Justia Criminal Law Opinion Summaries

Deoman Reeves was convicted by a jury of eleven counts related to narcotics and firearms offenses. The charges stemmed from a series of events in 2019, including a shooting incident in University City, Missouri, and subsequent involvement in drug and firearms trafficking. Reeves was identified as a primary suspect in the shooting and was linked to a narcotics trafficking organization. He was involved in a retaliatory shooting that resulted in the death of a bystander, David Anderson, whom Reeves mistakenly believed to be a rival drug trafficker. Reeves was later involved in several controlled buys of fentanyl and firearms set up by ATF agents.The United States District Court for the Eastern District of Missouri denied several of Reeves's pretrial motions, including a motion to suppress location data obtained from his cellphones and a motion to sever the count charging him with possession of a firearm in furtherance of a drug trafficking crime resulting in death. The district court also denied Reeves's motions for judgment of acquittal and for a new trial. Reeves was sentenced to life imprisonment on one count, 120 months on seven counts to be served concurrently, and 60 months on three counts to be served consecutively.The United States Court of Appeals for the Eighth Circuit reviewed the case and found no reversible error. The court held that the district court did not abuse its discretion or plainly err in denying the motion to sever, as the offenses were connected to the same drug trafficking conspiracy. The court also upheld the denial of the motion to suppress, finding that the warrants were supported by probable cause and sufficiently particular. The court affirmed the denial of the motion for judgment of acquittal, concluding that sufficient evidence supported the convictions. Finally, the court determined that Reeves waived his challenges to the jury instructions by not objecting during the trial. The judgment of the district court was affirmed. View "United States v. Reeves" on Justia Law

Alexander Laurel-Olea pleaded guilty to unlawful possession of a firearm as an unlawful user of a controlled substance and was sentenced to twenty-four months’ imprisonment and thirty-six months of supervised release. After serving his sentence, he began his supervised release on August 30, 2022. In June 2024, he was arrested for committing fifty-four violations of his supervised release conditions. The district court sentenced him to fourteen months’ imprisonment and a one-year term of supervised release.The United States District Court for the Northern District of Iowa determined that the advisory guideline range for Laurel-Olea’s violations was three to nine months’ imprisonment. The court considered both mitigating and aggravating factors. Mitigating factors included his age, lack of adult criminal history, mental health and substance abuse issues, and acceptance of responsibility. Aggravating factors included his involvement in a dangerous shooting, fifty-four violations of release conditions, becoming a fugitive, and failing to meet his restitution obligation.The United States Court of Appeals for the Eighth Circuit reviewed the case. Laurel-Olea argued that his sentence was unreasonable under 18 U.S.C. § 3583(e), claiming it was disproportionate and did not account for his mental health issues, background, and potential for reintegration. The appellate court applied a deferential abuse-of-discretion standard, noting that it is rare to reverse a district court sentence as substantively unreasonable.The Eighth Circuit found that the district court did not abuse its discretion. The court had considered relevant factors and provided a reasoned explanation for the upward variance from nine to fourteen months, including credit for accepting responsibility. The judgment of the district court was affirmed. View "United States v. Laurel-Olea" on Justia Law

Moses Crowe was convicted of aiding and abetting a carjacking resulting in serious bodily injury, aiding and abetting the use of a firearm during and in relation to a crime of violence, and unlawful possession of a firearm as a felon. The incident involved Crowe and his accomplices forcing Phillip Moore at gunpoint to drive a van, assaulting him, and subsequently beating him unconscious. Crowe was sentenced to 235 months’ imprisonment.The United States District Court for the District of South Dakota initially sentenced Crowe, applying a four-level increase under the sentencing guidelines for abduction. Crowe appealed, arguing that the court erred in applying this increase and improperly considered conduct not relevant to his sentencing guideline range. The court also remanded for resentencing after vacating one of Crowe’s convictions and reducing it to a lesser charge.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court properly considered Crowe’s conduct at Nike Road under the sentencing factors of 18 U.S.C. § 3553(a) and correctly applied the four-level increase for abduction. The court determined that Moore was abducted to facilitate the escape from the carjacking scene, thus justifying the increase. Additionally, the court held that the district court did not abuse its discretion in sentencing Crowe within the advisory range and adequately considered the § 3553(a) factors. The Eighth Circuit affirmed the judgment of the district court, upholding Crowe’s 235-month sentence. View "United States v. Crowe" on Justia Law

