Justia Criminal Law Opinion Summaries

Plaintiff brought a claim under 42 U.S.C. 1983 for, inter alia, excessive force against officers of the St. Paul, Minnesota Police Department. The district court granted summary judgment to Officers Storey and Sipes on plaintiff's failure-to-protect claim and the jury returned a verdict in favor of Officer Smith. The court held that the district court did not abuse its discretion in admitting any of the challenged evidence where much of Officer Smith's testimony regarding his purported "mental state" was elicited by plaintiff's counsel; all of the objected-to statements actually provided context for Officer Smith's conduct; Officer Smith's concern about potential weaponization of the cell phone was not based on speculation; and the district court's jury instruction on excessive force advised the jury not to consider Officer Smith's "state of mind, intention, or motivation." The district court did not err in giving the model jury instruction. Finally, the district court did not err in denying plaintiff's motion for a new trial on his excessive-force claim as dispositive of his failure-to-protect claim against Officers Storey and Sipes. Accordingly, the court affirmed the judgment. View "Farrington v. Officer Steven Smith, et al" on Justia Law

Defendant pleaded guilty to possession with intent to distribute a controlled substance. On appeal, defendant argued that the government breached the plea agreement and the plea agreement was ambiguous and should be construed against the government. The court enforced the appeal waiver contained in the plea agreement and dismissed defendant's appeal. View "United States v. Guzman" on Justia Law

Plaintiffs sued the deputies of Woodbury County, Iowa, and the County under 42 U.S.C. 1983 and Iowa law. The deputies and the County subsequently appealed the district court's denial in part of their motion for summary judgment. The court held that Defendant McCrystal was not entitled to summary judgment based on qualified immunity from Plaintiff Small's claim of unlawful arrest; McCrystal was not entitled to summary judgment based on qualified immunity from Small's claim of excessive force; the deputies were not entitled to summary judgment based on qualified immunity from plaintiffs' claim of unlawful arrest of the Warrant Plaintiffs, retaliatory inducement to prosecute, and conspiracy under section 1983; and the deputies' appeal of the denial of summary judgment on the malicious prosecution, abuse-of-process claim, and civil conspiracy claim were dismissed for lack of jurisdiction. Accordingly, the court affirmed the judgment. View "Small, et al v. McCrystal, et al" on Justia Law

Defendant was indicted for failure to register as a sex offender pursuant to 18 U.S.C. 2250(a). Defendant moved to dismiss the indictment on the ground that the Sex Offender Registration and Notification Act (SORNA), 42 U.S.C. 16913(d), violated the nondelegation doctrine of the United States Constitution. The court affirmed the district court's denial of defendant's motion, holding that section 16913(d) was a valid delegation of authority because Congress provided the Attorney General with an intelligible principle to follow. View "United States v. Kuehl" on Justia Law

Defendant pleaded guilty to making threatening interstate communications and mailing threatening communications. On appeal, defendant challenged her sentence of 180 months' imprisonment. The court concluded that the district court properly imposed an obstruction-of-justice enhancement under U.S.S.G. 3C1.1; the district court properly imposed an "official victim" enhancement under U.S.S.G. 3A1.2(a); the district court did not err in denying defendant a sentencing reduction for acceptance of responsibility; and the district court imposed a sentence that properly considered all 18 U.S.C. 3553(a) factors. Accordingly, the court affirmed the judgment. View "United States v. Hutterer" on Justia Law

Defendants Mariso Lopez-Soto and Douglas Hoffman appealed their convictions stemming from offenses related to a methamphetamine distribution enterprise. The court held that the evidence was sufficient for a reasonable jury to conclude that Lopez-Soto knowingly and voluntarily joined an agreement to launder money; the district court did not plainly err when it adjusted Lopez-Soto's sentence by three levels for her management role in the conspiracy; there was no error in the district court's grouping of Lopez-Soto's two counts pursuant to U.S.S.G. 3D1.2(c); and the district court did not abuse its discretion when it sentenced Lopez-Soto to life imprisonment. The court also held that it found no error on the part of the district court where the district court gave Hoffman an opportunity to speak prior to the imposition of his sentence; the Probation Office report was not outside the scope of the district court's discretion; and Hoffman was not entitled to plain error relief. Accordingly, the court affirmed the judgment. View "United States v. Hoffman" on Justia Law

Defendant appealed his conviction for conspiracy to possess with intent to distribute and distribute controlled substances. The court held that a reasonable jury could conclude that an overt act in furtherance of the single conspiracy, of which defendant was a member, occurred in North Dakota, making venue proper there; the district court did not err in denying defendant's motion to dismiss the indictment where the evidence demonstrated that he was a member of the conspiracy prior to the reversal sale; a reasonable jury could have concluded that defendant had knowledge of and intended to join the alleged conspiracy and therefore, the district court properly denied defendant's motion for judgment of acquittal; the district court did not abuse its discretion by admitting evidence of defendant's prior conviction to show knowledge and intent; and because the jury instructions, taken as a whole, fairly and adequately submitted the issues to the jury, the court found no error. Accordingly, the court affirmed the judgment. View "United States v. Banks" on Justia Law

Defendant was convicted of one count of conspiring to manufacture 50 grams or more of methamphetamine and seven counts of possessing pseudoephedrine with the intent to manufacture methamphetamine. On appeal, defendant challenged his convictions and sentence. The court held that the district court properly admitted the pseudoephedrine logs and certain portions of a special agent's testimony; the evidence was sufficient to establish that the conspiracy involved at least 50 grams of methamphetamine; because the government proved that defendants possessed pseudoephedrine, a listed chemical, with the intent to manufacture methamphetamine, his convictions for counts two through eight must stand; and the district court did not err in imposing a two-level enhancement for defendant's leadership role in the offense and in imposing a three-level enhancement for creating a substantial risk of harm to human life. Accordingly, the court affirmed the judgment. View "United States v. Well" on Justia Law

Defendant pleaded guilty to conspiring to distribute less than 50 grams of marijuana, possessing a firearm in furtherance of a drug trafficking offense, and possessing a firearm following a conviction for domestic violence. On appeal, defendant challenged the district court's denial of his motion to withdraw his plea. Because defendant was told of his statutory range and was also told the advisory guidelines would apply, he was not entitled to withdraw his plea. The court rejected defendant's remaining claims and affirmed the judgment. View "United States v. Thomas" on Justia Law

Defendant appealed his conviction of conspiring to manufacture 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine. The court held that the district court properly denied defendant's motion to suppress evidence found on defendant's father's property and in his vehicle where defendant had no reasonable expectation of privacy in his father's home when he did not live there and his father expressly permitted the police search of the property, and where the circumstances indicated a fair probability that contraband or evidence of a crime would be found in the vehicle. The court also held that there was sufficient evidence to support defendant's conviction for conspiracy to manufacture methamphetamine. Accordingly, the court affirmed the judgment. View "United States v. Skoda" on Justia Law