Justia Criminal Law Opinion Summaries

Michael Williams was convicted by a Wisconsin jury of reckless homicide and possession of a firearm as a convicted felon. He appealed his convictions to the Wisconsin Court of Appeals, arguing that a jury instruction unconstitutionally lowered the government's burden of proof and that the prosecutor's closing arguments improperly shifted the burden of proof to him. The Wisconsin Court of Appeals affirmed the convictions, and the Wisconsin Supreme Court denied his petition for review.Williams then filed a petition for habeas corpus in the United States District Court for the Eastern District of Wisconsin. The district court held that the state appellate court reasonably applied Supreme Court precedent in concluding that it was not reasonably likely the jury applied the instruction in an unconstitutional manner. The court also held that Williams had not demonstrated that the prosecutor's remarks violated clearly established Supreme Court precedent.On appeal to the United States Court of Appeals for the Seventh Circuit, Williams raised the same two arguments. The Seventh Circuit affirmed the district court's decision. The court held that the Wisconsin Court of Appeals did not unreasonably apply Supreme Court precedent regarding the jury instruction on reasonable doubt. The court also found that the prosecutor's comments during closing arguments did not shift the burden of proof to the defense in a manner that violated due process, especially considering the trial court's curative instructions. The Seventh Circuit concluded that Williams had not shown that the state court's rulings were so lacking in justification as to constitute an unreasonable application of clearly established federal law. View "Williams v Meisner" on Justia Law

Fourteen plaintiffs, including pilots, a physician, a nurse, and an attorney, were required to undergo alcohol testing to maintain their employment and professional licenses. The tests, developed by United States Drug Testing Laboratories, Inc. (USDTL), indicated positive results for alcohol consumption, leading to significant professional harm. The plaintiffs alleged that the tests were unreliable and sued USDTL and its officers under the Racketeer Influenced and Corrupt Organizations Act (RICO) and state law. They also sued Choice Labs Services (CLS) and its owners, who provided the tests to the administrators.The plaintiffs initially filed suit in the Southern District of Florida, asserting claims for fraud and negligence. The district court dismissed the case without prejudice, finding the complaint insufficient. The plaintiffs then filed a second amended complaint, adding CLS as defendants. The case was transferred to the Northern District of Illinois, where the district court dismissed the RICO claims under Rule 12(b)(6) and denied supplemental jurisdiction over the state law claims. The plaintiffs' motion to alter or amend the judgment was also denied.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court's decision. The court held that the plaintiffs failed to establish proximate causation for their RICO claims, as they did not adequately allege a direct link between USDTL's alleged misrepresentations and their professional injuries. The court also found that the plaintiffs did not meet the heightened pleading requirements for fraud under Rule 9(b). Consequently, the RICO claims were dismissed with prejudice, and the state law claims were dismissed without prejudice. View "Ratfield v United States Drug Testing Laboratories, Inc." on Justia Law

Defendants Falandis Russell and Terrance Williams committed a series of armed commercial robberies in Chicago over nearly a year and a half. They were indicted for conspiracy to obstruct commerce by robbery, with Russell facing eleven additional counts and Williams six counts of obstruction of commerce by robbery. Russell's counsel requested a forensic psychologist to assess his cognitive capacity, leading to a diagnosis of intellectual disability and ADHD. A competency examination was conducted, and Dr. Jajko found Russell unfit for trial. However, further evaluations by Dr. Muhkin and Dr. Dinwiddie concluded that Russell was competent, suggesting he was malingering.The United States District Court for the Northern District of Illinois held a competency hearing and found Russell competent to stand trial. Both defendants pleaded guilty, with Russell reserving the right to challenge the competency determination. Russell was sentenced to 180 months of imprisonment and 60 months of supervised release, while Williams received 114 months of imprisonment. Williams objected to a supervised release condition requiring him to notify another person if his probation officer determined he posed a risk, but the court imposed it with amendments.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's competency determination for Russell, finding no clear error in the reliance on the evaluations by Drs. Muhkin and Dinwiddie. The court also found no procedural error in Russell's sentencing, noting that the district court adequately considered his cognitive impairments. However, the court vacated the supervised release condition imposed on Williams, agreeing that certain terms were vague, and remanded for further proceedings to reconsider the necessity and scope of the condition. View "USA v Williams" on Justia Law

