Justia Criminal Law Opinion Summaries

Breion Woodson was convicted in Wisconsin state court on charges of firearm and drug possession and sentenced to 19 years in prison. During sentencing, the government presented a video from social media showing men with guns and drugs, which the judge used to assess Woodson's character and danger to the community. Woodson argued that he was misidentified in the video, but the judge denied his motion for a new sentencing hearing. The Wisconsin Court of Appeals affirmed, stating Woodson failed to prove he was not the man in the video.Woodson then filed a federal habeas corpus petition in the Eastern District of Wisconsin, introducing booking photos from the time of his sentencing that suggested he was not the man in the video. However, the district court ruled it could not consider the photos since they were not presented in state court and denied his petition, finding the state appellate court's decision reasonable based on the evidence it had.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that under the Antiterrorism and Effective Death Penalty Act (AEDPA), habeas relief is unavailable unless the state court's decision was contrary to or an unreasonable application of federal law or based on an unreasonable determination of facts. The court found that Woodson's claim was not procedurally defaulted and that the actual innocence exception did not apply to his case. The court also ruled that it could not consider the new evidence (booking photos) under AEDPA's strict limitations. Consequently, the Seventh Circuit affirmed the district court's denial of Woodson's habeas petition. View "Woodson v Mlodzik" on Justia Law

Michael Malinowski was sentenced to 150 months in prison followed by a lifetime of supervised release after pleading guilty to receiving child pornography. His release conditions included participating in sex-offender treatment, avoiding committing another crime, and not having deliberate contact with children. After moving to the Northern District of Illinois, Malinowski underwent a psychosexual assessment, leading to a recommendation that he refrain from accessing any pornography. A probation officer proposed modifying his supervised release conditions to include a prohibition on possessing or accessing any pornographic or sexually stimulating materials, which Malinowski accepted without a hearing.In 2022, Malinowski violated his supervised release by cashing a fraudulent check and failing to attend a therapy session. The district court did not revoke his release but warned him to comply with his conditions. A week later, Malinowski was found in a school with a child, violating his release conditions. The district court found him guilty of three violations and sentenced him to 12 months in prison, above the advisory range but below the statutory maximum. The court also modified his supervised release conditions, including a prohibition on possessing sexually stimulating materials and a condition barring children from entering his home.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed Malinowski's 12-month sentence, finding no procedural error. However, it vacated the two challenged supervised release conditions. The court found the condition barring possession of sexually stimulating materials to be overbroad and unconstitutional, requiring revision consistent with United States v. Adkins. The court also noted a conflict between the district court's oral pronouncement and written judgment regarding the condition barring children from entering Malinowski's home, requiring correction on remand. View "United States v Malinowski" on Justia Law

Kamala McCombs pleaded guilty to two counts of drug trafficking for her involvement in a conspiracy to transport methamphetamine from Arizona to Illinois. She was sentenced to concurrent terms of 121 months of imprisonment and 60 months of supervised release. McCombs appealed, arguing she deserved a mitigating role reduction under the U.S. Sentencing Guidelines because one of her co-conspirators received such a reduction.The government indicted McCombs and her co-conspirators for conspiracy to distribute methamphetamine and possession with intent to distribute. McCombs pleaded guilty and stipulated to the conduct. The probation office calculated her offense level and recommended a two-level downward variance, resulting in a guidelines range of 121 to 151 months. McCombs objected to the probation office's determination that she was not entitled to a mitigating role reduction. The district court overruled her objection, finding she was not substantially less culpable than her co-conspirators, and sentenced her to 121 months.The United States Court of Appeals for the Seventh Circuit reviewed the case. McCombs argued that the district court erred in not granting her a mitigating role reduction and that this resulted in an unwarranted sentencing disparity. The appellate court found that the district court correctly compared McCombs to her co-conspirators and concluded that her involvement was not substantially less than theirs. The court noted that McCombs's actions exceeded those of her co-conspirators, as she agreed to receive and transport drugs. The appellate court held that the district court's denial of the mitigating role reduction was not clearly erroneous and that the sentencing disparity was justified based on the record. The Seventh Circuit affirmed the sentence. View "USA v McCombs" on Justia Law

