Justia Criminal Law Opinion Summaries

Defendant pleaded guilty to one count of being a felon in possession of a firearm. On appeal, defendant challenged the district court's denial of his motion to suppress the firearm and other evidence as a result of an inventory search of his vehicle. Based on the totality of the circumstances - an emergency call, the history of criminal activity in the area, the behavior of the group, and defendant's own behavior - the officers had reasonable suspicion to justify a Terry stop of defendant. Therefore, the court affirmed the district court's denial of defendant's motion to suppress. View "United States v. Hightower" on Justia Law

Defendant, convicted of conspiracy to distribute and possession with intent to distribute methamphetamine, appealed the district court's order dismissing his post-conviction motion to vacate and set aside the conviction and sentence. The court affirmed the judgment, rejecting defendant's 36 claims of ineffective assistance of pretrial, trial, and appellate counsel. The court concluded that the district court did not abuse its discretion in dismissing defendant's motion without an evidentiary hearing. View "Winters v. United States" on Justia Law

Defendant appealed his conviction and sentence stemming from various drug and firearm offenses. The court concluded that 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 where the evidence was sufficient to support the finding that there was an agreement to distribute heroin in the Waterloo area, that defendant was aware of this agreement, and that defendant knowingly contributed to the furtherance of this agreement; the district court's failure to include the names of coconspirators in the jury instructions was not a constructive amendment of the indictment; no variance existed between the indictment and the government's proof; the district court did not err in giving certain jury instructions; and the court rejected defendant's contention that his sentence was inconsistent with the district court's oral pronouncement of sentence. Accordingly, the court affirmed the conviction and sentence. View "United States v. Johnson" on Justia Law

Defendant appealed his sentence for violating the terms of his supervised release. Defendant was released from custody and his sentence was fully discharged before his appeal was heard. The court dismissed defendant's appeal as moot, concluding that the possibility the supervised release violation might increase defendant's sentence for a future conviction was insufficient to maintain the appeal; defendant lacked any authority in his argument that he would suffer social stigma as a result of the violation; and defendant's appeal did not fall within the exception to mootness cases capable of repetition yet evading review. View "United States v. Dunlap, Jr." on Justia Law

Defendant was indicted for being a felon in possession of a firearm in the Eastern District of Arkansas and for being a felon in possession of ammunition in the Middle District of Florida. The district court granted a joint motion to consolidate the two cases and defendant pleaded guilty. The parties agreed to leave the district court the determination of whether the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e), applied. Defendant's prior convictions included three offenses under the assault statutes of the State of California. On appeal, defendant argued that his two prior violent felony convictions for assault with a deadly weapon were actually misdemeanors under California law. The court concluded that these convictions were felonies for sentencing purposes because, although each of the assault offenses could wobble between a felony and a misdemeanor, neither conviction resulted in a judgment and neither court declared the convictions to be misdemeanors. The court also concluded that the rule of lenity was not applicable in this case where there was no grievous ambiguity or uncertainty. Accordingly, the district court properly classified defendant as an armed career criminal and the court affirmed the judgment. View "United States v. Adams" on Justia Law

Defendant appealed his conviction for possession with intent to distribute fifty grams or more of methamphetamine and sentence of a mandatory term of life in prison. The court concluded that the district court did not err in denying defendant's motion to suppress evidence seized from a vehicle where the absence of a Miranda warning prior to the search did not nullify defendant's otherwise voluntary consent and where an objectively reasonable person would have understood defendant to have consented to a search of the entire vehicle. The court also concluded that defendant's sentence did not violate the Eighth Amendment where, in light of his two prior drug convictions, his sentence was not grossly disproportionate. Accordingly, the court affirmed the conviction and sentence. View "United States v. Capps" on Justia Law

After defendant was indicted for failing to register as a sex offender and the parties stipulated that he was incompetent to understand the proceedings against him or to assist in his defense, the government moved to medicate him involuntarily to restore his competency to stand trial. Pursuant to Sell v. United States, the court concluded that an important government interest was at stake; that involuntary medication would significantly further that governmental interest; that involuntary medication was necessary to further that interest; and that administration of the drugs was medically appropriate. Accordingly, the court affirmed the district court's grant of the government's motion to medicate defendant involuntarily. View "United States v. Mackey" on Justia Law

Defendant appealed his conviction for domestic assault by a habitual offender in violation of 18 U.S.C. 117. The court concluded that the district court did not err by denying defendant's motion for a judgment of acquittal where, viewing all the evidence in the light most favorable to the verdict, a reasonable jury could find that defendant was cohabitating with the victim as intimate partners at the time of the assault. Accordingly, the court affirmed the judgment. View "United States v. St. John" on Justia Law

Defendant pled guilty to larceny and subsequently appealed his sentence. The court concluded that the district court did not err in departing upward under U.S.S.G. 4A1.3; although the district court's written statement of reasons for the departure checked the U.S.S.G. 5K2.0 box, that guideline expressly excluded the reasons the district court referenced in its oral statement; the district court did not procedurally err by failing to consider arguments for leniency and adequately explained the basis for his sentence; the district court also took into account all the 18 U.S.C. 3553(a) factors, discussed the facts of the case, and examined defendant's personal characteristics and history; and the district court did not substantively err in sentencing defendant to 30 months' imprisonment. Accordingly, the court affirmed the judgment. View "United States v. Olson" on Justia Law

Defendant pleaded guilty to one count of bank fraud, three counts of aggravated identity theft, and one count of conspiracy. On appeal, defendant challenged the district court's denial of his motion to suppress. The court concluded that defendant's arrest was supported by probable cause; probable cause still existed because of the attenuation doctrine, even assuming the investigation involved an illegal search; the seizure of a laptop bag was justified in order to preserve evidence; the inventory search was not merely a pretext to search for evidence; and defendant's argument, under Franks v. Delaware, regarding the validity of the warrant was rejected. Accordingly, the court affirmed the judgment. View "United States v. Smith" on Justia Law