Justia Criminal Law Opinion Summaries

A physician who owned and operated a hospice company in Louisiana was convicted by a jury of twenty-three counts of health care fraud. The company, under his direction, systematically billed Medicare at higher reimbursement rates than were warranted, particularly by utilizing the General Inpatient Care (GIP) rate for patients who did not qualify, and by billing for additional services already included in hospice per diem rates. Despite being notified by Medicare auditors multiple times that the company’s billing was improper and lacked sufficient documentation, the physician failed to disclose these findings to his staff or to change the company’s billing practices. The fraudulent activity resulted in the company billing Medicare for more than $84 million and receiving over $42 million in payments.Earlier, the United States District Court for the Eastern District of Louisiana presided over the trial. The defendant attempted to introduce an expert witness on Medicare billing and coding, but the court only permitted the witness to testify regarding clinical decision-making, not billing practices, due to insufficient qualifications. After the jury found the defendant guilty on all counts, the district court sentenced him to 240 months in prison—an upward variance from the Sentencing Guidelines—and ordered restitution. The court justified the increased sentence based on the defendant’s lack of remorse, repeated violations of court orders, and the need to deter similar conduct.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether the district court erred in excluding expert testimony, whether the evidence was sufficient to support the convictions, and whether the sentence was unconstitutionally excessive or substantively unreasonable. The Fifth Circuit held that any error in excluding the expert testimony was harmless, found the evidence sufficient to support the convictions, and concluded that the sentence was neither grossly disproportionate nor substantively unreasonable. The court affirmed the judgment of the district court. View "USA v. Akula" on Justia Law

In June 2000, a woman identified as M.M. was attacked in her barracks at Fort Hood, where she was stabbed multiple times and sexually assaulted by an unknown assailant. The investigation initially went cold after DNA collected at the scene did not match any suspects. Nearly two decades later, forensic genetic genealogy linked the DNA to Allen James, who had been stationed at Fort Hood and matched the description of the attacker. He was indicted and ultimately convicted by a jury for attempted murder based on DNA evidence and M.M.'s testimony.Proceedings in the United States District Court for the Western District of Texas resulted in James's conviction for attempted murder. At sentencing, the district court used the 2023 Sentencing Guidelines Manual, which prescribed a higher advisory range than the 1998 Manual that was in effect when the offense occurred. James was sentenced to 200 months’ imprisonment and three years of supervised release. He appealed, arguing insufficient evidence of intent to kill, erroneous jury instructions regarding intent, and a violation of the Ex Post Facto Clause due to use of the later Guidelines Manual.The United States Court of Appeals for the Fifth Circuit reviewed the appeal. The court held that the evidence was sufficient for a rational jury to find specific intent to kill, and the jury instructions, while imperfect, did not constitute reversible error because any defect was invited by James’s own proposed language and did not result in manifest injustice. However, the court found plain error in the district court’s application of the later Guidelines Manual, in violation of the Ex Post Facto Clause, as this resulted in a higher sentencing range. The Fifth Circuit affirmed James’s conviction, vacated his sentence, and remanded for resentencing under the correct Guidelines Manual. View "USA v. James" on Justia Law

Curtis Squire was indicted on a federal charge for possessing a firearm as a convicted felon after police found a handgun in his home during a search related to a shooting investigation. Although the firearm was not linked to the shooting and state charges were dropped, Squire was charged under 18 U.S.C. § 922(g)(1) due to his prior felony convictions, which included drug trafficking, firearm offenses, obstruction of justice, burglary, and unauthorized use of a motor vehicle.The United States District Court for the Eastern District of Louisiana denied Squire’s motion to dismiss the indictment. Squire’s motion argued, among other things, that § 922(g)(1) was unconstitutional as applied to him under the Second Amendment, particularly following New York State Rifle & Pistol Ass’n v. Bruen and United States v. Rahimi. He contended that his right to possess a firearm in his home was protected by historical tradition. After the denial, Squire pleaded guilty without a plea agreement and was sentenced to fifty-two months’ imprisonment and three years of supervised release. He preserved his right to appeal and timely did so.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and considered whether the Second Amendment protects a convicted drug trafficker from being dispossessed of a firearm in his home. The court held that, in light of historical tradition and its own precedent, Congress may disarm individuals convicted of dangerous offenses like drug trafficking, even within the home. The court clarified that this holding is narrow and does not address whether Congress may disarm individuals in the home based on non-dangerous convictions. The Fifth Circuit affirmed the judgment of conviction and sentence. View "USA v. Squire" on Justia Law