Jonathan Peoples pleaded guilty to felony possession of a controlled substance and was sentenced to one year of incarceration plus one year of mandatory supervised release. He received credit for time served, effectively completing his incarceration term. However, due to Illinois Department of Corrections (IDOC) policies, he was detained at Cook County Jail for four additional days until he could be transferred to IDOC for processing and release.Peoples filed a Section 1983 claim against Cook County and Sheriff Thomas J. Dart, alleging that his detention beyond his sentence violated his constitutional rights. The U.S. District Court for the Northern District of Illinois granted summary judgment in favor of the defendants, concluding that neither the Fourth nor the Fourteenth Amendments applied to Peoples's claim and that he failed to present a triable Eighth Amendment claim.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court determined that the Fourth Amendment did not apply to Peoples's post-conviction detention. Instead, the Eighth Amendment, which prohibits incarceration beyond the end of a sentence without penological justification, was applicable. The court found that the Cook County Sheriff's Office had a penological justification for detaining Peoples until IDOC could process him, as required by Illinois law and the court's commitment order.The Seventh Circuit affirmed the district court's decision, holding that Peoples failed to establish that the Sheriff acted with deliberate indifference, a necessary element for an Eighth Amendment violation. Consequently, without a constitutional injury, Peoples's Section 1983 claim could not succeed. View "Peoples v Cook County" on Justia Law

Police stopped Martin Devalois for a traffic violation. During the stop, a drug-sniffing dog alerted to narcotics in Devalois’s rental vehicle. Instead of complying with the police request to exit the car, Devalois initiated a high-speed chase that ended in a crash. Police searched the vehicle and found a small amount of marijuana and a gun. Devalois, a convicted felon, was charged with illegally possessing a firearm. He moved to suppress the gun, arguing that the police unconstitutionally prolonged the traffic stop to conduct the dog sniff. The district court denied his motion, and a jury found him guilty.The United States District Court for the Northern District of Indiana held a suppression hearing where the court found the police officer’s testimony credible and determined that the officer did not extend the length of the stop. The district court denied Devalois’s motion to suppress the gun, and the jury subsequently found him guilty of the firearm charge. Devalois was sentenced to 92 months’ imprisonment and appealed the denial of his motion to suppress.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the district court’s factual finding that the officer did not prolong the traffic stop was not clearly erroneous. The court held that the officer’s actions during the stop were within the mission of the traffic stop and did not unlawfully extend its duration. The court also held that the dog sniff did not violate the Fourth Amendment as it was conducted while the officer was still diligently pursuing the stop’s mission. Consequently, the search of the vehicle and the seizure of the gun were lawful. The Seventh Circuit affirmed the district court’s decision denying Devalois’s motion to suppress the gun. View "United States v. Devalois" on Justia Law

The case involves Shamond Jenkins, who was convicted of robbing a Centier Bank branch in South Bend, Indiana, in December 2020. Jenkins was identified as a suspect in three robberies in northern Indiana between December 2020 and January 2021. During a traffic stop on January 8, 2021, Jenkins was found with cash, including a bait bill from the South Bend robbery, and was wearing red-and-white Air Jordan sneakers similar to those worn by the robber. Jenkins was charged with multiple counts, including the South Bend bank robbery, to which he pleaded not guilty.In the district court, Jenkins was found guilty of the South Bend bank robbery but not guilty of the Granger Centier Bank robbery. The jury could not reach a unanimous decision on the Check Into Cash robbery. Jenkins objected to the Presentence Investigation Report's recommendations, including an enhancement for obstructing justice by presenting false testimony and the inclusion of juvenile adjudications in his criminal history. The district court overruled these objections and sentenced Jenkins to 100 months in prison.The United States Court of Appeals for the Seventh Circuit reviewed Jenkins's appeal. Jenkins argued that the evidence was insufficient to convict him, that his Fifth and Sixth Amendment rights were violated due to the face mask he had to wear during the trial, and that the district court erred in applying a sentencing enhancement for perjury and in counting his juvenile convictions. The Seventh Circuit found no error in the district court's decisions. The court held that the face mask did not render the in-court identifications unduly suggestive or violate Jenkins's confrontation rights. The court also upheld the sufficiency of the evidence and the sentencing decisions, affirming Jenkins's conviction and sentence. View "USA v Jenkins" on Justia Law

Kein Eastman was abducted at gunpoint from his grandmother’s house by Kenwyn Frazier, taken to an apartment in East St. Louis, and subjected to threats, beatings, and a gunshot over a piece of jewelry. Eastman fled the scene with a bloodied face and has not been seen since. Kenwyn and his brother Kendrick Frazier were charged with kidnapping and found guilty by a jury. They appealed on several grounds, including a violation of Kendrick’s Sixth Amendment right to his choice of counsel, the constitutionality of the federal kidnapping statute, the sufficiency of the evidence, and aspects of their sentencing.The United States District Court for the Southern District of Illinois denied the Fraziers' motion to dismiss the indictment and their post-trial motions for acquittal or a new trial. The court also applied a four-level sentencing enhancement, finding that Eastman sustained permanent or life-threatening bodily injury. Kendrick’s request for joint representation by attorney Beau Brindley was denied due to potential conflicts of interest, and he retained separate counsel.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decisions. The appellate court found no abuse of discretion in denying Kendrick’s choice of counsel, given the potential for conflicts of interest. The court upheld the constitutionality of the federal kidnapping statute, citing precedent that the use of instrumentalities of interstate commerce, such as cars and cellphones, suffices for federal jurisdiction. The court also found sufficient evidence to support Kendrick’s conviction for aiding and abetting the kidnapping. Lastly, the court affirmed the application of the sentencing enhancement, agreeing that the evidence supported the finding that Eastman sustained a permanent or life-threatening injury. View "United States v. Frazier" on Justia Law

