Justia Criminal Law Opinion Summaries

Jessie Hoffman was convicted of first-degree murder for the kidnapping, rape, and murder of Mary "Molly" Elliot in 1998 and sentenced to death. After exhausting all state and federal post-conviction remedies, his execution was delayed due to the unavailability of lethal injection drugs. In 2024, Louisiana adopted nitrogen hypoxia as a method of execution. Hoffman challenged this new method, arguing it violated the Eighth Amendment.The United States District Court for the Middle District of Louisiana granted Hoffman's motion for a preliminary injunction, preventing his execution by nitrogen hypoxia. The court concluded that Hoffman had exhausted his administrative remedies under the Prison Litigation Reform Act (PLRA) and found that nitrogen hypoxia posed a substantial risk of superadding pain and suffering. The court suggested that execution by firing squad would be a reasonable alternative that would reduce the risk of severe pain.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that Hoffman had indeed exhausted his administrative remedies. However, it disagreed with the district court's conclusion regarding the Eighth Amendment. The Fifth Circuit held that nitrogen hypoxia is painless and that the district court erred in suggesting that the Eighth Amendment requires a more painful method of execution, such as a firing squad. The court emphasized that the Eighth Amendment does not guarantee a painless death and that Hoffman failed to show that nitrogen hypoxia presented a substantial risk of severe pain compared to other methods.The Fifth Circuit vacated the preliminary injunction, allowing Louisiana to proceed with Hoffman's execution by nitrogen hypoxia. View "Hoffman v. Westcott" on Justia Law

In 2017, Dr. Oscar Lightner opened Jomori Health and Wellness in Houston, Texas, where he prescribed controlled substances to 97% of his patients, often without proper examinations. Many patients were brought in by "runners" who paid fees to reserve spots and later resold the prescribed pills. Andres Martinez, Jr., the office manager, collected these payments. Both Lightner and Martinez were indicted on drug-related charges under the Controlled Substances Act.The United States District Court for the Southern District of Texas tried the case. After a five-day trial, the jury found both defendants guilty on all counts. The district court sentenced each to 84 months of imprisonment. Martinez and Lightner appealed their convictions and sentences.The United States Court of Appeals for the Fifth Circuit reviewed the case. Martinez argued that the evidence was insufficient to support his convictions, but the court found that the evidence, including his interactions with runners and knowledge of Lightner's prescribing practices, was sufficient. Lightner raised several issues, including the jury instructions, alleged spoliation of evidence, and the denial of a motion to strike a witness's testimony. The court found no reversible error in these claims.The court also reviewed the sentencing enhancements applied to Lightner, including the calculation of drug weight, a two-level premises enhancement, and a four-level leadership enhancement. The court found that the evidence supported these enhancements and that any potential error was harmless given the substantial downward variance in Lightner's sentence.The Fifth Circuit affirmed the district court's judgment, finding no reversible error in the convictions or sentences of Martinez and Lightner. View "United States v. Lightner" on Justia Law

In 2017, Dr. Oscar Lightner opened Jomori Health and Wellness in Houston, Texas, where he prescribed controlled substances to 97% of his patients, often without proper examinations. Many patients were brought in by "runners" who paid fees to reserve spots and later resold the prescribed pills. Andres Martinez, Jr., the office manager, collected these payments. Both Lightner and Martinez were indicted on drug-related charges under the Controlled Substances Act and pleaded not guilty.The United States District Court for the Southern District of Texas conducted a five-day trial, after which the jury found both defendants guilty on all counts. The district court sentenced each to 84 months of imprisonment. Martinez and Lightner appealed their convictions and sentences.The United States Court of Appeals for the Fifth Circuit reviewed the case. Martinez challenged the sufficiency of the evidence for his convictions, but the court found the evidence sufficient to support the jury's verdicts. The court noted that Martinez's involvement with runners and his knowledge of Lightner's prescribing practices indicated his participation in the conspiracy. The court also upheld Martinez's conviction under Pinkerton liability for the substantive count.Lightner raised several issues on appeal, including the jury instructions, alleged spoliation of evidence, and the denial of a motion to strike a witness's testimony. The court found that while the jury instructions contained an error, it did not affect Lightner's substantial rights due to the ample evidence of his unlawful prescribing practices. The court also found no abuse of discretion in the district court's handling of the spoliation claim and the witness testimony.Regarding sentencing, the court upheld the district court's calculations of drug weight and the application of enhancements for maintaining a premises for drug distribution and for Lightner's leadership role in the conspiracy. The court affirmed the district court's judgment in all respects. View "United States v. Martinez" on Justia Law

