Justia Criminal Law Opinion Summaries

Defendant, a business owner, appealed his sentence after being convicted of bribing a state official in order to ensure that his company would continue to receive government contracts. Over a period of four years, defendant doled out over $600,000 in bribes and his company reaped over $5 million in profits as a result of the corrupt payments. The court concluded that the concurrent three-year probationary sentences were substantively unreasonable given the factors set forth in 18 U.S.C. 3553(a): (1) the sentences convey the message "that would-be white-collar criminals stand to lose little more than a portion of their ill-gotten gains and practically none of their liberty," and accordingly do not constitute just punishment for defendant's offenses or promote respect for the law; (2) the sentences do not provide general deterrence; and (3) the sentences were not required to eliminate any sentencing disparity among similarly situated offenders because no such disparity existed. Accordingly, the court vacated and remanded. View "United States v. Hayes" on Justia Law

Defendant appealed his conviction for charges related to enticement of a minor to engage in sexual activity and possession of child pornography. Defendant alleged that his criminal conviction was obtained in violation of the Sixth Amendment and the Supreme Court's holding in United States v. Cronic. The court concluded that defendant was denied counsel at a critical stage because defendant was a sole defendant during his criminal trial; the afternoon session of defendant's trial commenced while his counsel was actually and physically absent; and during that absence, evidence directly inculpating defendant in a crime for which he was eventually convicted was presented to the jury. Accordingly, the court reversed defendant's conviction as to all counts and remanded for a new trial. View "United States v. Roy" on Justia Law

Petitioner, convicted of capital murder and sentenced to death, appealed the district court's denial of his petition for a writ of habeas corpus. The court concluded that the record supported the state courts' fact findings regarding petitioner's defense team having access to the information in the Holt and Luce statements; the state courts' conclusions as to the non-exculpatory nature of the Brown statement, and the Luce statement for that matter, were not unreasonable applications of Brady v. Maryland; and, therefore, the court deferred to the state courts' adjudications of petitioner's claims about the statements. The court also concluded that petitioner failed to establish that he received ineffective assistance of counsel under Strickland v. Washington and rejected petitioner's aggravating circumstances claim. Accordingly, the court affirmed the judgment of the district court. View "Wright v. Secretary, FL DOC" on Justia Law

Petitioner, a death row inmate, appealed the district court's denial of his petition for writ of habeas corpus after a federal evidentiary hearing. The court carefully reviewed the record and considered the totality of the relevant circumstances bearing on the ultimate question of whether the prosecutor excused even a single black juror based on race, and the court concluded that there are two plausible views of the evidence, both of which have some support. The court deferred to the district court's credit of the prosecutor's race-neutral explanations for striking the six black jurors and rejected petitioner's arguments that the prosecutor's reasons were pretextual. Accordingly, the court denied petitioner's Batson and Fourteenth Amendment claims and affirmed the judgment of the district court. View "Madison v. Commissioner, AL DOC, et al." on Justia Law

Petitioner, convicted of first degree murder and sentenced to death, appealed the district court's denial of his 28 U.S.C. 2254 petition for a writ of habeas corpus. The court rejected petitioner's claim that trial counsel rendered ineffective assistance of counsel in the investigation and presentation of mitigation evidence during the penalty phase, and concluded that petitioner failed to show that the state court's decision was an unreasonable application of clearly established federal law or based on an unreasonable determination of the facts. Accordingly, the court affirmed the judgment of the district court. View "Mendoza v. Secretary, FL DOC" on Justia Law

Defendant appealed his conviction for receipt of child pornography by computer over the internet. The court concluded that the search of the computers was valid because, despite the infirmities that the district court detected in defendant's consent to search the computers, his wife consented to a full search of the computers and defendant failed to show that the search violated his rights under Georgia v. Randolph. Accordingly, the court affirmed the judgment of the district court. View "United States v. Watkins" on Justia Law

Petitioner, convicted of first degree murder and sexual battery, appealed the district court's denial of habeas relief. The court concluded that the state court's refusal to grant relief based on the exclusion of the victim's sisters' proffered testimony was neither contrary to nor an unreasonable application of clearly established Supreme Court law. Further, petitioner failed to establish that the state court's determination about trial counsel's performance, regarding counsel calling petitioner to testify at trial and having him reenact the murder, was contrary to or an unreasonable application of Strickland v. Washington. Accordingly, the court affirmed the judgment of the district court. View "Taylor v. Secretary, FL Dept. of Corrections" on Justia Law

Petitioner, proceeding pro se, appealed the denial of his 28 U.S.C. 2241 petition for writ of habeas corpus. Petitioner contended that the district court erred in ruling that he could not rely on Alleyne v. United States to attack his sentence on collateral review. The court concluded that even if petitioner demonstrated the five requirements under Bryant v. Warden, FCC Coleman-Medium, petitioner's claim is without merit where the Alleyne Court's holding did not upset its previous ruling that the fact of a prior conviction is not an "element" that must be found by a jury. Accordingly, the court affirmed the judgment of the district court. View "Jeanty, Jr. v. Warden, FCI - Miami" on Justia Law

Petitioner, a death row inmate, appealed the denial of his petition for writ of habeas corpus under 28 U.S.C. 2254. The court concluded that the state court's conclusion that trial counsel did not provide ineffective assistance during the guilt phase was not an unreasonable application of or contrary to Strickland v. Washington. The court concluded, however, that the state court unreasonably applied Strickland in holding that the omitted mitigation evidence in this case had no reasonable probability of reducing petitioner's sentence. Because of trial counsel's deficient performance, petitioner's jury was given almost no reason to spare his life as demonstrated by the paucity of the mitigating evidence actually presented during the penalty phase and the fact that the state trial court found only one mitigating circumstance. Accordingly, the court affirmed in part, reversed in part, and remanded. View "DeBruce v. Commissioner, AL DOC" on Justia Law

Defendant, convicted of illegal reentry, appealed the district court's application of a 16-level guideline enhancement under U.S.S.G. 2L1.2(b)(1)(A)(ii). The court concluded that defendant's conviction under Fla. Stat. 790.19 for wantonly or maliciously throwing, hurling, or projecting a missile, stone, or other hard substance at an occupied vehicle did not constitute a crime of violence for purposes of the Guidelines. Accordingly, the court reversed and remanded for resentencing. View "United States v. Estrella" on Justia Law