Justia Criminal Law Opinion Summaries

A seven-year-old child, J.F., died from malnutrition and an infection caused by untreated head lice while living in a house on the Red Lake Indian Reservation in Minnesota. The home was shared by Sharon Rosebear, her husband, their son Derrick’s five children, and, starting in 2021, her son Julius and his five children, including J.F. The house lacked running water, but free showers and medical care were available nearby. Rosebear regularly provided food for Derrick’s children but not for Julius’s, including J.F., who was often kept home from school due to chronic head lice. In the days before J.F.’s death, Julius left his children in Rosebear’s care, and she acknowledged being responsible for them during that time. J.F. ultimately died on December 25, 2022. The autopsy revealed severe malnutrition and a prolonged lice infestation.The United States District Court for the District of Minnesota presided over Rosebear’s trial. The jury found her guilty of felony child neglect under the Major Crimes Act, which incorporates applicable Minnesota law. The district court denied Rosebear’s motion for acquittal or a new trial and sentenced her to 15 months in prison and two years of supervised release. Rosebear argued both that the evidence was insufficient to prove she was J.F.’s caretaker and that her sentence exceeded the state’s mandatory maximum under Minnesota’s sentencing guidelines, in violation of the Major Crimes Act and Supreme Court precedents.The United States Court of Appeals for the Eighth Circuit affirmed the conviction and sentence. The court held that sufficient evidence supported the jury’s finding that Rosebear was J.F.’s caretaker and had willfully deprived her of food and medical care. The court also held that the Major Crimes Act requires sentencing within the statutory minimum and maximum penalties set by state law, but not adherence to state sentencing guidelines; instead, the federal sentencing guidelines apply, as long as the sentence does not exceed the state statute’s maximum. View "United States v. Rosebear" on Justia Law

Law enforcement uncovered a large-scale fentanyl distribution conspiracy involving multiple individuals transporting fentanyl pills from Phoenix, Arizona, to the Twin Cities. The conspirators concealed pills inside stuffed animals and shipped them as birthday gifts, taking measures to evade detection. Da’Shawn Domena participated by coordinating, receiving, and delivering packages he knew contained fentanyl. Police intercepted some packages, but others were shipped undetected. A search of Domena’s apartment revealed fentanyl pills and other evidence linking him to the conspiracy. Domena admitted his involvement, specifically acknowledging the receipt and distribution of multiple packages containing fentanyl.The United States District Court for the District of Minnesota accepted Domena’s guilty plea to conspiracy to distribute 400 grams or more of fentanyl, an offense carrying a statutory minimum sentence of 120 months under 21 U.S.C. §§ 841(b)(1)(A), 846. Despite being eligible for safety-valve relief under 18 U.S.C. § 3553(f), which could have avoided the mandatory minimum, Domena chose not to cooperate with the government. The Presentence Investigation Report found him responsible for 30.8 kilograms of fentanyl and calculated a lower guidelines range, but the statutory minimum controlled. At sentencing, Domena argued that the mandatory minimum violated the Eighth Amendment’s prohibition on cruel and unusual punishment, citing his minor role, lack of criminal history, absence of violence, and personal struggles. The district court rejected this argument, referencing existing Eighth Circuit precedent.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed Domena’s Eighth Amendment challenge de novo. The court held that the mandatory minimum sentence was not grossly disproportionate to the crime and did not violate the Eighth Amendment. The court emphasized that circuit precedent consistently upholds mandatory minimum sentences for drug offenses and found Domena’s arguments unpersuasive. The Eighth Circuit affirmed the sentence imposed by the district court. View "United States v. Domena" on Justia Law

A man engaged in sexually explicit exchanges with a 13-to-14-year-old girl, during which he solicited and received images and videos depicting the minor’s genitalia and acts of self-penetration with a sex toy. His communications included explicit language suggesting rough and anal sex and requesting increasingly graphic content. After he received sexually explicit media from the minor, he was arrested and charged with several offenses, including sexual exploitation of a minor, receipt and possession of child pornography, and transfer of obscene material to a minor. He ultimately pled guilty to the receipt of child pornography.The United States District Court for the Southern District of Iowa applied a four-level sentence enhancement under U.S.S.G. § 2G2.1(b)(4)(A), reasoning that the material he received depicted sadistic or masochistic conduct or other depictions of violence, specifically the minor’s self-penetration with a foreign object. The court sentenced him to 240 months in prison. The defendant appealed, contending that the enhancement did not apply because the victim was not prepubescent, used a sex toy rather than another object, and appeared to experience sexual pleasure rather than pain.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s factual findings for clear error and its application of the Sentencing Guidelines de novo. The appellate court held that, under its precedent including United States v. Starr, acts of self-penetration by a minor with a foreign object constitute "violence" under the guideline, regardless of the minor’s age, the type of object, or whether the minor experienced pain. The appellate court affirmed the district court’s judgment, upholding the four-level enhancement. View "United States v. Vannausdle" on Justia Law

Patrick J. Newcomer was serving supervised release for two separate federal convictions related to burglary of a Post Office and possession of a firearm by a felon. After completing his prison terms and beginning supervised release, he was again convicted in state court of two counts of burglary and possession of a firearm by a prohibited person. These new convictions constituted violations of his federal supervised release conditions.Following Newcomer’s state convictions, the United States District Court for the District of Nebraska revoked his supervised release for both federal cases. The court imposed 24 months’ imprisonment for each federal conviction, to run concurrently, and ordered these terms to be served after his state sentences. Additionally, the district court imposed two terms of supervised release—12 months each—set to run consecutively upon his release from imprisonment. Newcomer appealed, arguing that under 18 U.S.C. § 3624(e), the new terms of supervised release should run concurrently.The United States Court of Appeals for the Eighth Circuit reviewed the legality of the district court’s revocation sentence de novo. It held that 18 U.S.C. § 3624(e) governs only the commencement of original supervised release terms and does not apply to supervised release imposed following revocation. Instead, 18 U.S.C. § 3583 provides the relevant authority, permitting a district court to impose additional supervised release upon revocation, and does not require such terms to run concurrently. The Eighth Circuit found that the district court acted within its discretion in imposing consecutive supervised release terms and affirmed the judgment. View "United States v. Newcomer" on Justia Law

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