Justia Criminal Law Opinion Summaries

In this case, the defendant applied for U.S. citizenship in 2011 and, on his application and during an interview, denied ever having committed a crime for which he was not arrested. However, in 2013, he pleaded guilty in North Carolina state court to attempted statutory rape for conduct that occurred in 2008, admitting to engaging in a sexual act with a minor. He did not disclose this conduct on his naturalization application. Years later, a federal grand jury indicted him for naturalization fraud, alleging he knowingly concealed his criminal history to obtain citizenship.The United States District Court for the Western District of North Carolina denied the defendant’s motion to dismiss the indictment for unconstitutional preindictment delay, finding he had not shown actual prejudice from the delay. The court also denied his motion to suppress evidence of his state guilty plea, ruling that he could not collaterally attack the validity of his state conviction in federal court except for a deprivation of counsel, which did not apply here. At trial, the court limited the testimony of the defendant’s expert witness regarding his cognitive abilities, excluding certain opinions about his capacity to understand the application question. The jury convicted the defendant, finding he knowingly made a false statement, and the court sentenced him to six months in prison and revoked his citizenship.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that the defendant failed to demonstrate substantial actual prejudice from the preindictment delay, that the district court properly refused to suppress the state guilty plea, and that while the limitation of the expert’s testimony was error under recent Supreme Court guidance, the error was harmless given the other evidence presented. The conviction and sentence were therefore affirmed. View "US v. Palmer" on Justia Law

Several individuals associated with the Reccless Tigers, a Northern Virginia-based drug gang, were charged with a range of offenses, including drug trafficking, racketeering, kidnapping, and murder. The gang was involved in distributing marijuana and cocaine, and members targeted those who failed to pay drug debts or cooperated with law enforcement. The case centered on the murder of Brandon White, who owed a drug debt and had testified against a gang member. Evidence showed that gang members, including the defendants, orchestrated White’s abduction and murder, with some directly participating in the killing.The United States District Court for the Eastern District of Virginia presided over a joint trial. The court denied several pretrial motions, including requests for continuances, motions to substitute counsel, and a motion to dismiss based on alleged violations of the Speedy Trial Act and the Sixth Amendment. The jury convicted three defendants—Lamborn, Yoo, and Peter—of racketeering conspiracy, murder in aid of racketeering, kidnapping conspiracy, kidnapping resulting in death, drug conspiracy, and killing while engaged in drug trafficking, with Lamborn also convicted of using a firearm resulting in death. Tony was convicted of racketeering and drug conspiracy but acquitted of destructive device charges. The court sentenced Lamborn, Yoo, and Peter to life imprisonment and Tony to 312 months.The United States Court of Appeals for the Fourth Circuit reviewed the case. It affirmed the convictions and most sentences, finding no abuse of discretion in the denial of continuances or substitution of counsel, and sufficient evidence supported the convictions. The court also upheld the district court’s application of sentencing enhancements and rejected the Speedy Trial Act and Sixth Amendment claims. However, it vacated the sentences of Lamborn, Yoo, and Peter due to inconsistencies between the oral pronouncement and written judgments regarding supervised release conditions, remanding for resentencing on that issue. View "US v. Lamborn" on Justia Law

Three individuals, all Cameroonian Americans, participated in a secretive group dedicated to sending firearms and ammunition from Maryland to Anglophone fighters in Cameroon. The group, known as the “Peanut Project,” operated out of a basement in Baltimore County, where they assembled, modified, and packaged weapons and ammunition for overseas shipment. Their concealment methods included obliterating serial numbers from firearms and hiding the items within compressor tanks and other cargo. In 2019, law enforcement intercepted a shipping container en route to Nigeria containing over 35,000 rounds of ammunition and 39 firearms, many with defaced serial numbers. A subsequent search of the group’s base revealed a full-scale operation for manufacturing and preparing firearms for export.A federal grand jury in the United States District Court for the District of Maryland indicted the defendants on five counts, including conspiracy, illegal exportation, transportation of firearms with obliterated serial numbers, and smuggling. After a ten-day jury trial, the defendants were convicted of conspiracy, transporting firearms with obliterated serial numbers, and smuggling, but acquitted on the exportation counts. The district court denied post-trial motions challenging the sufficiency of the evidence and various trial rulings. At sentencing, the court applied enhancements for the number of firearms involved and for trafficking, sentencing each defendant to 63 months’ imprisonment and two years of supervised release.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the convictions and sentences. The court held that the evidence was sufficient to support the jury’s findings, the district court did not abuse its discretion in evidentiary or instructional rulings, and the sentencing enhancements were properly applied. The court also found no error in the oral and written pronouncement of supervised release conditions. The judgments of the district court were affirmed. View "US v. Nji" on Justia Law

