Justia Criminal Law Opinion Summaries

The defendant pleaded guilty in 2010 to conspiracy to distribute and possess with intent to distribute a large quantity of cocaine base, for which he was sentenced to a lengthy prison term and a supervised release period. His sentence was later reduced under the First Step Act, resulting in a shorter prison term and an eight-year supervised release. After his release, the defendant demonstrated significant rehabilitation, complied with all conditions of supervision, and maintained steady employment and a stable residence, with no new criminal conduct.Following his positive adjustment, the defendant filed three separate motions in the United States District Court for the Eastern District of Tennessee seeking early termination of his supervised release. The district court denied the first motion, acknowledging his model behavior but emphasizing the seriousness of his offense and the statutory minimum term. The second motion was denied based solely on the judge’s custom of not considering early termination until at least half of the supervised release term had been served. After appealing this denial, the defendant filed a third motion, which the district court also denied, reiterating the importance of its fifty-percent custom and referencing deterrence and public safety.The United States Court of Appeals for the Sixth Circuit reviewed the consolidated appeals. The court held that the district court abused its discretion by employing a blanket rule requiring completion of at least half the supervision term before considering early termination, instead of conducting an individualized assessment under the relevant statutory factors in 18 U.S.C. § 3553(a) and § 3583(e)(1). The appellate court concluded that the district court’s reliance on its custom, without adequate consideration of the defendant’s circumstances and the statutory factors, was improper. The Sixth Circuit vacated the district court’s orders and remanded for further proceedings. View "United States v. Collins" on Justia Law

Two brothers operated an energy-conservation contracting business and, beginning in 2013, engaged in a bribery scheme involving the Mass Save program, a state-mandated initiative to promote energy efficiency. One brother owned CAP Electric, Inc., and recruited the other to establish Air Tight Solutions, LLC as a Mass Save contractor with the assistance of a CLEAResult employee, who was responsible for selecting and overseeing contractors. The brothers paid this employee, and later another, regular bribes in cash and gifts to secure contracts, favorable treatment, and advance warning of audits. Air Tight performed little or no work directly, subcontracted projects, and disguised employees and payments to conceal the scheme. Over several years, their companies received multi-million dollar payments from the program.The United States District Court for the District of Massachusetts accepted their guilty pleas to conspiracy, honest-services wire fraud, making false statements, and (for one brother) aiding and assisting false tax returns. The district judge sentenced both to 27 months in prison (above-guidelines for one), and ordered forfeiture of $13.2 million and $3.6 million respectively. The brothers challenged the sentences and forfeitures on several grounds, including alleged errors in calculating tax loss, application of sentencing enhancements, and the process and proportionality of the forfeiture orders.The United States Court of Appeals for the First Circuit reviewed the case. It held that the district court did not err in calculating tax loss or applying sentencing enhancements for sophisticated means, obstruction of justice, and aggravating role. The appellate court also held that the district court correctly found a sufficient connection between the criminal conduct and the forfeited proceeds, and that any procedural errors in the forfeiture process were harmless. Finally, the court determined that the forfeiture orders were not unconstitutionally excessive. The First Circuit affirmed the sentences and forfeiture orders. View "United States v. Ponzo" on Justia Law

The case involves Michael Donnell Lee, who was charged with murder and related offenses following the shooting death of Aaron James Grant. After his arrest, Lee underwent a custodial interrogation by Detective Charles Sendling of the Atlanta Police Department, during which Lee made incriminating statements. Prior to making these statements, Lee invoked his rights to counsel and to remain silent after being read his Miranda rights. The detective, after a brief pause and some procedural activity, re-engaged Lee in conversation, during which Lee ultimately agreed to talk and then made several incriminating statements during the ensuing interview.Before trial, the State moved to admit Lee’s statements, but the Superior Court of Fulton County excluded them, ruling that they were inadmissible under Miranda v. Arizona and Edwards v. Arizona because Lee had invoked his constitutional rights and had not reinitiated communication with the police. The trial court also found the statements to be involuntary as a matter of due process, citing Lee’s limited education and potential intellectual disability, and the detective’s conduct during the interrogation.The Supreme Court of Georgia reviewed the State’s interlocutory appeal. It agreed with the lower court that Lee did not reinitiate communication after invoking his rights, and that the detective’s subsequent interrogation was improper under Miranda and Edwards. The court clarified that Lee’s follow-up questions were mere clarifying inquiries and not an indication of a desire to discuss the investigation. However, the Supreme Court of Georgia disagreed with the trial court’s finding that the statements were involuntary under due process principles, finding no evidence of coercive police activity. The court affirmed the suppression of Lee’s statements for the prosecution’s case-in-chief but reversed their exclusion for impeachment purposes if Lee testifies. View "STATE v. LEE" on Justia Law

