Justia Criminal Law Opinion Summaries

A dual citizen of the United States and Pakistan, the defendant traveled from the U.S. to Pakistan in 2009, along with four others, with the intent to join jihad in Afghanistan. Upon arrival, the group attempted to make contact with terrorist organizations and made efforts to cross into Afghanistan. Pakistani authorities arrested them in Sargodha, Pakistan, and subsequently tried and convicted them on terrorism-related offenses. The defendant served approximately ten years in a Pakistani prison. After completing his sentence, he was extradited to the United States, where he faced federal charges arising from the same underlying conduct.The United States District Court for the Eastern District of Virginia arraigned the defendant and, after he waived his Speedy Trial Act rights, considered his motion to dismiss the indictment on Sixth Amendment speedy trial grounds. The motion argued that the government’s delay in seeking his extradition and prosecution in the U.S. violated his constitutional rights. The district court denied the motion, finding that, although the length of the delay was significant, the government made reasonably diligent and good-faith efforts to secure his return, and the remaining factors weighed against finding a violation. The defendant entered a conditional guilty plea, reserving his right to appeal the speedy trial ruling.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision, applying the four-factor balancing test from Barker v. Wingo. The appellate court agreed that only the length of the delay favored the defendant, but reasoned that the government’s efforts, the defendant’s own conduct in resisting extradition, and the absence of actual prejudice outweighed that factor. The court held there was no Sixth Amendment speedy trial violation and affirmed the conviction. View "US v. Chaudhry" on Justia Law

The defendant pleaded guilty in 2020 to two counts of distributing a mixture containing heroin and fentanyl, in violation of federal drug laws. At sentencing, the United States District Court for the Eastern District of Virginia determined he qualified as a career offender, which substantially increased his advisory sentencing range under the Guidelines. The court ultimately imposed a below-Guidelines sentence of 96 months’ imprisonment, followed by a five-year term of supervised release.Subsequently, the defendant moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), arguing that changes in the law meant he would not now be classified as a career offender, and, therefore, his Guidelines range would be much lower if sentenced today. He asked the court to reduce his sentence to time served. The district court found that the significant difference between his original and recalculated Guidelines ranges constituted an “extraordinary and compelling” reason for a sentence reduction. However, the court ultimately denied the motion, concluding that the factors outlined in 18 U.S.C. § 3553(a)—particularly the defendant’s lengthy and serious criminal history and the need to promote respect for the law—outweighed his arguments for release. The court also noted his rehabilitative efforts but found them insufficient to demonstrate a reduced danger to the public.The United States Court of Appeals for the Fourth Circuit reviewed only whether the district court abused its discretion in denying the motion for compassionate release. Applying a deferential standard, the Fourth Circuit held that the district court had considered all relevant arguments and provided sufficient reasoning for its decision. The appellate court affirmed the denial of compassionate release, holding that the district court did not act arbitrarily or irrationally and satisfied all statutory requirements in its analysis. View "United States v. Washington" on Justia Law

Drug task force officers in West Virginia observed a car with expired registration, dark window tint, and a malfunctioning taillight, driven by Cornelious Johnson—an individual known to them from a prior drug conviction and currently on federal supervised release. The officers watched as Johnson and his passenger interacted with a man, Jackie Byrd, at an apartment complex previously associated with drug investigations. Although the officers suspected a drug transaction, they did not witness any exchange of items. Shortly after, Tremayne Hawkins entered the back seat, and the car left the complex. Officer Stanley, informed by the task force, stopped the car for the observed traffic violations and, suspecting drug activity, separated and questioned the occupants about their interaction with Byrd. Citing minor inconsistencies in their answers, Stanley called for a K9 unit, which alerted to drugs. A subsequent search yielded a firearm on Hawkins, who admitted to being prohibited from possessing one due to a prior conviction.The United States District Court for the Northern District of West Virginia denied Hawkins’ motion to suppress the firearm, holding that the officers had reasonable suspicion to extend the stop based on the area’s reputation, Johnson’s prior conviction, the observed interaction with Byrd, and the inconsistent statements from the occupants.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s legal conclusions de novo and its factual findings for clear error. The Fourth Circuit held that none of the cited factors—alone or in combination—provided reasonable suspicion to extend the stop. The court emphasized that presence in an area associated with prior investigations, a dated conviction, innocuous interactions, and minor, reconcilable inconsistencies in statements did not collectively amount to reasonable suspicion of criminal activity. Accordingly, the Fourth Circuit reversed the district court’s denial of the suppression motion and remanded the case for further proceedings. View "US v. Hawkins" on Justia Law

