Justia Criminal Law Opinion Summaries

Defendant pleaded guilty to possessing counterfeit currency and being a felon in possession of a firearm. On appeal, defendant challenged his sentence of 240 months' imprisonment. The court held that the district court properly concluded that defendant was subject to a fifteen-year minimum prison sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e)(1), where his murder and arson convictions were separate predicate offenses. The court further held that defendant's sentence was not unreasonable and rejected defendant's arguments. Accordingly, the court affirmed the judgment of the district court. View "United States v. Chappell" on Justia Law

Defendants Chantharath and Guzman-Ortiz were convicted of conspiracy to distribute controlled substances. Both defendants challenged their convictions and sentences. The court held that the evidence was sufficient to convict both defendants of participating in a single conspiracy; the jury in this case reasonably decided that defendants knowingly entered into a general agreement to distribute methamphetamine with others; and the district court did not err in upholding the jury's verdict where there was no spillover prejudice if all of the evidence adduced at trial related to a single conspiracy. The court rejected Chantharath's challenges to the district court's denial of his motion to suppress evidence; Chantharath's argument that the district court erred in failing to instruct the jury not to consider evidence concerning Guzman-Ortiz's possession of firearms when evaluating the charge against Chantharath was without merit; and it was not plain error for the district court to impose the mandatory minimum sentence under 21 U.S.C. 841(b)(1)(a)(viii). The court further held that the district court did not abuse its discretion in applying the firearms enhancement to Guzman-Ortiz's sentence and the district court did not abuse its discretion in sentencing Guzman-Ortiz at the low end of the Guidelines range. View "United States v. Chantharath" on Justia Law

Defendant pleaded guilty to one count of concealment from the SSA in violation of 42 U.S.C. 408(a)(4). On appeal, defendant challenged his sentence. The court held that the district court did not procedurally err in accepting the government's intended loss calculation and defendant's sentence was well below the advisory Guidelines range. Because the district court did not procedurally err or abuse its discretion in sentencing defendant to 25 months' imprisonment, the court affirmed the judgment. View "United States v. Frisch" on Justia Law

Defendant pled guilty to conspiring to manufacture marijuana. On appeal, defendant challenged his sentence after the district court found him ineligible for the safety valve in 18 U.S.C. 3553(f). Because of defendant's two criminal history points and his failure to truthfully disclose not later than the time of his sentencing hearing, defendant was not eligible for the safety valve. Accordingly, the court affirmed the judgment. View "United States v. Foote" on Justia Law

Petitioner, convicted of two drug offenses and sentenced to 300 months in prison, requested authorization to file a second 28 U.S.C. 2255 motion in light of Lafler v. Cooper and Missouri v. Frye. Petitioner claimed that he rejected a favorable plea offer because trial counsel failed to adequately explain the terms of the offer and the consequences of rejecting it. The court held that neither Lafler nor Frye announced a new rule of constitutional law and therefore, the court denied petitioner's request to file a second petition. View "Williams v. United States" on Justia Law

Defendant was convicted of possession with intent to distribute five grams or more of methamphetamine and sentenced to 262 months' imprisonment. On appeal, defendant argued that the court erred in failing to instruct the jury on the lesser included offense of possession of methamphetamine and that his sentence was unreasonable. The court held that the district court properly rejected defendant's requested instruction where the circumstantial evidence of distribution was sufficiently compelling to preclude a rational finding that defendant possessed the drugs merely for personal use. The court also held that a sentence within the recommended guideline range was presumed reasonable and the district court acted within its broad discretion in rejecting defendant's arguments for a lighter sentence. Accordingly, the court affirmed the judgment. View "United States v. Ponce" on Justia Law

Defendant was convicted of three federal narcotics crimes and subsequently appealed the district court's partial denial of his 18 U.S.C. 3582(c)(2) motion for a sentence modification. The district court refused to reduce defendant's sentence further based on an earlier, non-retroactive amendment to the Sentencing Guidelines and defendant contended that this refusal was neither authorized by statute or permitted by the Constitution. Because Congress had not authorized the court to "hold unlawful and set aside" action by the Commission "found to be... arbitrary, capricious, [or] an abuse of discretion," the court rejected defendant's argument that the court could "disregard" the Commission's non-retroactivity determination as arbitrary and capricious. The district court, by complying with section 3582(c)(2) and the Commission's non-retroactivity determination, did not violate defendant's Fifth Amendment right to due process because section 3582(c)(2) proceedings did not implicate a "constitutionally protected liberty interest." Accordingly, the court affirmed the judgment. View "United States v. Johnson" on Justia Law

Defendant was convicted of conspiracy to distribute and possession with intent to distribute methamphetamine and Oxycodone, and aiding and abetting possession with intent to distribute methamphetamine. On appeal, defendant challenged his sentence. The court affirmed the district court's application of the leadership enhancement under U.S.S.G. 3B1.1 and the dangerous weapon enhancement under U.S.S.G. 2D1.1(b)(1). View "United States v. Garcia" on Justia Law

Defendant pled guilty to possession of child pornography and subsequently appealed his sentence. Defendant had a prior conviction under a Nebraska statute, Neb. Rev. Stat. 28-320.01, for sexual assault of a child. The court held that defendant's Nebraska conviction triggered application of the ten-year mandatory minimum. The court also held that defendant waived all other challenges to his sentence in his plea agreement. Accordingly, the court affirmed the sentence. View "United States v. Cover" on Justia Law

Defendants appealed their convictions for conspiracy to distribute methamphetamine, following their joint jury trial. The court held that the district court did not abuse its discretion in limiting a suspect's cross-examination. In regards to Defendant Camarena, the court held that the district court did not err in failing to give his proffered jury instruction regarding a suspect's credibility and defendant did not meet his burden of demonstrating that the cumulative errors required reversal of his convictions. In regards to Defendant Baldenegro-Valdez, because his arrest was valid and he was correctly given his Miranda warnings, which he waived, his post-arrest statements were properly admitted at trial; the district court's denial of the motion to suppress was proper where, even if the inventory search was not valid, the search was valid under the automobile exception; the district court did not abuse its discretion in refusing to exclude the government's proffered English translation of certain transcripts; the district court did not abuse its discretion in denying his motion for a mistrial; the prosecutor's use of the words "suppression hearing" also did not require a mistrial; and the district court did not err in its jury instructions. Accordingly, the court affirmed both defendants' convictions. View "United States v. Baldenegro-Valdez" on Justia Law