Justia Criminal Law Opinion Summaries

A father, Scott Williams, and his son, Taeyan Williams, were convicted by a federal jury of various drug-related offenses, including conspiracy to distribute and possess with intent to distribute marijuana and cocaine. The case stemmed from an investigation into the disappearance of a drug dealer, Noah Smothers, who supplied drugs to Scott and Taeyan. A search of Scott's home revealed large quantities of drugs, firearms, and cash. Both Scott and Taeyan were found guilty of conspiracy and possession with intent to distribute, while Scott was also convicted of additional charges related to methamphetamine and evidence destruction.The United States District Court for the District of Maryland denied Scott's motion to suppress evidence obtained from the search, despite his claim that law enforcement failed to knock and announce before entering. The court held that suppression was not the appropriate remedy. Scott and Taeyan were sentenced to 276 months and 150 months in prison, respectively, followed by five years of supervised release. Both appealed their convictions and sentences.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed Taeyan's conviction, finding sufficient evidence to support his possession with intent to distribute charges, based on his connection to the drugs found in Scott's home. The court also upheld the district court's denial of Scott's motion to suppress, citing exigent circumstances that justified the no-knock entry. Additionally, the court rejected Scott's request for a sentence reduction under the newly promulgated U.S.S.G. § 4C1.1, advising him to seek relief through a motion under 18 U.S.C. § 3582. Finally, the court found no improper delegation of judicial authority in the conditions of Scott's supervised release, affirming the district court's judgments in their entirety. View "United States v. Williams" on Justia Law

Police officers responded to a noise complaint at a house party in Sanford, North Carolina, on September 12, 2021. They heard gunshots and saw the defendant, Chad Marques Jennings, run to a van and speed away. After a chase, officers detained Jennings, who admitted to having a gun in his waistband. Bullet casings found at the scene matched Jennings' gun. Jennings, a convicted felon, was charged with being a felon in possession of a firearm and pled guilty.The United States District Court for the Middle District of North Carolina held a sentencing hearing where Jennings' attorney spoke, and Jennings was invited to address the court. Jennings spoke about his struggles with alcoholism, read a poem, and a prepared speech. The court interrupted Jennings twice with questions and later prevented him from reading a letter to his mother, focusing instead on questioning him about his criminal history. The court sentenced Jennings to the statutory maximum of 120 months, citing the seriousness of the offense and his criminal history. Jennings appealed, arguing that the court denied him the full exercise of his allocution right.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court did not err in its handling of Jennings' allocution. The court found that the district court's interruptions were permissible clarifying questions and that the exclusion of the letter to Jennings' mother was within the court's discretion to limit irrelevant or repetitive information. The court concluded that Jennings was given a reasonable opportunity for allocution and affirmed the district court's judgment and sentence. View "United States v. Jennings" on Justia Law

William Davis Jr. was arrested for reckless driving after police observed him using a handheld device while driving. During the arrest, officers discovered a firearm hidden in his waistband. Davis, a convicted felon, pleaded guilty to being a felon in possession of a firearm. At sentencing, the district court varied upward from the Sentencing Guidelines range of 21 to 27 months and imposed a sentence of 72 months. Davis appealed, arguing that the sentence was procedurally and substantively unreasonable.The United States District Court for the Eastern District of Virginia initially calculated Davis's Sentencing Guidelines range as 57 to 71 months, based on a base offense level of 24 due to his prior felony convictions for controlled substance offenses. However, the court later applied the categorical approach from United States v. Campbell, which led to a recalculated base offense level of 14 and a revised Guidelines range of 21 to 27 months. Despite this, the district court granted the government's motion for an upward variance, citing Davis's extensive criminal history and the seriousness of his offense.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The appellate court found that the district court had conducted an individualized assessment of the facts and arguments, adequately explained its reasoning, and properly considered the § 3553(a) factors. The court emphasized that the district court's findings regarding the seriousness of Davis's offense and his extensive criminal history justified the upward variance. The appellate court concluded that the 72-month sentence was both procedurally and substantively reasonable. View "US v. Davis" on Justia Law

