Justia Criminal Law Opinion Summaries

After pleading guilty in 2018 to conspiracy to distribute heroin, the defendant served a 48-month sentence and began supervised release in 2023. During his initial term of supervision, he was charged with sex trafficking offenses, which he argued violated a “No Further Prosecution” clause in his plea agreement. Although the district court initially denied his motion to dismiss those charges, the United States Court of Appeals for the Eighth Circuit later held that the plea agreement barred the new charges, vacated his sex trafficking convictions, and ordered his release. Upon release, the district court imposed modified and additional special conditions of supervised release, citing evidence of prior sex trafficking and violent conduct.Following his release, the defendant repeatedly violated the terms of his supervised release. The United States District Court for the Southern District of Iowa revoked his supervision twice, each time imposing new terms of incarceration and supervised release, and reimposing or adding special conditions, including GPS monitoring, a curfew, and restrictions on contact with minors. The defendant did not appeal the first revocation judgment, but after the second revocation and reimposition of conditions, he objected to certain conditions and appealed.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s imposition of the challenged conditions for abuse of discretion. The appellate court held that the district court did not abuse its discretion in imposing GPS monitoring and curfew, given the defendant’s extensive violations and history of evading supervision. The court also upheld the restriction on unapproved contact with minors, finding it reasonably tailored in light of evidence of past conduct and allowing for contact with prior approval. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Thomas" on Justia Law

Marcus Rexrode, a convicted felon, arranged to sell marijuana to a sixteen-year-old, J.M. During the transaction, J.M. attempted to rob Rexrode at gunpoint, and J.M.’s companion also produced a firearm and fired at Rexrode. Rexrode fled while shooting back, fatally wounding J.M. Rexrode subsequently entered a plea agreement with the government, pleading guilty to being a felon in possession of a firearm. In exchange, the government agreed to dismiss a murder charge. The plea agreement included a joint recommendation for a 180-month sentence, acknowledged the possibility of guideline departures, and reserved both parties’ rights to object to any departures.The United States District Court for the District of North Dakota adopted the Presentence Investigation Report, which calculated a guidelines range of 41 to 51 months but identified grounds for upward departures due to the offense resulting in death and uncharged conduct. At sentencing, the court applied these departures, raising the guidelines range to 97 to 121 months, and imposed a 120-month sentence—substantially below the joint recommendation. Rexrode appealed, arguing procedural error in applying the departures and that the sentence was substantively unreasonable.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that there was no procedural error, as Rexrode had agreed to the possibility of departures and did not object to the Presentence Investigation Report or the departures at sentencing. The court also found that any error would have been harmless, as the district court stated it would have imposed the same sentence regardless. Additionally, the court determined that Rexrode had waived his right to appeal the sentence, as it fell within the adjusted guidelines range. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Rexrode" on Justia Law

In August 2022, a Rosebud Sioux Tribe police officer stopped a black Chevy Impala after observing it attempt to avoid his patrol car and learning that its license plates were registered to a different vehicle. The driver, Lydia Stead, and the passenger, Tevin Thin Elk, Sr., could not provide ownership documents. While the officer checked the vehicle’s VIN and their licenses, another officer arrived with a trained drug-detection dog, Iwan. During the stop, Iwan alerted to the presence of narcotics in the vehicle. Shortly after, the officer learned that Stead had an outstanding warrant and arrested both Stead and Thin Elk. A search of the vehicle revealed a firearm, and a search of Thin Elk uncovered marijuana and a pen testing positive for methamphetamine.The United States District Court for the District of South Dakota held two hearings on Thin Elk’s motion to suppress the evidence obtained from the searches. The court denied the motion, finding that Thin Elk lacked standing to challenge the vehicle search as a mere passenger, that the traffic stop was not unreasonably prolonged, and that the canine alert provided probable cause for the search. The court credited the officers’ testimony and found the drug-detection dog to be reliable, despite expert testimony to the contrary.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The appellate court affirmed the district court’s rulings, holding that Thin Elk did not have a reasonable expectation of privacy in the vehicle, the stop was not unlawfully extended, and the dog’s alert established probable cause for the search. The court also found no clear error in the district court’s credibility determinations regarding the officers and the reliability of the canine. The judgment was affirmed. View "United States v. Tevin Thin Elk, Sr." on Justia Law

