Justia Criminal Law Opinion Summaries

Darrick Ferguson pleaded guilty to being a felon in possession of a firearm, in violation of federal law. At the time of sentencing, Ferguson had three prior felony convictions, one of which was under Arkansas law for delivery of a controlled substance—specifically, cocaine. The district court determined that all three prior convictions, including the Arkansas drug conviction, qualified as predicate offenses for an enhanced sentence under the Armed Career Criminal Act (ACCA), which mandates a minimum sentence for individuals with three or more prior convictions for “serious drug offenses.” Ferguson was sentenced to 180 months’ imprisonment.The United States District Court for the Eastern District of Arkansas found that Ferguson’s Arkansas conviction qualified as a serious drug offense under the ACCA. Ferguson appealed, contending that the Arkansas statute under which he was convicted criminalizes a broader range of cocaine isomers than are covered by the federal Controlled Substances Act, and therefore, his conviction should not count as a predicate offense for ACCA purposes.The United States Court of Appeals for the Eighth Circuit reviewed de novo whether Ferguson’s Arkansas conviction qualified as a predicate offense under the ACCA. Applying the categorical approach, the court held that the Arkansas statute criminalizes all cocaine isomers, while the federal law only covers specific ones. Because the Arkansas statute is broader and punishes conduct not included in the federal definition, Ferguson’s conviction does not qualify as a predicate offense under the ACCA. The Eighth Circuit vacated Ferguson’s sentence and remanded the case for resentencing without the ACCA enhancement. The court did not address Ferguson’s argument regarding his burglary conviction since the drug conviction was dispositive. View "United States v. Ferguson" on Justia Law

Robbie Dean Fetters was convicted by a jury in 2011 of several serious offenses, including being a felon in possession of a firearm, using or carrying a firearm in furtherance of a drug crime, conspiracy to distribute methamphetamine, distribution of methamphetamine, and possession with intent to distribute methamphetamine. Following his conviction, the United States District Court for the Southern District of Iowa imposed a downward-variant sentence of 320 months’ imprisonment and five years of supervised release. Fetters later developed multiple significant medical conditions, such as cirrhosis, diabetes, and complications with a feeding tube, and is classified by the Bureau of Prisons as a Level Three chronic care inmate.In 2020, Fetters sought compassionate release from the district court, arguing that his health issues warranted a reduction in his sentence. The district court denied the motion, finding that he did not establish that the sentencing factors under 18 U.S.C. § 3553(a) supported release. In 2024, Fetters renewed his motion for compassionate release, emphasizing the progression and severity of his medical conditions. Again, the United States District Court for the Southern District of Iowa denied the request, concluding that his medical needs, while serious, did not amount to “extraordinary and compelling reasons” for release and that the Bureau of Prisons could provide adequate care.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial for abuse of discretion. The appellate court held that the district court properly exercised its broad discretion, considered both the guideline and BOP definitions of “terminal illness,” and thoroughly evaluated Fetters’s health and criminal history. The court further found that the district court appropriately weighed the § 3553(a) factors and did not err in denying compassionate release. The judgment of the district court was affirmed. View "United States v. Fetters" on Justia Law

