Justia Criminal Law Opinion Summaries

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

Devon Holt was charged with being a felon in possession of a firearm after investigators obtained a warrant to search his Facebook account and found posts and messages referencing firearms. These included statements suggesting he was carrying a firearm and expressing motives related to self-protection and respect. Holt pleaded not guilty, and his case proceeded to trial. He objected to the admission of this Facebook content, arguing it was prejudicial, but the district court admitted some of the posts for the limited purpose of showing knowledge and motive, instructing the jury accordingly. The jury convicted Holt.The United States District Court for the District of Minnesota sentenced Holt to 42 months’ imprisonment, slightly above the minimum of the guideline range. Holt argued for a lower sentence, citing difficult pretrial detention conditions and uncertainty before sentencing. The district court explained its reasoning in detail, acknowledging both aggravating and mitigating factors, including Holt’s positive use of his time in jail. Holt then appealed, challenging both the admission of the Facebook evidence and the adequacy of the sentencing explanation.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s evidentiary and sentencing decisions. It held that the Facebook content was properly admitted under Federal Rule of Evidence 404(b) because it was relevant to issues of Holt’s knowledge and motive and was not unfairly prejudicial. The appellate court also found that the district court gave a sufficiently detailed explanation for its sentencing decision, considered the relevant factors, and imposed a substantively reasonable sentence. Consequently, the Eighth Circuit affirmed both the conviction and the sentence. View "United States v. Holt" on Justia Law

Raphael Nunn was convicted of kidnapping, bank fraud, and aggravated identity theft based on three incidents involving separate victims. In the first incident, Nunn robbed C.L. at gunpoint and stole her purse, later using her bank cards for unauthorized purchases. The second incident involved the theft of J.T.’s backpack, which contained her bank cards, subsequently used without her permission. In the third incident, Nunn kidnapped S.E. from a parking garage, forced her to withdraw cash from a bank, and left her at a park. Law enforcement identified Nunn as the perpetrator in all three cases and arrested him.Prior to trial in the United States District Court for the District of Minnesota, Nunn moved to suppress statements made during a custodial interview, arguing he had invoked his right to counsel. The magistrate judge denied the motion, finding the invocation ambiguous, and the district court adopted this ruling. At trial, the government introduced Nunn’s interview statements and allowed C.L. to make a spontaneous in-court identification, to which Nunn did not object. The jury found Nunn guilty on all counts. The Presentence Investigation Report calculated an advisory guidelines range of 168 to 210 months plus a 24-month mandatory minimum. The district court varied upward, citing Nunn’s lengthy criminal history and imposed a total sentence of 288 months.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the conviction and sentence. The court held that the district court did not clearly err in denying the motion to suppress because Nunn’s statement was not an unambiguous invocation of his Miranda rights. The admission of C.L.’s in-court identification did not constitute plain error. Additionally, the district court did not abuse its discretion in imposing an above-guidelines sentence, properly weighing both aggravating and mitigating factors. View "United States v. Nunn" on Justia Law

Two individuals from Colorado, involved in drug trafficking, drew law enforcement attention while driving through South Dakota. After a high-speed chase ended on the Pine Ridge Indian Reservation, their vehicle ran low on gas. When they stopped, an FBI victim specialist, returning from a work assignment in an official vehicle, stopped to offer assistance. The defendants carjacked him at gunpoint, forced him into the backseat, and drove to a gas station. The victim escaped, and the defendants later abandoned the stolen vehicle. Both men were subsequently arrested in Colorado. The government brought multiple charges, including kidnapping a federal officer, carjacking, using a firearm during a crime of violence, and illegal firearm possession.The United States District Court for the District of South Dakota oversaw their joint trial. The court denied Morales’s motions to sever the trials and to obtain the victim’s medical records. It allowed limited portions of a codefendant’s confession and evidence of other drug activity, some as intrinsic and some as extrinsic under Federal Rule of Evidence 404(b). Both defendants were convicted on all counts by a jury and received lengthy sentences. The district court applied enhancements and upward variances based on the facts found at sentencing.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed several trial and sentencing issues. It held that the district court did not abuse its discretion in denying severance or in admitting the challenged evidence. The court found that any error in failing to give a limiting instruction regarding the confession did not affect the outcome. The court concluded the evidence was sufficient to support all convictions, including the statutory elements of kidnapping a federal officer and using a firearm. The Eighth Circuit affirmed the sentences, finding no clear or obvious error with the enhancements or the upward variance. Accordingly, the court affirmed the district court’s judgments. View "United States v. Alvarez-Sorto" on Justia Law

