Justia Criminal Law Opinion Summaries

Petitioner John Waldron, a native and citizen of the United Kingdom, had his permanent resident status in the United States terminated because of his conviction for second degree assault. Petitioner sought an adjustment of status and a waiver of inadmissibility. An immigration judge (IJ) concluded that Petitioner was eligible for relief, granting both Petitioner's adjust of status and the waiver. The Board of Immigration Appeals (BIA) reversed and ordered Petitioner removed to the United Kingdom. The Eighth Circuit Court of Appeals reversed, holding that the BIA erred by failing to review the IJ's factual findings for clear error. Remanded.

Defendant entered into a plea agreement with the government wherein he pled guilty to arson and aiding and abetting arson. The government agreed it would recommend a sentence at the bottom of the advisory Sentencing Guidelines range. At sentencing the government recommended a sentence at the low end of the advisory Sentencing Guidelines range. The district court denied the request and instead departed upward under the United States Sentencing Commission. The court then sentenced Defendant to sixty months of imprisonment, the statutory maximum. The Eighth Circuit Court of Appeals affirmed, holding (1) Defendant's sentence was not substantively unreasonable; and (2) there was no breach of the plea agreement by the government.

Defendant entered a conditional plea of guilty to possession with intent to distribute cocaine base and possession of a firearm in furtherance of a drug trafficking crime. Defendant appealed. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court did not err in denying Defendant's motion to suppress evidence obtained from a warrantless search of a rental vehicle, as consent for the search was validly obtained, and thus, the warrantless search did not violate the Fourth Amendment; (2) the discovery of drugs and a firearm in the vehicle was not a fruit of Defendant's detention, and thus, the Court did not need to decide whether Defendant's initial detention violated the Fourth Amendment; and (3) Defendant waived his right to appeal his sentence.

After a jury trial, Defendant was convicted on six counts related to willfully causing bodily injury to another because of that person's race, color, or national origin in violation of certain provisions of the Shepard-Byrd Hate Crimes Prevention Act. The district court sentenced Defendant to 135 months' imprisonment. The Eighth Circuit Court of Appeals affirmed Defendant's convictions and sentence, holding (1) 18 U.S.C. 249(a)(1) was constitutional; (2) the evidence was sufficient to sustain the conviction; (3) the district court did not abuse its discretion in refusing to grant Defendant's motion for a new trial; and (4) the district court did not err in failing to sua sponte grant Defendant a minor role adjustment.

Defendant pleaded guilty to distributing methamphetamine and being a felon in possession of a firearm. The district court sentenced Defendant to 151 months' imprisonment. Defendant appealed his sentence, raising as his sole issue the propriety of the district court's enhancement of his sentence for obstructing justice. The district court found that while in prison, after pleading guilty, Defendant engaged in a conspiracy to murder a confidential informant in this case. The Eighth Circuit Court of Appeals reversed the sentence, holding that the sentencing enhancement did not apply because there was no showing the plot was intended to obstruct justice on the instant offense of conviction.

Defendant pleaded guilty to one count of interstate transportation of a minor with intent to engage in criminal sexual activity. The district court sentenced Defendant to 360 months' imprisonment, applying an upward variance of thirty-three months from the high end of the Guidelines range. Defendant appealed, arguing that his sentence was substantively unreasonable based on the factors in 18 U.S.C. 3553(a). The Eighth Circuit Court of Appeals affirmed, holding (1) given the record, the district court did not impose a sentence greater than necessary to comply with the purposes of section 3553(a)(2); and (2) under the circumstances, the district court gave sufficient weight to mitigating factors.

A jury convicted Defendant of distribution of heroin and distribution of heroin resulting in death. The district court sentenced Defendant to 240 months on each count, concurrently. Defendant appealed, arguing the court erred by admitting hearsay testimony and denying his motions for judgment of acquittal and a new trial. The Eighth District Court of Appeals affirmed, holding that the district court did not err (1) by rejecting Defendant's proximate cause instructions or by using "contributing cause" language to define the causation element; (2) in denying Defendant's motion for a new trial because of remarks made by the prosecutor, where the remarks were proper; (3) in denying Defendant's motion for a judgment of acquittal, as the evidence was sufficient to sustain the convictions; and (4) in admitting certain testimony, because even if the district court erred in admitting the testimony, the error was harmless.

A North Dakota jury convicted Defendant of manufacturing methamphetamine, possessing methamphetamine, and possessing drug paraphernalia, all in violation of state law. After the North Dakota Supreme Court affirmed Defendant's conviction and the denial of his motion for state postconviction relief, Defendant filed a petition for writ of habeas corpus, arguing that the state court erred in requiring him to prove that his counsel's error was prejudicial under Strickland v. Washington. At issue on appeal was whether the wearing of prison clothing was necessarily prejudicial under United States v. Cronic, and therefore, a specific showing of prejudice was not required. The district court denied the petition. The Eighth Circuit Court of Appeals affirmed, holding that based on the record before the state courts, the decision of the Supreme Court was not an unreasonable application of clearly established law.

A jury convicted Appellant of four counts of deprivation of rights and two counts of making false statements. The district court sentenced Appellant to 120 months' imprisonment on the deprivation of rights counts and sixty months' imprisonment on each of the false statements counts, with all terms to be served concurrently. In imposing this sentence, the court applied an enhancement for physical restraint under U.S.S.G. 3A1.3 and an enhancement for aggravated assault resulting in serious bodily injury under U.S.S.G. 2A2.2. On appeal, Appellant challenged the application of the two enhancements. The Eighth Circuit Court of Appeals affirmed, holding (1) because Appellant moved his victims to an enclosed area to be assaulted, the district court did not err in applying the physical restraint enhancement; and (2) because Appellant had the requisite intent to assault his victims, the district court did not err in applying the enhancement for a crime resulting in serious bodily injury.

A jury found Appellant guilty of being a felon in possession of a firearm. The Eighth Circuit Court of Appeals affirmed, holding that the district court did not err by (1) permitting Appellant to represent himself pro se, as Appellant's waiver to counsel was knowing and voluntary and the district court adequately warned him of the dangers of self-representation; (2) denying Appellant's motion to suppress evidence recovered from a warrantless search of his vehicle; and (3) denying Appellant's motion for judgment of acquittal, as the evidence was sufficient to prove that Appellant knowingly possessed the weapons discovered in the truck he was driving.