An 11-year-old child, L.D., was placed in foster care with Trina Mae Johnson. Over a period of fifteen months, Johnson inflicted severe abuse on L.D., including physical torture, starvation, denial of medical care, and psychological torment. The abuse resulted in significant weight loss, untreated injuries, and lasting trauma. Johnson concealed the abuse, enlisted others in her household to participate, and intimidated L.D. into silence. The abuse came to light when Johnson brought L.D. to a youth shelter, prompting an investigation by child services and the FBI.Johnson and several co-defendants were indicted on charges of child torture, child neglect, child endangerment, and assaulting a minor with a dangerous weapon in both federal and Minnesota state law violations. Some co-defendants pleaded guilty, while Johnson’s sister went to trial. Johnson was unable to accept a plea agreement because it was contingent on both sisters pleading guilty. She ultimately pleaded guilty without an agreement. The United States District Court for the District of Minnesota sentenced Johnson to 216 months in prison, after considering the relevant sentencing factors and victim impact statements. The sentence was below the government’s recommendation but above the prior plea offer.On appeal to the United States Court of Appeals for the Eighth Circuit, Johnson argued that the district court judge’s direct, sympathetic comments to L.D. at sentencing demonstrated judicial bias and violated her due process right to an impartial tribunal. The Eighth Circuit applied plain error review, noting Johnson did not object to the judge’s comments at sentencing or seek recusal. The court held that the judge’s empathetic remarks to the victim did not display deep-seated favoritism or antagonism that would make fair judgment impossible. Finding no plain error or due process violation, the Eighth Circuit affirmed the district court’s judgment. View "United States v. Johnson" on Justia Law

Jonathan Russell Wright was convicted by a jury in 2012 for possession with intent to distribute cocaine base, a federal offense, and sentenced to life imprisonment under the Controlled Substances Act. The life sentence was imposed due to three prior convictions under Arkansas law for cocaine-related offenses, which triggered a mandatory minimum enhancement. Years later, Congress enacted the First Step Act, which reduced mandatory minimum penalties for certain drug offenses but did not apply retroactively. Wright sought a sentence reduction in 2024, arguing that changes in law, including the First Step Act and recent case law, created a gross disparity between his sentence and what he would receive today. He claimed his prior Arkansas convictions should no longer qualify as predicate offenses for enhancement.The United States District Court for the Eastern District of Arkansas-Central granted Wright’s motion in part, reducing his sentence to 420 months and imposing ten years of supervised release. The court acknowledged the disparity created by the First Step Act as an “extraordinary and compelling reason” for reduction but rejected Wright’s argument that his prior Arkansas convictions could not serve as predicate offenses, citing prior decisions. Wright appealed, arguing for a lower sentence and challenging the district court’s treatment of his prior convictions and its weighing of sentencing factors.The United States Court of Appeals for the Eighth Circuit reviewed the case, first addressing whether President Biden’s commutation of Wright’s sentence to 330 months mooted the appeal. The Eighth Circuit held that the commutation did not moot the case, as courts retain authority over judicial sentences. On the merits, the court found that Wright’s Arkansas convictions no longer qualify as predicate offenses under federal law and that the district court abused its discretion by failing to consider this legal development. The Eighth Circuit vacated Wright’s sentence and remanded for resentencing consistent with its ruling. View "United States v. Wright" on Justia Law

An undercover law enforcement operation targeted individuals seeking to purchase sex from minors through an online platform known for prostitution ads. An agent created a fake profile of a 45-year-old woman but, upon contact, informed the defendant that "she" was actually 13 years old. Despite multiple text exchanges in which the defendant expressed reluctance to engage with someone underage, he continued the conversation, eventually requesting photos, discussing sexual acts, and arranging a meeting while being repeatedly reminded of the minor’s age. At the meeting site, agents seized his phone, which he attempted to wipe, erasing relevant evidence.The United States District Court for the Northern District of Iowa conducted a trial in which a jury convicted the defendant of attempted sex trafficking of a child and destruction of evidence. The court sentenced him to concurrent terms of 292 months and 240 months’ imprisonment. The defendant appealed, challenging the admission of lay-opinion testimony by the undercover agent regarding the perceived maturity of the fictitious minor’s responses, the denial of his request to contact a juror based on alleged outside influence, and the refusal to grant a downward sentencing variance on grounds of purported sentencing manipulation.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s rulings. The appellate court held that the agent’s lay-opinion testimony was appropriately admitted under Federal Rule of Evidence 701, as it was based on personal knowledge and aided the jury’s understanding. The court found no abuse of discretion in denying juror contact, as the defendant’s claims were speculative and unsupported by evidence of outside influence. Finally, the court rejected the sentencing manipulation claim, determining that law enforcement had a legitimate goal in targeting those seeking sex with very young minors and that the agent’s actions were not solely intended to enhance the sentence. The judgment was affirmed. View "United States v. Johnson" on Justia Law

