Justia Criminal Law Opinion Summaries

William Dahl was charged with production and receipt of child pornography based on two separate incidents. In the first, Dahl, then 36, communicated with a 16-year-old girl, S, via social media, provided her with gifts, and received a nude video from her over Snapchat. In the second incident, Dahl engaged in sexually explicit conversations with the mother of a seven-year-old girl, M, who then produced and sent Dahl images of M’s genitals. Dahl admitted to receiving both the video and the images but claimed he intended to turn the images over to police and believed S was 17.The United States District Court for the Eastern District of Missouri conducted a bench trial and found Dahl guilty of production of child pornography and two counts of receipt of child pornography. At sentencing, the district court ordered Dahl’s federal sentence to run consecutively to sentences in six pending Missouri state cases. However, the record was unclear as to whether the court intended the federal sentence to run consecutively to state sentences involving the same victims or relevant conduct.The United States Court of Appeals for the Eighth Circuit reviewed the sufficiency of the evidence and the sentencing order. The court held that, viewing the evidence in the light most favorable to the verdict, a reasonable factfinder could conclude that the materials received by Dahl constituted child pornography under federal law, applying the Dost factors as required by circuit precedent. The court affirmed Dahl’s convictions. However, because of ambiguity regarding whether the federal sentence was intended to run consecutively to all state sentences or only those unrelated to the federal offenses, the Eighth Circuit vacated the sentence and remanded the case for the district court to clarify its sentencing intent. View "United States v. Dahl" on Justia Law

Miguel Alcantar Mercado participated in a drug distribution operation, possessing and distributing over 1,300 grams of heroin and wiring more than $45,000 in drug proceeds. He pled guilty to conspiracy to distribute a controlled substance. The United States Probation Office calculated an advisory Guidelines range of 210 to 262 months’ imprisonment, factoring in his criminal history. The district court sentenced him to 204 months, six months below the Guidelines range, considering both the seriousness of the offense and mitigating factors such as his modest criminal history and family support.Following a retroactive amendment to the Sentencing Guidelines, which revised the calculation of criminal history categories, Alcantar Mercado’s criminal history category was reduced from III to II, making his new Guidelines range 188 to 235 months. This made him eligible for a discretionary sentence reduction. The Probation Office identified him as eligible, noting his good behavior and participation in rehabilitative programs. However, the district court declined to modify his sentence, stating that the variance he received was consistent with the new Guidelines range.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion. The court found that the district court had considered the relevant factors under 18 U.S.C. § 3553(a) and noted Alcantar Mercado’s good behavior. The appellate court held that the district court was not required to provide a lengthy explanation for its decision and that its consideration of the factors was sufficient. The Eighth Circuit affirmed the district court’s judgment, concluding that the decision was within the permissible range of discretion. View "United States v. Mercado" on Justia Law

Britt Lander was stopped by police in June 2022, and drug paraphernalia and methamphetamine were found in his vehicle. After being read his Miranda rights, Lander requested the presence of his partner, whom he jokingly referred to as his attorney. The officer denied this request and continued the interrogation, during which Lander made incriminating statements about his involvement in methamphetamine trafficking. Lander was subsequently indicted for conspiring to distribute methamphetamine after a prior felony drug conviction.The United States District Court for the Northern District of Iowa denied Lander's motion to suppress his statements, concluding that his waiver of Miranda rights was voluntary and that his request for his partner was not a clear invocation of his right to counsel. The court also denied his motion for a new trial, finding the evidence against him, including testimony from co-conspirators and video evidence, sufficient to support the conviction. Lander was sentenced to 360 months in prison, the bottom of the advisory sentencing range under the United States Sentencing Guidelines.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decisions. The appellate court held that Lander's waiver of his Miranda rights was voluntary, as he appeared to understand the situation despite his claims of intoxication and sleep deprivation. The court also found that Lander's request for his partner was not a clear and unequivocal request for an attorney. Additionally, the court upheld the denial of Lander's motion for a new trial, noting that the testimony of cooperating witnesses was consistent and corroborated by other evidence. Finally, the court found no error in the district court's sentencing calculation and determined that the 360-month sentence was substantively reasonable. View "United States v. Lander" on Justia Law

