Justia Criminal Law Opinion Summaries

Jessie Hoffman was convicted of first-degree murder for the kidnapping, rape, and murder of Mary "Molly" Elliot in 1998 and sentenced to death. After exhausting all state and federal post-conviction remedies, his execution was delayed due to the unavailability of lethal injection drugs. In 2024, Louisiana adopted nitrogen hypoxia as a method of execution. Hoffman challenged this new method, arguing it violated the Eighth Amendment.The United States District Court for the Middle District of Louisiana granted Hoffman's motion for a preliminary injunction, preventing his execution by nitrogen hypoxia. The court concluded that Hoffman had exhausted his administrative remedies under the Prison Litigation Reform Act (PLRA) and found that nitrogen hypoxia posed a substantial risk of superadding pain and suffering. The court suggested that execution by firing squad would be a reasonable alternative that would reduce the risk of severe pain.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that Hoffman had indeed exhausted his administrative remedies. However, it disagreed with the district court's conclusion regarding the Eighth Amendment. The Fifth Circuit held that nitrogen hypoxia is painless and that the district court erred in suggesting that the Eighth Amendment requires a more painful method of execution, such as a firing squad. The court emphasized that the Eighth Amendment does not guarantee a painless death and that Hoffman failed to show that nitrogen hypoxia presented a substantial risk of severe pain compared to other methods.The Fifth Circuit vacated the preliminary injunction, allowing Louisiana to proceed with Hoffman's execution by nitrogen hypoxia. View "Hoffman v. Westcott" on Justia Law

Kenneth Pontz was convicted by a jury of violating a federal embezzlement statute, 18 U.S.C. § 641, by misrepresenting his financial situation to obtain public benefits over an eight-year period. The government presented evidence that Pontz had received Supplemental Security Income (SSI) benefits by falsely claiming he lived alone, while he actually lived with his wife, who received Social Security Disability Insurance (SSDI) benefits. Pontz's misrepresentations allegedly began in 2004 and continued until 2020.The United States District Court for the District of Massachusetts denied Pontz's motion to dismiss the indictment, which argued that the statute of limitations barred charges for conduct occurring before June 16, 2017. The district court ruled that § 641 embezzlement was a "continuing offense," allowing the government to charge Pontz for conduct dating back to 2014. At trial, the court admitted testimony from an SSA employee, Luis Aguayo, as lay opinion under Federal Rule of Evidence 701, despite Pontz's objections that it was based on technical knowledge requiring expert testimony.The United States Court of Appeals for the First Circuit reviewed the case and held that § 641 embezzlement is not a continuing offense under the standard established in Toussie v. United States. The court found that the nature of embezzlement does not involve a renewed, daily threat of harm once the elements of the crime are complete. Consequently, the government could not charge Pontz for embezzlement occurring more than five years before his indictment. The court vacated the restitution and forfeiture orders and remanded to the district court to determine the appropriate remedy for the statute-of-limitations error. The court upheld the district court's evidentiary rulings regarding Aguayo's testimony. View "United States v. Pontz" on Justia Law

James Ervin pleaded guilty to possessing a semi-automatic rifle as a convicted felon, violating 18 U.S.C. § 922(g)(1). He later sought to withdraw his guilty plea through a 28 U.S.C. § 2255 motion, claiming ineffective assistance of counsel and that the government provided false inculpatory information about the rifle. Ervin's arguments centered on the interpretation of the phrase “in or affecting commerce” in § 922(g).The United States District Court for the Western District of North Carolina denied Ervin's motion to vacate his plea. The court found that the rifle had traveled in interstate commerce, thus meeting the statutory requirement. Ervin's ineffective assistance claim failed because he could not establish prejudice, as the firearm's interstate travel was sufficient to satisfy the commerce element of § 922(g). The court also denied his motion for reconsideration and his request for a certificate of appealability.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the phrase “in or affecting commerce” in § 922(g) should be interpreted broadly, consistent with the Supreme Court's decision in Scarborough v. United States. The court found that the rifle, which traveled from North Carolina to Louisiana, Georgia, and back to North Carolina, met the interstate commerce requirement. Consequently, Ervin's claims of ineffective assistance of counsel and due process violations were rejected. The court affirmed the district court's denial of Ervin's motion to withdraw his guilty plea, concluding that his interpretation of the statute was incorrect and that his defense would have been meritless. View "United States v. Ervin" on Justia Law

