Justia Criminal Law Opinion Summaries

In this case, the petitioner was arrested after an incident in which he was accused of firing a gun into a neighbor’s trailer. Law enforcement recovered evidence at the scene and, following his arrest, the petitioner gave a written statement after being advised of his rights. He was indicted on two counts: shooting into a dwelling and possession of a firearm by a convicted felon. Due to a series of administrative errors, judicial conflicts, and continuances, the petitioner remained incarcerated for over three years before trial. During this period, a key defense witness died. The petitioner repeatedly asserted his right to a speedy trial through pro se motions.The Circuit Court of Tishomingo County, Mississippi, applied the four-factor test from Barker v. Wingo to the petitioner’s speedy trial claim. The court found a violation as to the first count (shooting into a dwelling) but not the second (firearm possession), and dismissed only the first count. The petitioner was tried and convicted on the remaining count and sentenced as a habitual offender. The Mississippi Court of Appeals affirmed, holding that the speedy trial right could be analyzed and remedied on a count-by-count basis in a multi-count indictment. The Mississippi Supreme Court and the United States Supreme Court denied further review.The United States Court of Appeals for the Fifth Circuit reviewed the case on habeas corpus. The court held that, under clearly established federal law as determined by the Supreme Court, when a speedy trial violation is found, the only permissible remedy is dismissal of the entire indictment, not just the affected count. The Fifth Circuit concluded that the Mississippi appellate court’s approach was an unreasonable application of federal law. The judgment of the district court was reversed, and the case was remanded with instructions to grant the writ of habeas corpus. View "Berryman v. Huffman" on Justia Law

Juan Alaniz was convicted of possessing a firearm and ammunition as a convicted felon, in violation of 18 U.S.C. § 922(g)(1). Alaniz had prior state felony convictions for illegally possessing a controlled substance and for burglary. He challenged his conviction on constitutional grounds, arguing that the statute exceeded Congress’s authority under the Commerce Clause, violated the Second Amendment on its face, and violated the Second Amendment as applied to him.The United States District Court for the Southern District of Texas reviewed the case and entered a conviction against Alaniz. On appeal, Alaniz raised the same constitutional arguments before the United States Court of Appeals for the Fifth Circuit. He specifically argued that only his controlled substance conviction should be considered as the predicate for his § 922(g)(1) conviction, and that his burglary conviction should not be relevant to the constitutional analysis.The United States Court of Appeals for the Fifth Circuit rejected Alaniz’s Commerce Clause and facial Second Amendment challenges, citing circuit precedent. The court reviewed his as-applied Second Amendment challenge de novo and held that the government may consider Alaniz’s entire criminal record, including his burglary conviction, when evaluating the constitutionality of § 922(g)(1) as applied to him. The court found that founding-era laws support the constitutionality of disarming individuals convicted of burglary. Therefore, Alaniz’s as-applied challenge was foreclosed by circuit precedent, and the Fifth Circuit affirmed the judgment of the district court. View "United States v. Alaniz" on Justia Law

A group of individuals with large social media followings was charged with securities fraud and conspiracy to commit securities fraud. The government alleged that these individuals engaged in a “pump and dump” scheme: they would purchase securities, then use their social media platforms to post false or misleading information about those securities to induce their followers to buy, thereby artificially inflating the price. After the price increased, the defendants would sell their holdings for a profit. The indictment claimed that the defendants collectively profited $114 million from this scheme.After indictment in the United States District Court for the Southern District of Texas, one defendant pleaded guilty while the others moved to dismiss the indictment. The district court granted the motion to dismiss, reasoning that the indictment failed to allege a scheme to deprive victims of a traditional property interest, instead only alleging deprivation of valuable economic information. The district court relied on the Supreme Court’s decision in Ciminelli v. United States, which held that deprivation of economic information alone does not constitute fraud under federal law.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the sufficiency of the indictment de novo. The Fifth Circuit concluded that the indictment adequately alleged both a scheme to defraud and an intent to defraud, as required by the securities fraud statute. The court distinguished the case from Ciminelli, finding that the indictment alleged a fraudulent-inducement theory—whereby the defendants used misrepresentations to induce followers to part with money by purchasing securities—not merely a deprivation of information. The court also held that the fraud statutes do not require proof that the defendants intended to cause economic harm, only that they intended to obtain money or property by deceit. The Fifth Circuit reversed the district court’s dismissal of the indictment and remanded the case for further proceedings. View "USA v. Constantinescu" on Justia Law