In the summer of 2022, law enforcement in Illinois and Iowa investigated Kpangbala Benyan Blamah after two shooting incidents involving vehicles linked to him. On June 27, a black Toyota Camry was involved in a shooting in Rock Island, Illinois. On August 4, a shooting occurred in Davenport, Iowa, involving a vehicle registered to Blamah’s ex-girlfriend. On August 7, officers observed the Camry at Blamah’s ex-girlfriend’s residence, leading to a chase where Blamah fled, leaving behind a loaded Glock 9mm handgun and several iPhones. A search of the Camry revealed marijuana, a digital scale, and packaging material. Further investigation linked Blamah to drug trafficking activities, including shipping packages containing cocaine from California to Iowa.The United States District Court for the Southern District of Iowa convicted Blamah of conspiracy to distribute cocaine and marijuana, possession of a firearm in furtherance of a drug trafficking crime, and being a felon in possession of firearms. The jury found the conspiracy involved five or more kilograms of cocaine. Blamah was sentenced to 360 months in prison. He appealed, challenging the sufficiency of the evidence and the admission of evidence from the two shootings.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that there was sufficient evidence to support the jury’s finding that the conspiracy involved more than five kilograms of cocaine, based on intercepted packages, testimony, and text messages. The court also found sufficient evidence to support the firearm possession conviction, noting the proximity of firearms to drugs and expert testimony on the use of firearms in drug trafficking. The court ruled that the district court did not abuse its discretion in admitting evidence from the shootings, as it was intrinsic to the charged offenses. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Blamah" on Justia Law

Wilbur Morrison, Jr. was convicted by a jury of two counts of aggravated sexual abuse of a child in Indian territory and one count of assault resulting in serious bodily injury. The district court sentenced him to 480 months’ imprisonment for the sexual abuse counts and 120 months for the assault count, to run concurrently. The court also imposed concurrent supervised release terms of five years for the sexual abuse counts and three years for the assault count, but the written judgment incorrectly stated five years for all counts.Morrison appealed, arguing that the district court abused its discretion by admitting a forensic interview and accompanying testimony, that the evidence was insufficient to convict him on the sexual abuse counts, that his sentence was substantively unreasonable, and that the written judgment conflicted with the oral pronouncement of his sentence.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court did not abuse its discretion in admitting the forensic interview under the residual exception to the hearsay rule, as it had sufficient circumstantial guarantees of trustworthiness. The court also found that there was sufficient evidence to support Morrison’s convictions for both counts of aggravated sexual abuse, based on the testimonies of the children and the medical evidence presented. The court held that the district court did not abuse its discretion in sentencing Morrison to 480 months’ imprisonment, as it properly considered the relevant factors.However, the court agreed with Morrison that the written judgment conflicted with the oral pronouncement regarding the terms of supervised release. The Eighth Circuit affirmed the district court’s decisions on the admission of evidence, the convictions, and the sentence of imprisonment, but vacated the terms of supervised release and remanded the case for the district court to amend its written judgment to conform to its oral pronouncement. View "United States v. Morrison" on Justia Law

In late October 2021, Shamsa Issack was sitting in her car in Fargo, North Dakota, when a man, later identified as Sharmake Mohamed Abdullahi, approached her with a gun and forced her to drive to Moorhead, Minnesota. After attempting to withdraw money from an ATM unsuccessfully, Abdullahi took Issack's cell phone and fled. Issack sought help from bank employees, who called the police. Abdullahi was later arrested and charged with state robbery and kidnapping.The United States District Court for the District of North Dakota admitted Issack's statements to bank employees as excited utterances and allowed the jury to hear part of a recording of Issack's conversation with police before striking it from the record. Abdullahi's motion for a mistrial was denied, and he was convicted by a jury of kidnapping and attempted witness tampering. The district court sentenced him to 180 months' imprisonment on each count, to be served concurrently.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the kidnapping conviction, finding sufficient evidence that Abdullahi's actions constituted kidnapping under 18 U.S.C. § 1201(a)(1). However, the court vacated the attempted witness tampering conviction, concluding that the government failed to prove that Abdullahi contemplated a particular, foreseeable federal proceeding when he made phone calls from state custody. The court held that Abdullahi's actions did not meet the statutory definition of attempted witness tampering under 18 U.S.C. §§ 1512(b)(1) and 2. View "United States v. Abdullahi" on Justia Law

B.J.S., a Native American born in 2004, was charged with multiple acts of aggravated sexual abuse against his younger sister L.S. between August 2019 and June 2022, when he was 15 to 17 years old. The government filed a juvenile information and moved to transfer the proceedings to adult court. The charges included causing L.S. to engage in sexual acts by force, engaging in sexual acts with L.S. under 12, and causing sexual contact with L.S. under 12 with intent to abuse, humiliate, harass, degrade, or arouse sexual desire.The United States District Court for the District of North Dakota granted the government's motion to transfer the case to adult court. B.J.S. moved to dismiss the transfer motion, arguing that the charges did not qualify as "crimes of violence" under 18 U.S.C. § 5032. The district court denied his motion and granted the transfer after an evidentiary hearing. B.J.S. appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that the charges under 18 U.S.C. §§ 2241(a), 2241(c), and 2244(a)(5) did not qualify as "crimes of violence" under 18 U.S.C. § 16(a). The court applied the categorical approach, considering only the statutory elements of the offenses. It found that § 2241(a) was overbroad and indivisible, covering more conduct than § 16(a). Similarly, § 2241(c) and § 2244(a)(5) did not require the use, attempted use, or threatened use of physical force against another person. Consequently, the court concluded that none of the charges met the definition of a "crime of violence" for purposes of § 5032 permissive transfer.The Eighth Circuit reversed the district court's decision and remanded the case, determining that the transfer to adult court was not justified. View "United States v. B.J.S." on Justia Law