In 2017, Dr. Oscar Lightner opened Jomori Health and Wellness in Houston, Texas, where he prescribed controlled substances to 97% of his patients, often without proper examinations. Many patients were brought in by "runners" who paid fees to reserve spots and later resold the prescribed pills. Andres Martinez, Jr., the office manager, collected these payments. Both Lightner and Martinez were indicted on drug-related charges under the Controlled Substances Act.The United States District Court for the Southern District of Texas tried the case. After a five-day trial, the jury found both defendants guilty on all counts. The district court sentenced each to 84 months of imprisonment. Martinez and Lightner appealed their convictions and sentences.The United States Court of Appeals for the Fifth Circuit reviewed the case. Martinez argued that the evidence was insufficient to support his convictions, but the court found that the evidence, including his interactions with runners and knowledge of Lightner's prescribing practices, was sufficient. Lightner raised several issues, including the jury instructions, alleged spoliation of evidence, and the denial of a motion to strike a witness's testimony. The court found no reversible error in these claims.The court also reviewed the sentencing enhancements applied to Lightner, including the calculation of drug weight, a two-level premises enhancement, and a four-level leadership enhancement. The court found that the evidence supported these enhancements and that any potential error was harmless given the substantial downward variance in Lightner's sentence.The Fifth Circuit affirmed the district court's judgment, finding no reversible error in the convictions or sentences of Martinez and Lightner. View "United States v. Lightner" on Justia Law

In 2017, Dr. Oscar Lightner opened Jomori Health and Wellness in Houston, Texas, where he prescribed controlled substances to 97% of his patients, often without proper examinations. Many patients were brought in by "runners" who paid fees to reserve spots and later resold the prescribed pills. Andres Martinez, Jr., the office manager, collected these payments. Both Lightner and Martinez were indicted on drug-related charges under the Controlled Substances Act and pleaded not guilty.The United States District Court for the Southern District of Texas conducted a five-day trial, after which the jury found both defendants guilty on all counts. The district court sentenced each to 84 months of imprisonment. Martinez and Lightner appealed their convictions and sentences.The United States Court of Appeals for the Fifth Circuit reviewed the case. Martinez challenged the sufficiency of the evidence for his convictions, but the court found the evidence sufficient to support the jury's verdicts. The court noted that Martinez's involvement with runners and his knowledge of Lightner's prescribing practices indicated his participation in the conspiracy. The court also upheld Martinez's conviction under Pinkerton liability for the substantive count.Lightner raised several issues on appeal, including the jury instructions, alleged spoliation of evidence, and the denial of a motion to strike a witness's testimony. The court found that while the jury instructions contained an error, it did not affect Lightner's substantial rights due to the ample evidence of his unlawful prescribing practices. The court also found no abuse of discretion in the district court's handling of the spoliation claim and the witness testimony.Regarding sentencing, the court upheld the district court's calculations of drug weight and the application of enhancements for maintaining a premises for drug distribution and for Lightner's leadership role in the conspiracy. The court affirmed the district court's judgment in all respects. View "United States v. Martinez" on Justia Law

In 1979, Karu Gene White, along with two accomplices, committed a brutal home invasion and murder of three elderly individuals in Kentucky. White, who had known the victims, planned the crime to steal money they had saved. The victims were beaten to death with a crowbar and other weapons. White was subsequently arrested and charged with burglary, robbery, and capital murder.At trial, White's defense initially focused on an alibi, but this strategy collapsed when one of his accomplices agreed to testify against him in exchange for immunity. White's counsel then pursued an insanity defense, presenting evidence of White's abusive and traumatic childhood. Despite this, the jury found White guilty on all counts and recommended the death penalty, which the trial judge imposed.White appealed his conviction and sentence, but the Kentucky Supreme Court affirmed the decision, and the U.S. Supreme Court denied certiorari. White then sought post-conviction relief, arguing ineffective assistance of counsel for failing to investigate and present mitigating evidence. The Kentucky Supreme Court ultimately rejected this claim, finding that counsel's performance was reasonable and that additional mitigating evidence would not have changed the jury's decision.White filed for federal habeas relief, which was denied by the U.S. District Court for the Eastern District of Kentucky. The court found that counsel's investigation and presentation of mitigating evidence were reasonable and that the Kentucky Supreme Court's application of Strickland v. Washington was not unreasonable. The Sixth Circuit Court of Appeals affirmed this decision, holding that White's counsel's performance was within the wide range of reasonable professional assistance and that there was no substantial likelihood that additional mitigating evidence would have changed the jury's recommendation for the death penalty. View "White v. Plappert" on Justia Law

