Justia Criminal Law Opinion Summaries

Defendant was charged with possession with intent to distribute cocaine and cocaine base. Defendant moved to suppress evidence seized during a search of his vehicle. The district court granted the motion and the government appealed. The court held that a reasonable person in defendant's position would have understood that he could decline the officer's request that a drug dog search his vehicle. Accordingly, the court reversed and remanded for further proceedings. View "United States v. Grant" on Justia Law

Plaintiffs, wrongly convicted in 1989 for participating in the rape and murder of the victim, individually filed causes of action pursuant to 42 U.S.C. 1983 against defendants, contending that defendants violated their rights to due process by recklessly investigating the murder and by coercing plaintiffs to plead guilty. On appeal, plaintiffs challenged the district court's grant of defendants' motion for summary judgment based on qualified and absolute immunity. The court concluded that the district court erred by failing to grant all reasonable inferences to plaintiffs and that the evidence was sufficient to support plaintiffs' claims that their individual rights to fair criminal proceedings were violated as the result of a reckless investigation and defendants' manufacturing of false evidence. The district court did not err, however, in its determination that there was insufficient evidence to support plaintiffs' claims that their guilty pleas were unconstitutionally coerced. Additionally, the district court did not err in granting absolute immunity to the prosecutor. Accordingly, the court affirmed in part and reversed in part. View "Thomas v. Smith, et al" on Justia Law

Petitioner, convicted of two counts of mail fraud and one count of money laundering, appealed the district court's denial of his motion to vacate his conviction under 28 U.S.C. 2255. Because the court found that petitioner could not demonstrate that it was more likely than not that no reasonable juror would have convicted him of the offenses under the statute's narrower interpretation, petitioner did not meet the exception for actual innocence to excuse his procedural default. Accordingly, the court affirmed the judgment. View "Jennings v. United States" on Justia Law

Plaintiff, wrongly convicted of murder and rape and imprisoned for these convictions, filed an action under 42 U.S.C. 1983 against defendants and various state entities, alleging that they violated his due process rights by conspiring to manufacture evidence and obtain false testimony against him. The court concluded that the facts viewed in the light most favorable to plaintiff gave rise to the reasonable inference that defendants acted in concert with the goal of securing plaintiff's convictions and thus, the district court did not err in denying defendants' request for summary judgment on the conspiracy claim. The court also concluded that a factfinder could reasonably infer that defendants' actions shocked the conscience and that the right to be free from a reckless investigation was clearly established during the 1989 investigation into this case. Further, the right to be free from a conviction purposefully obtained by false evidence and false testimony was also established. View "White v. Searcey, et al" on Justia Law

Defendant pled guilty to being a felon in possession of a firearm. The district court found that defendant qualified for an enhanced base offense level under U.S.S.G. 2K2.1(a)(2) based on two previous felony convictions that were crimes of violence under U.S.S.G. 4B1.2(a)(2) and sentenced him to 85 months' imprisonment. The court held that, based on the Supreme Court precedent in James v. United States and Sykes v. United States, defendant's argument that U.S.S.G. 4B1.2 was unconstitutionally vague necessarily failed. Accordingly, the court affirmed the judgment. View "United States v. Cowan" on Justia Law

Defendant was convicted of aiding and abetting the use, carrying, and brandishing of a firearm in furtherance of an armed bank robbery, and being a felon in possession of a firearm. On appeal, defendant challenged the reasonableness of his sentence. The court held that defendant's sentence was procedurally and substantively reasonable and affirmed the district court's upward variance from the Sentencing Guidelines range to 240 months imprisonment. View "United States v. Overbey" on Justia Law

Defendant, an Indian, was charged with brutally assaulting the victim in a town within the original boundaries of the Red Lake Indian Reservation. The district court denied defendant's motion to dismiss the indictment, concluding as a matter of law that the alleged assault occurred within the boundaries of the Reservation and therefore in "Indian country." The court concluded that the district court made its Indian country ruling on an inadequate record and remanded with directions to permit defendant to withdraw his guilty plea. Therefore, the court need not address defendant's additional contention that his sentence was substantively unreasonable. View "United States v. Jackson" on Justia Law

Defendant was sentenced to 216 months imprisonment for possession with intent to distribute methamphetamine. On appeal, defendant claimed that the district court procedurally and substantively erred by departing upwards 108 months under U.S.S.G. 5K2.2. The court held that the district court did not plainly err or abuse its discretion either in varying upwards or in departing upwards to a sentence of 216 months imprisonment. Nor did the district court plainly err in explaining the reasons for the variance or departure. The court also held that the sentence was not substantively unreasonable and the district court did not abuse its discretion. View "United States v. Franklin" on Justia Law

Defendant pled guilty to charges related to his involvement in a marijuana and cocaine conspiracy. On appeal, defendant challenged his sentence. The court agreed with the district court that it was unnecessary for it to decide who had the burden to prove whether U.S.S.G. 2D1.8(a)(1) or 2D1.8(a)(2) applied; since the evidence established that defendant did much more than merely "allow use of his premises," the district court properly determined that he was ineligible for the lower base offense level under Section 2D1.8(a)(2); the district court did not plainly err in not granting defendant safety-valve relief pursuant to U.S.S.C. 5C1.2; and defendant's sentence was substantively reasonable. View "United States v. Dengler" on Justia Law

Defendant was convicted of seven counts of wire fraud, two counts of mail fraud, and one count of conspiracy to commit wire fraud and mail fraud. On appeal, defendant challenged his sentence. The court held that there was no abuse of Federal Rule of Evidence 403 discretion expressly granted the district court in Rule 609(a)(1)(A); there was no abuse of the district court's substantial discretion to permit expert testimony; and the sentence was substantively reasonable. However, the judgment of the district court was reversed insofar as it included a final order of restitution, and the case remanded for further restitution proceedings. View "United States v. Chaika" on Justia Law