Law enforcement stopped a vehicle in which Michael Henderson was a passenger. During a search, a K-9 alerted to drugs in Henderson’s bag, which contained approximately 1,921.2 grams of pure methamphetamine. Henderson was arrested, and while in jail, he made phone calls instructing associates on drug distribution using coded language. One associate, Bonnie Cagle, revealed to police that Henderson’s references to “puppies” were code for firearms, and “sockets” and “tools” referred to drugs. Police recovered two firearms linked to Henderson from Cagle and her mother’s home.Henderson pleaded guilty in the United States District Court for the Southern District of West Virginia to possessing 500 grams or more of methamphetamine with intent to distribute. The presentence investigation report initially recommended a two-level enhancement for possession of a firearm, but after Henderson’s timely objection and the government’s lack of response, the probation officer removed the enhancement. The revised report also recommended a reduction for acceptance of responsibility. The district court later requested supplemental briefing on Henderson’s eligibility for “safety valve” relief under 18 U.S.C. § 3553(f). The government then argued for sentencing enhancements and against the reduction for acceptance of responsibility, which Henderson claimed were untimely.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court acted within its discretion in considering the government’s late arguments for sentencing enhancements, finding that the request for supplemental briefing constituted good cause. The court also found sufficient evidence to support the firearm enhancement, concluding that Henderson constructively possessed firearms in connection with drug trafficking. The court affirmed the district court’s judgment, upholding Henderson’s sentence. View "US v. Henderson" on Justia Law

Gregory Bonnie was serving a 144-month federal prison sentence in South Carolina, consisting of 120 months for drug trafficking convictions and a consecutive 24 months for violating supervised release, which included a conviction under 18 U.S.C. § 924(c) for possession of a firearm during a drug trafficking crime. While incarcerated, Bonnie sought to earn time credits under the First Step Act (FSA) for the 120-month portion of his sentence related to drug offenses, acknowledging that the 24-month portion for the § 924(c) conviction was disqualifying under the FSA.The Bureau of Prisons (BOP) denied Bonnie’s request, treating his consecutive sentences as a single, aggregate term of imprisonment pursuant to 18 U.S.C. § 3584(c), and finding him ineligible for FSA time credits because his aggregate sentence included a disqualifying § 924(c) conviction. After exhausting administrative remedies, Bonnie filed a habeas petition under 28 U.S.C. § 2241 in the United States District Court for the District of South Carolina. The district court granted summary judgment for the warden, holding that the plain text and statutory context of the FSA and § 3584(c) required aggregation of sentences, making Bonnie ineligible for FSA time credits for the entire 144-month sentence.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the statutory interpretation de novo. The court held that, under the FSA and § 3584(c), the BOP must treat multiple consecutive or concurrent sentences as a single, aggregate sentence for administrative purposes, including the computation of FSA time credits. Because Bonnie’s aggregate sentence included a conviction under § 924(c), he was ineligible for FSA time credits for any portion of the sentence. The Fourth Circuit affirmed the district court’s judgment denying Bonnie’s habeas petition. View "Bonnie v. Dunbar" on Justia Law

The defendant was indicted on three charges related to the production and possession of child pornography. He pleaded guilty to one count—production of child pornography—and was sentenced to 256 months in prison, followed by a lifetime of supervised release. The terms of his supervised release included both mandatory and special conditions. Of particular relevance was a special condition requiring him to submit to substance abuse testing and contribute to the cost of such testing, as determined by a sliding scale approved by the Probation Office.The United States District Court for the District of South Carolina imposed these conditions at sentencing. The defendant did not object to the special condition regarding substance abuse testing during the sentencing proceedings. On appeal, he argued that this special condition unconstitutionally delegated a core judicial function—specifically, the authority to determine the number of drug tests—to the Probation Office.The United States Court of Appeals for the Fourth Circuit reviewed the case for plain error, given the lack of objection below. The court found that the plain language of the special condition did not delegate authority to determine the number of drug tests to the Probation Office; rather, it addressed only the payment for drug testing ordered by the court. The court concluded that the discretion over the number of drug tests remained with the district court, and the special condition merely facilitated payment. As a result, the Fourth Circuit held that there was no error, let alone plain error, in imposing the special condition and affirmed the defendant’s sentence. The government’s motion to dismiss the appeal based on an appeal waiver was denied as moot. View "US v. Jones" on Justia Law

The defendant purchased fifty-nine firearms over sixteen months, completing federal transaction records for each purchase and listing two Virginia addresses as his residence. However, he did not live at either address—one did not even exist. A grand jury indicted him on twenty-four counts of making false statements to a federal firearms licensee. The government had substantial evidence, including testimony from residents of the listed addresses and GPS data showing the defendant’s actual residence in Maryland. On the eve of trial, the defendant entered into a plea agreement, pleading guilty to one count in exchange for dismissal of the remaining counts and a sentencing recommendation for acceptance of responsibility.The United States District Court for the Eastern District of Virginia accepted the guilty plea after a colloquy that omitted several requirements of Federal Rule of Criminal Procedure 11, such as explicit discussion of the appeal waiver and the nonbinding nature of the Sentencing Guidelines. The defendant did not object at the time. Months later, after replacing his original counsel due to alleged ineffectiveness and disciplinary issues, the defendant moved to withdraw his plea, arguing it was not knowing and voluntary. The district court denied the motion and sentenced him to fourteen months’ imprisonment and two years of supervised release.The United States Court of Appeals for the Fourth Circuit reviewed the case, applying plain error review to the Rule 11 colloquy and abuse of discretion review to the denial of the motion to withdraw. The court held that, despite the procedural deficiencies, the defendant failed to show a reasonable probability that he would not have pleaded guilty absent the errors. The court also found no fair and just reason to permit withdrawal of the plea, given the evidence, the delay in seeking withdrawal, and the lack of prejudice to the defendant. The judgment of the district court was affirmed. View "United States v. Smith" on Justia Law