Rhonda and Robert Notgrass fraudulently obtained benefits from the Pandemic Unemployment Assistance program by falsely claiming unemployment due to the COVID-19 pandemic. Robert, a minister, and Rhonda, his wife, were ineligible for these benefits as Robert was fired for reasons unrelated to the pandemic, and Rhonda had not lost her job. They both pleaded guilty to misdemeanors and were sentenced to probation by the district court.The United States District Court for the Southern District of West Virginia sentenced the Notgrasses to five years of probation, including several conditions. The Notgrasses appealed four of these conditions: obtaining permission before leaving their judicial district, prohibition on possessing dangerous weapons, registering with an unemployment agency, and Robert's participation in a supervised mental-health treatment program. They argued that these conditions were both procedurally and substantively unreasonable.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court first determined that the Notgrasses' appellate waiver did not cover challenges to probation conditions, allowing the appeal to proceed. On the merits, the court found that the district court had adequately explained the conditions in light of the Notgrasses' objections. The travel-permission and weapons prohibition conditions were standard and self-evident, while the unemployment registration and mental-health treatment conditions were tailored to the Notgrasses' specific circumstances. The court held that all four conditions were reasonably related to the § 3553(a) sentencing factors and were not an abuse of discretion.The Fourth Circuit affirmed the district court's sentences, finding the probation conditions both procedurally and substantively reasonable. View "US v. Notgrass" on Justia Law

Plaintiffs, business entities owning recovery rights assigned by health insurers and other third-party Medicare payors, alleged that Defendants, including a drug manufacturer, a specialty pharmacy, and healthcare nonprofits, colluded to inflate the price and quantity of the drug Xenazine. This alleged scheme purportedly violated the Racketeer Influenced and Corrupt Organizations Act (RICO) and various state laws, causing the Assignors to reimburse inflated Xenazine prescriptions at supra-competitive prices.The United States District Court for the Eastern District of Virginia dismissed the class-action complaint with prejudice, concluding that Plaintiffs failed to adequately allege that Defendants’ conduct proximately caused their injuries. The court emphasized that RICO’s proximate-causation requirement focuses on the directness of the harm, not its foreseeability. The court found the alleged causal chain too attenuated, involving numerous independent actors like physicians and pharmacists, and dismissed the state-law claims for similar reasons.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal of the federal RICO claims, agreeing that Plaintiffs failed to establish proximate causation. The court noted that the alleged scheme had more direct victims, such as distributors and wholesalers, and that the volume of Xenazine prescriptions depended on the independent decisions of doctors. The court also affirmed the dismissal of the state-law consumer-protection and unjust-enrichment claims, finding them insufficiently pleaded.The Fourth Circuit reversed the district court’s conclusion that Plaintiffs had standing to bring claims on behalf of unidentified assignors, remanding those claims for dismissal without prejudice. The court upheld the district court’s denial of post-judgment relief and leave to amend the complaint, concluding that further amendment would be futile. View "MSP Recovery Claims, Series LLC v. Lundbeck LLC" on Justia Law

In early 2021, Jarohn Parham was stopped by Newport News, Virginia police for driving with an expired registration. During the stop, officers observed Parham reaching towards the center console and subsequently found a .25 caliber semi-automatic pistol in the vehicle. Parham, a convicted felon, was arrested and later indicted by a federal grand jury for being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1). He pled guilty to the charge without a plea agreement but with a stipulated statement of facts.The United States District Court for the Eastern District of Virginia calculated Parham’s Sentencing Guidelines range, determining his base offense level to be 20 under U.S.S.G. § 2K2.1(a)(4)(A), based on a prior conviction for Virginia common law robbery, which the court deemed a crime of violence. Parham objected, arguing that his prior conviction did not qualify as a crime of violence under the Guidelines. The district court overruled his objections, finding that Virginia robbery met the generic definition of robbery and imposed an 84-month sentence.The United States Court of Appeals for the Fourth Circuit reviewed the case and agreed with Parham, finding that Virginia robbery does not qualify as a crime of violence under the Sentencing Guidelines. The court noted that Virginia robbery can be committed by threatening to accuse the victim of sodomy, which does not involve the use, attempted use, or threatened use of physical force. Consequently, the court reversed the district court’s judgment, vacated Parham’s sentence, and remanded the case for resentencing. The appellate court also instructed the district court to consider whether Parham’s conviction for use of a firearm during a robbery qualifies as a crime of violence. View "United States v. Parham" on Justia Law

Robert Valladares, who struggled with drug addiction, distributed fentanyl to a friend who subsequently overdosed and died. Valladares was initially charged with distribution resulting in death but ultimately pleaded guilty to lesser charges without the death-resulting enhancement. He was sentenced to 144 months in prison. Valladares sought to earn time credits under the First Step Act, which allows incarcerated individuals to earn credits for participating in recidivism reduction programs, except for those convicted of certain offenses, including drug offenses resulting in death.The Bureau of Prisons (BOP) deemed Valladares ineligible for time credits, citing his conviction under 21 U.S.C. § 841(b)(1)(C) and the resulting death. Valladares challenged this decision through BOP’s administrative process and then filed a habeas corpus petition in the United States District Court for the Northern District of West Virginia. The district court denied his petition, agreeing with BOP that Valladares was ineligible due to the death associated with his crime.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the First Step Act’s ineligibility provision, 18 U.S.C. § 3632(d)(4)(D)(lviii), applies only to those convicted of the death-resulting enhancement element. Since Valladares was not convicted of this enhancement, he is eligible to earn time credits. The Fourth Circuit reversed the district court’s decision and remanded the case, allowing Valladares to earn time credits under the First Step Act. View "Valladares v. Ray" on Justia Law