Christopher Arthur was investigated after founding a business that sold military gear and later provided training and manuals on tactics including the use of explosives. The FBI became involved after a customer, Joshua Blessed, died in a shootout and was found to possess pipe bombs and Arthur’s manuals. Subsequently, an undercover informant, “Buckshot,” sought training from Arthur, who instructed him on fortifying his home and making explosive devices, knowing Buckshot claimed he wanted to use such tactics against federal agents. Arthur was arrested in January 2022 and a search of his home revealed illegal firearms and improvised explosives.A grand jury in the United States District Court for the Eastern District of North Carolina indicted Arthur under 18 U.S.C. § 842(p)(2)(B) for teaching explosives use with knowledge of criminal intent, and on additional firearms and explosives charges. Arthur moved to dismiss the primary count, arguing the statute was facially overbroad under the First Amendment. The district court denied the motion, finding the statute’s knowledge requirement limited its scope to conduct integral to criminal acts, not protected speech. After a three-day trial, the jury found Arthur guilty on all counts. At sentencing, the court applied the U.S.S.G. § 3A1.4 terrorism enhancement, increasing his guidelines range, and sentenced Arthur to a total of 300 months’ imprisonment.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that 18 U.S.C. § 842(p)(2)(B) is not unconstitutionally overbroad, concluding that the statute targets speech integral to criminal conduct and does not criminalize a substantial amount of protected expressive activity. The Fourth Circuit also found no reversible error in applying the terrorism enhancement, and determined any alleged guidelines error was harmless given the district court’s alternative sentencing rationale. The judgment of the district court was affirmed. View "US v. Arthur" on Justia Law

The case centers on Jessie Glass, whose estranged wife, April, reported to law enforcement that she witnessed a significant quantity of child sexual abuse material on Glass’s phone. April provided specific details about the alleged material, the devices Glass owned, and information for accessing his online accounts. Detective Jason Lowrance investigated April’s claims, which included reviewing her prior allegations against Glass as well as Glass’s history of previous investigations for similar offenses. Some of these earlier investigations had been closed without charges or with findings labeled “[u]nfounded.” Lowrance then prepared affidavits for search warrants to search Glass’s home and electronics, securing evidence of child sexual abuse material.The United States District Court for the Western District of North Carolina denied Glass’s motion to suppress, which argued that Lowrance recklessly omitted information in his warrant affidavits that would have undermined April’s credibility and thus probable cause. The district court found that any omissions were not made with intent to mislead or recklessness, and that the omitted facts would not have altered the probable cause determination. A jury later found Glass guilty on all counts, and the district court sentenced him to fifteen years’ imprisonment and imposed financial penalties.The United States Court of Appeals for the Fourth Circuit reviewed the appeal. It held that Lowrance’s affidavits contained sufficient detail to support probable cause, and that the omitted information about April’s credibility would not have defeated probable cause. The appellate court also rejected Glass’s double jeopardy argument, finding the convictions and sentences were based on distinct conduct. Finally, the court affirmed the district court’s imposition of a $5,000 special assessment, concluding the required statutory considerations were adequately addressed. The judgment was affirmed in all respects. View "US v. Glass" on Justia Law

