Justia Criminal Law Opinion Summaries

Defendant was convicted in Missouri state court and sentenced to life in prison for the first degree murder of his grandfather, armed criminal action, and second-degree arson. Defendant appealed the district court's denial of his petition for federal writ of habeas corpus, arguing that the state courts erred in finding him competent to stand trial and in concluding that trial counsel's failure to call the mental health professionals was not constitutionally defective performance. The court held that, based on the court's review of of the record, nothing suggested that defendant's behavior or demeanor at trial casted doubt on his competency or that counsel again raised this issue. The court also held that trial counsel's performance was not deficient by failing to present cumulative, no-more-favorable expert testimony. Because the court upheld the state court's resolution of the deficient performance issue, the court need not address the district court's alternative prejudice ruling.

Defendant was convicted of kidnapping in the first degree, attempted murder, and willful injury in violation of Iowa law. Defendant appealed the denial of his habeas corpus petition. The court held that even assuming defendant's counsel's performance was deficient for failing to challenge the evidence of the victim's injury and for failing to introduce evidence that she might have been psychotic, the district court correctly denied defendant's petition. Defendant failed to establish that the Iowa Court of Appeals unreasonably applied Strickland v. Washington or that it unreasonably found that there was sufficient evidence to prove serious injury.

Defendant was convicted of three counts relating to possession and manufacture of methamphetamine and one count of being a felon in possession of a firearm. Defendant appealed the district court's denial of his motions to suppress evidence and statements. The court held that because the district court did not clearly err in finding that defendant was outside his home at the time he was seized and because there was reasonable suspicion to support a Terry v. Ohio stop, the seizure of defendant's person was valid under the Fourth Amendment. Therefore, the court concluded that the evidence subsequently discovered and statements subsequently made were admissible.

Defendant was convicted of conspiracy to distribute and possess with intent to distribute heroin and possession of a firearm in furtherance of a drug trafficking offense. The court held that the district court did not abuse its discretion in finding that there was adequate time for defense counsel to prepare and the court could not find any abuse of discretion in denying defendant's motion to continue in order to substitute counsel. The district court satisfied its duty to inquire into defendant's claims regarding the breakdown of the attorney-client relationship and did not abuse its discretion in determining that the relationship between defendant and his defense counsel did not rise to the level of conflict necessitating a continuance and a new attorney. Defendant waived his right to object to the playback of wiretap tapes outside of his presence and the court rejected defendant's contention that the playback of the tapes for the injury amounted to structural error. Accordingly, defendant's conviction was affirmed.

Defendant appealed from the district court's imposition of a 135-month sentence on two counts of possession of child pornography. The court held that defendant waived his double jeopardy claim when he pled guilty to both counts of conviction and did not raise the double jeopardy argument; the district court did not clearly err in applying the five-level enhancement under U.S.S.G. 2G2(b)(3)(B) where the defendant had both received and distributed images via a file-sharing network and had done so knowingly; and the court did not abuse its discretion in denying defendant's request for a downward variance where the district court's sentence was not an abuse of discretion.

Defendant pled guilty to being a felon in possession of a firearm in violation of 18 U.S.C. 922(g)(1) and conceded the firearm was subject to forfeiture under 18 U.S.C. 924(d). On appeal, defendant argued that the district court clearly erred in finding that he had three prior convictions for violent felonies. The court rejected defendant's Shepherd v. United States claim; the court concluded that the district court was justified in rejecting defendant's claim that the misstatement of his date of birth casted doubt on the accuracy of the rest of his case history; and the court court concluded that defendant admitted the case history referred to him and the district court found the case history's multiple references to the burglary conviction to be internally consistent. Therefore, the district court properly applied the Armed Career Criminal Act, 18 U.S.C. 924(e)(1), enhancement.

Defendant was convicted of conspiracy to commit bank fraud, bank bribery, making false statements to a financial institution, and wire fraud and was sentenced to 78 months' imprisonment. Defendant appealed from his convictions and sentence. The court held that the district court adequately considered defendant's right to be represented by the counsel of his choice against the court's interest in the orderly administration of justice and that the district court did not abuse its discretion in denying a continuance for defendant to retain new counsel. In light of United States v. Hildebrand, the court could not say that the district court plainly erred in considering the statements defendant made at allocution. Accordingly, the convictions and sentence were affirmed.

Plaintiff appealed the district court's adverse grant of summary judgment on his 42 U.S.C. 1983 claim against several prison officials. Plaintiff, a pretrial detainee, was assaulted by three other inmates while he awaited trial. The court held that the evidence presented was insufficient to show that the prison officials knew or disregarded a known risk where plaintiff offered no evidence that the prison officials had any knowledge of any specified danger posed to plaintiff by another inmate in the protective custody pod. The court also held that plaintiff failed to offer evidence that prison officials provided constitutionally inadequate medical treatment. Accordingly, the judgment was affirmed.

Defendant was found guilty of three counts of mailing threatening communications, in violation of 18 U.S.C. 876(c), and one count of interstate communication of a threat, in violation of 18 U.S.C. 875(c). Defendant was sentenced to 88 months' imprisonment. Defendant appealed both his conviction and sentence. The court held that the district court did not violate defendant's right to self-representation; the district court did not abuse its discretion in quashing the witness subpoenas that defendant requested; there was sufficient evidence to support his convictions; defendant's conviction under section 876(c) did not violate his First Amendment rights; the district court did not err in assessing a two-level obstruction-of-justice enhancement; and defendant's sentence was reasonable.

Plaintiff filed suit pursuant to 42 U.S.C. 1983, alleging, inter alia, that his approximately 14-year detention in administrative segregation (Ad. Seg.) violated his procedural due-process rights under the Fourteenth Amendment because the periodic reviews of his detention were not meaningful. The district court subsequently found that four of the five defendants had in fact denied plaintiff due process by conducting meaningless Ad. Seg. review hearings and consequently, awarded him $4,846 in nominal damages - $1 for every day that plaintiff lived in Ag. Seg. - but denied plaintiff prayer for punitive damages. Both parties appealed. The court held that the district court did not clearly err in its factual findings as to the meaningfulness of plaintiff's Ad. Seg. reviews and affirmed that portion of the district court's decision. The court also held that plaintiff was entitled to no more than $1 for each procedurally defective Classification Committee hearing. Thus, based on this "per-constitutional-violation" analysis, the court reversed the district court's nominal damages award and remanded for recalculation. The court further held that it could not conclude that the district court abused its discretion on the record and affirmed the district court's denial of compensatory damages. The court finally held that the district court did not err in refusing to award plaintiff punitive damages.