Justia Criminal Law Opinion Summaries

Defendant, a Mexican citizen, pled guilty to conspiracy to distribute methamphetamine and re-entry as a previously removed alien. The district court imposed a 420-month sentence. Defendant appealed the denial of his motion to dismiss for improper venue and his sentence. The Eighth Circuit affirmed, holding (1) venue was proper in the Northern District of Iowa because authorities learned of Defendant's deportation in the Northern District; (2) the district court did not err procedurally by applying an importation enhancement and refusing to grant an acceptance-of-responsibility reduction; and (3) the district court did not abuse its discretion in imposing a 420-month sentence, as the sentence was substantively reasonable.

Defendant pled guilty to being a felon in possession of a firearm and defendant subsequently appealed his sentence of 65 months imprisonment. The court concluded that the district court committed no procedural error and that his sentence was also substantively reasonable where the district court did not abuse its considerable discretion in weighing the 18 U.S.C. 3553(a) factors.

Plaintiff filed suit under the Federal Tort Claims Act, 28 U.S.C. 2671-2680, alleging that employees of the United States negligently caused significant delay in the proper treatment of leg injuries that he suffered while an inmate at the Federal Correction Institution in Forest City, Arkansas. The district court found that the government was liable and awarded compensatory damages. The government subsequently appealed the amount of damages. The court concluded that an award of $813,000 in this case was generous but the court could not conclude that the decision of the experienced district judge was "monstrous" or "shocking" or that it resulted in a "plain injustice." Therefore, the court affirmed the judgment under the deferential standard of review that applied to an award of damages in a bench trial.

Plaintiff, a Missouri inmate serving life sentences, filed a 42 U.S.C. 1983 action against various MDOC correction officials and medical staff, asserting claims of deficient medical care and treatment, retaliation, and harassment. The district court dismissed the pro se complaint without prejudice, agreeing with defendants that plaintiff failed to exhaust available prison remedies, as required by the Prison Litigation Reform Act of 1995 (PLRA), 42 U.S.C. 1997e(a). The court concluded that some claims were properly exhausted; therefore, the court affirmed in part, reversed in part, and remanded for further proceedings; and the court denied as moot plaintiff's contention that the district court abused its discretion in denying his motion for appointment of counsel in the district court, and his motion for appointment of counsel on appeal.

Defendant pled guilty to burglary in violation of 18 U.S.C. 1153 pursuant to a plea agreement. Defendant subsequently appealed his sentence. The court held that the district court did not err in crediting the sentencing testimony of two eyewitnesses; the district court correctly entered an upward departure under U.S.S.G. 5K2.21; the district court was allowed to consider uncharged conduct, an attempted sexual assault, in entering an upward departure; and the sentence was substantively reasonable.

Defendant pled guilty to two counts of distributing five grams or more of cocaine base. Defendant was released pending sentencing and subsequently arrested for robbery. Defendant then appealed his sentence, arguing that the district court erred procedurally by denying him the three-level reduction for acceptance of responsibility. The court affirmed the district court's finding that defendant's arrest for robbery and his attempts to manufacture exculpatory evidence meant that he was not entitled to the reduction. Accordingly, the court affirmed the judgment.

Plaintiff brought a 42 U.S.C. 1983 action, alleging that his federal and state constitutional rights were violated when defendants unlawfully seized, searched, and detained him. Defendants moved for summary judgment on the basis of qualified immunity. The court concluded that defendants were entitled to consideration by the district court of their claims to qualified immunity as to each of the constitutional claims asserted against them. Therefore, the court remanded the matter to the district court to engage in a full qualified immunity analysis in the first instance.

Defendant was convicted of attempting to induce a child to engage in criminal sexual activities. On appeal, defendant challenged his conviction and sentence. The court held that the district court did not err in denying defendant's requested entrapment defense where defendant failed to introduce evidence to warrant a finding by a jury that he had been entrapped. The court also held that the evidence was sufficient to convict him of attempting to induce a child to engage in criminal activity. Finally, there was no abuse of discretion in the district court's imposition of defendant's sentence. Accordingly, the court affirmed the conviction and sentence.

Defendant pled guilty to being a felon in possession of a firearm under 18 U.S.C. 922(g) and 924(a)(2). Defendant appealed his sentence, challenging the district court's application of the Sentencing Guidelines and arguing that his sentence was substantively unreasonable. The court held that, regardless of the standard of review and even assuming the court erred procedurally in its application of U.S.S.G. 4A1.3, any such error was harmless because of that court's alternative reliance on an upward variance. The court also held that there was no abuse of discretion in that court's decision to impose a sentence of 80 months imprisonment. Accordingly, the court affirmed the sentence.

Defendant was convicted of distributing 50 grams or more of methamphetamine and conspiring to distribute more than 500 grams of methamphetamine. Defendant moved under 28 U.S.C. 2255 to vacate his sentence, alleging ineffective assistance of counsel. The district court denied his motion and a certificate of appealability. At issue was whether the district court should have held an evidentiary hearing before denying the motion. The court held that because the record conclusively showed that defendant was not entitled to relief, no evidentiary hearing was required.