Justia Criminal Law Opinion Summaries

In 2018, Detective James Gaddy of the St. Charles County, Missouri Police Department investigated a large-scale drug distributor, Guy Goolsby, and obtained wiretap authorization for Goolsby’s cell phone. The wiretap revealed that Freeman Whitfield IV was involved in the drug distribution. In 2019, Goolsby directed Whitfield to retrieve drugs, and Whitfield was later implicated in the murder of Antonio Boyd, a cooperating witness. Investigators linked Whitfield to the crime scene through cell tower data and intercepted conversations. In 2021, search warrants for Whitfield’s residences led to the discovery of firearms, ammunition, drugs, and drug proceeds.The United States District Court for the Eastern District of Missouri denied Whitfield’s pretrial motions to suppress evidence and to sever counts related to the murder from the drug charges. The court found probable cause for the search warrants and ruled that the wiretap evidence was obtained lawfully. The court also determined that the charges were sufficiently related to be tried together. Whitfield was found guilty on all counts and sentenced to life imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court upheld the district court’s denial of Whitfield’s motions to suppress, finding that the affidavits supporting the search warrants established probable cause and that the wiretap evidence met the necessity requirement under 18 U.S.C. § 2518. The court also affirmed the denial of the motion to sever, concluding that the charges were properly joined and that Whitfield failed to demonstrate any resulting prejudice. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Whitfield" on Justia Law

Byron Williams pled guilty to three counts of being a felon in possession of a firearm, violating 18 U.S.C. §§ 922(g)(1) and 924(a)(2). He was found with handguns on three separate occasions between January 2020 and March 2021, despite being prohibited from possessing firearms due to prior felony convictions. The incidents involved a traffic stop, an altercation reported by his ex-girlfriend, and a high-speed chase following a disturbance.The United States District Court for the Western District of Missouri sentenced Williams to 240 months’ imprisonment. Williams appealed, arguing procedural error and the substantive unreasonableness of his sentence. He contended that the district court improperly limited his argument for a downward variance at sentencing and failed to adequately consider his intellectual disabilities.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that while the district court initially interrupted Williams’s counsel, it ultimately allowed her to present arguments regarding Williams’s intellectual disabilities and other mitigating factors. The appellate court determined that the district court did not abuse its discretion in limiting arguments related to Williams’s competency, which had already been decided.Regarding the substantive reasonableness of the sentence, the Eighth Circuit held that the district court did not abuse its discretion. The court justified the upward variance from the Guidelines range based on Williams’s criminal history, high risk of recidivism, and the danger he posed to the community. The appellate court concluded that the district court appropriately weighed the relevant factors and affirmed the 240-month sentence.The Eighth Circuit affirmed the judgment of the district court, finding no procedural error or substantive unreasonableness in the sentence imposed on Williams. View "United States v. Williams" on Justia Law

Marqus Patton was convicted by a Nebraska jury of first-degree murder and using a deadly weapon during a robbery following the attempted robbery and fatal shooting of Kristopher Winters. Patton filed a habeas corpus petition under 28 U.S.C. § 2254(d), alleging that his due process rights were violated because the State failed to disclose tacit plea agreements with two witnesses, Emily Gusman and Drake Northrop, who testified against him at trial.The United States District Court for the District of Nebraska denied Patton’s habeas petition but granted a certificate of appealability. The district court was skeptical about the absence of agreements but concluded that the Nebraska Supreme Court’s finding that no tacit plea agreements existed was not unreasonable. The district court also found that any undisclosed agreements would not have been material to the trial's outcome due to the extensive cross-examination of the witnesses.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court noted that the Nebraska Supreme Court had determined there were no tacit plea agreements, and this conclusion was not unreasonable based on the evidence. The court emphasized that under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), a state court’s factual determinations are presumed correct unless rebutted by clear and convincing evidence. The Eighth Circuit found that the evidence supported either conclusion regarding the existence of tacit plea agreements and that the state court’s determination was reasonable.The Eighth Circuit affirmed the district court’s denial of Patton’s habeas petition, concluding that the state court’s adjudication did not involve an unreasonable determination of the facts. View "Patton v. Boyd" on Justia Law

