Justia Criminal Law Opinion Summaries

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

Alexander Laurel-Olea pleaded guilty to unlawful possession of a firearm as an unlawful user of a controlled substance and was sentenced to twenty-four months’ imprisonment and thirty-six months of supervised release. After serving his sentence, he began his supervised release on August 30, 2022. In June 2024, he was arrested for committing fifty-four violations of his supervised release conditions. The district court sentenced him to fourteen months’ imprisonment and a one-year term of supervised release.The United States District Court for the Northern District of Iowa determined that the advisory guideline range for Laurel-Olea’s violations was three to nine months’ imprisonment. The court considered both mitigating and aggravating factors. Mitigating factors included his age, lack of adult criminal history, mental health and substance abuse issues, and acceptance of responsibility. Aggravating factors included his involvement in a dangerous shooting, fifty-four violations of release conditions, becoming a fugitive, and failing to meet his restitution obligation.The United States Court of Appeals for the Eighth Circuit reviewed the case. Laurel-Olea argued that his sentence was unreasonable under 18 U.S.C. § 3583(e), claiming it was disproportionate and did not account for his mental health issues, background, and potential for reintegration. The appellate court applied a deferential abuse-of-discretion standard, noting that it is rare to reverse a district court sentence as substantively unreasonable.The Eighth Circuit found that the district court did not abuse its discretion. The court had considered relevant factors and provided a reasoned explanation for the upward variance from nine to fourteen months, including credit for accepting responsibility. The judgment of the district court was affirmed. View "United States v. Laurel-Olea" on Justia Law

Moses Crowe was convicted of aiding and abetting a carjacking resulting in serious bodily injury, aiding and abetting the use of a firearm during and in relation to a crime of violence, and unlawful possession of a firearm as a felon. The incident involved Crowe and his accomplices forcing Phillip Moore at gunpoint to drive a van, assaulting him, and subsequently beating him unconscious. Crowe was sentenced to 235 months’ imprisonment.The United States District Court for the District of South Dakota initially sentenced Crowe, applying a four-level increase under the sentencing guidelines for abduction. Crowe appealed, arguing that the court erred in applying this increase and improperly considered conduct not relevant to his sentencing guideline range. The court also remanded for resentencing after vacating one of Crowe’s convictions and reducing it to a lesser charge.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court properly considered Crowe’s conduct at Nike Road under the sentencing factors of 18 U.S.C. § 3553(a) and correctly applied the four-level increase for abduction. The court determined that Moore was abducted to facilitate the escape from the carjacking scene, thus justifying the increase. Additionally, the court held that the district court did not abuse its discretion in sentencing Crowe within the advisory range and adequately considered the § 3553(a) factors. The Eighth Circuit affirmed the judgment of the district court, upholding Crowe’s 235-month sentence. View "United States v. Crowe" on Justia Law

Robert Cottier was driving with a suspended license and a high blood alcohol concentration when he collided head-on with Cheryl Cross' vehicle, causing serious injuries to Cross and her passengers. Cottier's passenger, Harold Long Soldier, died from the crash. Cottier was charged with involuntary manslaughter and four counts of assault resulting in serious bodily injury. He pleaded guilty to the manslaughter charge and one count of assault.The United States District Court for the District of South Dakota accepted Cottier's guilty plea. The plea agreement included a government recommendation for sentences within the applicable Guideline range to run consecutively. The Presentence Investigation Report calculated a total offense level of 21, resulting in a guideline range of 37-46 months. The government’s Sentencing Memorandum recommended a 73-month sentence, which Cottier argued breached the plea agreement. The district court varied upwards and sentenced Cottier to 96 months, explaining the decision was based on the severity of the injuries and Cottier's history of DUI offenses.The United States Court of Appeals for the Eighth Circuit reviewed the case. Cottier argued that the government breached the plea agreement by recommending a 73-month sentence. The court found no breach, noting that the government’s final position at the sentencing hearing aligned with the plea agreement. The court also determined that any potential breach in the Sentencing Memorandum did not affect the district court’s decision to impose a 96-month sentence. The Eighth Circuit affirmed the district court’s judgment, concluding that the government honored its plea agreement obligations and that the district court’s sentence was justified. View "United States v. Cottier" on Justia Law

