Justia Criminal Law Opinion Summaries

During a traffic stop in July 2020, Jesse Mickles was pulled over by an Indiana state trooper. Mickles admitted to the trooper that he was a felon and that he had a firearm in his car, which was found under the driver's seat. Two weeks later, a grand jury indicted Mickles for violating 18 U.S.C. § 922(g)(1), which prohibits felons from possessing firearms. Mickles entered a plea agreement that stipulated these facts as the basis for his guilty plea. He also submitted an affidavit stating he was returning the firearm to its owner, but at the change-of-plea hearing, Mickles confirmed his understanding of the charge and agreed with the stipulated facts.The United States District Court for the Southern District of Indiana reviewed Mickles’s plea at a change-of-plea hearing. The court confirmed that Mickles understood the charge and its elements, that he had reviewed the plea agreement thoroughly with his attorney, and that the factual basis reflected his conduct. The court determined that Mickles’s plea was knowing, voluntary, and supported by an adequate factual basis, and accepted his guilty plea.On appeal before the United States Court of Appeals for the Seventh Circuit, Mickles argued that the district court plainly erred by accepting his plea without sufficient factual basis for knowing possession, as required under § 922(g)(1). The Seventh Circuit reviewed for plain error and found overwhelming evidence of constructive possession, including Mickles’s exclusive control of the vehicle, proximity to the firearm, and his admissions. The court held that the factual basis was more than adequate and rejected Mickles’s argument regarding intent. The Seventh Circuit affirmed the judgment of the district court. View "USA v Mickles" on Justia Law

Police in Terre Haute, Indiana, began investigating Maurice Whitesides after receiving a tip that he was distributing drugs. During a traffic stop, officers seized over $14,000 from Whitesides, who admitted he was en route to purchase methamphetamine. That same day, police searched a residence Whitesides rented on Spruce Street, recovering over 420 grams of pure methamphetamine, two digital scales, an empty box of sandwich baggies, and a loaded handgun. A separate search of his girlfriend’s home yielded additional methamphetamine, scales, and firearms. Officers also found messages on Whitesides’s cellphone in which he provided the addresses of both residences to suspected drug customers. Although only one sale at the Spruce Street home was confirmed, the evidence suggested ongoing drug distribution activity.A grand jury indicted Whitesides for possession with intent to distribute methamphetamine and for unlawful possession of a firearm by a convicted felon. He pleaded guilty to both charges in the United States District Court for the Southern District of Indiana. At sentencing, the district court applied a two-level enhancement under U.S.S.G. § 2D1.1(b)(12) for maintaining a drug premises, based on evidence found at the Spruce Street home and Whitesides’s use of the address in drug transactions. Whitesides objected, arguing the enhancement was improper and that the district court made certain factual misstatements. The district court overruled his objection and imposed a sentence of 188 months, noting it would have imposed the same sentence regardless.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court properly applied the premises enhancement, finding sufficient evidence that drug distribution was a primary use of the Spruce Street home. The appellate court also determined that any minor factual errors made by the district court were harmless and did not affect the sentencing outcome. The judgment was affirmed. View "USA v Whitesides" on Justia Law

Thomas Hawkins, while on federal supervised release for earlier federal robbery convictions, committed two additional armed robberies in Rockford, Illinois. He also participated in an armed home invasion, though the state did not charge him for that offense. Hawkins pleaded guilty to the two new robberies, which led the government to seek revocation of his supervised release.The United States District Court for the Northern District of Illinois, Western Division, held a combined hearing for Hawkins’ new criminal sentences and the supervised release revocation. For the new robberies, the court imposed a sentence of 135 months’ imprisonment and three years of supervised release, referencing the sentencing factors from 18 U.S.C. § 3553(a), including retribution. For the supervised release violations, after Hawkins admitted the violations, the court revoked his release and imposed a 108-month sentence, the statutory maximum under 18 U.S.C. § 3583(e)(3). The court noted the need to protect the public as the dominant consideration and listed relevant factors under § 3583(e), deliberately omitting retribution.On appeal to the United States Court of Appeals for the Seventh Circuit, Hawkins argued that the district court impermissibly considered retribution in the revocation sentence and that the sentence was both excessive and disparate relative to similar cases. The Seventh Circuit held that the district court did not consider retribution in imposing the revocation sentence, finding that its reasoning focused on public safety and conformed to the statutory limits of § 3583(e). The court also rejected arguments regarding unwarranted disparity and substantive unreasonableness, concluding the 108-month revocation sentence was not plainly unreasonable. Accordingly, the Seventh Circuit affirmed the district court’s judgment. View "USA v Hawkins" on Justia Law