Mark Isham and C.K. were in a long-term relationship, living together intermittently. In March 2023, after C.K. stayed with Isham following her release from a treatment center, the two drank alcohol and argued, resulting in Isham physically assaulting C.K. on two separate occasions. Several days after the second assault, C.K., who is an amputee, called 911 and reported being held against her will and physically abused. Police officers responded to Isham’s home, spoke separately to both individuals, and eventually arrested Isham after he admitted to hitting C.K. C.K. was hospitalized and required surgery for a fractured jaw.The United States District Court for the District of Minnesota heard Isham’s pretrial motions. The court denied Isham’s motion to suppress statements he made to officers before being arrested, concluding he was not in custody during the questioning. The court also partially granted a government motion to admit evidence of Isham’s prior assaults against C.K., allowing testimony about more recent incidents but excluding older ones. At trial, the jury acquitted Isham of assault with a dangerous weapon but convicted him of assault resulting in serious bodily injury and assault resulting in substantial bodily injury to an intimate partner.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of the suppression motion de novo and found that Isham was not subjected to custodial interrogation before his arrest, as the questioning was brief, non-coercive, and Isham voluntarily participated. The appellate court also held that the district court did not abuse its discretion in admitting evidence of prior assaults, finding it relevant to issues raised at trial and adequately limited by jury instructions. The judgment of the district court was affirmed. View "United States v. Isham" on Justia Law

A member of the Lower Brule Sioux Tribe, the defendant moved onto the Swallow Ranch, located in the Cuny Table area of the Pine Ridge Indian Reservation, in 2022. He lived in a camper and worked as a ranch hand. During his time there, he developed a relationship with a 15-year-old girl, A.S., whom he taught to train horses and later groomed and sexually abused. The abuse occurred at various locations on and near the ranch, including a campground, a rock formation, and his camper. On one occasion, he also abused A.S.’s 12-year-old sister, N.S. The defendant further solicited nude photos from A.S. and from another minor, C.J.E., through Snapchat. When confronted by family members about the abuse, he denied the allegations and messaged N.S., urging her to claim A.S. was lying to protect himself from potential jail time. An FBI agent later investigated, uncovering evidence of the defendant’s communications and the sexual abuse.The United States District Court for the District of South Dakota tried the case. A jury convicted the defendant on multiple counts, including sexual abuse of a minor, abusive sexual contact, attempted sexual exploitation of a minor, attempted receipt of child pornography, and witness tampering. The district court denied the defendant’s motion for judgment of acquittal and sentenced him to 480 months in prison.Reviewing the appeal, the United States Court of Appeals for the Eighth Circuit affirmed the convictions for sexual abuse, abusive sexual contact, attempted sexual exploitation, and attempted receipt of child pornography, holding that sufficient evidence supported the jury’s findings. However, the court vacated the witness tampering conviction, finding insufficient evidence that the defendant contemplated a particular, foreseeable proceeding as required by law. The Eighth Circuit also vacated the entire sentence and remanded for resentencing in light of the vacated conviction. View "United States v. Goodlow" on Justia Law

The case involves a defendant who, along with others, participated in two separate home invasion robberies targeting the residence of Michael Robertson. Surveillance footage captured Williams and others attempting to break in one night, and returning the following night to forcibly enter, simulating a police raid. During the second invasion, gunshots were fired by others, resulting in the death of Jessica Brandon, though Williams was not armed at that time. Substantial quantities of drugs and cash were found in the home, suggesting the motive was robbery of a drug dealer.Williams was indicted in the United States District Court for the District of Nebraska on charges including murder with a firearm during a crime of violence and two counts of interference with commerce by robbery. He pleaded guilty and was initially sentenced to a total of 660 months’ imprisonment. After the Supreme Court decided in United States v. Taylor that Hobbs Act robbery does not qualify as a crime of violence under 18 U.S.C. § 924, Williams’s conviction for murder with a firearm was vacated by the United States Court of Appeals for the Eighth Circuit, which remanded the case for resentencing on the two remaining robbery counts.Upon resentencing, the district court imposed consecutive sentences of 222 months for each count, resulting in a total of 444 months. Williams appealed, arguing the district court erred in applying the sentencing package doctrine, failed to adequately explain the equal sentences for each count, and imposed an unreasonable sentence. The United States Court of Appeals for the Eighth Circuit held that application of the sentencing package doctrine was proper, the district court’s explanation was sufficient, and the sentence was not substantively unreasonable. The court affirmed the amended judgment. View "United States v. Williams" on Justia Law

Late one night, the defendant called 911 to report his motel roommate was unconscious due to a possible overdose. When police and emergency medical personnel arrived, the roommate died, but the defendant was not initially considered a suspect. The police took his statement and released him. The following day, after the autopsy, police suspected a disturbance had occurred and brought the defendant to the station for further questioning. He was handcuffed during transport per department policy but was not under arrest. At the station, he waited in the lobby, was taken to an interview room, and was not restrained. During the interview, the detective began to read a Miranda advisement, at which point the defendant stated he wanted a lawyer. The detective agreed, and the defendant prepared to leave. Shortly afterward, police decided to arrest him, and upon being informed of his arrest for murder, the defendant indicated he would speak without a lawyer. He was then given a Miranda advisement, waived his rights, and made incriminating statements.The District Court for the City and County of Denver held a suppression hearing. The court, noting that both the prosecution and defense conceded the defendant was not in custody at the time he invoked his right to counsel, nonetheless ruled that his invocation was effective because a Miranda advisement had been attempted. The court suppressed the subsequent statements under Edwards v. Arizona, finding the police had not honored the defendant’s request for counsel by reinitiating questioning.The Supreme Court of Colorado reviewed the case. It concluded that the district court erred by applying Miranda and Edwards protections when the defendant was not in custody at the time he requested an attorney. The court held that an invocation of the right to counsel outside custodial interrogation is not effective, even when law enforcement attempts a Miranda advisement. The Supreme Court of Colorado reversed the suppression order and remanded the case for further proceedings. View "People v. Lulei" on Justia Law