Derrick Clark and Shawn Mesner worked for Didion Milling, Inc., a corn milling company. In May 2017, Didion’s grain mill exploded, killing five employees. The Occupational Health and Safety Administration (OSHA) investigated and referred Didion for criminal prosecution. The government charged Didion and several employees with federal crimes related to their work at the mill. Clark and Mesner proceeded to trial, challenging the district court’s evidentiary rulings, jury instructions, the indictment, the sufficiency of the evidence, and the constitutionality of their convictions.The United States District Court for the Western District of Wisconsin convicted Clark on four counts and Mesner on two counts. Clark was found guilty of conspiracy to commit federal offenses, false entries in records, using false documents within the EPA’s jurisdiction, and obstruction of agency proceedings. Mesner was found guilty of conspiracy to commit mail and wire fraud and conspiracy to commit federal offenses. Both defendants were sentenced to 24 months’ imprisonment and one year of supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court vacated Mesner’s conviction on Count 4, remanding for an entry of judgment of acquittal and further proceedings consistent with the opinion. The court affirmed the district court’s evidentiary rulings and jury instructions, as well as Clark’s convictions and Mesner’s conviction on Count 1. The court found sufficient evidence to support the convictions and determined that the jury instructions, when considered as a whole, accurately reflected the law. The court also rejected challenges to the constitutionality of the OSHA regulation involved. View "USA v Mesner" on Justia Law

Roger Snake, an elder member of the Ho-Chunk tribe, pleaded guilty in 2011 to two counts of abusive sexual contact with minors. After completing his prison sentence in 2020, he began a lifetime term of supervised release. Snake violated several conditions of his release, including having unapproved and unsupervised contact with minors and traveling outside the judicial district without permission. The district court revoked his supervised release and sentenced him to 24 months in prison, which was above the recommended range in the Sentencing Guidelines.The United States District Court for the Western District of Wisconsin initially addressed Snake's violations informally, reminding him of the conditions of his supervised release. However, after further violations, including being found alone with minors in his home, the court issued a summons. Snake admitted to the violations, and his lawyer requested home detention instead of prison, citing his role as a tribal elder. The district court rejected this argument, emphasizing the severity of his violations and the risk he posed to minors.The United States Court of Appeals for the Seventh Circuit reviewed the case. Snake argued that the district court failed to adequately explain the reasons for imposing a sentence above the guideline range. The appellate court, applying a highly deferential standard of review, found that the district court had sufficiently explained its decision. The court noted that the district judge had considered the relevant statutory factors and the egregiousness of Snake's violations. The appellate court affirmed the district court's decision, emphasizing the need for clear explanations in sentencing and the importance of addressing potential procedural errors promptly. View "United States v. Snake" on Justia Law

In January 2017, Deaunta Tyler, along with Ledell Tyler and Dalvent Jackson, forcibly entered a home in Rock Island, Illinois, armed with firearms, searching for cocaine. They found a family instead and, brandishing weapons, demanded the non-existent drugs. The intruders moved the family around the house at gunpoint, passing firearms among themselves and threatening to kill the victims. Jackson fired a handgun inside the house. The intruders eventually left with cash and a small amount of marijuana. The next day, police identified the men, leading to a high-speed chase and Tyler's eventual arrest.A grand jury indicted Tyler on three counts: attempted Hobbs Act robbery, possession of a firearm in furtherance of a crime of violence, and being a felon in possession of a firearm. Tyler was convicted on all counts. The district court sentenced him to 330 months in prison. Following the Supreme Court's decision in United States v. Taylor, which held that attempted Hobbs Act robbery is not a "crime of violence" under 18 U.S.C. § 924(c), Tyler moved to vacate his § 924(c) conviction. The district court granted the motion, vacated the § 924(c) conviction, and resentenced Tyler to 240 months.Tyler appealed his revised sentence, arguing that the district court failed to address his key arguments in mitigation and provided an inadequate explanation for the sentence. The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that Tyler waived any procedural objection regarding the court’s failure to consider his arguments in mitigation by confirming that the court had addressed his principal points. Additionally, the appellate court found that the district court adequately explained its reasons for imposing a revised sentence within the guideline range. View "United States v Tyler" on Justia Law

Thomas Wilkinson was charged with drug and firearm offenses, including possession with intent to distribute methamphetamine, possession of a firearm in furtherance of a drug trafficking crime, and possession of a firearm by a convicted felon. The indictment noted two prior state drug convictions relevant to sentencing. Wilkinson initially pleaded not guilty but later changed his plea to guilty. The government filed a notice under 21 U.S.C. § 851 to enhance Wilkinson's sentence based on one prior drug-trafficking conviction.The United States District Court for the Central District of Illinois accepted Wilkinson's guilty plea. However, before sentencing, it was discovered that the prior conviction cited in the § 851 notice did not qualify as a "serious drug felony" under federal law. The government then sought to use a different prior conviction, not mentioned in the § 851 notice, to enhance Wilkinson's sentence. The district court agreed, finding that the government had substantially complied with § 851's requirements, and sentenced Wilkinson to a total of twenty years in prison.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the government failed to comply with the notice requirements of 21 U.S.C. § 851(a)(1) by not providing written notice of the specific prior conviction it intended to use for the sentence enhancement before Wilkinson's guilty plea. The court found that this error was not harmless, as it affected Wilkinson's ability to make an informed decision about his plea and the district court's sentencing decision. Consequently, the Seventh Circuit vacated Wilkinson's sentence and remanded the case for resentencing. View "USA v Wilkinson" on Justia Law