In 2019, the FBI and DEA, along with local law enforcement, investigated a Mexican drug trafficking organization operating in Mexico, California, Georgia, and North Carolina. Oscar Pliego-Pineda, based in Atlanta, Georgia, was identified as a key figure in coordinating methamphetamine deliveries and managing drug proceeds. He arranged multiple drug transactions and coordinated logistics for methamphetamine shipments, including converting liquid methamphetamine to crystal form.The United States District Court for the Middle District of North Carolina sentenced Pliego-Pineda to 120 months in prison after he pled guilty to conspiracy to distribute methamphetamine and conspiracy to commit money laundering. The court applied a three-level managerial role enhancement under the United States Sentencing Guidelines, which Pliego-Pineda contested, arguing that the district court erred in applying the enhancement and that his sentence was substantively unreasonable.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court upheld the district court's application of the managerial role enhancement, finding that Pliego-Pineda exercised significant decision-making authority, participated extensively in the conspiracy, and managed the logistics of drug transactions. The court noted that the conspiracy involved at least ten individuals and large quantities of methamphetamine. Despite an error in considering Pliego-Pineda's supervision of an undercover officer, the court found sufficient evidence to support the enhancement.The Fourth Circuit also found Pliego-Pineda's sentence substantively reasonable, affirming the district court's decision. The court emphasized that the sentence was within the properly calculated Guidelines range and thus presumptively reasonable. The court concluded that the district court did not abuse its discretion in sentencing Pliego-Pineda. View "United States v. Pliego-Pineda" on Justia Law

Scott Rendelman was convicted in 2008 for mailing threatening communications under 18 U.S.C. § 876(c). The district court instructed the jury that the government only needed to prove that a “reasonable person” would find Rendelman’s communications threatening. In 2023, the Supreme Court held in Counterman v. Colorado that the First Amendment requires the government to prove that the defendant was subjectively aware of the threatening nature of his statements. Rendelman now seeks authorization to file a successive 28 U.S.C. § 2255 motion to vacate his conviction based on this new ruling.Previously, the district court denied Rendelman’s first § 2255 motion, and the United States Court of Appeals for the Fourth Circuit declined to authorize a second § 2255 motion. Rendelman’s conviction was affirmed on direct appeal.The United States Court of Appeals for the Fourth Circuit reviewed Rendelman’s motion for authorization to file a successive § 2255 motion. The court concluded that Rendelman satisfied the gatekeeping requirements of 28 U.S.C. § 2255(h), as the Supreme Court’s decision in Counterman announced a new rule of constitutional law that applies retroactively and was previously unavailable to Rendelman. The court rejected the government’s argument that Rendelman must also show a plausible claim for relief, adhering to the standard that a prima facie showing of possible merit is sufficient. Consequently, the Fourth Circuit granted Rendelman’s motion for authorization to file a successive § 2255 motion. View "In re Rendelman" on Justia Law

Jerry Lee Edwards pled guilty to escaping from a re-entry center in Charlotte, North Carolina, where he was completing a 130-month sentence for federal drug and firearm offenses. He left the center for work on April 29, 2023, and did not return, leading to his arrest after a brief police chase. During sentencing, the district court considered a presentence report that calculated ten criminal history points, including three points for a 2008 North Carolina fleeing-to-elude conviction, which initially involved special probation.The United States District Court for the Western District of North Carolina overruled Edwards's objection to the criminal history points. Edwards argued that his 2008 sentence should receive zero points because it did not exceed one year and was imposed over ten years ago. He contended that his original 53-day active term should not be counted separately from the 12-month suspended term. The district court, however, combined the 53-day term and the 12-month term, resulting in a total sentence of 12 months and 53 days, which merited three criminal history points.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The Fourth Circuit found that North Carolina’s special probation statute, N.C. Gen. Stat. § 15A-1351(a), clearly establishes two separate prison terms: an active term and a suspended term. The court held that the district court correctly combined these terms under U.S.S.G. § 4A1.2(k), resulting in a total sentence that exceeded one year and one month, thus justifying the three criminal history points. The Fourth Circuit concluded that the district court properly applied the Sentencing Guidelines and affirmed the 24-month sentence. View "United States v. Edwards" on Justia Law