the defendant’s absence during certain trial proceedings did not violate due process, and found no plain error regarding evidentiary exclusions. The Court also concluded that the ineffective assistance claims were either insufficiently specific or lacked merit. The judgment of the district court was affirmed. View "State v. Ansell" on Justia Law