Mark Johnson was convicted by an Indiana jury of felony rape, felony criminal confinement, and misdemeanor battery. He appealed, arguing that the exclusion of certain DNA evidence and the destruction of the victim's blood sample before toxicology testing violated his Fourteenth Amendment due process rights. The Indiana Court of Appeals vacated his convictions for criminal confinement and battery on double jeopardy grounds but affirmed the rape conviction. Johnson's petition to transfer to the Indiana Supreme Court was denied. He then sought post-conviction review in state court and, after exhausting state remedies, sought federal habeas review under 28 U.S.C. § 2254.The United States District Court for the Southern District of Indiana denied Johnson's habeas petition, concluding that his DNA-related claim was procedurally defaulted and that the state court reasonably applied federal law in determining that the State had not acted in bad faith when discarding the blood sample. Johnson appealed to the United States Court of Appeals for the Seventh Circuit.The Seventh Circuit affirmed the district court's decision. The court held that Johnson's claim regarding the exclusion of DNA evidence was procedurally defaulted because he failed to raise it in his petition for transfer to the Indiana Supreme Court. Additionally, the court found that the Indiana Court of Appeals reasonably applied federal law in determining that the police had not acted in bad faith when disposing of the blood sample, as the evidence was only potentially exculpatory and there was no clear indication of bad faith. The court concluded that the state court's decision did not deviate from established federal law or constitute an unreasonable determination of the facts. View "Johnson v Sevier" on Justia Law

Steven Lindsey was convicted of murdering his wife in 2016 after three trials. He was sentenced to fifty-five years in prison. Lindsey appealed his conviction, but the Court of Appeals of Indiana denied his appeal, and the Indiana Supreme Court declined to hear his case. In 2019, Lindsey filed a pro se postconviction petition in state court, which has seen little progress over six years due to state court inaction and prosecution delays.The state court appointed a public defender for Lindsey nearly two years after he filed his petition, despite his wish to represent himself. The case experienced multiple delays, including the appointment and withdrawal of special prosecutors and the state court's failure to rule on Lindsey's motions. Lindsey actively tried to move his case forward, filing motions and responding to discovery requests, but the state court and prosecution's actions significantly delayed the proceedings.Lindsey then filed a federal habeas petition in the Northern District of Indiana in 2023, arguing that the inordinate delay in his state postconviction proceedings should excuse the exhaustion requirement under 28 U.S.C. § 2254(b)(1). The district court dismissed his petition, finding the delays reasonable and attributing them to Lindsey's legal inexperience. Lindsey appealed, and the United States Court of Appeals for the Seventh Circuit reviewed the case.The Seventh Circuit found that the six-year delay in Lindsey's state postconviction proceedings was inordinate and attributable to the state. The court held that the delay rendered the state process ineffective in protecting Lindsey's rights, excusing him from the exhaustion requirement. The court vacated the district court's judgment and remanded the case for further proceedings on the merits of Lindsey's habeas petition. View "Lindsey v Neal" on Justia Law

Kevin Hodge was involved in a conspiracy to distribute methamphetamine and pleaded guilty to the charge. The indictment specified that the conspiracy involved more than 50 grams of methamphetamine, which typically carries a ten-year statutory minimum sentence. However, Hodge met the criteria for the statutory "safety valve," which allows courts to disregard mandatory minimum sentences. Despite this, the district court sentenced him to ten years without discussing his eligibility for safety valve relief.The United States District Court for the Southern District of Illinois initially handled the case. Hodge pleaded not guilty but later changed his plea to guilty. The court granted multiple continuances for his sentencing, partly due to his wife's serious health issues. The presentence investigation report (PSR) confirmed Hodge's eligibility for the safety valve, recommending a Guidelines range of 135 to 168 months. Hodge requested a sentence of time served, citing his wife's health and his role as primary caregiver. The district court sentenced him to 120 months, acknowledging his wife's health issues but emphasizing the large quantity of drugs involved. The court did not address Hodge's safety valve argument.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the district court had committed procedural error by not addressing Hodge's statutory safety valve argument, which is a principal mitigating argument. The Seventh Circuit noted that the district court's silence on this issue left uncertainty about whether it considered the safety valve's applicability. Consequently, the Seventh Circuit vacated Hodge's sentence and remanded the case for resentencing, requiring the district court to engage with the safety valve argument. View "United States v. Hodge" on Justia Law