Robert Cottier was driving with a suspended license and a high blood alcohol concentration when he collided head-on with Cheryl Cross' vehicle, causing serious injuries to Cross and her passengers. Cottier's passenger, Harold Long Soldier, died from the crash. Cottier was charged with involuntary manslaughter and four counts of assault resulting in serious bodily injury. He pleaded guilty to the manslaughter charge and one count of assault.The United States District Court for the District of South Dakota accepted Cottier's guilty plea. The plea agreement included a government recommendation for sentences within the applicable Guideline range to run consecutively. The Presentence Investigation Report calculated a total offense level of 21, resulting in a guideline range of 37-46 months. The government’s Sentencing Memorandum recommended a 73-month sentence, which Cottier argued breached the plea agreement. The district court varied upwards and sentenced Cottier to 96 months, explaining the decision was based on the severity of the injuries and Cottier's history of DUI offenses.The United States Court of Appeals for the Eighth Circuit reviewed the case. Cottier argued that the government breached the plea agreement by recommending a 73-month sentence. The court found no breach, noting that the government’s final position at the sentencing hearing aligned with the plea agreement. The court also determined that any potential breach in the Sentencing Memorandum did not affect the district court’s decision to impose a 96-month sentence. The Eighth Circuit affirmed the district court’s judgment, concluding that the government honored its plea agreement obligations and that the district court’s sentence was justified. View "United States v. Cottier" on Justia Law

Melissa Wanna discovered her profile on MyLife, an information broker, which contained a poor reputation score and references to court records. MyLife offered to provide details or remove the profile for a fee. Believing she lost employment opportunities due to this profile, Wanna filed a class action lawsuit against several Lexis entities, alleging violations of the Fair Credit Reporting Act (FCRA), Driver’s Privacy Protection Act (DPPA), and the federal Racketeer Influenced and Corrupt Organizations Act (RICO), along with several Minnesota state law claims.The United States District Court for the District of Minnesota dismissed Wanna’s claims, concluding that MyLife was not Lexis’s agent. The court found that the data-licensing agreement between Lexis and MyLife explicitly stated that their relationship was that of independent contractors, not principal and agent. As a result, Wanna’s federal claims, which depended on an agency relationship, failed. The district court also declined to exercise supplemental jurisdiction over Wanna’s state law claims and dismissed them without prejudice.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo and affirmed the dismissal. The appellate court agreed that Wanna’s federal claims required an agency relationship between Lexis and MyLife, which was not established. The court found that MyLife did not have actual or apparent authority to act on Lexis’s behalf, nor did Lexis ratify MyLife’s actions. Additionally, the appellate court held that the district court did not abuse its discretion in declining to exercise supplemental jurisdiction over the state law claims. View "Wanna v. RELX Group, PLC" on Justia Law

Milton Porter pled guilty to being a felon in possession of a firearm, violating 18 U.S.C. § 922(g)(1). The district court sentenced him to 200 months in prison under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e), based on three prior violent felony convictions: a 2008 domestic assault in the second degree, a 2018 domestic assault in the second degree, and a 2018 domestic assault in the third degree, all under Missouri law. Porter appealed, arguing he did not have the requisite three prior violent felony convictions to qualify as an armed career criminal.The United States District Court for the Eastern District of Missouri determined that each of Porter's domestic assault convictions qualified as violent felonies under the ACCA. The court did not address whether Porter’s 2018 Missouri conviction for burglary in the second degree qualified as a violent felony, as the domestic assault convictions were sufficient for the ACCA enhancement.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court applied the modified categorical approach to determine that Porter's 2008 and 2018 second-degree domestic assault convictions were violent felonies under the ACCA, as they involved knowingly causing physical injury. The court also determined that Porter's 2018 third-degree domestic assault conviction was a violent felony, as it involved attempting to cause physical injury. The court affirmed the district court's judgment, holding that Porter’s three domestic assault convictions were violent felonies under the ACCA, justifying the sentence enhancement. View "United States v. Porter" on Justia Law