Three individuals were prosecuted for their roles in an investment fraud scheme conducted through a company called The Brittingham Group. The defendants solicited large sums from investors, promising extraordinary returns within a short period and assuring them that their money was safe. They misrepresented the legitimacy and success of their operations, used fraudulent documents to bolster their claims, and routed investor funds through complex international transactions. When investors failed to receive returns, the defendants collaborated to provide misleading explanations. Ultimately, investors lost over sixteen million dollars, with most never recovering their contributions.The United States District Court for the Western District of Arkansas presided over the trial, where a jury convicted all three defendants of conspiracy to commit wire fraud, multiple counts of wire fraud, and conspiracy to commit money laundering. One defendant faced an additional money laundering charge. The court sentenced each to significant prison terms. Prior to trial, one defendant unsuccessfully sought to replace his appointed counsel, a decision upheld after a hearing before a magistrate judge. The defendants raised various challenges at trial and sentencing, including claims of insufficient evidence, improper testimony, and sentencing errors.The United States Court of Appeals for the Eighth Circuit reviewed the convictions and sentences. The court held that the magistrate judge did not abuse her discretion in denying the request for new counsel, and declined to consider ineffective assistance claims on direct appeal. The court found no plain error in the admission of the government investigator’s testimony. It determined that sufficient evidence supported the convictions of all defendants. The court also upheld the sentencing calculations, including enhancements for intended loss and abuse of trust, and found the sentences substantively reasonable. The court affirmed the forfeiture order against one defendant. The judgments of the district court were affirmed in all respects. View "United States v. Nock" on Justia Law

In this case, law enforcement in Little Rock, Arkansas, conducted a sting operation targeting illegal prostitution, which led to the arrest of A.B., a woman working for Deonte Womack. Initially, A.B. did not identify Womack, but after suffering physical abuse from him, she later cooperated with authorities. The FBI’s investigation revealed that Womack managed a prostitution ring involving at least twelve women, exerting control through violence, threats, and financial manipulation. Womack was arrested and charged with three counts of sex trafficking by force, fraud, or coercion, and one count of witness intimidation.The United States District Court for the Eastern District of Arkansas presided over Womack’s trial. The court allowed testimony from a woman, C.C., about uncharged conduct under Federal Rule of Evidence 404(b), with a limiting instruction to the jury. At the close of the government’s case, the district court granted Womack’s motion for judgment of acquittal on one sex trafficking count and the witness intimidation count, but denied it as to the remaining two sex trafficking counts. The court also denied Womack’s request for a lesser included offense jury instruction and sentenced him to 235 months’ imprisonment, applying a base offense level of 34 under the sentencing guidelines.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed four issues. The court held that the district court did not abuse its discretion in admitting C.C.’s testimony under Rule 404(b), nor in denying the lesser included offense instruction, and found sufficient evidence supported the convictions. However, the appellate court concluded that the district court erred in calculating the base offense level at sentencing, as Womack was not convicted under 18 U.S.C. § 1591(b)(1). The court affirmed the convictions but remanded the case for resentencing with the correct base offense level. View "United States v. Womack" on Justia Law

Aaron Cardinale was stopped by Omaha police officers after they observed him allegedly failing to signal a left turn at least 100 feet in advance, as required by Nebraska law. During the stop, a K-9 unit detected drugs in his vehicle, leading to his arrest and subsequent indictment for possession with intent to distribute methamphetamine. Cardinale moved to suppress the evidence, arguing the stop was not supported by reasonable suspicion.The United States District Court for the District of Nebraska denied Cardinale's motion to suppress. The court found that the officers had a reasonable belief that Cardinale violated the traffic signal law based on Officer Cleveland's testimony. The court reviewed video evidence and other exhibits but concluded that the evidence did not clearly show the officer's belief was unreasonable. Cardinale's motion to reconsider was also denied, with the court reiterating that the entire record supported the officer's reasonable suspicion.The United States Court of Appeals for the Eighth Circuit reviewed the case. Cardinale argued that the government did not present sufficient historical facts to justify the stop and that Officer Cleveland's testimony was too conclusory. The appellate court upheld the district court's decision, noting that the officer's testimony was credible and supported by the record. The court emphasized that reasonable suspicion does not require precise measurements or perfect knowledge, only that the officer's belief was reasonable under the circumstances. The court affirmed the district court's denial of Cardinale's motion to suppress evidence. View "United States v. Cardinale" on Justia Law

