Justia Criminal Law Opinion Summaries

M.B., a Pakistani woman, was forced into labor by her in-laws, Zahida Aman and her sons, Nauman and Rehan Chaudhri, after marrying another son, Salman. Upon arriving in Virginia, M.B. was isolated, had her documents confiscated, and was coerced into performing extensive household chores under threats of deportation and physical abuse. The abuse escalated over the years, including physical violence and psychological manipulation, until M.B. was eventually confined to a laundry room and later a garage annex. M.B. managed to escape in 2016 with the help of her brother and law enforcement.The United States District Court for the Eastern District of Virginia convicted the defendants of conspiracy to commit forced labor, forced labor, and document servitude. The defendants appealed, arguing that the forced labor statute did not apply to familial relationships, that the government improperly struck jurors based on race, that prejudicial evidence was admitted, and that the jury was improperly instructed.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the forced labor statute, 18 U.S.C. § 1589, applies broadly and includes familial relationships. The court found no Batson violation in the jury selection process, since the government's peremptory strikes were based on age, marital status, and childlessness, not race. The court also ruled that the evidence of abuse after the forced labor ended was intrinsic to the crime and necessary to complete the story. Finally, the court determined that the jury instructions were adequate, despite the defendants' objections.The Fourth Circuit affirmed the convictions, concluding that the statute applied to the defendants' conduct and that the district court did not err in its rulings during the trial. View "U.S. v. Chaudhri" on Justia Law

In 2011, Winston Sylvester Oliver II and his co-defendant, Warren Brown, were convicted of conspiracy to commit Hobbs Act robbery, attempted Hobbs Act robbery, and use of a firearm during these crimes. Oliver's firearm convictions were later vacated, necessitating resentencing for the remaining convictions. At his resentencing, Oliver argued that his Fifth and Sixth Amendment rights were violated when the court allowed Brown to invoke his Fifth Amendment right against self-incrimination due to his pending appeal. Oliver also contended that his sentence was procedurally and substantively unreasonable.The United States District Court for the Eastern District of Virginia initially sentenced Oliver to 630 months in prison. After his firearm convictions were vacated, the court resentenced him to 610 months. On appeal, the Fourth Circuit vacated his remaining firearm conviction and remanded for resentencing. At the second resentencing, Oliver's motion to recuse the entire bench of the Eastern District of Virginia was denied. The district court allowed Brown to invoke his Fifth Amendment right, excluded unauthenticated letters allegedly written by Brown, and calculated Oliver's Guidelines range, ultimately sentencing him to 480 months in prison.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court did not abuse its discretion in allowing Brown to invoke his Fifth Amendment right, as his testimony could have had adverse consequences due to his pending appeal. The court also found that the district court did not err in applying sentencing enhancements for Oliver's leadership role, obstruction of justice, and firearm discharge. The court concluded that the 480-month sentence was substantively reasonable, considering Oliver's extensive criminal history and the impact on the victims. The Fourth Circuit affirmed the district court's judgment. View "United States v. Oliver" on Justia Law

Anthony Williams was convicted of two drug offenses in 1999 and has been on supervised release since 2020. In March 2023, a woman Williams had been living with contacted the police, alleging that Williams had assaulted her by strangling and slapping her. The complainant provided photos of her injuries and reported symptoms consistent with strangulation. A police officer and a probation officer corroborated her account through interviews and evidence collection. The district court held a revocation hearing more than eight months later, during which the complainant was not present. The government introduced her out-of-court statements and other evidence, which Williams objected to as hearsay.The United States District Court for the Western District of North Carolina admitted the statements, finding that the government showed good cause for the complainant's absence and that the statements were reliable. The court found Williams had committed the violations and sentenced him to 24 months of imprisonment followed by 12 months of supervised release. Williams appealed, arguing that the district court erred in admitting the hearsay evidence.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 district court did not abuse its discretion in admitting the complainant's statements. The court found that the government made sufficient efforts to contact the complainant, establishing good cause for her absence. Additionally, the court determined that the complainant's statements were reliable, supported by corroborating evidence and consistent recounting. The balancing test weighed in favor of admissibility, and the district court's judgment was affirmed. View "United States v. Williams" on Justia Law

