Justia Criminal Law Opinion Summaries

Defendant appealed the district court's denial of his motion to suppress a firearm on the basis that it was the fruit of an unlawful seizure of his person. The court concluded that defendant was seized when his ID was retained while his companions were frisked. The totality of the factors outlined by the district court - an individual's presence at a gas station; prior arrest history of another individual; lawful possession and display of a firearm by another; defendant's submission of his ID showing an out-of-district address; all of which occurred in a high crime area at night - failed to support the conclusion that the officer had a reasonable suspicion to detain defendant. Therefore, the court held that there was no reasonable suspicion justifying defendant's seizure and the district court erred in denying his motion to suppress. Accordingly, the court reversed and vacated defendant's conviction and sentence. View "United States v. Black" on Justia Law

Defendant pleaded guilty to distributing five or more grams of crack cocaine. On appeal, defendant argued that the district court incorrectly calculated the applicable Sentencing Guidelines range and imposed an "illegal" and substantively unreasonable sentence. Defendant also contended that the district court's denial of his motion to continue his sentencing hearing was an abuse of discretion. The court granted the government's motion to dismiss with regard to the sentencing issues that fell within the scope of defendant's valid appeal waiver and affirmed as to his contentions regarding the continuance where the district court's denial was neither unreasonable nor arbitrary. View "United States v. Copeland" on Justia Law

Defendant appealed his conviction and capital sentence for conspiracy to commit murder-for-hire, among other charges stemming from the same course of events. The court rejected defendant's assertion that both the federal murder-for-hire statute and the federal carjacking statute were unconstitutional. The court held that there was sufficient evidence to convict defendant under both statutes. The court considered defendant's challenge of the nonstatutory aggravating factors submitted to the jury and the prosecutor's efforts to prove them; defendant's challenge of various statements made by the prosecution during the closing arguments of the penalty selection phase; and defendant's challenges of a number of other aspects of his sentencing proceeding on both constitutional and statutory grounds. The court found defendant's challenges unconvincing and affirmed the judgment. View "United States v. Runyon" on Justia Law

Defendant was charged with possession of an unregistered firearm. A law enforcement officer, responding to an armed domestic dispute, entered a locked closet without a search warrant, arrested defendant, removed him from the residence, and gained information that indicated that a grenade may have been present in the closet. At issue was whether the district court properly excluded evidence gained from the warrantless search. The court concluded that exigent circumstances did not exist to justify the warrantless search in this case and therefore, the evidence obtained from such a search was properly excluded. View "United States v. Yengel, Jr." on Justia Law

Defendant was convicted of interstate domestic violence and attempted witness intimidation. On appeal, defendant contended that the district court erred by declining to suppress certain aspects of the government's evidence stemming from his cell-mate's activities after speaking to the police which, defendant alleged, were obtained in deprivation of his Sixth Amendment right to assistance of counsel. The court concluded that no acts imputable to the State worked any deprivation of defendant's Sixth Amendment right to counsel with respect to the federal charges of which he stood convicted. The court held, however, that a substantial question remained as to whether those same acts contravened defendant's Fifth Amendment rights. The court held that remand was unnecessary in this instance because any Fifth Amendment error was harmless beyond a reasonable doubt and affirmed the convictions. View "United States v. Holness" on Justia Law

Petitioner appealed from the district court's denial of his petition for a writ of coram nobis, filed pursuant to the All Writs Act, 28 U.S.C. 1651(a). The petition alleged that the Supreme Court's decision in Skilling v. United States required vacatur of petitioner's 1994 mail fraud convictions in the District of Maryland. The district court concluded that no relief could be granted even though petitioner's honest services fraud scheme did not involve bribery or kickbacks. Because petitioner would not be entitled to relief on direct appeal under Skilling, the court concluded that the fourth prerequisite for coram nobis relief - identification of "an error of the most fundamental character" - was not satisfied. Accordingly, an award of the "extraordinary" remedy of coram nobis relief was unwarranted. View "Bereano v. United States" on Justia Law

Plaintiffs filed an amended complaint under 42 U.S.C. 1983, alleging that the conduct of police officers lead to their son's death, violating his Fourth Amendment rights. The court held that all three officers involved in the incident were entitled to qualified immunity and awarded summary judgment in their favor. The court held that the district court did not err in concluding that two of the officers were entitled to qualified immunity, but that the district court erred in awarding summary judgment in favor of the officer who repeatedly activated his taser at plaintiffs' son. Accordingly, the court affirmed in part and reversed in part. View "Meyers, Sr. v. Baltimore County, Maryland" on Justia Law

Petitioner, a citizen of El Salvador, sought discretionary relief from his removal under the Nicaraguan Adjustment and Central American Relief Act (NACARA), Pub. L. No. 105-100, 111, Stat. 2160, 2198. The BIA found petitioner ineligible for relief because he was unable to demonstrate that his 1996 Virginia conviction for assault and battery was not a crime of violence. The court concluded that the Illegal Immigration Reform and Immigrant Responsibility Act of 1996's, 8 U.S.C. 321(c), retroactive application of the revised definition of "aggravated felony" survived petitioner's constitutional challenges. The court also held that the government had demonstrated that petitioner's removability and petitioner had failed to demonstrate that he was eligible for discretionary relief from removal, as afforded by NACARA. Accordingly, the court denied his petitions for review. View "Mondragon v. Holder, Jr." on Justia Law

Plaintiff, a Virginia inmate, filed suit under 42 U.S.C. 1983 against defendants. Plaintiff is a pre-operative transsexual suffering from a diagnosed and severe form of a rare, medically recognized illness known as gender identity disorder (GID). She alleged that, in light of defendants' knowledge of her ongoing risk of self-mutilation, defendants' continued denial of consideration for sex reassignment surgery constituted deliberate indifference to her serious medical need in violation of the Eighth Amendment. The district court dismissed the complaint for failure to state a claim. The court concluded, however, that plaintiff's complaint stated a claim for relief that was plausible on its face and therefore, the court reversed the judgment of the district court and remanded for further proceedings. View "De'Lonta v. Johnson" on Justia Law

Plaintiff, a permanent resident alien and federal inmate, appealed the dismissal of his action under 8 U.S.C. 1503(a) for a judgment declaring him a United States national. Petitioner has resided in the United States since the age of eleven and has been a permanent resident for almost twenty-five years. Petitioner alleged that he was a United States national because he applied for citizenship, registered for the Selective Service, and declared his permanent allegiance to various United States officials. The court held that these facts failed to allege United States nationality under section 1503(a) and affirmed the dismissal of his action. Petitioner could not state a claim to be a United States national under United States v. Morin because the court must defer to the BIA's contrary, post-Morin interpretation of section 1101(a)(22). View "Patel v. Napolitano" on Justia Law