Melissa Wanna discovered her profile on MyLife, an information broker, which contained a poor reputation score and references to court records. MyLife offered to provide details or remove the profile for a fee. Believing she lost employment opportunities due to this profile, Wanna filed a class action lawsuit against several Lexis entities, alleging violations of the Fair Credit Reporting Act (FCRA), Driver’s Privacy Protection Act (DPPA), and the federal Racketeer Influenced and Corrupt Organizations Act (RICO), along with several Minnesota state law claims.The United States District Court for the District of Minnesota dismissed Wanna’s claims, concluding that MyLife was not Lexis’s agent. The court found that the data-licensing agreement between Lexis and MyLife explicitly stated that their relationship was that of independent contractors, not principal and agent. As a result, Wanna’s federal claims, which depended on an agency relationship, failed. The district court also declined to exercise supplemental jurisdiction over Wanna’s state law claims and dismissed them without prejudice.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo and affirmed the dismissal. The appellate court agreed that Wanna’s federal claims required an agency relationship between Lexis and MyLife, which was not established. The court found that MyLife did not have actual or apparent authority to act on Lexis’s behalf, nor did Lexis ratify MyLife’s actions. Additionally, the appellate court held that the district court did not abuse its discretion in declining to exercise supplemental jurisdiction over the state law claims. View "Wanna v. RELX Group, PLC" on Justia Law

Milton Porter pled guilty to being a felon in possession of a firearm, violating 18 U.S.C. § 922(g)(1). The district court sentenced him to 200 months in prison under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e), based on three prior violent felony convictions: a 2008 domestic assault in the second degree, a 2018 domestic assault in the second degree, and a 2018 domestic assault in the third degree, all under Missouri law. Porter appealed, arguing he did not have the requisite three prior violent felony convictions to qualify as an armed career criminal.The United States District Court for the Eastern District of Missouri determined that each of Porter's domestic assault convictions qualified as violent felonies under the ACCA. The court did not address whether Porter’s 2018 Missouri conviction for burglary in the second degree qualified as a violent felony, as the domestic assault convictions were sufficient for the ACCA enhancement.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court applied the modified categorical approach to determine that Porter's 2008 and 2018 second-degree domestic assault convictions were violent felonies under the ACCA, as they involved knowingly causing physical injury. The court also determined that Porter's 2018 third-degree domestic assault conviction was a violent felony, as it involved attempting to cause physical injury. The court affirmed the district court's judgment, holding that Porter’s three domestic assault convictions were violent felonies under the ACCA, justifying the sentence enhancement. View "United States v. Porter" on Justia Law

Law enforcement officers suspected Bandak Wiyual Deng of involvement in a shooting at a park on February 10, 2022. Surveillance video showed an individual matching his characteristics exiting a car with what appeared to be a gun. The car, a black Ford Taurus, lacked a license plate or paper registration tag. A confidential informant recorded a conversation with Deng, where Deng mentioned needing a gun for a funeral and a previous shooting. On the day of the funeral, officers stopped Deng, found marijuana and a gun in his car, and Deng admitted to using drugs and touching the gun.The United States District Court for the Southern District of Iowa upheld the government's peremptory strikes of two prospective jurors and refused to admit parts of Deng's interview with law enforcement. Deng's motion for a judgment of acquittal, arguing that 18 U.S.C. § 922(g)(3) violated the Second Amendment, was denied. The jury convicted Deng.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not clearly err in overruling Deng’s objections to the peremptory strikes, as the government provided race-neutral explanations. The court also found that any potential error in the district court's evidentiary rulings was harmless, given the ample evidence supporting Deng’s conviction. Finally, the court affirmed the denial of Deng’s motion for a judgment of acquittal, rejecting his facial challenge to the constitutionality of 18 U.S.C. § 922(g)(3). The judgment was affirmed. View "United States v. Deng" on Justia Law

Edgar Pratt was on supervised release after serving a prison term for possession with intent to distribute fentanyl. He violated the terms of his release multiple times, including accessing a firearm, communicating with a prohibited party, sending threatening messages, and absconding from a residential reentry center. After absconding, he ceased communication with his probation officer and failed to complete the reentry program. He was arrested eight months later.The United States District Court for the Western District of Missouri held a hearing, revoked Pratt's supervised release, and sentenced him to 24 months' imprisonment. Pratt appealed, challenging the procedural soundness and substantive reasonableness of his sentence.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court adequately explained its decision, noting Pratt's extensive criminal history and resistance to supervision. The district court's reference to Pratt's "bobbles" while on supervision was not plain error, as the court was familiar with his history. The appellate court also found no abuse of discretion in the district court's consideration of the § 3553(a) factors, including Pratt's criminal history and characteristics. The court held that the district court did not place undue weight on improper factors and acted within its discretion in imposing the statutory maximum sentence.The Eighth Circuit affirmed the judgment of the district court, upholding Pratt's 24-month imprisonment sentence. View "United States v. Pratt" on Justia Law