William Hudson was convicted in Wisconsin state court of conspiracy to commit first-degree intentional homicide and conspiracy to commit arson. The convictions stemmed from an agreement Hudson made with another inmate, Scott Seal, to kill Seal’s ex-girlfriend and commit arson in exchange for payment. Seal, however, was an informant. After Hudson was released, he met with an undercover officer posing as Seal’s defense attorney, accepted an envelope with $6,000 and the targets' addresses, and was arrested. Hudson claimed he never intended to commit the crimes but was trying to scam Seal to support himself and his sister, Dana Hudson.Hudson filed a direct appeal alleging outrageous governmental conduct and ineffective assistance of trial counsel for not arguing the government’s conduct. The Wisconsin circuit court denied postconviction relief, and the Court of Appeals of Wisconsin affirmed. The Supreme Court of Wisconsin denied review. Hudson then filed a postconviction motion under Section 974.06, claiming ineffective assistance of trial counsel for not calling Dana as a witness and not investigating her testimony. The Wisconsin circuit court held evidentiary hearings and denied relief, finding counsel’s performance was not deficient. The Court of Appeals of Wisconsin affirmed, and the Supreme Court of Wisconsin denied review.Hudson filed a habeas petition in federal court, claiming ineffective assistance of trial counsel and postconviction counsel. The district court denied the petition, holding that the state court had not misapplied Strickland v. Washington and that trial counsel’s performance satisfied Strickland’s deferential standard. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision, concluding that even if counsel’s performance was deficient, Hudson failed to demonstrate that the deficiencies prejudiced the outcome of the case. View "Hudson v DeHaan" on Justia Law

Rhonda Sutton was charged with conspiracy to commit health care fraud. At her arraignment in June 2018, the district court appointed counsel to represent her. Sutton pleaded not guilty in January 2020. After several delays due to the COVID-19 pandemic, the district court set her trial for November 2022. In September 2022, Sutton requested her attorneys to engage in plea negotiations, but she ultimately decided to proceed to trial. She then expressed dissatisfaction with her counsel and requested new representation. Her counsel filed a motion to withdraw, which the district court denied, citing no conflict or communication breakdown and suspecting a delay tactic.The United States District Court for the Northern District of Illinois denied Sutton's motion to substitute appointed counsel, finding no conflict or communication breakdown and suspecting her request was a delay tactic. The trial proceeded as scheduled, and the jury returned guilty verdicts on all counts. Post-trial, Sutton's counsel filed another motion to withdraw, which the district court granted, appointing new counsel for sentencing. At sentencing, Sutton raised objections to the proposed conditions of supervised release, but she waived her challenge to one condition by not objecting at the appropriate time.The United States Court of Appeals for the Seventh Circuit reviewed the case. Sutton raised two issues on appeal: the denial of her pretrial motion to withdraw and the constitutionality of a supervised release condition. The court held that the district court did not abuse its discretion in denying the motion to withdraw, as Sutton had no right to insist on counsel she could not afford, and her request appeared to be a delay tactic. The court also found that Sutton waived her challenge to the supervised release condition by not objecting at the appropriate time. The judgment of the district court was affirmed. View "USA v Sutton" on Justia Law

Jeffery Henson was convicted of federal fraud, including aggravated identity theft, money laundering, and wire fraud, for diverting nearly $330,000 from his employer to his personal account. He was ordered to pay $436,495.93 in restitution. Following his arrest, Illinois police found $17,390 in cash in his car. The government sought to apply this cash towards Henson's restitution, but Henson argued that the money was obtained through an illegal search and seizure, as the warrant was issued nine hours after the search.The United States District Court for the Central District of Illinois, through a magistrate judge, granted the government's motion to turn over the cash. Henson appealed, contending that the magistrate judge lacked the authority to issue a final decision on the matter.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court determined that the magistrate judge acted outside of his authority, as there was no final decision in the case. The Federal Magistrates Act and the local rules of the Central District of Illinois did not authorize the magistrate judge to issue a final decision on the turnover motion without the district court's explicit assignment. Consequently, the Seventh Circuit dismissed the appeal for lack of appellate jurisdiction, as the magistrate judge's order was not an appealable final decision. View "USA v Henson" on Justia Law