Lonnie Parker, a licensed medical practitioner, was found guilty by a jury of distributing oxycodone and promethazine HCl with codeine solution in a manner unauthorized by the Controlled Substances Act. The case began when an individual named N.C. was pulled over for reckless driving, found impaired, and later died in custody. The DEA suspected Parker of operating a "pill mill" and seized patient records from his clinic. An expert reviewed these records and found that Parker had prescribed controlled substances inappropriately.The United States District Court for the Western District of Arkansas sentenced Parker to 87 months’ imprisonment. Parker appealed, arguing that the evidence was insufficient to support his convictions, the jury instructions were improper, and the district court committed procedural error in sentencing. The district court had calculated Parker’s base offense level by including uncharged prescriptions as relevant conduct, resulting in a total offense level of 30 and an advisory sentencing guidelines range of 108 to 135 months. The court varied downwards to 87 months.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the evidence was sufficient to support Parker’s convictions, as the expert testimony provided enough basis for the jury to conclude that Parker prescribed controlled substances without a legitimate medical purpose. The court also found no plain error in the jury instructions, noting that the instructions as a whole clarified the requirements for criminal conduct. Finally, the court determined that any potential error in calculating the quantity of controlled substances for sentencing was harmless, as the district court stated it would have imposed the same sentence regardless. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Parker" on Justia Law

Shue Moua was convicted by a jury of possession with intent to distribute methamphetamine. The conviction stemmed from a traffic stop conducted by Deputy Nils Hansen, who observed Moua's erratic behavior at a gas station and suspected she was impaired. During the stop, Hansen noted several signs of impairment and discovered methamphetamine in Moua's vehicle during an inventory search after her arrest.Moua moved to suppress the evidence obtained from the search, arguing that the traffic stop was invalid and unreasonably prolonged. A magistrate judge recommended granting the motion, finding that Hansen lacked reasonable suspicion to initiate the stop. However, the United States District Court for the District of Minnesota overruled this recommendation, concluding that Hansen had reasonable suspicion based on Moua's impaired behavior and vehicle registration issues. The district court also found that the stop was not unreasonably extended. Moua was subsequently convicted and sentenced to 72 months' imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case and upheld the district court's decision. The appellate court found that Deputy Hansen had reasonable suspicion to stop Moua's vehicle based on her erratic driving and the absence of visible registration tags. The court also determined that the stop was not unreasonably prolonged, as Hansen's suspicions evolved during the encounter, justifying further investigation. The court affirmed the district court's denial of Moua's motion to suppress and upheld her conviction and sentence. View "United States v. Moua" on Justia Law

Verlynin Buckley pleaded guilty to being a felon in possession of a firearm. The district court determined that he was an armed career criminal and sentenced him to 180 months in prison. Buckley appealed, arguing that the court erred in deeming him an armed career criminal under the Armed Career Criminal Act (ACCA), which mandates a minimum of fifteen years in prison for defendants with three or more prior convictions for a violent felony or a serious drug offense.The United States District Court for the Eastern District of Arkansas held that Buckley’s prior Arkansas convictions for possessing cocaine with the intent to deliver and for delivering cocaine were serious drug offenses under the ACCA. Buckley conceded that his prior convictions involved prohibited activity subjecting him to ten or more years in prison but contended that his prior convictions did not involve a controlled substance as defined by federal law.The United States Court of Appeals for the Eighth Circuit reviewed the case and rejected Buckley’s argument. The court held that the Arkansas statutes under which Buckley was convicted did not incorporate the state’s drug schedules but instead referred to cocaine in its ordinary sense. The court found no reason to believe that Arkansas intended to define cocaine more broadly than federal law. Consequently, Buckley’s prior cocaine convictions were deemed serious drug offenses under the ACCA. The Eighth Circuit affirmed the district court’s decision, upholding Buckley’s sentence as an armed career criminal. View "United States v. Buckley" on Justia Law

Justin Johnson, a pretrial detainee at Jefferson County Jail, was attacked by two other inmates while in protective custody. Johnson sued correctional officers Jacob Schurman and Christopher Taylor under 42 U.S.C. § 1983 for failure to protect him and for negligence under Missouri law. The district court granted summary judgment in favor of the officers, finding that qualified immunity barred the § 1983 claims and that official immunity and the public duty doctrine barred the negligence claims.The United States District Court for the Eastern District of Missouri determined that Johnson could not show a constitutional violation necessary to overcome qualified immunity. The court found no evidence that the officers were deliberately indifferent to a substantial risk of serious harm, as the attackers were not known to be violent, and Johnson had no prior relationship with them. The court also dismissed the negligence claims, ruling that the officers were protected by official immunity because their actions were discretionary, not ministerial. Additionally, the court found that the public duty doctrine applied, as the officers owed no particular duty to Johnson beyond that owed to the general prison population.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court agreed that the officers were entitled to qualified immunity, as Johnson failed to show that they were deliberately indifferent to a known risk. The court also upheld the dismissal of the negligence claims, concluding that the officers' actions involved discretionary decisions protected by official immunity. The court did not address the public duty doctrine, as the official immunity finding was sufficient to resolve the negligence claims. View "Johnson v. Schurman" on Justia Law