Laguerre Payen, a federal inmate, was convicted in 2010 of multiple terrorism-related charges and sentenced to 25 years imprisonment. During his incarceration, Payen exhibited disruptive and dangerous behavior, including numerous assaults, threats, and other violations. He was diagnosed with schizophrenia and mild intellectual disability and was committed twice under 18 U.S.C. § 4245 for mental health treatment. Despite some improvement, Payen's behavior remained inconsistent, and he refused medication after his commitments ended.The United States District Court for the Western District of Missouri committed Payen under 18 U.S.C. § 4246, finding by clear and convincing evidence that his release would pose a substantial risk of bodily injury or serious property damage due to his mental illness. Payen appealed, arguing that the district court relied on erroneous facts and that the government failed to prove his dangerousness by clear and convincing evidence.The United States Court of Appeals for the Eighth Circuit reviewed the district court's finding of dangerousness for clear error. The court noted that the district court had relied on the unanimous opinions of experts, including an independent evaluator, who diagnosed Payen with schizophrenia and intellectual disability and concluded that his release would pose a substantial risk. The court also considered Payen's extensive history of violent and disruptive behavior, his refusal to take medication voluntarily, and the lack of a suitable release plan.The Eighth Circuit affirmed the district court's decision, finding no clear error in the determination that Payen's release would create a substantial risk of harm to others or their property. The court emphasized that the district court had properly focused on the expert reports and Payen's history of dangerous behavior in making its decision. View "United States v. Payen" on Justia Law

In 2020, Mujera Benjamin Lung’aho threw Molotov cocktails that damaged or destroyed three police cars belonging to state and municipal police departments. He was indicted under 18 U.S.C. § 844(f)(1) for maliciously destroying law enforcement vehicles possessed by local police departments receiving federal financial assistance. Lung’aho moved to dismiss the indictment, arguing that the statute was unconstitutional as applied to him.The United States District Court for the Eastern District of Arkansas denied Lung’aho’s motion to dismiss. The court held that while the Property Clause did not apply because the police cars were not federal property and were not bought with federal financial assistance, the prosecution was constitutional under the Spending Clause coupled with the Necessary and Proper Clause.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of the motion to dismiss de novo. The court held that Lung’aho’s conduct fell within the plain meaning of 18 U.S.C. § 844(f)(1) and that the statute was constitutional as applied to him. The court reasoned that under the Spending Clause and the Necessary and Proper Clause, Congress has the authority to ensure that federal funds are spent for the general welfare, and criminalizing the arson of police cars from departments receiving federal funding is a rational means of safeguarding federal dollars. The court affirmed the district court’s judgment, concluding that § 844(f)(1) was constitutionally applied to Lung’aho. View "United States v. Lung'aho" on Justia Law

Deoman Reeves was convicted by a jury of eleven counts related to narcotics and firearms offenses. The charges stemmed from a series of events in 2019, including a shooting incident in University City, Missouri, and subsequent involvement in drug and firearms trafficking. Reeves was identified as a primary suspect in the shooting and was linked to a narcotics trafficking organization. He was involved in a retaliatory shooting that resulted in the death of a bystander, David Anderson, whom Reeves mistakenly believed to be a rival drug trafficker. Reeves was later involved in several controlled buys of fentanyl and firearms set up by ATF agents.The United States District Court for the Eastern District of Missouri denied several of Reeves's pretrial motions, including a motion to suppress location data obtained from his cellphones and a motion to sever the count charging him with possession of a firearm in furtherance of a drug trafficking crime resulting in death. The district court also denied Reeves's motions for judgment of acquittal and for a new trial. Reeves was sentenced to life imprisonment on one count, 120 months on seven counts to be served concurrently, and 60 months on three counts to be served consecutively.The United States Court of Appeals for the Eighth Circuit reviewed the case and found no reversible error. The court held that the district court did not abuse its discretion or plainly err in denying the motion to sever, as the offenses were connected to the same drug trafficking conspiracy. The court also upheld the denial of the motion to suppress, finding that the warrants were supported by probable cause and sufficiently particular. The court affirmed the denial of the motion for judgment of acquittal, concluding that sufficient evidence supported the convictions. Finally, the court determined that Reeves waived his challenges to the jury instructions by not objecting during the trial. The judgment of the district court was affirmed. View "United States v. Reeves" on Justia Law