Justia Criminal Law Opinion Summaries

Stephen Bryant was sentenced to death by a South Carolina state court. During postconviction proceedings, Bryant filed a new application for relief, claiming his execution would violate the Eighth Amendment due to his intellectual disabilities, as defined in Atkins v. Virginia and Hall v. Florida. Later, Bryant sought to amend his application to include a claim that he suffers from fetal alcohol spectrum disorder (FASD) and that executing individuals with FASD should also be prohibited under the Eighth Amendment. The state postconviction court denied this request, ruling it was both impermissibly successive and filed too late.Bryant's initial appeal to the South Carolina Supreme Court, which focused on a single claim of evidentiary error, was denied. He then sought post-conviction relief on several grounds, none of which included the Eighth Amendment claim. The state trial court denied these claims, and the South Carolina Supreme Court denied discretionary review. Bryant subsequently filed for federal habeas corpus relief, which was stayed to allow him to exhaust state remedies. He filed two new applications in state court, one of which was allowed to proceed on the intellectual disability claim but not on the FASD claim. The state trial court ultimately denied the intellectual disability claim on its merits.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the state trial court's refusal to permit Bryant to amend his application to add the FASD claim rested on state procedural grounds that were independent of federal law and adequate to bar federal habeas review. The Fourth Circuit affirmed the district court's denial of habeas relief, concluding that Bryant's FASD claim was procedurally defaulted and could not be considered on its merits. View "Bryant v. Stirling" on Justia Law

Ikeviaun Johnson, a passenger in a black Ford Explorer, fired eight shots at a white Hyundai sedan, which was actually an unmarked car occupied by federal law enforcement officers. The incident occurred in Greenville, North Carolina, during an investigation. Johnson was charged and convicted of assaulting federal officers and discharging a firearm in furtherance of a crime of violence. The district court sentenced him to 198 months’ imprisonment, an above-Guidelines sentence.The United States District Court for the Eastern District of North Carolina handled the initial trial. Johnson was convicted by a jury on both counts. At sentencing, the court calculated a Guidelines range of 150 to 157 months but imposed a 198-month sentence, citing the severity of Johnson's actions and his lack of remorse.The United States Court of Appeals for the Fourth Circuit reviewed the case. Johnson appealed on three grounds: a defective indictment, insufficient evidence of assault, and an inadequately justified above-Guidelines sentence. The Fourth Circuit rejected all three arguments. The court held that the indictment, despite omitting the word "forcibly," provided sufficient notice of the charges. The court also found ample evidence that Johnson's actions caused the officers to apprehend immediate bodily harm, satisfying the assault element. Lastly, the court ruled that the district court had adequately justified the upward variance in Johnson's sentence, considering the seriousness of the offense and Johnson's conduct.The Fourth Circuit affirmed the district court's judgment, upholding Johnson's conviction and 198-month sentence. View "US v. Johnson" on Justia Law

Tytus Lamaar Shields pleaded guilty to possession of a firearm as a felon, violating 18 U.S.C. § 922(g)(1). In November 2021, law enforcement in Parkersburg, West Virginia, received information that Shields was transporting drugs. Shields, on bond for pending charges in Ohio and considered a fugitive, was arrested at his residence, where officers seized drugs, cash, and a loaded firearm. Shields admitted the firearm was his. He was charged with being a felon in possession of a firearm, knowing he had prior Ohio felony convictions, including one for drug trafficking.The United States District Court for the Southern District of West Virginia calculated an advisory Sentencing Guidelines range of 51 to 63 months and sentenced Shields to 51 months. Shields argued for a downward variance, citing an unwarranted sentencing disparity between his case and similar cases in West Virginia, but the district court did not address this argument. The court focused on Shields’s criminal history and sustained the government’s objection to the Presentence Investigation Report, which had not applied the increased base offense level for a "controlled substance offense."The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the district court committed procedural error by failing to address Shields’s non-frivolous argument for a downward variance based on sentencing disparities. The appellate court held that the district court must consider and explain its reasoning regarding such arguments to allow for meaningful appellate review. Consequently, the Fourth Circuit vacated Shields’s sentence and remanded the case for resentencing, emphasizing the need for the district court to address all non-frivolous arguments presented by the defendant. View "United States v. Shields" on Justia Law

