Justia Criminal Law Opinion Summaries

Defendant, through a plea agreement, pleaded guilty to conspiracy to distribute marijuana. On appeal, defendant challenged the reasonableness of his sentence. The court held that the district court did not procedurally err in imposing defendant's sentence where it considered the 18 U.S.C. 3553(a) factors and explained the sentence. The court also held that the district court properly calculated the Guidelines range, considered all relevant sentencing factors, and chose a sentence at the low end of the appropriate advisory Guidelines range. Defendant had not shown this sentence to be substantively unreasonable. Accordingly, the court affirmed defendant's sentence of 33 months in prison. View "United States v. Standafer" on Justia Law

Defendant was convicted of conspiracy to distribute and possess with intent to distribute crack cocaine. On appeal, defendant challenged his newly amended sentence. Applying United States v. Burrell, the court held that the district court abused its discretion by failing to provide its rationale for sentencing defendant at the middle of the newly applicable Guidelines range. Accordingly, the court vacated and remanded for further proceedings. View "United States v. Grant" on Justia Law

Defendant was convicted of conspiring to commit bank robbery, committing bank robbery, and using a firearm during a crime of violence. On appeal, defendant challenged the sentence that the district court imposed after granting him relief from his previous sentence under 28 U.S.C. 2255. The government cross-appealed, asserting that relief was time-barred and that the district court had no statutory power to resentence defendant. Because the district court did not err in noticing the error in the original calculation of defendant's sentence, and the government did not dispute that defendant's counsel was ineffective in not calling the court's attention to the error or that the error merited plain error relief, the court affirmed the judgment of the district court. View "United States v. Daily" on Justia Law

Plaintiff brought this action under 42 U.S.C. 1983, alleging that his constitutional rights were violated while he was detained at Faulkner County Detention Center (FCDC). The court held that, in the circumstances presented in this case, defendants' refusal to grant plaintiff's request for additional toilet paper did not violate any clearly established right. Accordingly, defendants were entitled to qualified immunity. Therefore, the order denying qualified immunity was reversed and the case was remanded to the district court for the entry of an appropriate order. View "Stickley v. Byrd, et al" on Justia Law

Defendant was convicted of sexual abuse of a minor, his wife's cousin, and abusive sexual contact with a minor, his biological daughter, in Indian country. Defendant appealed his convictions. The court held that there was no Confrontation Clause error when a government witness described a forensic interview and medical report of the daughter; defendant procedurally defaulted on his claim that the district court violated his Sixth Amendment right to a public trial by closing the courtroom to the public when the daughter testified; and the procedural default was not excused by ineffective assistance of appellate counsel. Accordingly, the court affirmed the judgment. View "Charboneau, III v. United States" on Justia Law

Defendant was convicted of conspiracy to commit bribery of an Indian tribal official, and aiding and abetting a bribery involving an agent of an Indian tribal government. Defendant raised evidentiary challenges on appeal. The court held that the district court did not plainly err in determining that evidence relating to uncharged bribery activity was "intrinsic" to the charged conspiracy and therefore admissible notwithstanding the government's failure to give defendant pretrial notice of its intent to use this evidence. Given the substantial evidence of defendant's guilt, and defendant's failure to object and his decision to rehash the same testimony on cross-examination, the court concluded that defendant was not sufficiently prejudiced by the admission of the testimony at issue for the court to exercise its discretion to recognize plain error, if any existed. Accordingly, the court affirmed the judgment. View "United States v. Duane Dale Big Eagle" on Justia Law

Petitioner, convicted of second-degree sexual abuse of his five-year-old daughter, petitioned for review of the district court's denial of his habeas corpus petition. At issue was whether petitioner received ineffective assistance of counsel for trial counsel's failure to challenge his ex-wife's testimony about his sexual behavior during their marriage. The court remanded the case to the district court to consider whether the Iowa Court of Appeal's decision in Paulson v. State was contrary to clearly established federal law, and for further proceedings. View "Paulson, II v. Newport Correctional Facility" on Justia Law

Defendants were convicted of one count of possessing a firearm to further drug trafficking and three counts of murder from possessing a firearm to further drug trafficking. Both defendants appealed. The court held that the district court properly admitted the cell phone evidence at issue; the district court did not err in admitting prior-acts evidence under Federal Rule of Evidence 404(b); the district court did not err in admitting three statements of a deceased co-conspirator; and the evidence was sufficient for a reasonable jury to find defendants joined a conspiracy to distribute drugs. The court disposed of the remaining claims and affirmed the judgment. View "United States v. Lindsey" on Justia Law

Defendant pled guilty to two counts of sexual exploitation of a minor and two counts of receipt of child pornography, conditioned on his right to appeal the denial of his motion to suppress. The court affirmed the denial of defendant's motion to suppress where, assuming that the warrant was based on evidence collected in violation of defendant's Fourth Amendment rights, the Leon good-faith exception barred application of the exclusionary rule to evidence seized pursuant to the warrant. The court also held that the district court did not err in imposing the U.S.S.G. 2G2.1(b)(4) four-level enhancement where defendant inflicted pain upon the victim prior to filming her. Accordingly, the court affirmed the judgment. View "United States v. Cannon" on Justia Law

Defendant pleaded guilty to wire fraud and income tax evasion after he admitted to conducting an eight-year scheme to defraud many persons by inducing them to invest more than $20 million in various schemes. On appeal, defendant challenged his sentence. The court held that defendant waived his contention that the district court adopted an inaccurate loss calculation when defendant signed the plea agreement; defendant's contention that the district court ignored a proper objection to Paragraph 33 of the PSR was without merit; the district court did not commit procedural error in denying defendant's request for a downward variance; and the district court did not commit procedural error under Criminal Rule 32(i)(1)(A). View "United States v. Krzyzaniak" on Justia Law