Telly Armstrong pled guilty in March 2005 to two counts of brandishing a firearm during a crime of violence under 18 U.S.C. § 924(c) and was sentenced to 384 months in prison. Armstrong later filed a motion for compassionate release, arguing that the disparity between his original sentence and the sentence he would receive under current law constituted an extraordinary and compelling reason for relief. The district court acknowledged the disparity but denied the motion, citing Armstrong's extensive criminal history and the violent nature of his offenses.Armstrong appealed the denial of his compassionate release motion and subsequently filed a pro se motion for reconsideration in the district court. The district court denied the motion for reconsideration, stating that Armstrong's arguments were without merit. Armstrong then appealed the denial of his motion for reconsideration.The United States Court of Appeals for the Fourth Circuit reviewed the case. The principal question was whether Fed. R. Crim. P. 37 allows district courts to deny motions for reconsideration while an appeal of the underlying order is pending. The Fourth Circuit held that Rule 37 does grant such authority, allowing district courts to deny, defer, or provide an indicative ruling on motions for reconsideration during a pending appeal. The court affirmed the district court's denial of Armstrong's motion for reconsideration, clarifying that the district court acted within its discretion under Rule 37. The court also noted that arguments raised by the government regarding the timeliness and propriety of Armstrong's motion for reconsideration were waived as they were not raised in the lower court. View "US v. Armstrong" on Justia Law

Melissa Barrett was serving a 168-month sentence for federal drug offenses when Amendment 821 to the Sentencing Guidelines took effect. This amendment, made retroactive by the Sentencing Commission, limited the impact of "status points" used in calculating Barrett's original Guideline range. Barrett moved to reduce her sentence to 120 months based on this amendment. The government agreed she was eligible for a reduction but disagreed on the scope of the amendment's retroactive effect. Barrett argued that the amendment affected both her criminal history category and her offense level, while the government contended it only applied to her criminal history category. The district court sided with the government and reduced Barrett's sentence to 150 months.The United States District Court for the Western District of Virginia initially reviewed the case. The court recognized Barrett's eligibility for a sentence reduction under 18 U.S.C. § 3582(c)(2) due to Amendment 821 but concluded that the amendment only applied to her criminal history category, not her offense level. Consequently, the court reduced her sentence to 150 months, reflecting a revised Guideline range of 135 to 168 months.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court erred by not giving full retroactive effect to Amendment 821. The Fourth Circuit determined that the amendment should apply to both Barrett's criminal history category and her offense level. The court explained that the policy statement at § 1B1.10(b)(1) requires determining the amended guideline range, which includes both the criminal history category and the offense level. The Fourth Circuit vacated the district court's judgment and remanded the case for further consideration of Barrett's motion, instructing the lower court to determine if Barrett qualifies for the offense-level reduction under § 2D1.1(b)(17). View "US v. Barrett" on Justia Law

James Ervin pleaded guilty to possessing a semi-automatic rifle as a convicted felon, violating 18 U.S.C. § 922(g)(1). He later sought to withdraw his guilty plea through a 28 U.S.C. § 2255 motion, claiming ineffective assistance of counsel and that the government provided false inculpatory information about the rifle. Ervin's arguments centered on the interpretation of the phrase “in or affecting commerce” in § 922(g).The United States District Court for the Western District of North Carolina denied Ervin's motion to vacate his plea. The court found that the rifle had traveled in interstate commerce, thus meeting the statutory requirement. Ervin's ineffective assistance claim failed because he could not establish prejudice, as the firearm's interstate travel was sufficient to satisfy the commerce element of § 922(g). The court also denied his motion for reconsideration and his request for a certificate of appealability.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the phrase “in or affecting commerce” in § 922(g) should be interpreted broadly, consistent with the Supreme Court's decision in Scarborough v. United States. The court found that the rifle, which traveled from North Carolina to Louisiana, Georgia, and back to North Carolina, met the interstate commerce requirement. Consequently, Ervin's claims of ineffective assistance of counsel and due process violations were rejected. The court affirmed the district court's denial of Ervin's motion to withdraw his guilty plea, concluding that his interpretation of the statute was incorrect and that his defense would have been meritless. View "United States v. Ervin" on Justia Law

