Justia Criminal Law Opinion Summaries

The petitioner, a noncitizen born in Venezuela who later overstayed a travel visa in the United States, became involved in a drug conspiracy led by her abusive husband. She was charged with conspiracy to distribute controlled substances. Her primary concern throughout the criminal proceedings was remaining in the United States, as she had two children who were U.S. citizens. Her court-appointed counsel assured her that accepting a plea agreement would allow her to "work out" any immigration issues after serving her sentence, despite warnings in the plea agreement and at the plea hearing that she "may" be deported. Relying on this advice, she pleaded guilty and was sentenced to 84 months' imprisonment and three years of supervised release.After completing her sentence, the petitioner received a removal notice, prompting her to seek legal assistance. Upon learning that her conviction rendered her mandatorily removable and permanently inadmissible to the United States, she filed a petition for a writ of coram nobis in the United States District Court for the District of New Hampshire. The district court held an evidentiary hearing and found that she had adequately explained her delay in seeking relief, the counsel's advice was constitutionally deficient under Padilla v. Kentucky, and she suffered prejudice because she would not have pleaded guilty if properly advised. The court granted the writ and vacated her conviction, concluding that equitable considerations favored relief.The United States Court of Appeals for the First Circuit reviewed the district court’s grant of coram nobis relief. Applying de novo review to legal conclusions and clear error to factual findings, the First Circuit affirmed the district court’s decision. The main holding is that the petitioner met all requirements for coram nobis relief: timely explanation for delay, ongoing collateral consequences, fundamental error due to ineffective assistance of counsel, and equitable grounds justifying relief. View "Morillo v. US" on Justia Law

A customer dined at a Mississippi restaurant specializing in local seafood, ordering premium snapper on three occasions between 2013 and 2018. The restaurant, along with its supplier and several managers, was later criminally charged for a long-running scheme to mislabel imported frozen fish as locally caught premium fish. All parties pled guilty, admitting to substituting and fraudulently selling over 29 tons of imported fish as local species during a multi-year period. The customer alleged that he paid high prices for what he believed to be premium Gulf snapper, but was instead served inferior imported fish, and he brought a class action seeking damages under federal and state law.The United States District Court for the Southern District of Mississippi dismissed the complaint under Rule 12(b)(1), finding no cognizable Article III injury. The court reasoned that since the plaintiff consumed his meals without complaint, paying for fish he would not have otherwise purchased was not a concrete injury. It also found the allegations insufficiently particularized, as the plaintiff did not specifically allege that imported fish was served on the dates he dined or that all snapper sold on those dates was misbranded. The court denied motions to amend the judgment and complaint, concluding any amendments would be futile.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and reversed the district court’s dismissal. The Fifth Circuit held that the plaintiff plausibly suffered a concrete and particularized injury in fact under Article III, either by being fraudulently induced to purchase inferior fish or by overpaying due to fraud. The court concluded that the allegations of widespread and routine fish substitution at the restaurant plausibly affected the plaintiff’s meals, particularly his August 21, 2018, visit. The denial of leave to amend was vacated, and the case was remanded for further proceedings. View "McCain v. Mary Mahoney's" on Justia Law

Antoine Cook was arrested after his then-girlfriend, E.C., contacted his parole officer and reported both his arrest for domestic violence and their recent drug use. When parole officers arrived at the hotel, E.C. had Cook’s cell phone and stated it was her only means of communication. She provided the officers with the phone’s passcode and consented to their request to search the device. On the phone, officers found incriminating images and videos depicting drugs and firearms. Based on this evidence and a subsequent consent search of the hotel room, officers discovered ammunition and controlled substances.The United States District Court for the Northern District of Ohio denied Cook’s motion to suppress evidence obtained from the cell phone, holding that Cook’s parole conditions permitted warrantless searches. The district court also rejected Cook’s challenges regarding the authority to consent to the phone search and permitted the evidence from the hotel room. Cook was later convicted by a jury on counts of possessing methamphetamine and cocaine with intent to distribute, and being a felon in possession of ammunition. He appealed, arguing improper denial of the suppression motion, ineffective assistance of counsel, and judicial bias.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court held that E.C. had common authority over the cell phone and could consent to its search, obviating the need to consider parole-based search arguments. The court also found no plain error in the seizure of the phone, as officers had probable cause and Cook’s possessory interest was not meaningfully interfered with while he was in custody. The court declined to address the ineffective assistance of counsel claim due to an insufficient record and found no evidence of judicial bias by the district judge. View "United States v. Cook" on Justia Law

