Justia Criminal Law Opinion Summaries

Petitioner, convicted of first-degree felony murder and attempted first-degree premeditated murder, appealed the district court's denial of his petition for writ of habeas corpus under 28 U.S.C. 2254. The court rejected petitioner's claim that counsel was ineffective by failing to discover that the jury foreperson worked at the same casino as the victim's roommate because petitioner failed to demonstrate prejudice where there was no evidence that the foreperson knew the roommate or that there was any jury bias; the court expanded the certificate of appealability (COA) to include petitioner's claim of juror partiality under 28 U.S.C. 2254(d)(2); the Minnesota Supreme Court's legal determination that petitioner failed to support his claim that the foreperson was unable to be impartial was reasonable; and the district court did not err by denying the request for an evidentiary hearing. Accordingly, the court affirmed the judgment of the district court. View "White v. Dingle" on Justia Law

Defendant appealed his conviction and sentence for conspiracy to manufacture 1,000 or more marijuana plants. The court concluded that the evidence was sufficient to support the jury's conclusion that defendant knowingly participated in an agreement to manufacture marijuana; the jury found the codefendants to be credible and minor inconsistencies in their testimony did not create a basis upon which the court would disturb the jury's finding; the court rejected defendant's claim that the district court abused its discretion in admitting into evidence five out-of-court statements because they were admissible as declarations of coconspirators and the statements were made in furtherance of the conspiracy; and a term of 240 months' imprisonment did not violate the Eighth Amendment and was not grossly disproportionate. Accordingly, the court affirmed the judgment of the district court. View "United States v. Meeks" on Justia Law

Defendant, a policeman until his arrest, appealed his sentence after pleading guilty to attempting to aid and abet the possession with intent to distribute approximately 1000 pounds of marijuana. The court concluded that the district court adequately considered 18 U.S.C. 3553(a) factors and explained the chosen sentence. Further, defendant's within-range sentence was not substantively unreasonable. Accordingly, the court affirmed the judgment of the district court. View "United States v. Jones" on Justia Law

Defendant appealed his sentence after pleading guilty to being found in the United States after committing a felony and being deported. The court joined its sister circuits and held that a district court performing a modified categorical analysis to determine whether a prior state conviction qualifies for a sentencing enhancement may not rely upon allegations in a superceded indictment to which the defendant did not plead guilty. Therefore, the court reversed the district court's determination that defendant's Arizona conviction for solicitation to commit "misconduct involving weapons" qualifies as a firearms offense under U.S.S.G. 2L1.2(b)(1)(A)(iii). View "United States v. Martinez" on Justia Law

Defendant appealed his conviction for violating 18 U.S.C. 39A(a), which imposes criminal liability on anyone who "knowingly aims the beam of a laser pointer at an aircraft in the special aircraft jurisdiction of the United States, or at the flight path of such an aircraft." Relying on plain text and common usage, the court concluded that section 39A(a)'s requirement that the laser beam be knowingly aimed does not require an offender to intend the beam to strike the aircraft or flight path in question. Because the district court correctly interpreted the statute, it did not err in excluding defendant's expert's irrelevant testimony and rejecting defendant's inapposite proposed instructions. Accordingly, the court affirmed the judgment of the district court. View "United States v. Smith" on Justia Law

Claimant appealed the the magistrate judge's order directing forfeiture of $48,100 seized pursuant to a traffic stop. Claimant contended that the evidence did not support the magistrate judge's conclusion that the currency was substantially connected to an intended drug transaction. The court concluded that the government failed to carry its burden to prove it more likely than not that claimant intended to use the seized currency in a planned drug transaction. Accordingly, the court reversed the order and remanded with directions to dismiss the action. View "United States v. Nelson" on Justia Law

Plaintiff filed suit alleging that, during his incarceration as a pretrial detainee, he received constitutionally deficient medical care and that medical officials used excessive force against him while responding to his medical emergency. The court affirmed the grant of summary judgment to Dr. Johnson's motion for summary judgment where plaintiff failed to show that the doctor acted with deliberate indifference; affirmed the grant of summary judgment to Nurse Smith where plaintiff has not identified any evidence that the nurse ever refused or failed to treat him; affirmed the grant of Nurse Anderson's and Nurse Washburn's motions for summary judgment on plaintiff's excessive-force claim; and concluded that, in this case, a nurse's act of hitting plaintiff's nose was a de minimus use of force that was not actionable under the Due Process Clause. Accordingly, the court affirmed the judgment of the district court. View "Tucker v. Holladay, et al." on Justia Law

Defendant appealed his sentence after pleading guilty to drug offenses pursuant to a written plea agreement. The court concluded that, given defendant's criminal history, the district court did not abuse its discretion by imposing a below-guidelines sentence of 176 months. Further, the disparity between defendant's and his codefendant's sentence was not unwarranted given that the codefendant was not a career offender and did not face a mandatory minimum sentence. Accordingly, the court affirmed the judgment of the district court. View "United States v. Edison" on Justia Law

Defendant appealed his 18-month sentence imposed after he violated his conditions of supervised release. A district court may rely on a defendant's actual conduct rather than the offense to which he pled guilty in classifying his supervised release violation under the sentencing guidelines. The court concluded that the sentence imposed by the district court was substantively reasonable where the district court treated defendant's Arizona conviction as a "Grade B" violation because his actual conduct constituted an offense punishable by a term of imprisonment exceeding one year. The district court did not abuse its discretion in sentencing defendant at the top of his guidelines range for violating the conditions of his supervised release. Accordingly, the court affirmed the judgment of the district court. View "United States v. Ceballos-Santa Cruz" on Justia Law

Defendant appealed his conviction for assault with a dangerous weapon and domestic assault by an habitual offender. Defendant argued that the district court abused its discretion in admitting statements from the victim as an excited utterance because the alleged victim was not under the stress of the incident at the time she made the statements. The court held that the district court did not abuse its discretion in admitting the statements as an excited utterance considering the 30 minute lapse of time between the incident and the statements, the victim was shaking and appeared to have been crying, and the statements were offered in response to the officer's general inquiry into what had happened. Further, while defendant may offer alternative explanations for the victim's appearance and behavior, those explanations did not undermine the district court's exercise of its discretion in determining that the victim's statements bore a "guarantee of trustworthiness" and were not subject to reflection and deliberation. Accordingly, the court affirmed the judgment of the district court. View "United States v. Graves" on Justia Law