The case involves Christopher Filline, who was the police chief of Castroville, Texas. In 2016, Filline’s wife’s Lincoln Navigator was found burned on a remote road. Filline later reported the vehicle stolen and submitted an insurance claim to Farmers Insurance Group, which paid out on the policy. The government alleged that Filline, facing significant financial difficulties, orchestrated the destruction of the Navigator to fraudulently obtain insurance proceeds. Evidence at trial showed Filline discussed his financial problems openly and repeatedly expressed a desire to “get rid of” the vehicle. He recruited an animal-control officer, Rymers, who then enlisted his cousin Hernandez, known for a criminal background, to burn the vehicle in exchange for no payment. The scheme involved staging the car with keys accessible, burning it, and then filing a false theft report and insurance claim.The United States District Court for the Western District of Texas presided over the trial. A jury found Filline guilty of conspiracy to commit wire fraud. Filline twice moved for judgment of acquittal, arguing the government failed to prove an agreement—an essential element of conspiracy—but the district court denied these motions. The court sentenced Filline to probation, a fine, and restitution. Filline appealed, contesting only the sufficiency of evidence regarding the existence of a conspiratorial agreement.The United States Court of Appeals for the Fifth Circuit reviewed the case. The Fifth Circuit applied a de novo standard, viewing the evidence in the light most favorable to the jury’s verdict. It held that the circumstantial evidence was sufficient for a rational jury to find, beyond a reasonable doubt, that Filline and at least one other person agreed to pursue the fraudulent objective. The court affirmed Filline’s conviction. View "USA v. Filline" on Justia Law

Federal agents suspected an individual of marijuana trafficking and coordinated with local law enforcement to stop his vehicle. Instead of complying, the individual led police on a high-speed chase, reaching speeds over 135 miles per hour and striking another vehicle before being apprehended. He was subsequently indicted and pled guilty to conspiracy to distribute and possess with intent to distribute marijuana.During sentencing in the United States District Court for the Western District of Louisiana, the defendant argued that he qualified for the “safety valve” exception under 18 U.S.C. § 3553(f), which allows certain nonviolent drug offenders to avoid statutory minimum sentences if they meet specific criteria, including not having used violence or credible threats of violence in connection with the offense. The district court imposed a 60-month sentence, reflecting the statutory minimum, but initially did not explain its reasoning for denying safety valve relief. On a limited remand from the United States Court of Appeals for the Fifth Circuit, the district court clarified that denial was based on its finding that the defendant’s high-speed flight from police, including striking another vehicle, constituted the “use of violence” under § 3553(f)(2).The United States Court of Appeals for the Fifth Circuit reviewed the district court’s legal interpretation de novo and its factual findings for clear error. The appellate court agreed with the district court that leading police on a dangerous high-speed chase and colliding with another vehicle amounted to “use of violence” within the meaning of the statute. As a result, the defendant was ineligible for safety valve relief. The Fifth Circuit affirmed the district court’s denial of the safety valve and upheld the 60-month sentence. View "USA v. Phillips" on Justia Law

The defendant pleaded guilty to charges of producing and transporting child pornography under federal statutes. As part of a plea agreement, he waived his right to appeal his conviction and sentence, with an exception allowing an appeal if his sentence exceeded the statutory maximum punishment. The presentence report recommended a lengthy prison term and a life term of supervised release, including specific conditions such as prohibiting contact with minors and requiring full disclosure of financial information. The district court adopted these recommendations and sentenced him to 50 years in prison and 15 years of supervised release with the specified conditions. The defendant did not object to these conditions at sentencing.The United States District Court for the Northern District of Texas imposed the sentence. On appeal to the United States Court of Appeals for the Fifth Circuit, the defendant challenged the supervised release conditions, arguing they violated the statutory requirements under 18 U.S.C. § 3583(d) and thus resulted in a sentence exceeding the statutory maximum punishment as contemplated by his plea agreement exception.The United States Court of Appeals for the Fifth Circuit reviewed whether the appeal waiver in the plea agreement barred the defendant’s appeal. The court held that the exception for a sentence “exceeding the statutory maximum punishment” refers only to the quantitative aspects of a sentence—such as the length of imprisonment or supervised release—not the qualitative conditions imposed. The court determined that challenges to the reasonableness of supervised release conditions under § 3583(d) do not fall within the statutory maximum exception. Thus, the defendant’s waiver barred his appeal, and the court dismissed it. View "USA v. Hackney" on Justia Law

Two major airline crashes in 2018 and 2019 involving Boeing 737 MAX aircraft led to the deaths of hundreds of passengers and crew. Investigations revealed that Boeing had concealed important safety information about modifications to the planes’ flight control system, contributing to the crashes. The Department of Justice (DOJ) charged Boeing with conspiracy to defraud the United States but later entered a Deferred Prosecution Agreement (DPA) in 2021, requiring Boeing to pay significant penalties and undertake compliance measures. After Boeing allegedly breached the DPA, the DOJ pursued a Non-Prosecution Agreement (NPA) in 2025, again imposing penalties and compliance obligations in exchange for dismissing the criminal charge. Family members of crash victims challenged both agreements, asserting violations of their rights under the Crime Victims’ Rights Act (CVRA).The United States District Court for the Northern District of Texas found that while the DOJ had originally failed to confer with families before the 2021 DPA due to a legal error, there was no bad faith, and the court lacked authority to modify or review the substance of the DPA or NPA. The district court later granted the DOJ’s motion to dismiss the prosecution against Boeing after the NPA, finding the DOJ’s actions were not in bad faith and were adequately explained.On appeal, the United States Court of Appeals for the Fifth Circuit held that the families’ challenge to the 2021 DPA was moot since the agreement was no longer in effect after Boeing’s breach. Addressing the NPA, the Fifth Circuit concluded the DOJ had fulfilled its obligation to confer with the families and had not misled them. The court also determined it lacked jurisdiction under the CVRA to substantively review the district court’s dismissal of the prosecution. The petitions for writ of mandamus were denied. View "Ryan v. USA" on Justia Law