Nasir Cooper was convicted after pleading guilty to one count of possessing ammunition as a convicted felon, in violation of 18 U.S.C. § 922(g)(1). Cooper was sentenced to 57 months in prison, followed by three years of supervised release, and a $100 mandatory special assessment. Cooper appealed, arguing that the district court erred in classifying his prior conviction for second-degree attempted assault under New York Penal Law § 120.05(7) as a crime of violence under the United States Sentencing Guidelines.The United States District Court for the Southern District of New York determined that Cooper's prior conviction for second-degree attempted assault was a crime of violence, which resulted in a base offense level of 24 under the Sentencing Guidelines. Cooper objected, arguing that the conviction should not be considered a crime of violence, which would have resulted in a lower base offense level of 20. The district court rejected Cooper's argument and sentenced him based on the higher offense level.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 Cooper had waived any argument that his conviction was not under N.Y.P.L. § 120.05(7) by acknowledging it in his sentencing submissions. The court also held that a conviction for second-degree attempted assault under N.Y.P.L. § 120.05(7) categorically constitutes a crime of violence for purposes of U.S.S.G. § 2K2.1(a). The court reasoned that the statute requires the use of physical force capable of causing physical pain or injury, meeting the criteria for a crime of violence under the Guidelines. Consequently, the appellate court found no procedural error in the district court's determination of Cooper's base offense level and affirmed the sentence. View "United States v. Cooper" on Justia Law

The defendant entered into a joint plea agreement covering offenses in both Johnson and Linn Counties. He committed a crime in Linn County first, then committed another crime in Johnson County. He pleaded guilty to a felony and a serious misdemeanor in Johnson County before pleading guilty to a felony in Linn County. The State argued that the defendant was ineligible for a deferred judgment in Linn County because of his prior felony conviction in Johnson County. The defendant contended that he was still eligible since the Linn County crime occurred before the Johnson County felony.The Iowa District Court for Linn County ruled in favor of the State, determining that the defendant was ineligible for a deferred judgment due to his prior felony conviction in Johnson County. The court imposed a suspended sentence and placed the defendant on supervised probation for three years. The defendant appealed the decision, arguing that the statutory language was ambiguous and should be interpreted in line with recidivism statutes, which require each offense to be complete as to conviction and sentencing before the commission of the next offense.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that the language of Iowa Code section 907.3(1)(a)(1) was clear and unambiguous, stating that a defendant is ineligible for a deferred judgment if he has a previous felony conviction. The court found that the statute's text and meaning were clear and did not require further interpretation. Consequently, the court affirmed the district court's ruling that the defendant was ineligible for a deferred judgment in Linn County due to his prior felony conviction in Johnson County. View "State v. Gardner" on Justia Law

Brandon Ruiz was convicted of second-degree sexual abuse in 2018. He was acquitted of six other counts but sentenced to a term not exceeding twenty-five years. Ruiz's conviction was affirmed on direct appeal. He then filed his first postconviction relief (PCR) application, which was denied on the merits by the district court, and this denial was affirmed by the Iowa Court of Appeals. Procedendo was issued on December 10, 2019.Ruiz filed a second PCR application on September 5, 2023, claiming actual innocence and ineffective assistance of both trial and appellate counsel. The State moved to dismiss this application as untimely, and the district court granted the motion, noting that the application was filed after the three-year statute of limitations had expired. Ruiz's appointed counsel did not file any briefs or additional pleadings on his behalf, and the district court dismissed the application without addressing its merits.The Iowa Court of Appeals affirmed the district court's dismissal, with one judge dissenting, arguing that Ruiz was denied effective assistance of PCR counsel. The Iowa Supreme Court reviewed the case and also affirmed the dismissal. The court held that Ruiz failed to preserve his equitable tolling argument and did not present any specific ways that PCR counsel could have prevented the dismissal of his action as time-barred. The court also found that Ruiz's claim of ineffective assistance of PCR counsel did not constitute structural error, as his first PCR application had been reviewed on the merits. Consequently, the court declined to remand the case for further proceedings. View "Ruiz v. State" on Justia Law

Detron L. Perry was convicted of driving under suspension and operating a motor vehicle to avoid arrest. Officer Molly Coon of the Bellevue Police Department stopped Perry's vehicle after observing it driving slowly and discovering that the owner had a suspended license. Coon also noticed that the vehicle's left rear turn signal was not working properly. During the stop, Perry fled the scene, leading to his arrest later.The district court for Sarpy County denied Perry's motion to suppress evidence obtained from the stop, finding that the stop was justified based on the malfunctioning turn signal. Perry was found guilty of both charges. At sentencing, Perry was sentenced to probation, but the court did not impose a mandatory 2-year license revocation as required by Neb. Rev. Stat. § 28-905(3)(b).The Nebraska Supreme Court reviewed the case and affirmed the district court's denial of Perry's motion to suppress, finding that the stop was reasonable based on the observed traffic violation. The court also found sufficient evidence to support Perry's convictions for driving under suspension and operating a motor vehicle to avoid arrest. However, the Supreme Court concluded that the district court committed plain error by not imposing the mandatory 2-year license revocation or impoundment as required by § 28-905(3)(b).The Nebraska Supreme Court affirmed Perry's convictions but vacated the sentence and remanded the case for resentencing to include the mandatory 2-year license revocation or impoundment. View "State v. Perry" on Justia Law