Curtis Wells parked his car near Arlington Cemetery and was noticed by Officer Armstrong due to his animated gestures while on a phone call. Armstrong approached Wells and discovered that his car had an expired registration. Arlington County police were called, and they found that Wells did not have a driver's license and had weapons in his car. The police decided to tow Wells's car and conducted an inventory search, which revealed various weapons and tactical gear, including a ballistic plate carrier. Wells was sent home, but further investigation suggested that the plate might have been stolen from the Army. Nine days later, Wells was arrested for receiving stolen property.In the United States District Court for the Eastern District of Virginia, Wells brought state and federal claims against various officers and entities, alleging Fourth and Fifth Amendment violations, among other claims. The district court dismissed all his claims, reasoning that the officers were protected by qualified immunity and that Wells had not plausibly alleged the necessary elements for his state tort claims.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's dismissal. The court held that the officers' actions were protected by qualified immunity because Wells did not have a clearly established right against the officers' conduct. The court found that the initial approach by Officer Armstrong was justified under the community-caretaking exception, the inventory search of Wells's car was conducted according to standard procedures, and Wells had consented to the safekeeping of his property. Additionally, the court held that Wells's Second Amendment claims failed because the right to public carry was not clearly established in 2020. The court also dismissed Wells's state law claims, finding that he had not plausibly alleged the necessary elements for false imprisonment or malicious prosecution. View "Wells v. Fuentes" on Justia Law

Margaret Ann Sutton was involved in a drug trafficking operation with Vicente Andres, a known drug dealer. Sutton initially visited Andres's house to buy and distribute drugs. Their relationship turned romantic, and they traveled together to California to purchase a large quantity of methamphetamine and marijuana. Upon returning to Virginia, they continued distributing the drugs. Sutton was actively involved in the drug sales, including a transaction with an undercover officer. During a police raid, Sutton was found with marked bills from a drug sale, and a large quantity of marijuana was discovered in a puzzle box in the house.The United States District Court for the Eastern District of Virginia convicted Sutton in a bench trial of various federal criminal offenses, including possession with intent to distribute marijuana and use of a drug-involved premises. Sutton was sentenced to twenty-nine years in prison. She appealed her convictions and sentence, arguing insufficient evidence and procedural and substantive unreasonableness in her sentencing.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that there was sufficient evidence to support Sutton's convictions. The court held that Sutton constructively possessed the marijuana found in the puzzle box, as she had control over the drugs and was aware of their presence. Additionally, the court determined that Sutton actively employed the house for the purpose of drug distribution, satisfying the requirements of 21 U.S.C. § 856(a)(1). The court also found that Sutton's sentence was neither procedurally nor substantively unreasonable, noting that her sentence was below the Guidelines range and that the district court had considered her background and history.The Fourth Circuit affirmed the district court's decision, upholding Sutton's convictions and sentence. View "United States v. Sutton" on Justia Law

In September 2018, police officers in Fayetteville, North Carolina, observed a car performing a U-turn and stopping in front of Allen Wendell McNeil's house. After a brief interaction with the car's occupants, the police conducted a traffic stop and found a small bag of marijuana on the passenger. Without a warrant, the officers then went to McNeil's house for a "knock and talk." When McNeil's children answered the door and said he was not home, the officers proceeded to the backyard, where they found McNeil in a shed and detected the smell of marijuana. This led to McNeil's detention and the subsequent search and seizure of marijuana, money, and guns from his property.McNeil was charged with marijuana distribution and firearm possession. He pleaded guilty without a plea agreement, and the district court sentenced him to 114 months in prison. McNeil's direct appeal was affirmed by the United States Court of Appeals for the Fourth Circuit.McNeil filed a pro se petition under 28 U.S.C. § 2255, claiming ineffective assistance of counsel for failing to file a motion to suppress evidence obtained from the warrantless search and for not pursuing a plea agreement despite his requests. The district court dismissed the petition without an evidentiary hearing, ruling that McNeil's Fourth Amendment claim was frivolous and that his statements during the Rule 11 hearing precluded his ineffective assistance claim regarding the plea agreement.The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that McNeil's ineffective assistance claims could not be resolved on the existing record. The court held that the district court erred in dismissing McNeil's claims without an evidentiary hearing, as the facts surrounding the police officers' entry into the backyard and the plea negotiations required further factual development. The Fourth Circuit vacated the district court's judgment and remanded the case for an evidentiary hearing. View "United States v. McNeil" on Justia Law

Conor Fitzpatrick pleaded guilty to conspiracy to traffic in stolen personally identifying information, fraudulent solicitation of personally identifying information, and possession of child pornography. While released on bond awaiting sentencing, Fitzpatrick violated his conditions of release by secretly downloading a virtual private network and accessing the Internet without his probation officer's knowledge. At sentencing, the district court calculated Fitzpatrick’s advisory Guidelines sentencing range to be 188 to 235 months’ imprisonment but sentenced him to a 17-day time-served term of imprisonment, citing his autism spectrum disorder and youth.The United States District Court for the Eastern District of Virginia initially handled the case. Fitzpatrick was released on bond pending sentencing, subject to several special conditions, which he violated. The district court, considering Fitzpatrick’s autism and youth, imposed a significantly reduced sentence of 17 days, arguing that the Federal Bureau of Prisons would not be able to treat Fitzpatrick’s autism spectrum disorder and that he would be vulnerable in prison.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the district court abused its discretion by imposing a substantively unreasonable sentence. The Fourth Circuit held that the district court failed to adequately consider the seriousness of Fitzpatrick’s offenses, the need to promote respect for the law, to deter similar wrongdoing, and to protect the public. The court vacated the 17-day sentence and remanded the case for resentencing, emphasizing that a sentence must fulfill the purposes of punishment, deterrence, and incapacitation. View "United States v. Fitzpatrick" on Justia Law

