Justia Criminal Law Opinion Summaries

After plaintiff was arrested on suspicion of passing a forged $100 bill, she sued two police officers under 42 U.S.C. 1983. Plaintiff alleged that the officers violated her Fourth Amendment right against arrest without probable cause. The court affirmed the district court's grant of summary judgment to the officers because, based on the totality of the circumstances, the officers had arguable probable cause to arrest plaintiff. The officers' conduct did not show plain incompetence or a knowing violation of the law. Accordingly, the officers were entitled to qualified immunity. View "Clayborn v. Struebing, et al." on Justia Law

Defendant pled guilty to possessing a controlled substance with intent to distribute. On appeal, defendant challenged the district court's denial of his motion to suppress cocaine and other evidence found after a traffic stop of a borrowed car he was driving. The court concluded that the district court properly denied defendant's motion to suppress because the evidence seized as a result of the installation and monitoring of the GPS device was admissible under the good faith exception to the Fourth Amendment exclusionary rule. Accordingly, the court affirmed the judgment of the district court. View "United States v. Barraza-Maldonado" on Justia Law

Petitioner, found guilty of second-degree felony murder and four counts of assaulting injured bystanders, appealed the district court's denial of his petition for a federal writ of habeas corpus. At issue was whether petitioner's Fifth and Sixth Amendment rights were violated when the trial court instructed the jury on the uncharged assault offenses. The court concluded that petitioner's right-to-remain-silent claim was procedurally barred because it was not presented to the state courts. The court also concluded that, given the unusual procedural facts of this case - petitioner had notice of and prepared to defend the assault charges in the trial court and then urged the state appellate courts to apply harmless error review to the resulting error - the court could not conclude that the Minnesota Court of Appeals decision applying harmless error review under state law was contrary to clearly established U.S. Supreme Court precedent. Accordingly, the court affirmed the judgment of the district court. View "Anderson v. King" on Justia Law

Defendant appealed her conviction for possession of methamphetamine with intent to distribute. The court concluded that the record showed that the trooper had probable cause necessary to make the traffic stop for improperly driving in the left lane, a reason the trooper articulated to defendant at the time of the stop; the court assumed, without deciding, that defendant had standing to challenge the search of the vehicle; because the troopers no longer needed defendant's consent to search once they discovered a hidden compartment, any effort to withdraw or limit her consent at that point would have been fruitless; the court affirmed the district court's finding that after the troopers discovered the hidden compartment, they had probable cause to continue the search; because defendant was read her Miranda rights, any statements she made at the garage or later at the Nebraska State Patrol Office were admissible; and, therefore, the court affirmed the judgment of the district court denying defendant's motion to suppress. View "United States v. Guevara" on Justia Law

After plaintiff served 24 years in prison for murder, a Missouri court found that plaintiff's trial had been fundamentally unfair and ordered his release. Plaintiff then filed suit against the St. Louis Board of Police Commissioners and others, alleging, inter alia, that defendants recklessly or intentionally manipulated evidence and conducted suggestive identification procedures. The court concluded that the district court did not err in granting summary judgment on plaintiff's claims that defendants manipulated the investigation or evidence against him or deprived him of a fair trial; plaintiff had not adduced evidence to show that the identification procedure in this case was impermissibly suggestive and the circumstances of the photo identification procedure did not create a very substantial likelihood of irreparable misidentification; the court found no evidence to support a reasonable inference that any of the defendants conspired to frame plaintiff or otherwise deprive him of his constitutional rights; and plaintiff's Monell claims against the Board failed where none of the individual defendants were liable on plaintiff's 42 U.S.C. 1983 claims. Accordingly, the court affirmed the judgment of the district court. View "Burton v. St. Louis Board of Police, et al." on Justia Law

The government appealed the district court's grant of defendant's motion for a new trial after he was found guilty of one count of conspiracy to launder money. The district court found that it committed two specific plain errors: (1) it determined that the verdict form for defendant was plainly erroneous because it was obvious that the form should have contained a place for the jury to indicate its verdict but that place was missing on the form, and (2) it substituted polling of the jury for the rendering of a verdict on a properly composed verdict form after private deliberations. The court concluded that the district court did not abuse its discretion in determining that the verdict form error and the substitution of a polling procedure for a return of the verdict constituted plain error. Accordingly, the court affirmed the judgment. View "United States v. Amaya" on Justia Law

Plaintiff filed suit against the County and others after her son Johnny died from multiple drug intoxication while in the county jail. At issue on appeal was the district court's denial of qualified immunity on summary judgment for the law enforcement officials. The court concluded that Officer Furr did not have subjective knowledge that Johnny required medical attention and that Officer Furr was not deliberately indifferent to Johnny's medical needs. Accordingly, Officer Furr was entitled to qualified immunity. In regards to Officer King, the court concluded that a reasonable officer would have known that a constitutional violation occurred by deliberately disregarding Johnny's serious medical needs in the circumstances Officer King confronted. Accordingly, the district court properly denied Officer King qualified immunity because this constitutional right was clearly established. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Thompson v. King, et al." on Justia Law

Defendant appealed his conviction for using and maintaining a premises for the purpose of distributing and using a controlled substance. The court concluded that the evidence was sufficient to convict defendant and the district court did not err in denying defendant's motion for judgment of acquittal, nor did it abuse its discretion in denying his motion for a new trial. View "United States v. Rhodes" on Justia Law

Defendant was indicted for possession with intent to distribute five grams or more of methamphetamine. On appeal, the government challenged the district court's grant of defendant's motion to suppress evidence seized from his person and vehicle. The court concluded that police officers had reasonable suspicion to believe that defendant was engaged in criminal activity and a reasonable belief that defendant was dangerous; defendant's furtive gestures under his seat as the officers approached the vehicle gave them reason to believe that there was a weapon in the vehicle that defendant might access when the Terry stop ended and he was permitted to return to the vehicle; this objectively reasonable concern for officer safety justified the officer's immediate protective sweep under the driver's seat of the vehicle; because reasonable suspicion was established, the officer's search of the vehicle's interior was permitted even though the occupants had been removed from the vehicle; the officer was also authorized to search the lockbox he found in the vehicle, which was large enough to conceal a weapon; the limits of the Terry stop were not exceeded when defendant was removed from the vehicle and handcuffed; and consequently, because there was no unlawful arrest, the district court's rationale did not justify suppression of the evidence and statements. Accordingly, the court reversed and remanded. View "United States v. Morgan" on Justia Law

Plaintiff filed suit under 1983 alleging that police officers violated his constitutional rights by arresting him in his home without first obtaining a warrant to do so. The court concluded that plaintiff demonstrated sufficient facts to show a violation of his Fourth Amendment right to be free from unreasonable searches and seizures; a reasonable officer would have known that at the time plaintiff tried to close the door, he stood within his home and thus could not be pulled therefrom and placed under arrest in the absence of exigent circumstances; and, therefore, the court affirmed the district court's order denying qualified immunity as to Defendant Shearer. The court dismissed for lack of jurisdiction plaintiff's cross appeal challenging the grant of qualified immunity as to Defendants Spiker and Bone where the district court has not issued a final decision and the collateral order doctrine did not apply when a party complains that the district court should not have granted summary judgment based on qualified immunity. View "Mitchell v. Shearrer" on Justia Law