Justia Criminal Law Opinion Summaries

Defendant appealed from his conviction after pleading guilty to conspiracy to violate the narcotics laws of the United States. Because the court concluded that the waiver of appeal was valid and that the relevant change in law caused by Dorsey v. United States did not affect a valid waiver of appeal, the court affirmed the judgment. View "United Statesv. Snyder (Harrison)" on Justia Law

Defendant appealed her convictions for attempted murder of United States nationals, attempted murder of United States officers and employees, armed assault of United States officers and employees, assault of United States officers and employees, and use of a firearm during a crime of violence. Defendant also challenged her sentence of 86 years imprisonment. The court held that the district court did not err in denying defendant's motion to dismiss Count One of the indictment; the district court appropriately denied defendant's motion to dismiss Counts Two through Seven of the indictment; the district court did not commit reversible error by admitting, under Federal Rule of Evidence 404(b), documents allegedly found in her possession at the time Afghan officials took her into custody; the district court did not err in allowing defendant to testify in her own defense; the district court did not err in allowing the government to rebut her testimony with un-Mirandized statements she gave to the FBI; and the district court did not err in applying the terrorism enhancement under U.S.S.G. 3A1.4. Accordingly, the court affirmed the convictions and sentence. View "United States v. Siddiqui" on Justia Law

Defendant appealed from a conviction and sentence for the production and distribution of child pornography. The court held that the district court did not err in determining that defendant did not invoke his right to counsel during an interrogation and that the sentence was procedurally and substantively reasonable. View "United States v. Oehne" on Justia Law

The government appealed from the district court's order suppressing evidence found following the stop and subsequent search of a vehicle driven by defendant. The vehicle stop was executed by two officers of the St. Regis Mohawk Police Department (SRMPD), one of whom was also cross-designated as a U.S. customs officer by ICE. The district court held that the vehicle stop violated the Fourth Amendment because the officers lacked the authority to act as law enforcement officers at the time of the stop. The court held that the violation of the ICE policy requiring prior authorization did not affect the constitutionality of the stop under the Fourth Amendment and that the stop and subsequent search comported with the Fourth Amendment because they were justified by probable cause. Accordingly, the court reversed the decision of the district court. Because the court determined that the stop was a constitutional exercise of designated customs authority, the court did not decide whether the stop was also a constitutional exercise of New York police authority. View "United States v. Wilson" on Justia Law

The State of New York appealed from the district court's grant of defendant's petition for a writ of habeas corpus, vacating his convictions for robbery and burglary, and barring the State from retrying him. The state argued that, because defendant has a full and fair opportunity to litigate his Fourth Amendment claim in state court, federal habeas relief was not available. Because the State failed to raise this non-jurisdictional argument in the district court, the court declined in the exercise of its discretion to consider it for the first time on appeal. The court agreed with the district court that the state court's determination that the victim's in-court identification derived from a source independent of a tainted lineup constituted an unreasonable application of, and was contrary to, clearly established Supreme Court law. Finally, although the court concluded that the in-court identification substantially and injuriously influenced the jury's deliberations, and while the court shared the district court's doubt whether the circumstantial evidence was legally sufficient to convict defendant without it, such doubt must be resolved if at all by the state court. Accordingly, the court vacated that portion of the district court's judgment barring the State from retrying defendant, but affirmed its vacatur of defendant's convictions. View "Young v. Conway" on Justia Law

Defendant, convicted of substantive and conspiratorial bank fraud and tax crimes, appealed from an amended judgment resentencing him to four months' imprisonment after he was found to have willfully violated probation by failing to pay ordered restitution. Defendant, who declared bankruptcy after his initial sentencing, submitted that the automatic stay provision of the United States Bankruptcy Code, 11 U.S.C. 362(a), temporarily halted his obligation to pay restitution and barred the district court from revoking his probation of nonpayment. At issue was what effect, if any, the Bankruptcy Code's automatic stay provision had on court-ordered conditions of a criminal sentence or proceedings to address violations of those conditions. The court concluded that such orders and proceedings fell within an express exception to the automatic stay because they constituted a "continuation of the criminal action or proceeding." Defendant's alternative argument was meritless. The court dismissed the part of defendant's appeal that asked the court to modify the amended judgment to clarify that he was under no obligation to pay restitution while incarcerated, because it was unripe for adjudication. View "United States v. Colasuonno" on Justia Law

Defendant appealed from a Memorandum and Order of Restitution by the district court resentencing him to pay restitution to the victims of a massive "pump-and-dump" securities fraud scheme he and his co-conspirators designed and executed. Defendant contended, inter alia, that the district court should have released some or all of defendant's money held by the court pending his resentencing. The court held that a district court could exercise its authority under the All Writs Act, 28 U.S.C. 1651(a), to restrain a convicted defendant's funds in anticipation of sentencing. Therefore, the court affirmed the restitution order. View "United States v. Catoggio" on Justia Law

Respondents, New York authorities, appealed from the district court's grant of a writ of habeas corpus to petitioner. The district court held that the New York Court of Appeals erred in concluding that the state trial court permissibly barred cross-examination of the main prosecution witness on the issue of whether she had accused petitioner of the crimes in question only after being told that petitioner had accused her. On appeal, respondents argued that petitioner's Confrontation Clause rights were not violated and that even if they were, any violation was harmless. The court agreed that no Confrontation Clause violation occurred and therefore reversed the judgment. View "Corby v. Artus" on Justia Law

Defendant, who stands indicted for substantive and conspiratorial drug crimes, and who, having been arraigned, has been detained with no trial date set, appealed from an order denying him bail pending trial. The court concluded that the district court properly applied the court's test for due process review of pretrial detention and that its findings of fact were not clearly erroneous. Therefore, the court affirmed the detention order without prejudice to defendant's moving the court to recall the mandate and reinstated his appeal if the district court did not begin defendant's trial, or set reasonable bail for him by a certain date. View "United States v. Brigg" on Justia Law

Defendant, a former police officer, appealed the district court's judgment, awarding compensatory and punitive damages to plaintiff on his claim of excessive force and battery. The court concluded that the district court did not exceed its discretion in refusing to grant a continuance because the court's decision was neither arbitrary nor prejudicial to defendant's defense. The court agreed, however, with defendant that the punitive damages award was excessive and concluded that a reduced award would more accurately reflect the severity of defendant's misconduct. View "Payne v. Jones" on Justia Law