Justia Criminal Law Opinion Summaries

Petitioner, convicted of murdering a police officer and sentenced to death, suffered strokes in recent years resulting in significant cognitive and physical decline. Petitioner sought habeas relief, arguing that he was mentally incompetent to be executed under Ford v. Wainwright and Panetti v. Quarterman. The Alabama trial court decided that petitioner was competent to be executed. The court agreed with petitioner that the trial court's decision relied on an unreasonable determination of the facts and involved an unreasonable application of Panetti. The court explained that Panetti required courts to look at whether the prisoner was able to rationally understand the connection between the crime he committed and the punishment he was to receive. In this case, one of the experts testified that due to a mental disorder, petitioner was not able to make this connection, and another expert never addressed this question at all. The court concluded that this record was therefore wholly insufficient to support the trial court's decision. Accordingly, the court reversed the district court's denial of habeas relief. View "Madison v. Commissioner, Alabama Department of Corrections" on Justia Law

Defendant pleaded guilty to several drug and firearm charges, and the district court reassigned the case to a new judge for sentencing. Defendant argued that the reassignment was unlawful because the judge initially assigned to the case was neither absent nor disabled. The court rejected this argument and concluded that the text of Rule 25 made clear that the rule does not apply where a defendant pleaded guilty. The court also rejected defendant's arguments that the traffic stop was unlawful, that the district court should have reassigned the case back to the initial judge, and that the district court committed procedural and substantive error when it sentenced defendant. Accordingly, the court affirmed the judgment. View "United States v. McCullough" on Justia Law

Petitioner, a Florida prisoner sentenced to death, filed a motion for a certificate of appealability (COA), seeking to appeal the denial of his motion for relief from judgment under Federal Rule of Civil Procedure 60(b). The court denied petitioner's three motions for a COA where reasonable jurists could not debate whether the district court abused its discretion in denying petitioner's Rule 60(b)(6) motion. In this case, petitioner has litigated and re-litigated variations on the same claims for decades. View "Lambrix v. Secretary, Florida Department of Corrections" on Justia Law

Petitioner, convicted of being a felon in possession of a firearm, petitioned for habeas relief, arguing that his earlier motion to vacate was inadequate to test his objection to his sentence enhancement because the court's caselaw about the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e), has changed. The court concluded that, because the motion to vacate gave petitioner an opportunity to challenge his sentence enhancement, his remedy was not inadequate or ineffective to test the legality of his sentence, regardless of any later change in caselaw. The court joined the Tenth Circuit in applying the law as Congress wrote it and held that a change in caselaw does not make a motion to vacate a prisoner's sentence "inadequate or ineffective to test the legality of his detention," 28 U.S.C. 2255(e). Accordingly, the court overruled the Wofford v. Scott test as applied in Bryant v. Warden, FCC Coleman-Medium and Mackey v. Warden, FCC Coleman-Medium, and affirmed the dismissal of the petition for habeas relief. View "McCarthan v. Director of Goodwill Industries-Suncoast" on Justia Law

Petitioner, convicted of murder and sentenced to death, appealed the district court's denial of his 28 U.S.C. 2254 petition for a writ of habeas corpus. The court agreed with the district court that petitioner failed to establish that the Georgia trial court unreasonably rejected his claim that trial counsel failed to investigate, develop, and present mitigating evidence at sentencing, or that petitioner was prejudiced by appellate counsel's failure to investigate and adequately present that claim during the unified appeal procedure. Accordingly, the court affirmed the judgment. View "Butts v. GDCP Warden" on Justia Law

Petitioner was sentenced to life imprisonment and chemical castration after he was convicted of burglary, aggravated kidnapping of a child, and two counts of capital sexual battery. The state court later granted petitioner's motion to correct an illegal sentence on the ground that the trial court failed to comply with the statutory prerequisites for chemical castration. In this appeal, petitioner challenged the district court's dismissal of his petition as second or successive under 28 U.S.C. 2244(b)(1). The court affirmed the dismissal of the petition as second or successive. In this case, because petitioner was not "in custody pursuant to," section 2254(b)(1), the consent order that he not undergo chemical castration did not trigger a new round of federal collateral review. View "Patterson v. Secretary, Florida Department of Corrections" on Justia Law

Defendant pleaded guilty to drug and firearm offenses, entering into a binding agreement with the government. At issue is whether the court should apply the rule of Marks v. United States to the splintered opinion in Freeman v. United States to determine whether a defendant who entered into a plea agreement that recommended a particular sentence as a condition of his guilty plea is eligible for a reduced sentence, 18 U.S.C. 3582(c)(2). The court agreed with the district court's determination that Justice Sotomayor's concurring opinion stated the holding in Freeman because she concurred in the judgment on the narrowest grounds, and the district court's denial of defendant's motion based on the reasoning of that concurring opinion. The court explained that, in this case, defendant was ineligible for a sentence reduction because he was not sentenced "based on a sentencing range," 18 U.S.C. 3582(c)(2), that has since been lowered. Accordingly, the court affirmed the judgment. View "United States v. Hughes" on Justia Law

Petitioner filed a petition for rehearing en banc, which also served under the court's rules as a petition for rehearing before the panel. The court granted the petition for rehearing to the panel to the extent that the court vacated its previous opinion and substituted in its place this one. Petitioner, convicted of battery and sexual battery of a five-year-old in Florida, appealed the dismissal of his habeas petition. The court granted him a certificate of appealability on the the issue of whether the district court improperly determined that his 28 U.S.C. 2254 petition was time-barred, based on its finding that he was not entitled to equitable tolling. The court held that an attorney's negligence, even gross negligence, or misunderstanding about the law is not by itself a serious instance of attorney misconduct for equitable tolling purposes, even though it does violate the ABA model rules as all, or virtually all, attorney negligence does. Because petitioner showed, at most, that his failure to meet the filing deadline was the product of his attorney’s good faith but negligent or grossly negligent misunderstanding of the law, the district court properly dismissed the habeas petition as untimely. View "Cadet v. Florida Department of Corrections" on Justia Law

Petitioner, convicted of conspiracy and drug-related charges, appealed the district court's order denying his motion to vacate his sentence under 28 U.S.C. 2255. The court affirmed the district court's judgment affirming petitioner's convictions on Counts 14 and 17, and its finding that petitioner abandoned any challenge to Count 11. However, the court agreed with the parties and concluded that petitioner's conviction for conspiracy to distribute crack cocaine, Count 1, should be vacated. In this case, a police officer's false testimony was material to the government's case, and the government conceded that it cannot show that the perjured testimony did not have a substantial and injurious effect on the verdict. Therefore, the court vacated petitioner's conviction on Count 1 and remanded for resentencing. View "Phillips v. United States" on Justia Law

Plaintiff, a Georgia state prisoner, filed suit alleging that the grooming policy enforced in Georgia state prisons violates the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc et seq. Specifically, plaintiff contends that the GDOC substantially burdened his exercise of a sincerely held religious belief that Islam requires him to grow an uncut beard. The district court granted summary judgment for the GDOC. The court concluded that the Supreme Court's opinion in Holt v. Hobbs rendered the district court's analysis inadequate. The court vacated and remanded for further consideration because the district court never analyzed the substantial burden, compelling interest, or least restrictive means of plaintiff's case, and because the GDOC has revised its grooming policy since the district court rendered its decision. View "Smith v. Owens" on Justia Law