Justia Criminal Law Opinion Summaries

Jeremy Young was convicted by a jury of possessing an unregistered firearm and being a felon in possession of a firearm. He was also convicted by a separate jury of assaulting a federal officer. Young received a total sentence of 84 months’ imprisonment and 3 years of supervised release. He appealed, challenging the Government’s use of peremptory strikes against Native American venirepersons, the district court’s decision to admit certain evidence as res gestae, and the sufficiency of the evidence at both trials.The United States District Court for the District of South Dakota denied Young’s Batson challenges, finding the Government’s reasons for striking the Native American jurors to be legitimate and race-neutral. The court also admitted excerpts of Young’s recorded interview with Agent Kumley, where Young discussed his plans to transport methamphetamine, as relevant res gestae evidence. The jury found Young guilty on all counts.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s rulings. The appellate court found no clear error in the district court’s Batson analysis, noting that the Government provided race-neutral reasons for striking the jurors and that Young failed to demonstrate pretext. The court also upheld the admission of the recorded interview, agreeing that it provided relevant context for Young’s possession of the shotgun. Finally, the court concluded that the evidence was sufficient to support Young’s convictions, as the jury reasonably found that Young had both actual and constructive possession of the firearm and that he intentionally assaulted Sergeant Antoine. View "United States v. Young" on Justia Law

Police discovered 788 pounds of marijuana and related paraphernalia in a Minnesota warehouse, where Danny Gehl and five others were present. Gehl was charged with conspiracy to distribute marijuana and possession with intent to distribute marijuana. Evidence included surveillance, searches of Gehl’s home, and his phone, revealing marijuana, cash, and drug paraphernalia. Gehl was convicted and sentenced to 120 months’ imprisonment, the mandatory minimum.The United States District Court for the District of Minnesota handled the initial trial. Gehl was convicted on both counts, and the court sentenced him to the mandatory minimum of 120 months. Gehl appealed, arguing insufficient evidence for his conviction and improper denial of safety-valve relief and a minor-participant downward adjustment at sentencing.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the evidence was sufficient to support Gehl’s conviction, noting his involvement in the conspiracy and the substantial amount of marijuana involved. The court also found no error in the district court’s denial of safety-valve relief, as Gehl’s proffer was not truthful. Lastly, the court deemed the issue of the minor-participant adjustment moot, as Gehl’s sentence would remain the same due to the mandatory minimum. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Gehl" on Justia Law

Kira Zielinski took her minor child to Mexico to deprive her ex-husband of his parental rights. Upon returning to the United States, she was indicted for international parental kidnapping under 18 U.S.C. § 1204(a). After a bench trial, the United States District Court for the Southern District of Iowa found her guilty and sentenced her to 36 months in prison. Zielinski appealed, arguing that the district court wrongly prevented her from presenting evidence that she fled to protect her child from sexual abuse by the father.The district court ruled that 18 U.S.C. § 1204(c)(2), which provides an affirmative defense for fleeing domestic violence, did not apply because Zielinski did not claim she was a victim of domestic violence herself. The court interpreted the statute to mean that the defense only applies if the defendant, not a third party like Zielinski’s child, suffered domestic violence. Zielinski contended that the statute should cover situations where the defendant aids a third party in escaping domestic violence, but the district court disagreed.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s interpretation of § 1204(c)(2) de novo and affirmed the lower court’s decision. The appellate court held that the statute’s plain language does not include defense of a third party and that Congress could have explicitly included such language if intended. The court also rejected Zielinski’s arguments that the statute is void for vagueness and that the district court’s interpretation violated the rule of lenity, finding the statute’s language clear and unambiguous. Consequently, the appellate court affirmed the district court’s judgment. View "United States v. Zielinski" on Justia Law

Clint Schram was convicted by a jury of multiple offenses related to his operation of child pornography websites. He was sentenced by the district court to a life term and four concurrent thirty-year terms of imprisonment. Schram appealed, arguing that the evidence was insufficient to support his convictions, that the district court improperly admitted multiple images of child pornography into evidence, and that the district court erred in calculating his guidelines sentencing range and imposing an overlong sentence.The United States District Court for the Western District of Missouri initially reviewed the case. The court found Schram guilty on five counts: four counts of advertising child pornography and one count of engaging in a child exploitation enterprise. The court admitted multiple images of child pornography into evidence and calculated Schram's guidelines sentencing range, ultimately imposing a life sentence and four concurrent thirty-year terms.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the evidence was sufficient to support Schram's convictions, as the jury could reasonably determine that the images depicted real children. The court also found no reversible error in the district court's admission of multiple images of child pornography, as they were highly probative and not unduly prejudicial. Additionally, the court upheld the district court's calculation of Schram's guidelines sentencing range and found his sentence to be substantively reasonable, given the seriousness of his offenses and his dangerous behavior.The Eighth Circuit affirmed Schram's convictions and sentence, concluding that there was no reversible error in the district court's decisions. View "United States v. Schram" on Justia Law