David Wood was convicted of capital murder and sentenced to death in 1992 for the brutal murders of six females in 1987. The victims were found buried near El Paso, and evidence indicated that Wood had sexually assaulted them before killing them. Wood's conviction and sentence were affirmed by the Texas Court of Criminal Appeals (CCA). Over the years, Wood pursued extensive litigation in state and federal courts, including multiple motions for post-conviction DNA testing under Chapter 64 of the Texas Code of Criminal Procedure. The trial court granted some of his motions, but the results did not exonerate him. Subsequent motions were denied, and the CCA affirmed these denials, concluding that Wood had engaged in a pattern of piecemeal litigation and delay.Wood then filed a 42 U.S.C. § 1983 suit in the United States District Court for the Western District of Texas, alleging that the CCA's construction of Chapter 64 violated his procedural due process rights. He claimed that the CCA's consistent denial of DNA testing rendered the state-created testing right illusory and that the CCA's interpretation of the statute's unreasonable-delay provision was novel and unforeseeable. The district court dismissed Wood's complaint and denied his motion to stay his execution.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Wood lacked standing for his first claim because a favorable ruling would not substantially likely lead to DNA testing. For his second claim, the court found it meritless, as the CCA's interpretation of the unreasonable-delay provision was neither novel nor unforeseeable. Consequently, the Fifth Circuit affirmed the district court's order and judgment and denied Wood's renewed motion to stay his execution. View "Wood v. Patton" on Justia Law

From 2009 to 2015, Clarence Roland engaged in a scheme to defraud mortgage lenders and title insurance companies by using aliases, fake businesses, and fraudulent documents. He promised homeowners facing foreclosure that he could help them eliminate their mortgages. Instead, he transferred property ownership to his shell entities, created fake mortgages, and sold the properties to unsuspecting buyers. Roland used fraudulent notary stamps and signatures to make these transactions appear legitimate.A jury in the United States District Court for the Southern District of Texas convicted Roland of conspiracy to commit wire fraud, wire fraud, and engaging in monetary transactions over $10,000 derived from unlawful activity. He was sentenced to ten years in prison, ordered to pay restitution of over $3 million, forfeit nearly $2 million, and assessed a $1,000 special assessment.The United States Court of Appeals for the Fifth Circuit reviewed Roland's appeal, where he raised several issues. He argued that the district court erred by admitting evidence of his and his co-conspirator’s prior convictions, limiting his good-faith defense, and denying his request for expert-witness funding. He also claimed that his conduct was not criminal and highlighted a clerical error regarding the special assessment.The Fifth Circuit found no reversible error in the district court's evidentiary rulings, determining that the admission of prior convictions was not plain error and that the limitations on Roland's good-faith defense were either appropriate or harmless. The court also upheld the denial of expert-witness funding, noting Roland's failure to make a formal request. The court agreed with Roland on the clerical error and modified the judgment to remove the $1,000 special assessment. In all other respects, Roland's conviction was affirmed. View "United States v. Roland" on Justia Law

In January 2023, law enforcement executed a search warrant at Juan David Cisneros's residence, resulting from a narcotics investigation. They found ammunition in his bedroom but no drugs or firearms attributable to him. Cisneros admitted to using the ammunition previously but claimed his mother-in-law purchased it. He was charged with possessing ammunition as a convicted felon under 18 U.S.C. § 922(g)(1).The United States District Court for the Southern District of Texas denied Cisneros's motion to dismiss the indictment, which argued that § 922(g)(1) was unconstitutional under the Second Amendment and exceeded Congress's power under the Commerce Clause. Cisneros pleaded guilty but reserved the right to appeal on Second Amendment grounds. The court adopted the Presentence Investigation Report, which included a four-level enhancement for possessing ammunition in connection with drug trafficking, and sentenced him to ninety-six months in prison.The United States Court of Appeals for the Fifth Circuit reviewed the case. Cisneros's facial challenge to § 922(g)(1) was foreclosed by precedent, and his as-applied challenge failed under plain error review. The court affirmed his conviction, finding no clear or obvious error in the application of § 922(g)(1) under the Second Amendment.However, the court found that the district court plainly erred in applying the sentencing enhancement under U.S.S.G. § 2K2.1(b)(6)(B) for possessing ammunition in connection with another felony offense. The court noted that there was no evidence the ammunition facilitated drug trafficking, as required by precedent. This error affected Cisneros's substantial rights, as it likely resulted in a longer sentence. Consequently, the Fifth Circuit vacated Cisneros's sentence and remanded for resentencing. View "United States v. Cisneros" on Justia Law