Dr. Anita Jackson, an otolaryngologist, was convicted of various offenses related to her private medical practice in North Carolina. She was the leading Medicare biller for balloon sinuplasty surgery, a procedure treating chronic sinusitis. Jackson reused single-use medical devices, specifically the Entellus XprESS Multi-Sinus Dilation Tool, on multiple patients without proper sterilization, leading to potential contamination. She also incentivized employees to recruit Medicare patients for the procedure, often bypassing proper medical assessments. Additionally, Jackson falsified documents and patient signatures in response to Medicare audits.The United States District Court for the Eastern District of North Carolina convicted Jackson on all counts, including violating the Food, Drug, and Cosmetics Act (FDCA) by holding for resale adulterated medical devices, violating the federal anti-kickback statute, making materially false statements, committing aggravated identity theft, mail fraud, and conspiracy. Jackson was sentenced to twenty-five years in prison and ordered to pay over $5.7 million in restitution. She moved for a judgment of acquittal and a new trial, which the district court denied.The United States Court of Appeals for the Fourth Circuit reviewed the case. Jackson argued that the devices were not "held for sale" under the FDCA, that her actions were protected under 21 U.S.C. § 396, and that the Government relied on a defective theory of per se adulteration. She also challenged the exclusion of certain evidence and jury instructions. The Fourth Circuit found no reversible error in the district court's rulings, holding that the devices were indeed "held for sale," that § 396 did not protect her conduct, and that the Government's theory was valid. The court also upheld the exclusion of evidence and the jury instructions. Consequently, the Fourth Circuit affirmed all of Jackson's convictions. View "United States v. Jackson" on Justia Law

Christopher William Kuehner was charged with engaging in a child exploitation enterprise. He used a website and a messaging server dedicated to sexual violence and the sexual exploitation of minors, employing two different usernames to produce and encourage the production of child sexual abuse material. Authorities identified Kuehner as the person behind these usernames and charged him accordingly.The United States District Court for the Eastern District of Virginia conducted a two-day bench trial, during which Kuehner was found guilty and sentenced to twenty years in prison. Kuehner raised several challenges on appeal, including the district court's interpretation of the child exploitation enterprises statute, the sufficiency of the evidence supporting his conviction, and the denial of his motion to vacate his conviction based on the Government's alleged failure to disclose certain information.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the child exploitation enterprises statute does not require each predicate felony to be committed in concert with three or more people; rather, the total number of people can be summed across the relevant predicate offenses. The court also found that there was substantial evidence to support Kuehner's conviction, including his own admissions, forensic evidence, and testimony from minor victims. Finally, the court determined that there was no Brady violation, as the undisclosed information from Google and Discord was not material to Kuehner's defense. View "U.S. v. Kuehner" on Justia Law

David Shanton, Sr. was involved in two armed bank robberies in Hagerstown, Maryland, shortly after completing a 20-year sentence for a previous bank robbery. During the first robbery, Shanton threatened to kill anyone who called the police and pointed a shotgun at a deputy sheriff while fleeing with nearly $34,000. He was apprehended during the second attempted robbery. Shanton was indicted and convicted on multiple counts, including armed bank robbery, discharging and brandishing a firearm during a crime of violence, and possessing a firearm as a felon.The United States District Court for the District of Maryland sentenced Shanton to 188 months for each armed bank robbery and firearm possession conviction, to be served concurrently, plus consecutive terms for the firearm offenses, totaling 608 months. Shanton's sentence was enhanced under the Armed Career Criminal Act (ACCA) due to his prior convictions, including Maryland robbery. Shanton did not initially object to the enhancement. On direct appeal, the Fourth Circuit affirmed his convictions and sentence.Shanton later filed a motion under 28 U.S.C. § 2255, challenging the constitutionality of his ACCA-enhanced sentences based on the Supreme Court's decision in Samuel Johnson v. United States, which invalidated the ACCA's residual clause. The district court allowed Shanton to supplement his motion, arguing that his Maryland robbery convictions no longer qualified as violent felonies under ACCA's elements clause. The district court rejected this argument, relying on Fourth Circuit precedent, and denied the motion but issued a certificate of appealability.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's judgment. The court held that Maryland robbery qualifies as a violent felony under ACCA's elements clause, consistent with prior Fourth Circuit decisions and the Supreme Court's ruling in Stokeling v. United States. The court concluded that Maryland robbery involves the use of force against a person, meeting the ACCA's definition of a violent felony. View "United States v. Shanton" on Justia Law