A man was accused of sexually abusing a minor, referred to as Jane Doe, based on allegations that surfaced in 2018 and 2019. Initially, the police received a referral from Child Protective Services after Doe made statements to a suicide hotline about being abused by her “father’s friend.” The case was closed when Doe refused to discuss the allegations. In 2019, after another suicide attempt, Doe identified the man by name during therapy, and this information was relayed to the police. Detective Thorsdottir conducted a forensic interview with Doe, who provided detailed accounts of abuse and identified the accused. The investigation included interviews with Doe’s parents and therapists, surveillance, and searches of the accused’s home, which yielded a handgun but no evidence of child pornography. The accused was arrested and indicted, but the charges were later dropped after new evidence suggested Doe had previously identified a different individual as her abuser.The accused filed a civil suit in Virginia state court, later removed to the United States District Court for the Eastern District of Virginia, alleging malicious prosecution under both state law and the Fourth Amendment. The district court dismissed the complaint under Rule 12(b)(6), finding that the plaintiff failed to plausibly allege a lack of probable cause for his arrest and prosecution, and that the detective was entitled to qualified immunity on the federal claim.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the dismissal de novo. The court held that the complaint and its exhibits did not plausibly allege that the detective acted with deliberate or reckless disregard for the truth, nor that she omitted material facts necessary to negate probable cause. The court concluded that probable cause existed based on Doe’s identification and corroborating evidence, and affirmed the district court’s dismissal of both the federal and state malicious prosecution claims. View "Moretti v. Thorsdottir" on Justia Law

Three individuals were tried and convicted following a three-week jury trial for their involvement in a violent criminal enterprise. The evidence showed that they were members of a gang operating in northern Virginia and participated in two attempted murders in 2019. One victim was lured into a car, attacked, and left for dead, while another was targeted after surveillance and shot. The defendants played various roles, including driving, surveillance, and assisting in evasion from law enforcement. The charges included racketeering conspiracy, conspiracy to commit murder, drug distribution conspiracy, and, for some, attempted murder, assault with a dangerous weapon, and firearms offenses.The United States District Court for the Eastern District of Virginia presided over the trial. During the proceedings, issues arose regarding the quality of interpretation provided by a court-appointed interpreter, leading the defendants to move for a mistrial. The district court conducted a hearing, found the interpretation errors to be limited and not material, and denied the motion for mistrial. After the trial, the government disclosed unrelated official misconduct by its expert witness on gangs, prompting the defendants to move for a new trial. The district court denied this motion, finding the new evidence was merely impeaching and not material, given the overwhelming evidence of guilt.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that the interpretation errors did not rise to the level of a constitutional or structural error, as they were isolated and did not render the trial fundamentally unfair. The court also held that the post-trial disclosure regarding the government’s expert witness did not warrant a new trial under Rule 33 or Brady, as it was not material and would not have likely produced a different result. The Fourth Circuit affirmed the district court’s judgment. View "US v. Sandoval" on Justia Law

Marian Hudak was charged with two federal hate crimes after separate assaults on two men in North Carolina. The first victim, J.D., was a Mexican-American neighbor whom Hudak had repeatedly harassed with racial slurs and threats, culminating in a physical attack. The second victim, J.S., was a Black man whom Hudak confronted in traffic, using racial epithets and threats, and physically attacked his vehicle before chasing him to his apartment complex and threatening further violence. Evidence showed Hudak possessed Nazi and Ku Klux Klan memorabilia and had a history of expressing racist views.The United States District Court for the Middle District of North Carolina presided over Hudak’s trial. The government presented evidence of Hudak’s racist motives, including testimony about his Nazi memorabilia and prior racist conduct. Hudak conceded intent to injure and intimidate but argued his actions were due to road rage and mental illness, not racial animus. The district court excluded expert testimony about Hudak’s mental illness, finding it unreliable and irrelevant under Federal Rule of Evidence 702 and the Insanity Defense Reform Act, since Hudak did not plead insanity. The court also admitted evidence of Nazi memorabilia after Hudak testified about his interest in military history, determining he had “opened the door” to its relevance.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s evidentiary rulings for abuse of discretion. The Fourth Circuit held that the district court properly excluded the mental health evidence and correctly admitted the Nazi memorabilia after Hudak’s own testimony. The court affirmed the jury’s verdict, holding that the government only needed to prove the victims’ race or national origin was a but-for cause of the assaults, and that Hudak received a fair trial. The judgment of the district court was affirmed. View "United States v. Hudak" on Justia Law