In 2015, Shirley Carter was found dead in her home from gunshot wounds. Jason Carter, her son, was later found civilly liable for her wrongful death. Following this, Iowa Division of Criminal Investigation Agent Mark Ludwick and Marion County Deputy Sheriff Reed Kious arrested Jason for first-degree murder. However, Jason was acquitted in a jury trial. Jason then filed a 42 U.S.C. § 1983 action against Ludwick and Kious, alleging violations of his constitutional and state-law rights during the investigation of his mother's murder.The United States District Court for the Southern District of Iowa dismissed Jason's complaint, granting Ludwick and Kious qualified immunity on all federal claims and ruling that Jason failed to state a claim for his state law claims. The court also dismissed Marion County from the suit, as Jason did not allege a pattern of unconstitutional conduct.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's dismissal, holding that Ludwick and Kious were entitled to qualified immunity. The court found that Jason failed to plausibly allege a constitutional violation for false arrest, as the arrest was conducted pursuant to a facially valid warrant. The court also held that Jason's claim of evidence concealment did not constitute a clearly established constitutional violation. Additionally, the court ruled that Jason's failure-to-investigate claim did not meet the threshold for a substantive due process violation. The court also affirmed the dismissal of Jason's state law claims for malicious prosecution and abuse of process, noting the presence of probable cause and the lack of improper motive. View "Carter v. Ludwick" on Justia Law

On March 15, 2022, law enforcement responded to a drug overdose in Rapid City, South Dakota, where they found K.S. conscious but sluggish after receiving Narcan. Officers suspected two individuals, including a woman with purple hair, of distributing fentanyl to K.S. Surveillance at a hotel led to a traffic stop of a red Ford Fiesta, where officers found Anthony Ward in the backseat. Ward was arrested for false impersonation after providing false names. A search of the vehicle revealed drugs, a stolen gun, and cash. Ward was charged with distribution of a controlled substance resulting in serious bodily injury and conspiracy to distribute fentanyl.The United States District Court for the District of South Dakota denied Ward's motions to suppress evidence from the traffic stop and to dismiss the indictment for failure to preserve evidence. After a five-day trial, the jury convicted Ward on both counts, and the court imposed concurrent 360-month sentences. Ward appealed the district court's decisions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court upheld the district court's denial of Ward's motions to suppress and dismiss, finding no unreasonable extension of the traffic stop and no bad faith in the handling of evidence. The court also found sufficient evidence to support Ward's convictions. The court concluded that the evidence showed Ward distributed fentanyl that caused K.S.'s serious bodily injury and that Ward was involved in a conspiracy to distribute fentanyl. The judgment of the district court was affirmed. View "United States v. Ward" on Justia Law

A Missouri state trooper stopped the defendant for minor traffic violations, during which the defendant disclosed his status as a registered sex offender. The trooper invited the defendant into his patrol car while checking his license and registration. During this time, the trooper learned that the defendant had not registered any social media accounts as required by Missouri law. The trooper then asked for and received consent to search the defendant’s vehicle. While searching, the trooper picked up the defendant’s cell phone, which illuminated to reveal social media app icons. The trooper questioned the defendant about the phone and, after repeated requests, obtained the defendant’s verbal consent to search the phone. The search revealed images suspected to be child pornography, leading to the defendant’s arrest. After being read his Miranda rights, the defendant made further incriminating statements. A subsequent warrant-based search of the phone uncovered additional illegal material.The United States District Court for the Western District of Missouri denied the defendant’s motion to suppress the evidence from the cell phone and his statements to law enforcement, adopting a magistrate judge’s recommendation. The defendant waived his right to a jury trial, proceeded to a bench trial, and was convicted of receiving child pornography.The United States Court of Appeals for the Eighth Circuit reviewed the case. It held that the trooper’s brief questioning and request for consent did not unlawfully prolong the traffic stop. The court found that moving the cell phone during a consensual vehicle search did not constitute an unlawful search or seizure, and that the defendant voluntarily consented to the phone search. The court also determined that the defendant was not in custody for Miranda purposes during pre-arrest questioning, so suppression of his statements was not warranted. The district court’s judgment was affirmed. View "United States v. Puckett" on Justia Law

Nicholas Nesdahl, posing as a teenager, used social media to contact several minor girls and solicit sexually explicit images and videos. In one instance, he directed a 13-year-old girl to record herself sexually abusing her 6-year-old stepsister. The abuse was discovered by the older girl’s mother, who notified authorities. Law enforcement identified Nesdahl as the recipient and found he had received similar material from at least seven other minors across the country. Nesdahl was indicted in both the District of North Dakota and the Western District of Pennsylvania, with the latter case transferred to North Dakota. He entered a plea agreement, pleading guilty to two counts from the Pennsylvania indictment (involving receipt of child pornography and sexual exploitation of a minor) and seven counts from the North Dakota indictment (all for sexual exploitation of a minor).The United States District Court for the District of North Dakota adopted the Presentence Investigation Report, which recommended the statutory maximum sentence and identified nine victims, triggering mandatory restitution under 18 U.S.C. § 2259(b)(2). Nesdahl did not object to the restitution order. At sentencing, the court imposed 600 months’ imprisonment and ordered $3,000 in restitution for each of the nine victims.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the restitution order for plain error and found that mandatory restitution under § 2259(b)(2) applies only to certain trafficking offenses, not to convictions under 18 U.S.C. § 2251(a). The court held that restitution was only authorized for the two victims associated with the § 2252(a)(2) conviction, not for the other seven victims. The Eighth Circuit vacated the restitution award and remanded for a new order reflecting only the two qualifying victims. The court affirmed the 600-month sentence, finding it substantively reasonable and within the district court’s discretion. View "United States v. Nesdahl" on Justia Law

