Justia Criminal Law Opinion Summaries

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

Dashawn Leonard Garrett pled guilty to three charges related to a drug trafficking investigation in Wilson County, North Carolina, after withdrawing his suppression motion. He later discovered information suggesting police and prosecutorial misconduct, which he argued rendered his plea involuntary. Garrett contended that the misconduct included misidentification by a confidential informant and the use of multiple informants, one of whom was paid and had never identified him.The United States District Court for the Eastern District of North Carolina initially denied Garrett's co-defendant's suppression motion. Garrett withdrew his own motion, fearing it would be risky to proceed, and accepted a plea deal. After his sentencing, Garrett learned from a Government disclosure that multiple confidential informants were used, and one was compensated, which had not been disclosed earlier. This led to his appeal, arguing that the new information would have influenced his decision to plead guilty.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the newly discovered information about the informants and the misidentification issue constituted egregious police and prosecutorial misconduct. The court held that a reasonable defendant in Garrett's position would not have pled guilty if aware of all the relevant information. The court determined that the misconduct affected the integrity of the prosecution and Garrett's ability to make an informed plea. Consequently, the Fourth Circuit vacated Garrett's guilty plea and remanded the case for further proceedings. View "United States v. Garrett" on Justia Law

Ganesa Rosales, a nurse, filed a False Claims Act (FCA) complaint against Amedisys North Carolina, LLC, Dr. Sanjay Batish, and Batish Medical Service, PLLC, alleging fraudulent practices in admitting and recertifying patients for hospice care who did not meet the requirements. Rosales claimed that these practices were widespread and systematic within the company. She also added a claim under the Anti-Kickback Statute in her amended complaint.The United States District Court for the Eastern District of North Carolina dismissed Rosales's federal claims without prejudice, citing the FCA’s first-to-file rule, which bars subsequent related actions based on the same facts as a pending action. The court declined to exercise supplemental jurisdiction over her state-law claim. Rosales appealed, arguing that her claims were distinct and that the district court should have considered her amended complaint.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court concluded that the first-to-file rule applies claim-by-claim and defendant-by-defendant, and it should consider the most recent properly filed complaint. However, the court found that Rosales's claims against Amedisys NC, Dr. Batish, and his practice were based on the same material elements of fraud as the earlier-filed complaint by Jackie Byers against Amedisys Holding and its South Carolina subsidiary. The court also noted that Rosales failed to develop an argument distinguishing her Anti-Kickback Statute claim from the earlier complaints.The Fourth Circuit affirmed the district court's dismissal of Rosales's complaint without prejudice for lack of jurisdiction, adhering to its precedent that the first-to-file rule is jurisdictional. View "United States ex rel. Rosales v. Amedisys North Carolina, L.L.C." on Justia Law

Angelo Jackson was identified as a suspect in a double murder in Montgomery County, Maryland, based on information from law enforcement officers. Detective Michael Carin used this information to obtain an arrest warrant for Jackson. After Jackson's arrest, Carin continued the investigation and found exculpatory evidence, including DNA and cellphone records, which led to the charges being dropped and Jackson's release after 65 days of detention.Jackson filed a lawsuit against Carin, alleging that Carin's affidavit for the arrest warrant and his grand jury testimony were deliberately false or made with reckless disregard for the truth. Jackson claimed that if the commissioner and grand jury had been presented with truthful evidence, they would not have found probable cause for his arrest and indictment.The United States District Court for the District of Maryland granted summary judgment in favor of Carin, finding that even with disputed material removed, the affidavit still provided probable cause for Jackson's arrest. The court also found that Carin was protected by qualified immunity on Jackson's federal claims and dismissed Jackson's gross negligence claim under Maryland law.The United States Court of Appeals for the Fourth Circuit affirmed the district court's judgment. The court concluded that Carin did not violate legal standards in his investigation and was shielded by qualified immunity. The court also found that Carin's actions were reasonable and based on information he received from other officers, and that Jackson failed to meet the burden of proving that Carin's statements were false, made with reckless disregard for the truth, or material to the probable cause determination. View "Jackson v. Carin" on Justia Law

Rojay Lawson was involved in a telemarketing sweepstakes scheme based in Jamaica that targeted elderly individuals in the United States. Lawson, operating from South Carolina, collected and laundered the fraudulent proceeds, keeping a portion for himself and sending the rest to his co-conspirators in Jamaica. The scheme defrauded at least 179 victims, most of whom were elderly, out of approximately $720,000. Lawson pleaded guilty to multiple counts, including wire fraud conspiracy, money laundering conspiracy, wire fraud, and mail fraud.The United States District Court for the District of South Carolina sentenced Lawson to 78 months in prison and ordered him to pay $405,401 in restitution. Lawson challenged his sentence, arguing against the application of a vulnerable victim enhancement, the denial of a minor role reduction, and the calculation of the loss amount. The district court overruled his objections, finding that the scheme specifically targeted elderly victims and that Lawson played a significant role in the conspiracy.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the vulnerable victim enhancement was appropriate because the elderly victims were particularly susceptible to the telemarketing fraud, and Lawson knew or should have known about their vulnerability. The court also upheld the denial of a minor role reduction, noting that Lawson's involvement in collecting and laundering the funds was substantial and essential to the scheme. Additionally, the court found no error in the calculation of the loss amount, which was based on actual losses suffered by the victims. The appellate court concluded that Lawson's sentence was both procedurally and substantively reasonable. View "United States v. Lawson" on Justia Law