Sammy Lee Ellis, Jr. shot Lamar Gross, the son of his estranged fiancé Dionne Beatty, in the abdomen after a heated argument. Ellis, who had been drinking, was charged with illegally possessing a firearm and ammunition as a convicted felon. The U.S. Probation Office prepared a presentence investigation report that applied a cross-reference to attempted murder under the U.S. Sentencing Guidelines, which Ellis contested.The United States District Court for the District of South Carolina applied the attempted murder cross-reference over Ellis's objections, determining it to be the operative base offense level for sentencing. Ellis argued that the district court failed to consider a voluntary intoxication defense to attempted murder and that there was insufficient evidence to support the cross-reference. The district court found Gross's testimony credible and concluded that Ellis's actions amounted to attempted murder, sentencing him to 97 months' imprisonment.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court correctly applied the attempted murder cross-reference, noting that under South Carolina law, voluntary intoxication is not a defense unless it results in permanent insanity, which was not the case here. The court also found substantial evidence supporting the district court's conclusion that Ellis intended to kill Gross, based on the circumstances and credible testimony. Consequently, the Fourth Circuit affirmed the district court's judgment. View "United States v. Ellis" on Justia Law

Gerald Wheeler was convicted in 2007 of various drug and firearm offenses and sentenced to 180 months of imprisonment. In 2018, one of his convictions was vacated, and he was resentenced to time served with a four-year term of supervised release starting in March 2019. In January 2023, Wheeler's probation officer filed a petition to modify his supervision conditions due to new charges of felony assault by strangulation and misdemeanor assault on a female. The district court ordered revocation proceedings instead.A United States Magistrate Judge found no probable cause for the felony assault charge but found probable cause for the misdemeanor assault charge. Wheeler remained on bond pending the final revocation hearing. During the hearing, the district court admitted hearsay evidence from the alleged victim, Nyasia Mobley, despite her absence. The court found that the government made sufficient efforts to secure her presence and deemed her statements reliable. The court ultimately found Wheeler violated his supervised release and sentenced him to six months of imprisonment followed by an additional year of supervised release.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court abused its discretion by not properly balancing Wheeler's interest in confronting Mobley against the government's reasons for not producing her. The court also found that the government did not provide a satisfactory explanation for Mobley's absence, as the probation officer made only a single attempt to serve her. The Fourth Circuit concluded that the district court's error was not harmless, as the hearsay evidence was essential to the finding of violation. The court vacated the district court's judgment and remanded with instructions to dismiss the Revocation Petition. View "US v. Wheeler" on Justia Law

Tyzeem Kwazhon Nixon pleaded guilty to one count of being a felon in possession of a firearm. While awaiting sentencing, he committed several violent acts, including multiple stabbings. The district court sentenced Nixon to more than double the Sentencing Guidelines range, primarily based on his violent behavior while incarcerated. The court also disregarded a report from a qualified medical expert, which attributed Nixon's violent conduct to his untreated mental health condition and suggested that proper treatment would mitigate his threat to society.The United States District Court for the Eastern District of North Carolina sentenced Nixon to 114 months, significantly above the Guidelines range of 41 to 51 months. The court justified the upward departure by citing Nixon's violent acts while awaiting sentencing and his criminal history. The court rejected the expert's report without counterevidence, stating it did not find the report credible. Nixon appealed the sentence, arguing that the district court's reliance on dissimilar conduct, failure to consider intermediate categories, and rejection of expert testimony rendered the sentence procedurally unreasonable.The United States Court of Appeals for the Fourth Circuit reviewed the case and found the district court's sentence procedurally unreasonable. The appellate court held that the district court improperly relied on dissimilar conduct for the upward departure, failed to consider intermediate criminal history categories, and erroneously rejected the expert testimony without justification. The Fourth Circuit vacated the sentence and remanded the case for resentencing, instructing the district court to recalculate Nixon's criminal history category without improper consideration of dissimilar conduct, to consider intermediate categories, and to properly evaluate the expert testimony. View "US v. Nixon" on Justia Law

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