In early 2023, law enforcement in Sioux City, Iowa, used a confidential informant, MS, to investigate methamphetamine distribution. MS identified AP as a supplier, who, in turn, sourced methamphetamine from a man known as “Arkansas,” believed to be Johnnie A. Cannon. Through three controlled buys, investigators observed Cannon’s involvement: he was seen at AP’s residence during each transaction, and physical evidence—including serialized cash from a controlled buy—was seized from him. During a post-arrest interview, Cannon admitted to distributing methamphetamine, including to AP.The United States District Court for the Northern District of Iowa presided over Cannon’s trial. Cannon’s counsel made several motions and challenges at trial, including a Batson challenge regarding jury composition, a motion for judgment of acquittal, and motions for a new trial and arrest of judgment. The district court denied these motions. A jury found Cannon guilty of conspiracy to distribute methamphetamine and three counts of distribution and aiding and abetting distribution. The court sentenced him to 262 months’ imprisonment for these convictions and revoked his supervised release from a prior conviction, imposing an additional 37 months.On appeal, Cannon argued before the United States Court of Appeals for the Eighth Circuit that his Sixth Amendment right to a jury drawn from a fair cross-section was violated, that the admission of his prior conviction was improper under Rule 404(b), that there was insufficient evidence to support his convictions, and that he received ineffective assistance of counsel. The Eighth Circuit held that Cannon’s cross-section jury claim lacked evidence of systematic exclusion, affirmed the admission of his prior conviction as relevant under established precedent, found the trial evidence sufficient to sustain the convictions, and declined to consider the ineffective assistance claim on direct appeal. The court affirmed both the convictions and the revocation of supervised release. View "United States v. Cannon" on Justia Law

Late on January 10, 2022, Kansas City police officers stopped a pickup truck with a broken headlight and expired license plate. The driver, Alonzo Miller, was not the vehicle’s owner and could not provide proof of insurance. The officers recognized the area Miller had driven from as one known for criminal activity. During the stop, Miller exhibited nervous behavior. A computer check revealed Miller was on probation and parole for a violent felony involving a firearm. The officers, noting a significant age difference between Miller and his passenger and the late hour, suspected possible illicit activity. After Miller mentioned “something under there” when asked about illegal items and consented to a vehicle search, the officers asked him to step out. Miller behaved unusually, triggering further suspicion. As an officer attempted a frisk, Miller resisted, and a firearm discharged from his coat pocket. Miller was arrested and later indicted for being a felon in possession of a firearm.The United States District Court for the Western District of Missouri denied Miller’s motion to suppress evidence from the stop and search. The magistrate judge found the stop lawful, that Miller’s consent to search was voluntary, and that the officers had reasonable suspicion to extend the stop and frisk Miller based on the totality of the circumstances—including Miller’s criminal history, behavior, and responses during the encounter. The district court adopted these findings. Miller then entered a conditional guilty plea, preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Eighth Circuit reviewed the denial of Miller’s suppression motion, applying de novo review to legal conclusions and clear error review to factual findings. The court held that, under the totality of the circumstances, the officers had reasonable suspicion to extend the stop, request consent to search the vehicle, and frisk Miller. The judgment of the district court was affirmed. View "United States v. Miller" on Justia Law

A woman who immigrated from Vietnam to the United States and became active in the Vietnamese community in Sioux City, Iowa, organized a campaign in 2020 to assist Vietnamese Americans—many of whom had limited English proficiency and were unfamiliar with the U.S. election system—in registering to vote and casting absentee ballots. Her efforts were not solely for civic engagement; she hoped these voters would support her husband, who was a candidate in the election. She facilitated the process by providing forms, translating, and returning completed documents to the county auditor. However, she also engaged in fraudulent conduct by instructing family members to complete and submit voting documents for absent adult children, and in some cases, she filled out and signed the forms herself. In total, she submitted 26 documents with forged signatures. The county auditor became suspicious and contacted the FBI, leading to her arrest and indictment on 52 counts of voter fraud under two federal statutes.The United States District Court for the Northern District of Iowa presided over her trial. The court used model jury instructions that did not require the jury to find that she knew her conduct was illegal or that the children did not consent to her actions, despite her request for such an instruction. The jury found her guilty on all counts, and her motion for judgment of acquittal was denied.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether the jury instructions accurately reflected the law and whether the evidence was sufficient to support the convictions. The court held that the instructions properly conveyed the required mental states—knowledge and willfulness—and did not need to require knowledge of the specific law violated. The court also found the evidence sufficient for conviction, including for counts involving equivocal testimony, based on the defendant’s pattern of conduct. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Taylor" on Justia Law