Yuri Chachanko and an accomplice committed a series of armed robberies in South Dakota and Montana, leading to federal charges in both states. He was first prosecuted in Montana, where he received a 219-month sentence for Hobbs Act violations and firearm use. After completing that sentence, he faced prosecution in South Dakota, where he pleaded guilty to another firearm offense and was sentenced to 300 months, to be served consecutively after the Montana sentence. Years later, after legislative changes under the First Step Act, Chachanko sought a reduction of his South Dakota sentence, arguing that it was unusually long and that his medical conditions warranted relief.The United States District Court for the District of South Dakota considered his motion. The court focused on whether Chachanko had served at least 10 years of the South Dakota sentence, as required for a reduction based on an unusually long sentence under the Sentencing Guidelines. It found that, although Chachanko had spent 17 years in custody overall, he had only just begun serving the South Dakota sentence, as the sentences were consecutive. The court also found that his medical conditions were adequately managed and did not meet the standard for extraordinary and compelling reasons, and that no combination of circumstances justified relief.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The Eighth Circuit held that the phrase “the term of imprisonment” in the relevant statute and guidelines refers specifically to the sentence imposed by the court reviewing the motion—here, the South Dakota sentence—and not to an aggregate of multiple sentences. As Chachanko had not served 10 years of the South Dakota sentence, he was ineligible for relief on that basis. The court also found no abuse of discretion in denying relief based on medical or other circumstances. View "United States v. Chachanko" on Justia Law

A man was charged with several federal offenses, including being a felon in possession of a firearm, transporting a minor with intent to engage in prostitution, and possession of child pornography. The charges arose after he met a 16-year-old runaway through Craigslist, transported her across state lines, and engaged in a sexual relationship with her. Law enforcement discovered him with the minor, searched his residence, and found child sexual abuse material and multiple firearms. The defendant admitted to knowing the minor’s age and her mental health issues.He ultimately pled guilty to the firearm charge and one transportation count, with the remaining charges dismissed as part of a plea agreement. At sentencing in the United States District Court for the Southern District of Iowa, he received 292 months for transportation of a minor and 180 months for the firearm offense, to run concurrently. Thirteen days later, he moved to withdraw his guilty plea on the transportation count, arguing that he only learned at sentencing that the minor was missing and that this constituted exculpatory evidence the prosecution should have disclosed. The district court denied his motion, stating it lacked authority to consider post-sentencing withdrawal of a guilty plea except by direct appeal or collateral attack, and found that the minor’s unavailability was not exculpatory since public records of her status were available before the plea.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial under the abuse of discretion standard and affirmed. The appellate court held that Federal Rule of Criminal Procedure 11(e) barred post-sentencing withdrawal of a guilty plea except by direct appeal or collateral attack, and that no Brady violation occurred because the information about the minor’s status was publicly available. The court also declined to review the firearm sentence under the concurrent sentence doctrine, as any ruling would not affect the defendant’s time to be served. The judgment was affirmed. View "United States v. Adkins" on Justia Law

