Justia Criminal Law Opinion Summaries

Petitioner, a Texas death row inmate, filed a state petition for clemency and his execution has been stayed by the Texas courts. Petitioner then moved the federal district court to allow funds to hire a mitigation specialist. The court affirmed the district court's denial of petitioner's motion where he had not demonstrated that the funds he requested for investigative services are reasonably necessary for clemency proceedings. Accordingly, the court did not abuse its discretion by denying the requested funds. View "Brown, Jr. v. Stephens" on Justia Law

Keith Thompson was killed when a county sheriff ended a two-hour high-speed chase by firing an assault rifle into the vehicle Keith had stolen. Plaintiffs, Keith's parents, filed suit against the sheriff and the County under 42 U.S.C. 1983, alleging that the sheriff used excessive force. On appeal, plaintiffs challenged the district court's grant of defendants' motion for summary judgment. The court concluded that there was no constitutional violation in the sheriff's use of deadly force and he was entitled to qualified immunity. Because there was no Fourth Amendment violation of the seizure of Keith, plaintiffs' section 1983 claims failed as a matter of law. Accordingly, the court affirmed the judgment of the district court. View "Thompson, et al. v. Mercer, et al." on Justia Law

Andres Sanchez-Espinal appealed his sentence and term of supervised release for being unlawfully present in the United States after deportation following a felony conviction. The court held that Sanchez-Espinal's prior violation of subsection (1) of New York's aggravated criminal contempt statute, section 215.52(1), is a crime of violence. Therefore, it constituted an aggravated felony warranting the application of an eight-level enhancement. Accordingly, the court affirmed the judgment of the district court. View "United States v. Sanchez-Espinal" on Justia Law

Defendant conditionally pled guilty to possession of marijuana with intent to distribute. On appeal, defendant challenged the district court's denial of his motion to suppress evidence. The court concluded that sufficient reasonable suspicion existed to justify an investigatory stop under Terry v. Ohio, which augmented the right to investigate that arose from the airport ramp check; the justification under Terry to hold defendant ended when an agent arrived; and the prolonged detention was close enough to the line of validity that an objectively reasonable officer preparing the affidavit for the warrant would believe in the validity of the prior conduct. The court also concluded that the warrant executed by the agent was properly obtained and executed under the Leon good faith exception. Accordingly, the court affirmed the judgment of the district court. View "United States v. Massi" on Justia Law

Petitioner was convicted of robbery and murder and sentenced to death. After the district court denied his petition for writ of habeas corpus, petitioner sought a certificate of appealability (COA) under 28 U.S.C. 2253(c)(2). The court rejected petitioner's eight claims asserting that his trial counsel was ineffective because reasonable jurists could not debate the district court's conclusion that the state courts did not unreasonably apply Strickland v. Washington. In regards to petitioner's ninth and final claim asserting that he is intellectually disabled and is ineligible for the death penalty under Atkins v. Virginia, the court concluded that reasonable jurists could not debate the district court's resolution of petitioner's claim of intellectual ability. Accordingly, the court denied the COA request. View "Williams v. Thaler" on Justia Law

Petitioner, convicted of murder and sentenced to death, appealed the district court's denial of habeas relief. Petitioner sought a certificate of appealability on nine claims: (1) ineffective assistance of counsel; (2) waiver of counsel; (3) cross-examination of a government witness; (4) Brady claims; (5) actual innocence; (6) coercive Allen charge; (7) security procedures at trial; (8) cumulative errors; and (9) failure to grant discovery or hold an evidentiary hearing. The court addressed each claim and held that reasonable jurists could not debate the district court's conclusions. Accordingly, the court denied petitioner's request for a certificate of appealability. View "United States v. Fields" on Justia Law

Defendant appealed his sentence for his involvement in a plan to kidnap a group of undocumented aliens from an alien smuggling-organization in an attempt to extort monies from the family members of the aliens. The court concluded that the district court did not plainly err in applying the ransom enhancement, the vulnerable victim enhancement, and the minor victim enhancement to defendant's sentence. The court also concluded that defendant's sentence of 180 months of imprisonment was substantively reasonable. Accordingly, the court affirmed the sentence. View "United States v. Cedillo-Narvaez" on Justia Law

Defendants Wallace and Blocker appealed the jury's verdict finding them guilty on all counts of an indictment charging conspiracy and drug offenses, and the district court's rulings. The court concluded that a reasonable jury could find that defendants were guilty of the charged conspiracy and affirmed defendants' convictions as to that count; the district court did not abuse its discretion by allowing the government to present evidence of defendants' prior bad acts; Wallace's challenge to the government's notice and ultimately the district court's application of the 21 U.S.C. 851(a) sentencing enhancement was without merit; the district court did not commit plain error by finding that defendants were previously convicted of drug felonies or by sentencing them accordingly; and the court declined to address the merits of Blocker's ineffective assistance of counsel claims on direct appeal. Accordingly, the court affirmed defendants' convictions and sentences. View "United States v. Wallace" on Justia Law

Petitioner, convicted of capital murder of his mother, appealed the denial of his federal habeas petition and denial of a certificate of appealability (COA). The court concluded that petitioner's first claim involving allegations of ineffective assistance at the punishment phase of trial did not warrant full consideration on the merits; petitioner procedurally defaulted on his second claim involving allegations of ineffective assistance at the guilt phase of the trial; and, even assuming arguendo that petitioner had not procedurally defaulted on that claim, the claim did not warrant a COA. Accordingly, the court denied the application for a COA. View "Beatty v. Stephens" on Justia Law

Defendant appealed his conviction for failure to register as a sex offender, contending that he was not required to register because his Wisconsin conviction for having sexual intercourse with a child age sixteen or older does not qualify as a "sex offense" within the meaning of the Sex Offender Registration and Notification Act (SORNA), 42 U.S.C. 16901 et seq. The court concluded that, based on the language, structure, and broad purpose of SORNA, Congress contemplated a non-categorical approach to the age-differential determination in the section 16911(5)(C) exception; the district court properly found that the (5)(C) exception does not apply and that defendant was required to register as a sex offender; defendant's contention that SORNA's criminal penalty and civil registration requirement exceeded Congress's power under the Commerce Clause was foreclosed by United States v. Whaley; and, therefore, the court affirmed the judgment of the district court. View "United States v. Gonzalez-Medina" on Justia Law