The petitioner was convicted of capital murder and sentenced to death in Texas in 2010 for the killing of his fiancée’s thirteen-month-old daughter. The prosecution’s case relied heavily on DNA evidence and forensic testimony. Over the years, the petitioner pursued multiple avenues of postconviction relief, including direct appeal, state habeas petitions, and federal habeas petitions, all of which were denied. In 2024, he sought access to additional electronic DNA data from the Southwestern Institute of Forensic Sciences, arguing that this information was necessary to evaluate the reliability of the forensic evidence used at trial. After being denied access by the district attorney and the convicting court, he filed a lawsuit under 42 U.S.C. § 1983, claiming that Texas’ postconviction relief procedures violated his due process rights by giving prosecutors unreviewable discretion to withhold evidence.The United States District Court for the Eastern District of Texas dismissed the § 1983 complaint for failure to state a claim, finding that the petitioner had not sufficiently alleged a due process violation and that his request for an injunction resembled an improper petition for a writ of mandamus. The district court also denied his motion for discovery. The petitioner appealed and, in the interim, sought a stay of execution and authorization to file a successive habeas petition based on new evidence and scientific developments.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s dismissal, holding that Texas’ postconviction relief procedures do not violate due process, as they provide adequate opportunities for discovery and judicial review in habeas proceedings. The court also denied the motions for a stay of execution and for authorization to file a successive habeas petition, finding that the petitioner failed to meet the stringent requirements for such relief. The court granted leave to file a motion in excess of the word limit. View "In Re: Milam" on Justia Law

Celia Ignacia Esquivel-Bataz, a Mexican citizen, was previously convicted of making a false statement to obtain credit and deported in 2012. In April 2025, she was found by ICE agents at an illegal gambling parlor in Houston. She was indicted for illegal reentry after deportation following a felony conviction, in violation of 8 U.S.C. § 1326(a) and (b). ICE lodged an immigration detainer against her, indicating that she would be taken into custody and removed to Mexico if released.A magistrate judge initially found that Esquivel-Bataz was not a flight risk and ordered her release on bond pending trial. The Government responded with an emergency motion to stay and revoke the release order, which the United States District Court for the Southern District of Texas granted. Esquivel-Bataz then moved for pretrial release, and the district court held an evidentiary hearing. After hearing testimony, including from an ICE officer about the detainer’s effect, the district court denied her motion, finding her to be a flight risk based on her criminal history, Mexican citizenship, prior deportation, and current unlawful presence.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s order under an abuse-of-discretion standard. The appellate court held that the district court did not abuse its discretion in denying pretrial release. The Fifth Circuit clarified that the district court did not treat the immigration detainer or potential deportation as flight risk per se, but rather considered the totality of circumstances, including individualized factors required by the Bail Reform Act. The order denying pretrial release was affirmed. View "United States v. Esquivel-Bataz" on Justia Law

In early 2023, police responded to a disturbance at a residence in Odessa, Texas, where Deimon Nolan Simpson, who had recently been evicted, attempted to enter the house he believed was still his. After being blocked by the new tenant, Simpson retrieved a firearm from his car, entered through a window, and shot the tenant’s dog. Simpson, a convicted felon with prior convictions including possession of a controlled substance, evading arrest or detention with a vehicle, and being a felon in possession of a firearm, was charged with violating 18 U.S.C. § 922(g)(1), which prohibits felons from possessing firearms.The United States District Court for the Western District of Texas denied Simpson’s motion to dismiss the indictment. Simpson then pleaded guilty, admitting to the relevant prior felony convictions. On appeal, Simpson challenged the constitutionality of § 922(g)(1) as applied to him under the Second Amendment, and also raised facial and Commerce Clause challenges, which he acknowledged were foreclosed by existing Fifth Circuit precedent.The United States Court of Appeals for the Fifth Circuit reviewed the constitutional challenge de novo. The court held that the felon-in-possession statute is constitutional as applied to Simpson because his predicate felony—evading arrest or detention with a vehicle—involved violent conduct, and there is a historical tradition of disarming individuals who pose a credible threat of violence. The court found that both historical and contemporary laws support permanent disarmament in such circumstances, and that the statute does not broadly restrict firearm rights but targets those with demonstrated threats to public safety. Accordingly, the Fifth Circuit affirmed the district court’s denial of the motion to dismiss. View "USA v. Simpson" on Justia Law

Luis Alfredo Lezama-Ramirez, a noncitizen who had previously been removed from the United States, pleaded guilty to unlawfully reentering the country in violation of federal law. After his guilty plea, the Probation Office prepared a presentence report (PSR) that included a list of standard and special conditions for supervised release. At sentencing, Lezama-Ramirez’s counsel indicated there were no objections to the PSR, and the district court adopted it. The court imposed a one-year term of supervised release, referencing compliance with standard and special conditions, but did not read these conditions aloud. The written judgment later included the same conditions as those in the PSR.The United States District Court for the Eastern District of Louisiana entered the judgment, and Lezama-Ramirez appealed, arguing that there were discrepancies between the oral pronouncement of supervised release conditions at sentencing and those listed in the written judgment. He specifically challenged the imposition of certain standard and special conditions that were not read aloud, as well as differences between the oral and written versions of two particular conditions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that because Lezama-Ramirez had notice of the supervised release conditions through the PSR and did not object at sentencing, there was no reversible error in imposing the conditions that were not read aloud. However, the court found that the written version of one special condition (Special Condition 2) imposed an additional reporting requirement not included in the oral pronouncement, which constituted an impermissible conflict. The Fifth Circuit vacated the imposition of Special Condition 2 and remanded for the district court to conform it to the oral pronouncement, while affirming the remainder of the judgment. View "United States v. Lezama-Ramirez" on Justia Law

