Justia Criminal Law Opinion Summaries

Defendant appealed his sentence after pleading guilty to using interstate commerce facilities in the commission of murder-for-hire. Defendant had posted a classified ad on Craigslist.com offering to pay for the murder of police officers. The court affirmed, concluding that the district court gave great weight to defendant's mental illness, departing downward from his guidelines sentence by 48 months despite finding that his history of inappropriate behavior, combined with his access to firearms, created a "potentially explosive situation." Accordingly, defendant's sentence was substantively reasonable where the district court was within its discretion to consider defendant's capacity to cause harm in the future. View "United States v. Lawrence" on Justia Law

Plaintiffs, pretrial detainees at a detention center, filed suit under 42 U.S.C. 1983 against prison guards and the Sheriff, alleging a variety of constitutional violations. The court concluded that the district court correctly denied summary judgment on the basis of qualified immunity where the record supported a claim of excessive force in violation of the Eighth Amendment. The record also supported a claim for failure to protect plaintiffs from harm in violation of the Due Process Clause and the district court correctly denied the guards qualified immunity on this claim. Given the fact that the Sheriff was not at the detention center, he could not have used excessive force against plaintiffs, nor could he have an opportunity to intervene to prevent the guards from employing excessive force. Accordingly, the court reversed the district court's denial of summary judgment based on qualified immunity with respect to the Sheriff. The court affirmed in all other respects. View "Edwards, Jr., et al. v. Byrd, et al." on Justia Law

Petitioner, an insanity acquitee committed to the custody of the Missouri Department of Mental Health, filed a petition under 28 U.S.C. 2254, challenging the denial of his state-court application for unconditional release. As a preliminary matter, the court concluded that the district court did not exceed the scope of the court's mandate by considering the Warren County Circuit Court's 2011 findings and decisions. The court concluded that petitioner failed to rebut the presumption that the circuit court's implicit finding of current mental illness is correct. Petitioner also failed to rebut the presumption of correctness of the Warrant County Circuit Court's express finding that he currently presented a danger to others. Accordingly, the court affirmed the district court's denial of the petition for habeas corpus. View "Grass v. Reitz" on Justia Law

Defendant was found incompetent to stand trial after he was indicted on one count of possession of a firearm after having been committed to a mental institution. The district court ordered defendant to be involuntarily medicated to restore him to competency. The court held that the district court did not err in finding that the government had satisfied the second Sell v. United States factor: that involuntary medication would significantly further the government's important interest in prosecuting the case. In the absence of a specific determination by the district court whether administering the medication constituted a medically appropriate treatment for defendant, as required by the fourth Sell factor, there was no finding for the court to review. Therefore, the court remanded with directions that the district court determine whether the government had established by clear and convincing evidence that involuntarily administering the recommended medication regime to defendant was medically appropriate. View "United States v. Curtis" on Justia Law

Claimant appealed the district court's order denying his post-trial motion to suppress evidence obtained as the result of a traffic stop. The government had instituted a civil in rem forfeiture lawsuit against the $45,000.00 found in claimant's vehicle but claimant was not charged with any crime. The arresting officer had pulled claimant's vehicle over for violation of Nebraska Revised Statute Sec., 60-399(2), which provided that license plates be plainly visible, but the officer was clear in his trial testimony that he was able to read "Utah" while still traveling a safe distance behind claimant on the highway. The court concluded that the district court clearly erred in characterizing the facts in its order on claimant's motion for reconsideration; that claimant drove a vehicle with out-of-state license plates and exited from the highway at an unlikely exit for cross-country travelers did not provide the officer with the requisite level of suspicion to stop claimant; and therefore, the initial traffic stop violated claimant's Fourth Amendment rights and any evidence obtained as a result should have been suppressed. Accordingly, the court reversed the judgment of the district court. View "United States v. Martin" on Justia Law

Plaintiff, a prison inmate, filed suit asserting various claims, including 42 U.S.C. 1983 claims alleging violations of the First and Fourteenth Amendments, that prison officials wrongfully censored and confiscated his mail. The court concluded that when an official properly and timely files a motion for dismissal or for summary judgment asserting qualified immunity, the official was entitled to a ruling on the issue of qualified immunity. As such, the district court must issue a reviewable ruling before requiring the officials to progress further in litigation at the district court. Therefore, the court reversed the district court's order converting the officials' motion to dismiss into a motion for summary judgment; vacated the district court's partial denial of the officials' motion for summary judgment; and remanded with instructions for the district court to decide, consistent with this opinion, whether the officials were entitled to qualified immunity on the pleadings under Rule 12(b)(6). View "Payne v. Britten, et al." on Justia Law

Defendant was convicted of conspiracy to launder money and conspiracy to possess with intent to distribute methamphetamine, cocaine and marijuana after two mistrials. The district court denied defendant's motion to dismiss based on double jeopardy and declined to impose sanctions for the government's failure to disclose its GPS surveillance. The court concluded that the district court's factual finding that the government did not intend to goad defendant into requesting a mistrial was not clearly erroneous where the prosecutor's conduct did not reflect an intent to subvert the protections afforded by the Double Jeopardy Clause. Neither of defendant's mistrials resulted from government acts intended to provoke a mistrial and defendant's conviction did not violate double jeopardy. The court also concluded that the district court did not abuse its discretion in declining to impose sanctions where the district court found that the government did not act in bad faith by failing to disclose the GPS surveillance, any prejudice to defendant was modest and had for the most part been remedied, and sanctions were unnecessary to ensure compliance. Accordingly, the court affirmed the judgment of the district court. View "United States v. Amaya" on Justia Law

Plaintiff, convicted of raping his two minor nieces, appealed the district court's denial of his petition for a writ of habeas corpus under 28 U.S.C. 2254. Plaintiff claimed that his counsel was ineffective by failing to object to an expert vouching for a witness and by stating, during opening statements, that plaintiff would only be called to testify if the state had proven its case. The court affirmed the district court's ruling that plaintiff did not suffer from ineffective assistance of counsel where the state court's decision was not an unreasonable application of clearly established federal law or resulted in a decision that was based on an unreasonable determination of the facts. Accordingly, the court affirmed the judgment of the district court. View "Abernathy v. Hobbs" on Justia Law

Defendant appealed his conviction for unlawful possession of marijuana as a previously convicted felon. The court concluded that the district court did not abuse its discretion by admitting evidence of the firearm-purchasing scheme as context for defendant's unlawful possession of the ammunition; the disputed evidence in this case demonstrated the circumstances surrounding the offense and tended logically to prove one or more elements of defendant's unlawful possession of ammunition; evidence of the firearm-purchasing scheme was probative of defendant's knowledge and explained how and why he used another individual to acquire prohibited ammunition; and recent straw purchases by the individual arguably played an integral role in the offense of conviction. Accordingly, the court affirmed the district court's judgment. View "United States v. Morrison, Jr." on Justia Law

Defendant appealed his conviction for one count of criminal sexual conduct. The court held that the government must prove beyond a reasonable doubt defendant's knowledge that his victim lacked the capacity to consent to sexual conduct. The court reversed the conviction because the jury instructions did not require the jury to make such a finding. The court remanded for a new trial. View "United States v. Fast Horse" on Justia Law