Jon Thomas Kucharo was convicted of transportation and receipt of explosives with intent, and unlawful receipt and possession of destructive devices. He conditionally pleaded guilty after the district court denied his motion to suppress evidence obtained from searches of his van and cell phone. Kucharo appealed, arguing that the district court erred in denying his motion to suppress evidence from the second search of his van and in determining that a state court harassment conviction was not relevant conduct for sentencing purposes.The Scott County District Court convicted Kucharo of first-degree harassment for threatening an Iowa county prosecutor. On the same day, investigators found a pontoon boat damaged by a homemade pipe bomb. Witnesses linked Kucharo to the explosion, and investigators found incriminating evidence in his van and cell phone. Kucharo moved to suppress evidence from the second search of his van, claiming the warrant was invalid due to a false statement in the supporting affidavit. The district court denied the motion, finding no Fourth Amendment violation and that any procedural sentencing error was harmless.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that there was no Fourth Amendment violation because the affidavit provided sufficient probable cause for the second search warrant, even without the contested statement. The court also found that any procedural error in sentencing was harmless, as the district court stated that the relevant conduct determination did not affect its ultimate sentencing decision. The court affirmed the district court's judgment, upholding Kucharo's conviction and sentence. View "United States v. Kucharo" on Justia Law

Derrecol Jennings was pulled over by St. Louis police officers for having improperly registered plates. A record check revealed active municipal arrest warrants and past felony convictions. Jennings informed officers of a gun under the middle seat, and they found a loaded semiautomatic pistol and magazines with ammunition. Jennings was indicted on one charge of illegally possessing a firearm. He entered a plea agreement, agreeing to plead guilty in exchange for a joint recommendation of 40 months’ imprisonment.The United States District Court for the Eastern District of Missouri sentenced Jennings to 54 months’ imprisonment, despite the joint recommendation. Jennings argued that the government breached the plea agreement by informing the court of a mistake in calculating his criminal history score and that his sentence was substantively unreasonable.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the government did not breach the plea agreement. The government had made the promised recommendation for 40 months’ imprisonment and only mentioned the miscalculation in response to the court’s skepticism. The court also found that Jennings’s 54-month sentence was substantively reasonable. The district court had adequately considered the relevant factors under 18 U.S.C. § 3553(a) and provided a sufficient explanation for the sentence, emphasizing Jennings’s pattern of legal violations and the need to promote respect for the law.The Eighth Circuit affirmed the 54-month sentence imposed by the district court. View "United States v. Jennings" on Justia Law

In 2022, Theodore Watkins, Jr. approached an elderly woman's home, offering to mow her lawn. After she declined, he returned with a handgun, forced his way inside, and demanded money. He took $40 from her purse and searched the house for valuables while holding her at gunpoint. A neighbor witnessed the forced entry and called the police. When officers arrived, Watkins tried to cover up his crime by instructing the homeowner to lie about his presence. The homeowner heard a noise from the furnace vent and suspected Watkins had hidden the gun there. Police later found the firearm in the furnace.The United States District Court for the Western District of Missouri admitted testimony from Sergeant Jeff Pagel, who had discovered the firearm. Watkins objected to this testimony, claiming it was unnoticed expert testimony. The district court overruled the objection, and the jury convicted Watkins of unlawfully possessing a firearm as a felon. He was sentenced to 120 months in prison.The United States Court of Appeals for the Eighth Circuit reviewed the case. Watkins argued that the district court erred in admitting Sergeant Pagel's testimony and that his trial counsel was ineffective for not seeking a continuance. The Eighth Circuit found that Sergeant Pagel's testimony was proper lay opinion based on his firsthand knowledge and personal experience, not requiring expert disclosure. The court also declined to review the ineffective assistance of counsel claim, as the record was not fully developed for such a review. Consequently, the Eighth Circuit affirmed Watkins's conviction. View "United States v. Watkins" on Justia Law

