Justia Criminal Law Opinion Summaries

Plaintiffs filed suit under 42 U.S.C. 1983 for claims arising out of their son's death. The district court granted summary judgment on the basis of qualified immunity against their claims that law enforcement personnel used excessive force in restraining him. Plaintiffs appealed and argued that the use of a four-point restraint in this case was excessive force and defendants were not entitled to qualified immunity. The court held that the treatment of plaintiffs' son did not violate a clearly established right and consequently, defendants were protected by qualified immunity even if their conduct constituted excessive force.

Defendants were convicted of bank robbery by force or violence and aiding and abetting the commission of bank robbery by force or violence. Both defendants appealed the denial of their motions to sever and argued that there was insufficient evidence to support the guilty verdict. Additionally, defendant Kirkwood appealed the denial of her motion for a mistrial. The court held that the district court did not abuse its discretion when it denied Kirkwood's motion to sever, defendant Owen's motion to sever, and Kirkwood's motion for a mistrial. The court also held that there was sufficient evidence to support the jury's decision to convict both defendants. Accordingly, the court affirmed the convictions.

Defendant was sentenced to death for the murder of a fellow inmate and subsequently appealed his conviction and sentence. Defendant raised several issues on appeal, including errors surrounding another inmate's dismissal; evidentiary errors at the guilt/innocence phase; prosecutorial misconduct throughout the trial; sentencing errors; and post-trial error. The court addressed each category of issues separately, ultimately affirming defendant's convictions and death sentence. The court also affirmed the district court's denial of defendant's motion for a new trial.

Months before his criminal trial, petitioner moved to dismiss his appointed counsel in exercise of his constitutional right to represent himself under Faretta v. California. The trial court denied the motion and petitioner was subsequently convicted. On direct appeal, a state appellate court reversed the conviction due to the denial of petitioner's right to self-representation, but the court then granted rehearing, and a five-judge panel affirmed petitioner's conviction and sentence. Petitioner subsequently filed a habeas corpus application in federal district court under 18 U.S.C. 2254, and the court granted relief. The court concluded that petitioner made a clear and unequivocal invocation of his Sixth Amendment right to represent himself and that the state trial court erroneously denied his request in violation of Faretta. The state court's implicit finding of waiver was unreasonable in light of the evidence presented in the state court proceeding. Therefore, the court affirmed the district court's grant of habeas relief.

Petitioner, convicted of capital murder and sentenced to death in Texas state court, appealed the district court's denial of his habeas petition in federal district court pursuant to 28 U.S.C. 2254. At issue was whether the state withheld impeachment evidence from petitioner in violation of Brady v. Maryland. The court held that the state court did not unreasonably apply Brady in holding that the evidence at issue was immaterial. Petitioner's remaining claims were foreclosed by precedent and the court denied his request for a certificate of appealability as to each of these issues. Accordingly, the court affirmed the judgment.

Defendants appealed their conviction of and sentencing for false reporting of natural gas trades in violation of the Commodities Exchange Act (CEA), 49 U.S.C. 1491, and the federal wire fraud statute. The government alleged that defendants violated the CEA and the wire fraud statute by sending false information about natural gas prices to trade magazines that reported natural gas prices in indexes, in an effort to affect and manipulate those indexes, which, in turn, would affect the market for natural gas futures and benefit the company's financial positions. The court held that defendants failed to show clear error in the district court's factual findings, and under those facts, the court found that denial of the motion to dismiss the indictment was proper; the CEA covered no constitutionally protected speech; beyond the issue of whether the means rea applied to the final element of the false reporting offense - which the court was confident was harmless if it was erroneous - the court found no errors in the jury instructions and held that the cumulative error doctrine did not require reversal; defendants' argument that the district court erred by denying their motion for acquittal because they were convicted for answering fundamentally ambiguous questions was rejected; in regards to defendants' claims of evidentiary error, the district court did not err; and because the court found defendants' arguments unavailing, the court affirmed the sentences.

Petitioner was convicted of possession or transportation of anhydrous ammonia, a chemical used in manufacturing methamphetamine, in a container or receptacle not designed or manufactured for the storage or transport of anhydrous ammonia. The district court subsequently granted defendant habeas relief under 28 U.S.C. 2254 because the reporter for the state trial court lost her notes, impairing resolution of the prisoner's challenges to his conviction. The court was persuaded that the district court could likely have reconstructed an adequate record and vacated the grant of relief, remanding for further proceedings.

Defendants were charged with knowingly violating the Clean Water Act, 33 U.S.C. 1251 et seq., and were convicted on multiple counts. Defendant Pruett, through LLWC and LWC Management, was responsible for the operation of 28 wastewater treatment facilities in northern Louisiana. The court concluded that section 1319(c)(1)(A) of the Act required only proof of ordinary negligence and thus held that the district court's jury instructions were proper; the district court did not err in admitting Rule 404(b) evidence at issue; the district court did not abuse its discretion in admitting negative character evidence; the district court properly ruled that a government witness's prior conviction was not admissible under Rule 609(a)(2); the district court was within its discretion to excuse Juror No. 8 and replace him with an alternate; the district court did not clearly err in concluding that Pruett used his position as the president and CEO of LLWC and LWC Management to facilitate the commission of the offenses and therefore, did not err in applying the U.S.S.G. 3B1.3 enhancement; and the fines imposed on defendants were reasonable. Accordingly, the convictions and sentences were affirmed.

Petitioner was convicted of capital murder and sentenced to death. The district court subsequently rejected his petition for habeas relief, but granted him a certificate of appealability to pursue three claims arising from his sentencing hearing dealing with, respectively, the restrictions on his expert's testimony, the alleged ineffective assistance of his trial counsel in failing to object to victim impact testimony, and the restriction on execution impact testimony. The court held that petitioner's first claim was procedurally defaulted and, alternatively, failed on the merits. Petitioner's ineffective assistance claim also failed on the merits, and his execution impact claim was procedurally barred. Therefore, the court affirmed the denial of habeas relief.

Defendant pleaded guilty to a one-count indictment charging him with attempting to reenter the United States unlawfully after removal. At sentencing, the district court enhanced his offense level by sixteen levels based on its conclusion that his prior Arkansas conviction for aggravated assault was a conviction for a crime of violence within the meaning of U.S.S.G. 2L1.2(b)(1)(A)(ii). The court held that defendant was not convicted of "aggravated assault" for sentencing enhancement purposes because his crime of conviction lacked proof of an underlying assault. Because the government had not shown that such error was harmless under the court's precedent, the court vacated the sentence and remanded for resentencing.