A police officer in Decatur, Alabama, was involved in a fatal shooting that occurred while a tow-truck driver attempted to repossess a vehicle from a homeowner’s property. The tow-truck driver had experienced a prior confrontation with the homeowner, who allegedly pointed a gun at him and ordered him to leave. When the tow-truck driver returned with several police officers prepositioned for safety, the homeowner again emerged armed and pointed his gun, first at the tow-truck driver and then in the direction of one of the officers. The officer fired, resulting in the homeowner’s death.After being indicted for murder, the officer moved for pretrial dismissal, claiming statutory immunity under Alabama’s defense-of-persons statute, which justifies the use of force under certain conditions and provides for immunity from prosecution if the statute’s requirements are met. The Morgan Circuit Court held a pretrial hearing but denied the motion, reasoning that the peace-officer-specific use-of-force statute was the applicable law rather than the more general defense-of-persons statute. The court focused on whether the officer acted as a “reasonable police officer” and whether he was acting within the scope of his police authority, ultimately setting the case for trial but staying proceedings pending appellate review. The Alabama Court of Criminal Appeals affirmed this approach, also applying the peace-officer statute.The Supreme Court of Alabama reviewed the case and determined that the lower courts had applied the incorrect legal standard by relying on the peace-officer statute instead of the defense-of-persons statute. The Supreme Court held that the officer had a clear legal right to have his immunity claim evaluated under the defense-of-persons statute, which applies to all persons, not just police officers, and provides for pretrial immunity. The Court issued a writ of mandamus, directing the circuit court to vacate its previous order and reevaluate the officer’s claim under the correct statute. View "In re: State of Alabama v. Marquette" on Justia Law

A man was found inside a residence in Woodville, Mississippi, by a woman who recognized him as someone she had known since childhood. His behavior was described as markedly different and concerning. He was reportedly armed with multiple firearms and made threats toward those present in the house. The woman and others eventually left the residence and alerted law enforcement to his presence and the fact that he was armed. When law enforcement, including two police chiefs, arrived and attempted to apprehend him, the man exited the house and fired two shots in the direction of the officers. One officer initially believed he had been struck, but it was determined he was hit by debris. The man fled and was apprehended approximately a week later.The Circuit Court of Wilkinson County held a jury trial, where the jury found the defendant guilty of aggravated assault on a law-enforcement officer under Mississippi law. He was sentenced to thirty years in prison. On appeal, he argued that the jury was not properly instructed on the essential elements of the offense and that the verdict was contrary to the overwhelming weight of the evidence because no physical or forensic evidence linked him to the shooting.The Supreme Court of Mississippi reviewed the appeal. It held that the supplemented record showed the jury was properly instructed on all essential elements of aggravated assault on a law-enforcement officer, in accordance with statutory requirements. The court also found that credible testimonial evidence from eyewitnesses supported the verdict, and that it was not against the overwhelming weight of the evidence. The Supreme Court of Mississippi affirmed the conviction and sentence. View "Carr v. State of Mississippi" on Justia Law

A defendant was indicted as a violent habitual offender for aggravated assault on a law enforcement officer, shooting into a motor vehicle, and unlawful possession of a firearm or weapon by a convicted felon. After his indictment, the court scheduled his trial. On the day of trial, his counsel requested a mental-health evaluation, resulting in a continuance. The court granted this motion, and the defendant was evaluated by Dr. Montgomery, who found him competent to stand trial. The court held a competency hearing, admitted Dr. Montgomery’s report without objection, and found the defendant competent. Later, the defendant moved for a second mental-health evaluation at county expense, which the State opposed.The Jackson County Circuit Court denied the request for county-funded payment for a second evaluation but allowed the defendant to obtain a second evaluation at his own expense. The court initially denied the defendant’s oral motion for a continuance but later granted a written motion when it was shown that the second evaluation could not be performed before the scheduled trial date. The trial was ultimately rescheduled, allowing the defendant eight additional months before trial. The defendant did not offer the second evaluation into evidence at trial. A jury found him guilty on all counts, and he was sentenced to three concurrent life sentences as a habitual offender.On appeal to the Supreme Court of Mississippi, the defendant argued that the trial court erred by denying his motion for a continuance to obtain a second mental-health evaluation. The Supreme Court of Mississippi held that the trial court did not abuse its discretion in denying the continuance and did not impede the defendant’s ability to obtain a second evaluation, as a later continuance was granted and the defendant had ample time before trial. The court affirmed the convictions and sentences. View "Howard v. State of Mississippi" on Justia Law

The defendant participated as a street-level drug distributor in a Massachusetts-based organization led by another individual. The organization’s operations involved receiving orders through a leader, who then relayed instructions to distributors such as the defendant. These distributors were provided with cars stocked daily with drugs, which they delivered in user-level quantities to customers. The defendant worked in this role for approximately two months, during which intercepted phone calls and a subsequent police stop resulted in the government attributing responsibility to him for distributing over 300 grams of fentanyl and additional amounts of cocaine. Upon arrest, drugs were found hidden in his car.After pleading guilty to conspiracy to possess with intent to distribute and to distribute forty grams or more of fentanyl, the United States District Court for the District of Massachusetts calculated a Guidelines Sentencing Range of forty-six to fifty-seven months. Probation recommended a two-level minor-role reduction under U.S.S.G. § 3B1.2(b), but the court denied this adjustment, reasoning that the defendant did not qualify as substantially less culpable than the average participant and that a recent guideline amendment did not apply to his circumstances. The court imposed a sentence of thirty-six months.The United States Court of Appeals for the First Circuit reviewed the district court’s interpretation of the newly added U.S.S.G. § 2D1.1(e)(2)(B)(ii), which expands the circumstances for minor-role adjustments. The appellate court held that the district court misapplied the guideline by reading into it categorical exclusions for those who possessed more than user-level quantities or who were paid employees in the organization’s business model. The First Circuit vacated the sentence and remanded for resentencing, directing the district court to properly consider the defendant’s primary function based on the totality of the circumstances. View "US v. Vizcaino Vizcaino" on Justia Law