Law enforcement officers arrested an individual in a public parking lot while he was carrying a backpack. The arrest was pursuant to a warrant based on allegations of arson. After detaining him, officers seized the backpack and searched it a few minutes later, discovering a loaded handgun and drugs inside. The individual was subsequently charged with federal offenses.The defendant filed a motion in the United States District Court for the Northern District of Illinois, Eastern Division, seeking to suppress the evidence found in the backpack. He argued that the search violated the Fourth Amendment. The district court denied the motion, holding that the search was permissible under the inventory search exception to the warrant requirement. The defendant then pleaded guilty, reserving his right to appeal the suppression ruling.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the search of the backpack was lawful. The court held that law enforcement may take custody of an arrestee’s personal property when the arrest occurs in a public place, and that an inventory search conducted according to established procedures is lawful. The court found that, although there were minor deviations from departmental policy in the way the search was conducted and documented, these did not render the search unreasonable. The court also rejected the defendant’s argument that officers acted in bad faith, finding no evidence to support this claim. Additionally, the court declined to consider a Fourth Amendment challenge to law enforcement’s use of a license plate reader database because the defendant forfeited the issue by not raising it earlier. Accordingly, the Seventh Circuit affirmed the district court’s denial of the suppression motion. View "USA v Fillyaw" on Justia Law

Clifton Coleman participated in a drug trafficking organization operating in Chicago between 2019 and 2020. He supplied heroin to three managers, who then cut, mixed, and packaged the drugs for distribution. Coleman also owned an apartment used for these activities, which he rented to one of the managers. Over the course of the operation, Coleman provided at least 25 kilograms of heroin and 40 grams of fentanyl. Law enforcement intercepted wiretapped conversations revealing Coleman’s involvement in decision-making and personnel management within the organization.The United States District Court for the Northern District of Illinois, Eastern Division, sentenced Coleman after he pled guilty to conspiracy to possess with intent to distribute a controlled substance. The court applied two sentencing enhancements: a four-level increase for being a leader under U.S.S.G. § 3B1.1(a), and a two-level increase for maintaining a drug premises under U.S.S.G. § 2D1.1(b)(12). Probation’s recommendation was based on charging documents, Coleman’s plea, and summaries of co-defendants’ post-arrest interviews. Coleman objected, arguing the government withheld recordings that could undermine his leadership status and that he did not maintain the apartment for drug distribution.The United States Court of Appeals for the Seventh Circuit reviewed Coleman’s claims. Applying plain error review for the Brady claim, the Court found that transcript summaries provided sufficient information and that the district court relied primarily on wiretap evidence rather than the disputed agent’s statement. For the drug premises enhancement, the Seventh Circuit concluded that Coleman’s ownership, control, and participation in drug activities at the apartment justified the enhancement, distinguishing the case from prior precedents. The Court affirmed the district court’s judgment. View "USA v Coleman" on Justia Law

Dennis McKay pled guilty to three counts of Hobbs Act robbery affecting commerce and one count of discharging a firearm in connection with a crime of violence. In his plea agreement, he also admitted to four additional robberies and to possessing a firearm as a felon. The U.S. Probation Office prepared a Presentence Investigation Report recommending, among other terms, Special Condition 13 for supervised release, which would require McKay to notify third parties of any “risk” he posed, as determined by a probation officer. McKay submitted written objections to two other conditions but did not object in writing to Special Condition 13. At sentencing, defense counsel did not initially object but, when specifically asked by the district judge, argued that the condition was unwarranted because McKay’s history did not show a persistent threat of violence.The United States District Court for the Northern District of Illinois, Eastern Division, imposed Special Condition 13 despite defense counsel’s oral objection, noting the lack of an initial objection but allowing the defense to respond after hearing from probation and the government. The district judge stated that she would reconsider the condition if there were evidence of it being abused in the future. McKay then appealed, challenging only Special Condition 13.The United States Court of Appeals for the Seventh Circuit reviewed whether McKay’s objection was waived and found that his oral objection at sentencing was sufficient to preserve the issue for appeal, even though his arguments on appeal were broader than those made at sentencing. On the merits, the Seventh Circuit held that Special Condition 13 was impermissibly vague, following its own precedents, and vacated the condition. The case was remanded to the district court for further proceedings to clarify or modify the condition. View "USA v. McKay" on Justia Law

Adam Blocker used Dropbox, a cloud storage service, to share files, some of which contained child pornography. Dropbox detected these illegal files through its own monitoring, as permitted by its terms of service, and reported them to the National Center for Missing and Exploited Children (NCMEC). Following this report, NCMEC notified federal authorities, which led the FBI to obtain a search warrant for Blocker’s digital storage. The subsequent search uncovered additional illegal images. Blocker pleaded guilty to two counts related to possession and distribution of child pornography, but reserved the right to appeal the denial of his motion to suppress the evidence obtained from Dropbox and his devices.In the United States District Court for the Northern District of Illinois, Eastern Division, Judge Lee denied Blocker’s suppression motion. The court concluded that Blocker had consented to Dropbox’s search and disclosure of his files by agreeing to its terms of service. Blocker argued that the terms were not specific or clear enough to constitute voluntary consent, especially because NCMEC is a government-affiliated entity. After Judge Lee’s elevation to the appellate court, the case was transferred to Chief Judge Kendall, who oversaw Blocker’s sentencing.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decision. The court held that Blocker’s acceptance of Dropbox’s terms of service constituted effective consent for Dropbox to scan his files and disclose them for certain purposes, including reporting to authorities. The court rejected Blocker’s argument that the consent was invalid because the terms did not obligate Dropbox to search every file or regularly disclose information. The Seventh Circuit found no clear error in the district court’s finding of consent, and thus upheld the denial of the motion to suppress. View "USA v. Blocker" on Justia Law