Law enforcement officers suspected Bandak Wiyual Deng of involvement in a shooting at a park on February 10, 2022. Surveillance video showed an individual matching his characteristics exiting a car with what appeared to be a gun. The car, a black Ford Taurus, lacked a license plate or paper registration tag. A confidential informant recorded a conversation with Deng, where Deng mentioned needing a gun for a funeral and a previous shooting. On the day of the funeral, officers stopped Deng, found marijuana and a gun in his car, and Deng admitted to using drugs and touching the gun.The United States District Court for the Southern District of Iowa upheld the government's peremptory strikes of two prospective jurors and refused to admit parts of Deng's interview with law enforcement. Deng's motion for a judgment of acquittal, arguing that 18 U.S.C. § 922(g)(3) violated the Second Amendment, was denied. The jury convicted Deng.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not clearly err in overruling Deng’s objections to the peremptory strikes, as the government provided race-neutral explanations. The court also found that any potential error in the district court's evidentiary rulings was harmless, given the ample evidence supporting Deng’s conviction. Finally, the court affirmed the denial of Deng’s motion for a judgment of acquittal, rejecting his facial challenge to the constitutionality of 18 U.S.C. § 922(g)(3). The judgment was affirmed. View "United States v. Deng" on Justia Law

Edgar Pratt was on supervised release after serving a prison term for possession with intent to distribute fentanyl. He violated the terms of his release multiple times, including accessing a firearm, communicating with a prohibited party, sending threatening messages, and absconding from a residential reentry center. After absconding, he ceased communication with his probation officer and failed to complete the reentry program. He was arrested eight months later.The United States District Court for the Western District of Missouri held a hearing, revoked Pratt's supervised release, and sentenced him to 24 months' imprisonment. Pratt appealed, challenging the procedural soundness and substantive reasonableness of his sentence.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court adequately explained its decision, noting Pratt's extensive criminal history and resistance to supervision. The district court's reference to Pratt's "bobbles" while on supervision was not plain error, as the court was familiar with his history. The appellate court also found no abuse of discretion in the district court's consideration of the § 3553(a) factors, including Pratt's criminal history and characteristics. The court held that the district court did not place undue weight on improper factors and acted within its discretion in imposing the statutory maximum sentence.The Eighth Circuit affirmed the judgment of the district court, upholding Pratt's 24-month imprisonment sentence. View "United States v. Pratt" on Justia Law

Louis Rabbitt was convicted by a jury of failing to register as a sex offender, assaulting a federal officer with a deadly weapon, and committing a crime of violence while failing to register as a sex offender. His probation officer testified that Rabbitt missed a scheduled meeting and was not found at his registered address. Deputy U.S. Marshals later found Rabbitt in a parked car, holding a metal baseball bat, and after a chase, he was captured and subdued.The United States District Court for the District of South Dakota denied Rabbitt's motion for a judgment of acquittal, which argued that the evidence was insufficient to support his convictions. The court found that a reasonable jury could conclude that Rabbitt had moved out of his registered residence and failed to update his registration as required. Additionally, the court found that Rabbitt's actions with the baseball bat constituted a threat or display of physical aggression towards the officers.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decision de novo, considering the evidence in the light most favorable to the verdict. The appellate court affirmed the district court's decision, holding that sufficient evidence supported Rabbitt's convictions. The court found that Rabbitt knowingly failed to update his registration, used the bat to inspire fear in the officers, and that his actions were intentional. Consequently, the court upheld Rabbitt's convictions for failing to register as a sex offender, assaulting a federal officer, and committing a crime of violence while failing to register. View "United States v. Rabbitt" on Justia Law

In early 2023, investigators conducted six controlled buys of fentanyl pills from Tyran Locure, with Anthony Jackson, Jr. present for two of these buys, which took place in Jackson’s vehicle. A GPS tracker on Jackson’s vehicle showed it frequently parked at an apartment building in Des Moines, Iowa, where both Jackson and Locure were surveilled. A search warrant executed at the apartment found firearms, thousands of fentanyl pills, marijuana, cocaine, cell phones, and a money counter. Jackson’s wallet and documents were also found in the apartment, and $2,263 in cash, including serialized money from a controlled buy, was found on Jackson.The United States District Court for the Southern District of Iowa charged Jackson with conspiracy to distribute controlled substances, possession with intent to distribute fentanyl, possession of firearms in furtherance of a drug trafficking crime, and being a felon in possession of firearms. The jury convicted Jackson on all counts, and the district court sentenced him to 270 months of imprisonment, revoked his supervised release, and added 30 months for violating supervised release terms.The United States Court of Appeals for the Eighth Circuit reviewed Jackson’s appeal, which challenged the admission of a forensic report, evidence of prior bad acts, and the sufficiency of evidence for the conspiracy conviction. The court held that Jackson waived his confrontation rights by stipulating to the forensic report’s findings. The court also found that the admission of evidence of Jackson’s prior conviction and firearm photographs was proper and not unduly prejudicial. Finally, the court concluded that sufficient evidence supported Jackson’s conspiracy conviction, given the controlled buys, GPS data, and items found during the search. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Jackson" on Justia Law