Jacob McWaters was stopped by law enforcement in January 2023, and they found 19,910 grams of methamphetamine in his vehicle. During a post-Miranda interview, McWaters admitted to transporting methamphetamine from Texas to Minnesota and had done so on two prior occasions. He pleaded guilty to possession with intent to distribute 50 grams or more of methamphetamine.The United States District Court for the Southern District of Iowa sentenced McWaters to 240 months in custody, followed by five years of supervised release. McWaters objected to the Presentence Report’s (PSR) calculation of his Guidelines range, arguing for a reduction in his offense level due to his mitigating role. The district court overruled his objection and calculated his Guidelines range at 292 to 365 months. However, the court granted a partial downward variance, resulting in a 240-month sentence.McWaters appealed to the United States Court of Appeals for the Eighth Circuit, arguing that the district court erred in not applying a role reduction under USSG § 3B1.2. The Eighth Circuit reviewed the district court’s factual finding for clear error. The court noted that McWaters needed to prove his conduct involved more than one participant and that his culpability was minor compared to others. McWaters emphasized his role as a low-level courier with minimal knowledge of the drug operation but failed to provide evidence comparing his conduct to other participants. The court found no clear error in the district court’s decision and upheld the denial of the role reduction.The Eighth Circuit affirmed the district court’s judgment, maintaining McWaters’s 240-month sentence. View "United States v. McWaters" on Justia Law

A 13-year-old girl reported to her school principal that her mother’s ex-boyfriend had inappropriately touched her in a bathtub on tribal land. During a forensic interview, she described being touched on the outside of her vaginal area and feeling the man’s penis on her back. The accused denied the allegations but later admitted to being naked in the bathtub with the children, claiming he left immediately. In a subsequent law enforcement interview, he responded “mmhmm” to statements that he had touched the girl’s vagina, which an agent interpreted as acknowledgments rather than admissions. At trial, the girl testified about two incidents: one in a bathtub when she was seven, and another in a bedroom where she awoke bleeding. The government introduced a recording of the “mmhmm” responses, and the jury was instructed that silence or failure to deny an accusation could be considered an admission.A jury in the United States District Court for the District of South Dakota convicted the defendant of aggravated sexual abuse of a child under 12 and abusive sexual contact of a child. The defendant moved for acquittal or a new trial, arguing insufficient evidence and inconsistencies in the victim’s testimony. The district court denied acquittal but granted a new trial, citing concerns about leading questions during testimony, the prejudicial effect of the “mmhmm” responses and related jury instruction, and the mandatory minimum sentence.The United States Court of Appeals for the Eighth Circuit reviewed the case. It held that the district court abused its discretion by granting a new trial on grounds not raised in the defendant’s Rule 33 motion, as required by the Federal Rules of Criminal Procedure. The appellate court reversed the order granting a new trial, reinstated the convictions, and remanded the case for sentencing. View "United States v. Drum" on Justia Law

A police officer in Bismarck, North Dakota, smelled marijuana in a hotel and traced the scent to Room 118, occupied by Leonard Tate. The officer obtained a search warrant based on the smell and Tate's criminal history. The search revealed fentanyl, cash, firearm parts, and other items. Tate was charged with three drug-related crimes and moved to suppress the evidence, arguing the warrant lacked probable cause and the search exceeded its scope. The district court denied the motion, and Tate pled guilty to one count of conspiracy, preserving his right to appeal the suppression order.The United States District Court for the District of North Dakota found that the search warrant was supported by probable cause, the search did not exceed the warrant's scope, and the good-faith exception applied. Tate appealed the denial of his motion to suppress, arguing the warrant was not supported by probable cause and that the search exceeded its scope.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the smell of marijuana alone provided substantial support for probable cause, especially given the officer's training and experience. The court also found that the search did not exceed the warrant's scope, as the items seized were in plain view and their incriminating nature was immediately apparent. The court affirmed the district court's denial of Tate's motion to suppress. View "United States v. Tate" on Justia Law