Glenn Wooden was caught selling nearly 100 grams of methamphetamine to confidential informants in a series of controlled buys organized by the West Central Illinois Task Force. Police obtained audio and video evidence of the transactions, searched Wooden’s apartment, and found an additional 222 grams of methamphetamine packaged for distribution, along with proceeds from the sales. After his arrest, Wooden confessed on video to distributing methamphetamine, describing the substance as “hot”—slang for illegal. He was indicted on three counts of distributing and one count of possessing methamphetamine.At trial in the United States District Court for the Central District of Illinois, Wooden represented himself. He did not dispute the facts but argued that the government failed to prove the methamphetamine involved was the specific “optical isomer” form that is illegal under federal law, asserting that not all methamphetamine is criminalized by the Controlled Substances Act. He raised this defense throughout trial and in a post-trial motion. The district court rejected his argument, instructed the jury using the Seventh Circuit’s pattern instructions that treat “methamphetamine” as a generic term, and clarified to the jury that all methamphetamine is illegal. Wooden was convicted on all counts and sentenced to 25 years in prison.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and held that the Controlled Substances Act criminalizes the possession and distribution of methamphetamine generically, not limited to specific isomers. The court affirmed the district court’s instructions and found the government’s evidence sufficient. The Seventh Circuit also found no error in allowing testimony from a DEA chemist and declined to adopt Wooden’s narrow statutory interpretation. The district court’s judgment was affirmed. View "USA v Wooden" on Justia Law

A longtime Speaker of the Illinois House of Representatives was prosecuted in federal court for engaging in extensive bribery schemes. The first involved a major utility company, Commonwealth Edison (ComEd), which, facing financial difficulties, funneled more than $3 million to the defendant’s political associates through intermediaries and sham contracts in exchange for the defendant’s legislative support of ComEd’s agenda over several years. The government presented evidence that these payments resulted in concrete legislative actions by the defendant that benefitted ComEd, including support for specific bills and regulatory changes. The second scheme involved the defendant’s agreement to recommend a Chicago alderman for a state board appointment in exchange for business referrals and benefits to the defendant’s family.Following a lengthy trial in the United States District Court for the Northern District of Illinois, the jury convicted the defendant on several counts, including conspiracy, federal-program bribery, honest-services wire fraud, and Travel Act violations. The jury acquitted him on some counts and was deadlocked on others. The district court denied the defendant’s motions for acquittal and for a new trial, then imposed a sentence of imprisonment and a substantial fine.On appeal to the United States Court of Appeals for the Seventh Circuit, the defendant challenged the sufficiency of the evidence and the adequacy of the jury instructions. The Court of Appeals held that sufficient evidence supported each conviction and found no prejudicial error in the jury instructions, including those related to the definition of “official act,” “corruptly,” and the intent elements of bribery. The court also concluded that any potential instructional error regarding state law bribery under the Travel Act was harmless beyond a reasonable doubt. The convictions and sentence were affirmed. View "USA v. Madigan" on Justia Law

The case centers on Ashantae Corruthers, who, at the request of her friend Regina Lewis, agreed to purchase a firearm for Lewis’s cousin, Darrion Lafayette, in exchange for money. In November 2020, the group traveled from Illinois to Indiana, where Corruthers bought a Glock 48 pistol and ammunition for Lafayette, falsely certifying on the ATF purchase form that she was the true buyer. The firearm was later used by Lafayette in multiple incidents, including the fatal shooting of a police officer in Champaign, Illinois. Afterward, Corruthers falsely reported the firearm as stolen and made misleading statements to federal agents regarding her involvement.A federal grand jury indicted Corruthers and Lewis for conspiracy to illegally purchase and transfer a firearm and conspiracy to engage in misleading conduct. Lewis pled guilty and was sentenced to 60 months’ imprisonment on the firearm charge and 102 months on the misleading conduct charge, to run concurrently. Corruthers also pled guilty. In her case, the United States District Court for the Central District of Illinois calculated her guidelines range at 21 to 27 months but imposed an above-guidelines sentence of 48 months, citing the seriousness and consequences of her conduct. The court rejected the government’s argument to apply the higher offense level for obstruction of a murder investigation, finding that the post-shooting inquiry was not a murder investigation.The United States Court of Appeals for the Seventh Circuit reviewed both Corruthers’s appeal of her sentence and the government’s cross-appeal. The court held that the district court did not abuse its discretion by imposing an above-guidelines sentence, as it fully considered the relevant factors and provided adequate justification. It also affirmed the district court’s refusal to apply the higher guidelines for obstruction, finding no clear error in its determination of the investigation’s scope. The sentence was affirmed. View "USA v. Corruthers" on Justia Law