Edrick Denorris Ellis was stopped by Arkansas State Trooper Dean Pitchford for a hanging taillight. Ellis, a passenger, fled and was pursued by Trooper Cleyton McDonald. During the chase, Ellis threw an object over a fence, which was later found to be a 9mm handgun. Ellis was charged with being a felon in possession of a firearm. At trial, multiple troopers testified, and dashboard camera footage was presented showing Ellis tossing an object. The jury found Ellis guilty.The United States District Court for the Eastern District of Arkansas sentenced Ellis to 120 months’ imprisonment and 2 years of supervised release. Ellis appealed, challenging the sufficiency of the evidence and the classification of his prior Arkansas robbery convictions as crimes of violence under the Sentencing Guidelines.The United States Court of Appeals for the Eighth Circuit reviewed the sufficiency of the evidence de novo, affirming the conviction. The court found that the evidence, including the dashboard camera footage, was sufficient for a reasonable jury to conclude that Ellis knowingly possessed the firearm. The court also reviewed the classification of Ellis' prior robbery convictions for plain error, as Ellis did not raise this argument in the lower court. The court held that Arkansas robbery qualifies as a crime of violence under the enumerated offenses clause of the Sentencing Guidelines, referencing previous decisions that align Arkansas robbery with generic robbery. The court concluded that there was no error in the district court's calculation of Ellis' Sentencing Guidelines range or the sentence imposed. The judgment of the district court was affirmed. View "United States v. Ellis" on Justia Law

Larry Bradley was convicted of four gun offenses related to the fatal shooting of Thomas Willett. Bradley admitted to shooting Willett but claimed it was in self-defense as Willett allegedly came at him with a hatchet. Bradley was charged with being a felon in possession of a firearm, stealing a firearm, possession of a stolen firearm, and receiving a firearm while under indictment. He was convicted on all counts.The United States District Court for the Western District of Missouri initially applied the United States Sentencing Guidelines (USSG) cross-reference for voluntary manslaughter, rejecting Bradley's self-defense claim. The court considered witness testimony and the Presentence Investigation Report (PSR), which contained conflicting accounts of the incident. The court found the testimony of Dena Bunger, a witness to the shooting, credible and determined that Bradley did not act in self-defense. Bradley was sentenced to 120 months' imprisonment.Bradley appealed, arguing that the district court erred in applying the cross-reference and that Counts 2 and 3 were multiplicitous. The Government agreed that it had erroneously described Bunger’s testimony and that Counts 2 and 3 were multiplicitous. The United States Court of Appeals for the Eighth Circuit vacated and remanded the case. On remand, the district court dismissed Count 3 and reaffirmed the application of the voluntary manslaughter cross-reference, sentencing Bradley to 108 months' imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case and found no clear error in the district court’s factual findings. The court affirmed the district court’s application of the voluntary manslaughter cross-reference, noting that the district court’s credibility determinations and inferences from the evidence were entitled to deference. The judgment of the district court was affirmed. View "United States v. Bradley" on Justia Law

Kyle Syphax was sentenced to 84 months in prison after pleading guilty to possession of a firearm by a felon, violating 18 U.S.C. § 922(g)(1) and 18 U.S.C. § 924(a)(8). He contested the calculation of his criminal history score, which was based on his prior convictions.The United States District Court for the Eastern District of Missouri calculated Syphax's criminal history score by assigning three points for each of his three state felony cases, resulting in a subtotal of 13 criminal history points. This calculation included points for committing the federal offense while on probation. Syphax argued that his criminal history score should be lower, asserting that only one of his prior sentences should receive three points, while the others should receive one point each, resulting in a total of 10 points.The United States Court of Appeals for the Eighth Circuit reviewed the district court's interpretation of the sentencing guidelines de novo and its factual findings for clear error. The court found that the district court correctly calculated Syphax's criminal history score. The court determined that Note 11 to Section 4A1.2 of the sentencing guidelines, which Syphax relied on, did not apply because the state court had ordered three separate revocations for his three state felony cases. The court concluded that each case should receive three points, as the state court revoked probation and ordered prison sentences in separate cases.The Eighth Circuit affirmed the district court's judgment, upholding Syphax's 84-month prison sentence. View "United States v. Syphax" on Justia Law