Hector Flores, Jr. was sentenced to five years of probation under the Assimilative Crimes Act (ACA) for child endangerment, a state jail felony under Texas Penal Code § 22.041. The offense occurred on federal property, Big Bend National Park, where Flores placed his daughter in imminent danger by not providing food for four days in freezing temperatures. After violating his probation terms by testing positive for cocaine, the district court revoked his probation and resentenced him to two years of imprisonment followed by one year of supervised release.The United States District Court for the Western District of Texas initially sentenced Flores to probation. After he violated the terms of his probation, the court revoked his probation and imposed a new sentence of two years of imprisonment, the maximum allowed under Texas law for his offense, followed by one year of supervised release. Flores appealed, arguing that the additional one-year term of supervised release exceeded the maximum sentence authorized by Texas law.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that under the ACA, a federal court may impose a term of supervised release in addition to the maximum term of imprisonment allowed by state law. The court reasoned that supervised release serves rehabilitative purposes distinct from imprisonment and does not extend the term of imprisonment. The court affirmed the district court's decision, concluding that the combined sentence of imprisonment and supervised release was permissible under federal law and consistent with the ACA's requirement for "like punishment." View "USA v. Flores" on Justia Law

Detective Jeff Scroggins of the Livingston Parish Sheriff’s Office suspected Quwinton Norman of supplying methamphetamine to Fleet Wallace, a narcotics distributor. Scroggins applied for search warrants for Norman’s apartment and a nearby house where Norman stayed after a drug transaction. The affidavit supporting the warrants included summaries of text messages between Norman and Wallace and observations of Norman’s activities. A Louisiana state court judge issued the warrants, and officers found drugs, cash, and other incriminating items in the house and Norman’s vehicle. Norman was indicted on federal charges of possession with intent to distribute methamphetamine and cocaine.Norman moved to suppress the evidence, arguing that the affidavit did not establish probable cause and was bare bones. The United States District Court for the Middle District of Louisiana held a hearing and granted the motion to suppress. The government appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s ruling, examining the good-faith exception to the exclusionary rule. The court determined that the good-faith exception applied because the affidavit was not bare bones. It contained specific facts and circumstances, such as text messages indicating drug transactions and observations of Norman’s movements, which allowed officers to reasonably believe there was a nexus between the house and evidence of drug trafficking. The court concluded that the state judge could draw reasonable inferences from the affidavit to determine probable cause. Therefore, the good-faith exception applied, and the court reversed the district court’s order excluding the evidence and remanded the case for further proceedings. View "United States v. Norman" on Justia Law

Matthew Kerns, the sole member and manager of Glade Creek Livestock, LLC, personally guaranteed a loan from First State Bank of Ben Wheeler (FSBBW) using equipment and cattle as collateral. When Glade Creek faced financial difficulties, Kerns sold some of the cattle, leading FSBBW to demand full repayment. Kerns filed for Chapter 7 bankruptcy, and during the automatic stay, FSBBW reported the sale of the collateral to a special ranger with the Texas and Southwestern Cattle Raisers Association (TSCRA). This led to Kerns' indictment and arrest for hindering a secured creditor.The bankruptcy court granted summary judgment in favor of FSBBW, holding that FSBBW's actions fell within the safe harbor provision of the Annunzio-Wylie Money Laundering Act, which protects financial institutions from liability for reporting possible violations of law. Kerns appealed to the district court, which affirmed the bankruptcy court's decision. Kerns then appealed to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit reviewed the case de novo and affirmed the lower courts' decisions. The court held that FSBBW's report to the special ranger was protected under the safe harbor provision of the Annunzio-Wylie Act, as the special ranger qualified as law enforcement under Texas law. The court also found that Kerns had forfeited his argument for the recusal of the bankruptcy judge by not raising it earlier, despite knowing the basis for recusal since 2021. The court concluded that FSBBW's conduct was shielded from liability, and the summary judgment in favor of FSBBW was affirmed. View "Kerns v. First State Bank" on Justia Law

A neighbor called the Fort Worth Police Department at 2:25 a.m. on October 12, 2019, to report that Atatiana Jefferson's front door was open, which was unusual. Officer Aaron Dean and another officer responded, arriving at 2:28 a.m. and 2:29 a.m., respectively. Following protocol, they parked out of view and did not use emergency lights or sirens. They conducted a perimeter sweep of the house, using flashlights to look for signs of a break-in. Jefferson, who was home with her nephew, noticed someone outside and approached the window. Dean, without announcing himself as an officer, commanded Jefferson to show her hands and then fired a shot, killing her.The United States District Court for the Northern District of Texas denied Dean's motion to dismiss based on qualified immunity and stayed discovery. Dean appealed the denial of qualified immunity.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court's judgment regarding the excessive force claim, holding that Dean's use of deadly force without warning was objectively unreasonable under clearly established law. However, the court reversed the district court's judgment on the unreasonable search claim, finding that Dean was performing a community caretaking function and that there was no clearly established law indicating his actions were unreasonable. The case was remanded for further proceedings consistent with the opinion. View "Bakutis v. Dean" on Justia Law