Eric Holmes was convicted by an Indiana jury in 1992 of two counts of murder, attempted murder, robbery, and conspiracy to commit robbery, stemming from an incident at a restaurant. During sentencing, the jury could not unanimously recommend the death penalty, so the trial judge, as allowed by Indiana law at the time, found aggravating circumstances and imposed a death sentence. Holmes exhausted his direct appeals and post-conviction relief in state court, then filed a federal habeas corpus petition.While that federal petition was pending, Indiana amended its death penalty statute in 2002 to require jury findings on aggravating circumstances, in response to Apprendi v. New Jersey and Ring v. Arizona. In Saylor v. Indiana, the Indiana Supreme Court vacated a death sentence for a defendant whose jury had unanimously recommended against death, holding it inappropriate to execute someone sentenced under the old procedure. Holmes sought similar relief in state court, but the Indiana Supreme Court denied his request, distinguishing his case because his jury had not reached a recommendation at all, as opposed to Saylor’s unanimous recommendation against death.Holmes then filed a second federal habeas petition in the United States District Court for the Southern District of Indiana, claiming the Indiana Supreme Court’s decision violated his Fourteenth Amendment rights to equal protection. The district court dismissed the petition as “second or successive,” lacking jurisdiction. On appeal, the United States Court of Appeals for the Seventh Circuit disagreed with the district court’s procedural ruling, finding Holmes’s equal protection claim was not “second or successive” because it was not ripe during his first petition. However, the court affirmed the dismissal on the merits, holding the Indiana Supreme Court had a rational basis for treating Holmes differently, since his jury had not reached a unanimous recommendation, and thus there was no Equal Protection violation. View "Holmes v Neal" on Justia Law

Jesse Owens, while serving a term of supervised release following a federal conviction for possessing a firearm and ammunition while under a domestic violence restraining order, was accused of several violations, including new criminal conduct. Specifically, he was charged in South Carolina state court with first-degree assault and battery after an incident where the victim testified that Owens bit, choked, and punched her over an eight-hour period, causing significant injuries. Photographic evidence of her injuries was presented at the revocation hearing.The United States District Court for the District of South Carolina found Owens had violated his supervised release by committing first-degree assault and battery under South Carolina law. The court classified the conduct as a Grade A violation, calculated the advisory Sentencing Guidelines range as 12 to 18 months, but imposed an upward variance, sentencing Owens to 24 months in prison and an additional 12 months of supervised release. The court justified the sentence based on Owens’s history of violence and his disregard for imposed conditions. Owens did not object to the characterization of his conduct or the severity of the violation at the time.Owens appealed to the United States Court of Appeals for the Fourth Circuit, arguing that the district court erred by categorizing South Carolina first-degree assault and battery as a “crime of violence,” affecting the guidelines calculation. The Fourth Circuit applied the categorical and modified categorical approaches, referencing its own precedent in United States v. Mack, and rejected Owens’s reliance on United States v. Clemons from the Supreme Court of South Carolina, noting Clemons did not directly address first-degree assault and battery. The Fourth Circuit held that the district court did not commit plain error and affirmed the district court’s judgment. View "US v. Owens" on Justia Law

Three individuals departed from Dana Point Harbor in Southern California at night, ostensibly for a lobster-fishing trip. When the boat returned, one person was missing, and his body was later found floating in the ocean with evidence of drowning, gunshot wounds, and blunt force trauma. Location data placed the incident within three nautical miles of the California coast. The surviving participants did not report the death. Following an investigation, federal authorities charged one of the surviving individuals with first-degree murder, conspiracy to commit murder, and possession of a firearm in furtherance of murder.The United States District Court for the Central District of California heard the case. The defense argued that the federal government lacked jurisdiction because the death occurred within the three-nautical-mile territorial sea, which they claimed was under California's exclusive criminal jurisdiction. The district court rejected this argument, finding that federal jurisdiction extended twelve nautical miles from shore under the Antiterrorism and Effective Death Penalty Act of 1996. At trial, the jury was instructed accordingly and convicted the defendant on all counts. During jury deliberations, a juror experiencing distress and mental health concerns, which were linked to pressure from other jurors regarding the verdict, was excused and replaced by an alternate, with the agreement of both parties. The reconstituted jury returned guilty verdicts.On appeal, the United States Court of Appeals for the Ninth Circuit held that the federal government’s jurisdiction under Title 18 did extend to the first three nautical miles from shore. However, the appellate court found that the removal of the juror violated the defendant’s Sixth Amendment right to a unanimous jury verdict because her dismissal stemmed from her views on the merits of the case. The Ninth Circuit vacated the convictions and remanded the case for further proceedings. View "USA V. LE" on Justia Law