A member of the Kuwaiti royal family was defrauded by a Baltimore restaurateur, who convinced her to send nearly $7.8 million under the guise of investing in real estate and restaurant ventures in the United States. The restaurateur used the funds to acquire multiple properties, including a condominium in New York City and a home in Pikesville, Maryland, but secretly held ownership in his own name and for his personal use. After the fraud was uncovered, the investor sued the restaurateur for fraud and sought to impose a constructive trust over the properties purchased with her funds. Around the same time, she attempted to file a notice of lis pendens to protect her interest in the Pikesville property, but the notice was recorded against the wrong property and was thus ineffective.During discovery, the investor learned that World Business Lenders, LLC (WBL) had issued three loans to the restaurateur, each secured by properties acquired with her funds. She then filed suit against WBL in the United States District Court for the District of Maryland, alleging that WBL aided and abetted the restaurateur’s fraud by encumbering the properties with liens, thereby hindering her ability to recover on any judgment. Following a bench trial, the district court found for WBL on two of the loans, but found WBL liable for aiding and abetting fraud in relation to the loan secured by the Pikesville home, awarding compensatory and punitive damages.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The appellate court affirmed the district court’s judgment for WBL on the first two loans but reversed as to the Pikesville loan. The Fourth Circuit held that WBL was not willfully blind to the restaurateur’s fraud in any of the loans as a matter of law and remanded with instructions to enter final judgment for WBL on all claims. View "Al-Sabah v. World Business Lenders, LLC" on Justia Law

A decorated Army sergeant was convicted in Virginia after pleading guilty to two counts of malicious wounding and other charges stemming from separate incidents occurring on a single day in March 2011. At the time, he had recently returned home from combat in Afghanistan, where he had suffered multiple serious injuries, including two traumatic brain injuries. His crimes included shooting a woman during an altercation and, later that day, assaulting a man in a bar. He received a sentence of 46 years, well above the state’s discretionary sentencing guidelines.On direct appeal, the Court of Appeals of Virginia and the Supreme Court of Virginia both affirmed his convictions and sentence, finding no error in the sentencing court’s weighing of mitigating evidence. The defendant then pursued state habeas relief in the Circuit Courts for the City and County of Roanoke, arguing ineffective assistance of counsel under the Sixth Amendment. He contended his lawyer failed to present readily available mitigating evidence, including details of his military service, combat injuries, mental health struggles (especially PTSD), and failed to object to the use of his expunged juvenile criminal record. The state court denied relief, concluding there was no prejudice, and the Supreme Court of Virginia summarily refused further appeal.In subsequent federal habeas proceedings under 28 U.S.C. § 2254, the United States District Court for the Western District of Virginia denied relief, holding that the state decision was not contrary to or an unreasonable application of federal law.The United States Court of Appeals for the Fourth Circuit reversed. The court held that the state court applied the wrong legal standard for prejudice under Strickland v. Washington, failed to consider the totality of available mitigating evidence, and that there was a reasonable probability of a different sentence had counsel performed adequately. The case was remanded with instructions to grant a writ of habeas corpus unless the Commonwealth provides plenary resentencing within a reasonable time. View "Coleman v. Dotson" on Justia Law

The defendant was convicted by a jury in 2002 on multiple federal drug and firearm charges, receiving a lengthy sentence. He unsuccessfully challenged his convictions and sentence through direct appeals and several motions for habeas relief under 28 U.S.C. § 2255, including claims of ineffective assistance, vindictive prosecution, and arguments based on later Supreme Court rulings. After a First Step Act sentence reduction in 2019, which resulted in an amended judgment and a reduced sentence, the defendant filed another pro se § 2255 motion in 2022, arguing that he was actually innocent of one of his firearm convictions because both firearm offenses occurred as part of the same drug conspiracy.The United States District Court for the District of South Carolina dismissed the defendant’s 2022 habeas motion on two alternative grounds: first, that it was an unauthorized “second or successive” motion because a First Step Act sentence reduction does not create a “new judgment” for purposes of AEDPA; and second, that it was untimely under the one-year limitations period, with no basis for equitable tolling. The district court found that even if the motion was not successive, it was still time-barred, and the merits of his claim did not justify tolling.The United States Court of Appeals for the Fourth Circuit reviewed only the question of whether a First Step Act sentence reduction results in a “new judgment” under AEDPA, having denied the defendant’s request to expand the appeal to include the timeliness issue. The Fourth Circuit held that, because the district court’s alternative ruling of untimeliness was not appealable and would remain unaffected regardless of the outcome on the “new judgment” issue, the court had no ability to redress the defendant’s injury. As a result, the appeal was dismissed as moot. View "United States v. Robinson" on Justia Law

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