The defendant pleaded guilty to possessing a firearm after a felony conviction, in violation of 18 U.S.C. § 922(g)(1). The presentence investigation report determined that the defendant’s offense level was increased due to two prior Louisiana felony convictions: aggravated battery and distribution of cocaine. The report also applied enhancements for a stolen firearm and use of the firearm in connection with another felony. The defendant objected to these enhancements and the classification of his prior aggravated battery conviction as a “crime of violence.” The district court overruled the objections, adopted the report’s findings, and sentenced the defendant to 120 months in prison, the statutory maximum.On appeal to the United States Court of Appeals for the Fifth Circuit, the defendant argued that § 922(g)(1) is unconstitutional under the Second Amendment, relying on New York State Rifle & Pistol Ass’n, Inc. v. Bruen, and that the district court erred in treating his prior aggravated battery conviction as a crime of violence for sentencing purposes. The defendant had not raised these arguments in the district court, so the Fifth Circuit reviewed for plain error.The Fifth Circuit held that, under existing precedent, a conviction under § 922(g)(1) does not constitute plain error, and there has been no development in the law to suggest otherwise. Regarding the sentencing enhancement, the court found that the defendant failed to show a “realistic probability” that Louisiana courts would uphold an aggravated battery conviction based on reckless or negligent conduct, as required to demonstrate clear or obvious error under the categorical approach. The court concluded that neither the conviction nor the sentence was reversible under plain error review and affirmed the judgment of the district court. View "USA v. Sereal" on Justia Law

Five individuals were charged in federal court for their roles in a large-scale drug trafficking operation. The scheme involved purchasing marijuana from states where it was legal, such as California and Oregon, and distributing it to twenty-one other states. The operation used drivers to transport marijuana and related products, with cash proceeds handled outside of financial institutions to avoid detection. Law enforcement investigations included surveillance, traffic stops, and searches of residences, warehouses, and storage units, resulting in the seizure of large quantities of marijuana, THC products, cash, and firearms. The lead investigator analyzed cell phone data to estimate the scope of the conspiracy, concluding it involved over 23,000 kilograms of marijuana.The United States District Court for the Eastern District of Texas indicted the five appellants and ten co-defendants on multiple counts, including conspiracy to possess with intent to distribute marijuana, conspiracy to commit money laundering, and other individualized charges. Eight co-defendants pleaded guilty, while the five appellants went to trial. After an eight-day trial, the jury convicted all five of conspiracy to possess with intent to distribute 1,000 kg or more of marijuana and conspiracy to commit money laundering. Roberts was also convicted of continuing criminal enterprise and possession of a firearm in furtherance of a drug trafficking crime. Sentences ranged from 48 to 240 months’ imprisonment, with some counts dismissed or sentences ordered to run concurrently.The United States Court of Appeals for the Fifth Circuit reviewed the convictions and sentences. The court affirmed the convictions for conspiracy to possess with intent to distribute marijuana and promotional money laundering, but vacated the sentences for certain defendants due to errors in the admission of a summary chart used to estimate drug quantities and clerical errors in the judgments and presentence reports. The court remanded for resentencing under the default penalty provision and correction of clerical errors, while affirming other aspects of the convictions and venue determinations. View "United States v. McGuire" on Justia Law

Ricky Wilson was implicated in an incident at a Waffle House, where he allegedly brandished a green pistol with a drum magazine during a dispute, causing fear in another customer. The victim identified Wilson, his vehicle, and the weapon. A detective, already investigating Wilson for another matter, learned that Wilson’s girlfriend rented an apartment at 212 Central Avenue, where Wilson’s car was later observed. Two weeks after the Waffle House incident, the detective sought and obtained both an arrest warrant for Wilson and a search warrant for the apartment, based on an affidavit that recounted the Waffle House events and stated that items related to the assault were “believed to be located” at the apartment. The search yielded ammunition, marijuana, and a firearm, leading to federal charges against Wilson.The United States District Court for the Eastern District of Louisiana granted Wilson’s motion to suppress the evidence found at the apartment. The court found that the affidavit supporting the search warrant failed to establish a nexus between the Waffle House incident and the apartment, rendering the warrant unsupported by probable cause. The court also determined that the good-faith exception to the exclusionary rule did not apply because the affidavit was so lacking in indicia of probable cause that reliance on it was unreasonable. The government appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s suppression of the evidence. The Fifth Circuit held that the affidavit was a “bare-bones” statement, offering no facts connecting the alleged crime to the apartment, and thus failed to establish probable cause. The court further held that the good-faith exception did not apply because the affidavit was so deficient that no reasonable officer could believe it established probable cause. The suppression of the evidence was therefore proper. View "United States v. Wilson" on Justia Law