The defendant was charged with operating a motor vehicle with a blood alcohol concentration of .08% or greater (DUI per se), first offense, in the City of Whitefish, Montana. He pleaded guilty pursuant to a plea agreement that recommended a fine and surcharge, but also requested the court consider his ability to pay and suspend the fine if warranted. At sentencing, the defendant, then 73 years old, testified about his limited financial means, relying solely on Social Security income. The Municipal Court, while sympathetic, imposed the statutory $600 minimum fine, finding it lacked discretion to suspend it, but waived the surcharge.The defendant appealed to the Eleventh Judicial District Court, which affirmed the Municipal Court’s decision. On further appeal, the Montana Supreme Court, in a prior decision (City of Whitefish v. Curran, 2023 MT 118), found that the Municipal Court had the authority to consider alternatives to full payment of the fine and remanded for consideration of such alternatives. On remand, the Municipal Court held a new hearing, again reviewed the defendant’s financial circumstances, and suspended the $600 fine in its entirety, conditioned on the defendant’s completion of court-ordered alcohol education.The Supreme Court of the State of Montana reviewed the case. It held that the applicable sentencing statutes require sentencing courts to determine a defendant’s ability to pay fines and allow courts to suspend mandatory minimum fines to the extent a defendant cannot pay. The Supreme Court found that the Municipal Court complied with these statutory requirements by considering the defendant’s ability to pay, imposing the statutory fine, and then suspending it. The Supreme Court affirmed the District Court’s order upholding the Municipal Court’s sentence and judgment. View "City of Whitefish v. Curran" on Justia Law

The case concerns a defendant who pleaded guilty to two drug offenses and was sentenced in the United States District Court for the Eastern District of North Carolina. During the sentencing hearing, the court orally pronounced certain discretionary conditions for supervised release, including a condition regarding warrantless searches. The court stated that such searches would be allowed only upon reasonable suspicion of a violation or, without suspicion, for safety issues. Later that day, the court entered a written judgment that imposed broader conditions, permitting warrantless searches by probation officers as part of their general supervision functions, without limiting such searches to the occasions described orally.After sentencing, the defendant appealed, arguing that the written judgment contained conditions of supervised release that materially differed from those announced in open court. The government raised several arguments in response, including claims about waiver and harmlessness, and noted that the written condition matched the presentence report’s recommendation, which the defendant had not objected to. The United States Court of Appeals for the Fourth Circuit reviewed these arguments de novo, consistent with its precedent.The Fourth Circuit held that there was a material discrepancy between the oral pronouncement and the written judgment regarding the scope of warrantless searches, which constituted error under its Rogers–Singletary line of cases. The court rejected the government’s arguments that the error was harmless or waived by the plea agreement, emphasizing that the oral pronouncement controls and that a defendant has standing to challenge such discrepancies. Accordingly, the Fourth Circuit vacated the judgment and remanded the case for resentencing. View "United States v. Tostado" on Justia Law

The petitioner was convicted of two separate murders in Indiana and sentenced to death for each. He unsuccessfully challenged his convictions and sentences in Indiana’s courts, including direct appeals and post-conviction proceedings, with the Indiana Supreme Court affirming the outcomes. After the Supreme Court of the United States denied review, the petitioner’s deadline to seek federal habeas corpus relief under 28 U.S.C. § 2254 expired in February 2021. Despite being represented by counsel appointed during the COVID-19 pandemic, communication difficulties and alleged mental health issues were cited as reasons for the late filing of his federal petition, which was submitted two years past the deadline.Following the late filing, the State moved to dismiss the petition as untimely. The petitioner argued for equitable tolling, claiming extraordinary circumstances prevented timely filing and requested discovery and an evidentiary hearing to support this claim. As part of the process, he also sought an order under the All Writs Act to be transported to a hospital for brain scans to support his argument regarding his mental health limitations.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s order granting the transportation request. The appellate court held that, under Shoop v. Twyford, a transportation order for evidence-gathering is warranted only if there is a demonstrated nexus between the sought evidence and its admissibility or relevance to a particular claim for relief. The court found that the petitioner failed to establish how the requested brain scans would be relevant or admissible in support of equitable tolling. Therefore, the Seventh Circuit reversed the district court’s transportation order and remanded the case for further proceedings. View "Gibson v. Neal" on Justia Law