After Hurricane Harvey in 2017, an individual applied for disaster relief from FEMA, claiming her Houston residence was damaged and providing supporting documentation for her claim, such as hotel receipts, utility bills, and repair estimates. FEMA awarded her approximately $33,000. Later, federal authorities investigated and alleged that the application was fraudulent, asserting that the listed residence did not exist as described, the applicant never lived in Houston, and the supporting documents were fabricated.The United States charged the applicant with disaster relief fraud and wire fraud in the United States District Court for the Southern District of Texas. During trial, the government revealed late disclosures of two items: civil recoupment letters sent to the defendant in 2020 and an email to a third-party contractor who had supposedly inspected the property. The defense argued these late disclosures violated the government's obligations under Brady v. Maryland. The district court ultimately dismissed the indictment without prejudice, citing its supervisory powers and referencing concerns over discovery violations in this and other recent cases before it, despite finding no intentional misconduct by prosecutors.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether the district court erred in dismissing the indictment. The appellate court held there was no Brady violation because the defense failed to show prejudice from the late-disclosed evidence, and the information could have been obtained through reasonable diligence. The court further found that, even assuming a Rule 16 violation, the district court had not properly considered the required factors or imposed the least severe sanction. The Fifth Circuit concluded that the district court abused its discretion in dismissing the indictment and therefore reversed the dismissal order, remanding with instructions to reinstate the indictment. View "USA v. Kuyoro" on Justia Law

A sixteen-year-old girl disappeared from Floresville, Texas in October 2023. Police discovered that she had communicated online with Jayden Douglas Richard Vacchino before her disappearance. The communications revealed Vacchino’s intention to take her from Texas to Louisiana for sexual purposes. Investigators found evidence that Vacchino’s phone was near the victim’s house on the night she went missing, and security footage confirmed his car in the area. Two days later, authorities located Vacchino and the victim together in Shreveport, Louisiana, where he was arrested.Vacchino pleaded guilty in the United States District Court for the Western District of Texas to transporting a minor interstate with intent to engage in criminal sexual conduct under 18 U.S.C. § 2423(a). At the sentencing hearing, the district court did not explicitly adopt the presentence report but imposed a sentence of 260 months in prison, 15 years of supervised release, a $100 special assessment, and a $25,000 fine. The court recommended sex counseling treatment during incarceration and stated it would impose “standard conditions” of supervised release “plus the sex offender conditions.” The written judgment, however, included additional special conditions from the presentence report and omitted the specific recommendation for sex counseling treatment.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed several discrepancies between the oral sentence and the written judgment. The court held that mandatory supervised release condition 10, which required notification of economic changes, conflicted with the oral pronouncement and must be vacated. The court affirmed the other challenged conditions, finding that they either reflected the district court’s intent or clarified ambiguities. The Fifth Circuit also ordered correction of the written judgment to include the oral recommendation for sex counseling treatment. The judgment was thus vacated in part, affirmed in part, and remanded for further proceedings. View "USA v. Vacchino" on Justia Law

Law enforcement officers executed a search warrant at a residence in Starkville, Mississippi, after an officer obtained the warrant through an affidavit detailing three controlled drug purchases involving a confidential informant. The affidavit described the procedures followed during the buys, including continuous surveillance of the informant and searches for contraband before and after each transaction. The search resulted in the seizure of drugs, firearms, money, and cellphones, and the resident was arrested. During a subsequent police interview, the resident was read his Miranda rights and signed a form acknowledging this, but the waiver portion of the form was not read aloud or explained.The United States District Court for the Northern District of Mississippi granted the defendant’s motion to suppress both the physical evidence from the search and the statements made during the interview. The district court found the supporting affidavit for the search warrant to be “bare bones,” lacking sufficient detail or corroboration, and concluded that the officer’s reliance on the warrant was not objectively reasonable. The court further found that the defendant’s signature on the Miranda form did not amount to a voluntary waiver of his rights, as the waiver section was not explained and the officer’s conduct was considered deceptive.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision. The appellate court held that the good-faith exception to the exclusionary rule applied because the affidavit was not “wholly conclusory” and contained sufficient factual detail to justify an officer’s reasonable reliance on the warrant. Thus, the suppression of the physical evidence was reversed. Regarding the statements, the appellate court agreed that the express waiver was involuntary but remanded for the district court to determine whether an implied waiver occurred under the totality of the circumstances. The panel retained jurisdiction pending the district court’s further findings. View "USA v. Weaver" on Justia Law