Justia Criminal Law Opinion Summaries

Defendants appealed their convictions on several counts of money laundering and conspiracy to commit money laundering principally on the basis that the evidence at trial was insufficient to establish that the proven transactions involved proceeds of specified unlawful activity, namely drug trafficking. The court agreed and held that the government did not meet its burden of showing that the funds transferred were proceeds to drug trafficking or anything other than payment of the purchase price for drugs. Accordingly, the evidence was insufficient to support the convictions for money laundering.

Petitioner pled guilty to capital murder and was sentenced to death. Petitioner sought post-conviction relief from the Texas courts, alleging that he was mentally retarded, and his execution would therefore be unconstitutional. The Texas trial court and the Court of Criminal Appeals determined that petitioner was not mentally retarded. Petitioner subsequently applied for a writ of habeas corpus under 28 U.S.C. 2254 and the federal district court denied relief. The court held that the state's legal conclusions neither contradicted nor unreasonably applied federal law, nor were its factual conclusions unreasonable in light of the evidence presented in the state proceeding. Accordingly, the court affirmed the denial of habeas relief.

In this consolidated case, the court addressed the appeals of five individuals and one corporate defender convicted of conspiracy and substantive offenses for providing material aid and support to a designated terrorist organization. Defendants were charged with aiding Hamas by raising funds through the corporate entity Holy Land Foundation for Relief and Development, a Texas-based, pro-Palestinian charity that the Government charged was created for the sole purpose of acting as a financing arm for Hamas. Defendants raised a host of issues challenging both their convictions and their sentences, including numerous errors that they claimed deprived them of a fair trial. The court concluded from its review of the record, briefs, and oral argument, that defendants were fairly convicted. Therefore, the court affirmed the district court's judgments of conviction of the individual defendants and dismissed the appeal of the Holy Land Foundation.

Defendant was convicted of two counts of attempted first degree murder, one count of possession with intent to distribute cocaine, and one count of aggravated battery, and was sentenced to four concurrent terms of imprisonment. Subsequently, a life sentence on the first count of attempted first degree murder was imposed due to defendant's status as a habitual offender. Defendant's conviction was affirmed on direct appeal and state habeas relief was denied. Defendant filed a petition for writ of habeas corpus, raising several grounds for relief, including a violation of the Double Jeopardy Clause. The district court denied relief and the court granted a certificate of appealability as to defendant's double jeopardy claim only. The court held that the Louisiana Fifth Circuit Court of Appeal's decision regarding defendant's double jeopardy claim was neither contrary to, nor involved an unreasonable application of, clearly established federal law, as determined by the Supreme Court. The decision also did not involve "an unreasonable determination of the facts in light of the evidence presented in the State court proceeding." Accordingly, the district court properly denied defendant's petition for a writ of habeas corpus and the judgment was affirmed.

Plaintiffs, Mr. and Ms. Jimenez, sued the County under 42 U.S.C. 1983, alleging constitutional violations stemming from their arrests. Ms. Jimenez claimed that, because she was arrested for a minor offense, she could be strip-searched only upon reasonable suspicion that she was concealing weapons or contraband. The jury ultimately returned a verdict for Ms. Jimenez, the court entered a final judgment against the County, awarding Ms. Jimenez for past and future mental anguish, as well as punitive damages. The County appealed and a panel of the court affirmed. The court granted rehearing en banc and vacated the panel opinion. Because the County had not demonstrated reversible error in the jury instructions in this case, the court affirmed the judgment of the district court. The court reinstated Parts III, IV, and V of the panel opinion, which rejected other arguments that the County had not urged on rehearing.

Petitioner appealed the dismissal of his habeas petition as untimely filed under the Antiterrorism and Effective Death Penalty Act (AEDPA), 28 U.S.C. 2244(d). Petitioner argued that the court should treat his petition as having been timely filed because his prior unsuccessful effort to mail a habeas petition through his prison mail room, prior to the expiration of the one-year statute of limitations, entitled him to the benefits of the mailbox rule or equitable tolling of the statute of limitations. The court held that petitioner attempted to mail his petition in a manner consistent with the mail regulations, and that he was prevented from doing so because prison mail room officials wrongfully returned it for failure to comply with a nonexistent prison mail regulation. Accordingly, the court agreed that petitioner should have been afforded the benefit of the mailbox rule and that his petition should have been considered timely filed. Therefore, the court reversed the dismissal of the petition and remanded to the district court for further proceedings.

Defendant appealed his sentence of 27 months imprisonment and three years of supervised release for illegal reentry after deportation. The court affirmed the judgment of the district court and held that the staleness of a prior conviction in the proper calculation of a guidelines-range sentence did not render a sentence substantively unreasonable and did not destroy the presumption of reasonableness that attached to such sentences. The court also rejected defendant's contention that the district court erred in failing to accord proper weight to his cultural assimilation.

Petitioner pleaded guilty to one count of possession of cocaine with intent to distribute and one count of felony possession of a firearm. Petitioner, proceeding pro se, subsequently filed two petitions for habeas relief pursuant to 28 U.S.C. 2241, which the district court consolidated, construed as a second or successive section 2255 motion and transferred to this court. Petitioner appealed the district court's order. Petitioner also filed a motion for a Certificate of Appealability or, in the alternative, a motion for authorization to file a successive section 2255 motion. After first determining sua sponte that the court had jurisdiction over the appeal, the court affirmed the district court's transfer order and denied the motion for authorization to file a successive section 2255 motion.

Defendant, the Commissioner of the Mississippi Department of Corrections (MDOC), was found liable under 42 U.S.C. 1983 for violating plaintiff's constitutional rights by unlawfully incarcerating him for fifteen months beyond the expiration of his sentence. Defendant appealed the district court's denial of his motion for judgment as a matter of law, or in the alternative, motion for a new trial. The court held that because defendant was entitled to qualified immunity where no reasonable jury could have found that defendant's conduct was objectively unreasonable. Accordingly, the court reversed the judgment of the district court.

Defendant was convicted for being a felon in possession of a firearm and subsequently appealed the district court's denial of his motion to suppress a firearm uncovered during a warrantless automobile search by a trooper. The court held that because the trooper unconstitutionally prolonged defendant's detention by asking irrelevant and unrelated questions without reasonable suspicion of criminal activity, the court reversed and vacated the judgment of conviction, remanding the case for entry of a judgment of acquittal.