A federal grand jury charged the defendant with possessing methamphetamine with intent to distribute and being a felon in possession of a firearm. Task force officers at a bus station in Omaha, Nebraska identified the defendant’s suitcase as suspicious and removed it from the bus’s luggage compartment. After the defendant claimed and approached his bag, an officer questioned him about his travel plans and requested permission to search the suitcase, which the defendant consented to. The defendant then fled, prompting officers to detain him and search his belongings, ultimately discovering firearms and controlled substances.The defendant moved to suppress the evidence obtained from his suitcase, backpack, and person, arguing that the officers’ actions constituted unlawful searches and seizures under the Fourth Amendment. A magistrate judge recommended denying the suppression motion, concluding that the suitcase was not seized, the initial encounter was consensual, the consent to search was valid, and reasonable suspicion supported the later detention. The United States District Court for the District of Nebraska adopted the recommendation and denied the motion to suppress. At trial, a jury acquitted the defendant of possession with intent to distribute but found him guilty of simple possession and the firearms offense. The district court imposed consecutive sentences totaling 144 months’ imprisonment and a $2,500 fine, the latter without findings about the defendant’s ability to pay.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s denial of the suppression motion, holding there was no Fourth Amendment seizure of the suitcase, the initial encounter was consensual, the defendant’s consent to search was voluntary, and reasonable suspicion justified the post-flight detention. The court also affirmed the custodial sentence as substantively reasonable but vacated the fine, remanding for proper findings on the defendant’s ability to pay. View "United States v. Clay" on Justia Law

A member of the Sisseton Wahpeton Oyate tribe was observed by a tribal police officer driving erratically within the city limits of Sisseton, nearly causing multiple collisions and fleeing from law enforcement. He was apprehended in a tribal housing unit. Subsequently, the tribal prosecutor charged him in tribal court with driving under the influence (DUI) and resisting arrest, while South Dakota state court charged him with resisting arrest, reckless driving, and assaulting a law enforcement officer. He later pled guilty in state court to assault and was sentenced to two years in prison. The tribal court then dismissed the DUI charge without prejudice.He filed a federal lawsuit in the United States District Court for the District of South Dakota against various tribal officials, alleging that the DUI charge exceeded the tribe’s criminal jurisdiction and violated his rights under the Fourth Amendment and the Indian Civil Rights Act. The District Court dismissed the case for lack of subject matter jurisdiction, holding that the complaint failed to raise a federal question under 28 U.S.C. § 1331.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the dismissal. The court concluded that, even assuming it had jurisdiction to consider the scope of the tribe’s criminal authority, the case had become moot because the tribal DUI charge was dismissed and could not be refiled due to the expiration of the statute of limitations. The court found that neither the voluntary cessation exception nor the “capable of repetition, yet evading review” exception to mootness applied. Accordingly, the Eighth Circuit affirmed the district court’s judgment and vacated its decision, declining to address the underlying questions of tribal jurisdiction, sovereign immunity, or exhaustion of tribal remedies. View "LaBatte v. Gangle" on Justia Law

A police officer in Des Moines, Iowa attempted to stop a vehicle driven by Dylan Pettyjohn for lacking license plates or a temporary registration. Pettyjohn fled, leading the officer on a high-speed chase through a residential area before crashing. He then ran from the vehicle, discarding a loaded revolver and a fanny pack containing 54 fentanyl pills, $389 in small bills, marijuana, and about 85 grams of methamphetamine. A search of his vehicle yielded a digital scale with white residue, more marijuana, and shell casings. Pettyjohn was arrested, and a federal grand jury indicted him on multiple counts related to drug possession with intent to distribute, possession of a firearm in furtherance of a drug trafficking crime, and being a felon in possession of a firearm.The United States District Court for the Southern District of Iowa denied Pettyjohn’s motion to dismiss the felon in possession charge, rejecting his argument that 18 U.S.C. § 922(g)(1) violated the Second Amendment. The court also allowed limited admission of his prior felony convictions for impeachment purposes, after an agreement between Pettyjohn and the government. At trial, Pettyjohn moved for acquittal based on insufficient evidence, but the district court found the evidence sufficient and denied the motions. The jury found Pettyjohn guilty on all counts, and the court sentenced him to 300 months’ imprisonment.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the sufficiency of the evidence de novo, affirmed the district court’s evidentiary rulings under Rules 404(b) and 609, and upheld the constitutionality of § 922(g)(1) based on circuit precedent. The Eighth Circuit held that the evidence was sufficient to support the convictions, the district court did not abuse its discretion in admitting prior conviction evidence, and § 922(g)(1) is constitutional. The judgment of the district court was affirmed. View "United States v. Pettyjohn" on Justia Law