Justia Criminal Law Opinion Summaries

The case concerns a defendant who was arrested at a gas station mini-mart after officers, investigating an earlier robbery, observed him enter a single-occupancy restroom marked “Out of Order.” The defendant did not lock the door. Officers entered the restroom shortly after and found him standing on the handicap bars, reaching into the ceiling. A firearm was recovered from the ceiling area, and a subsequent search of the defendant revealed cash and various controlled substances. The government conceded that the officers lacked probable cause or reasonable suspicion to believe the defendant had committed a crime at the time they entered the restroom.The United States District Court for the Northern District of Illinois, Eastern Division, denied the defendant’s motion to suppress the evidence, finding he lacked a reasonable expectation of privacy in the out-of-order restroom. The court also found sufficient evidence to convict him of unlawful possession of a firearm by a felon and possession with intent to distribute a controlled substance following a bench trial. The defendant appealed, challenging the denial of the suppression motion, the sufficiency of the evidence for the firearm conviction, and sought to preserve a constitutional challenge to 18 U.S.C. § 922(g).The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that the defendant did not have a subjective or objectively reasonable expectation of privacy in the unlocked, out-of-order restroom, so the officers’ entry did not constitute a search under the Fourth Amendment. The court also found that sufficient evidence supported the conviction for unlawful possession of a firearm by a felon, based on constructive possession. Finally, the court held that the defendant waived his constitutional challenge to § 922(g) by failing to present any legal argument on appeal. View "United States v. Scott" on Justia Law

Miguel Salinas-Salcedo pled guilty to conspiracy to commit money laundering, admitting that over a two-and-a-half-year period he helped Mexican drug cartels launder nearly $3 million through 24 transactions. His role was to connect cartel members with individuals in the United States who could deposit and transfer large sums of cash into bank accounts without attracting government attention. Salinas-Salcedo acted as the intermediary, relaying instructions, authenticating transactions, and confirming deposits, ultimately earning over $44,000 in commissions. Unbeknownst to him, some of his contacts were undercover law enforcement agents.The United States District Court for the Northern District of Illinois, Eastern Division, sentenced Salinas-Salcedo after applying a four-level enhancement under U.S.S.G. §2S1.1(b)(2)(C) for being “in the business of laundering funds.” Salinas-Salcedo argued that he was merely a “middleman” and not in the business of laundering funds as contemplated by the guidelines. The district court rejected this argument, finding his participation integral to the conspiracy and imposing a below-guidelines sentence of 96 months.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s interpretation of the Sentencing Guidelines de novo, as the facts were undisputed. The appellate court held that Salinas-Salcedo’s conduct fell squarely within the scope of the “business of laundering funds” enhancement, as defined by the guidelines and relevant statutes. The court found that his regular, multi-year involvement, substantial earnings, and discussions with undercover agents satisfied the enhancement’s factors. The Seventh Circuit also rejected Salinas-Salcedo’s claim of procedural error, concluding that the district court adequately addressed his objections. The judgment was affirmed. View "United States v. Salinas-Salcedo" on Justia Law

Christopher Hill was charged with possession with intent to distribute methamphetamine after law enforcement, acting on information from a confidential informant, arranged a controlled purchase and arrested him en route to the meeting location. During the arrest, officers recovered approximately 100 grams of methamphetamine, a handgun, other drugs, and cash. Hill claimed the drugs were for personal use. He was indicted four days later and the case proceeded to a jury trial.During jury selection in the United States District Court for the Southern District of Indiana, two prospective jurors with family ties to law enforcement were questioned. Juror 53, who had been married to a sheriff’s officer and knew an officer involved in the case, expressed concerns about impartiality and was excused for cause. Juror 55, whose sons were in law enforcement, initially expressed concern about her ability to be impartial but ultimately stated she could judge the case based on the evidence and give equal weight to all testimony. The district court denied the motion to strike Juror 55 for cause, and she served on the jury. The jury found Hill guilty, and he was sentenced to 188 months in prison.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether Hill’s right to an impartial jury was violated by the district court’s decision to seat Juror 55. Applying an abuse of discretion standard, the appellate court held that the district court did not err in crediting Juror 55’s assurances of impartiality, distinguishing her responses from those of Juror 53. The Seventh Circuit concluded that the trial judge acted within her discretion and affirmed Hill’s conviction. View "United States v. Hill" on Justia Law

James Weiss owned a company that manufactured sweepstakes machines, which in 2018 operated in a legal gray area under Illinois law. Seeking to secure favorable legislation, Weiss arranged for his company to make monthly payments to a lobbying firm owned by State Representative Luis Arroyo, who then became a vocal advocate for legalizing sweepstakes machines. After initial legislative efforts failed, Weiss and Arroyo sought to amend existing gaming legislation by enlisting the support of State Senator Terrance Link. Unbeknownst to them, Link was cooperating with federal authorities. During meetings, Arroyo assured Link he would be compensated for his support, and Weiss’s company provided checks intended for Link under a fictitious name created by the FBI. Weiss was later stopped by FBI agents, interviewed without Miranda warnings, and made false statements during the encounter.The United States District Court for the Northern District of Illinois, Eastern Division, denied Weiss’s pretrial motions to suppress his statements to the FBI and to exclude Arroyo’s recorded statements. At trial, the jury heard evidence of the bribery scheme, including testimony from Link and federal agents, and found Weiss guilty on all charges after deliberation. The district court sentenced Weiss to 66 months’ imprisonment, exceeding the calculated guidelines range, and declined to delay sentencing for anticipated changes to the Sentencing Guidelines.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed Weiss’s challenges to the admission of his statements, the admission of Arroyo’s statements as coconspirator statements, the jury instructions regarding “official acts,” and the sentence imposed. The Seventh Circuit held that Weiss was not in custody for Miranda purposes during the FBI interview, the district court did not err in admitting Arroyo’s statements, the jury instructions did not constitute plain error, and the sentence was both procedurally and substantively reasonable. The court affirmed the district court’s judgment in all respects. View "United States v. Weiss" on Justia Law

Earl Miller, who owned and operated several real estate investment companies under the 5 Star name, was responsible for soliciting funds from investors, primarily in the Amish community, with promises that their money would be used exclusively for real estate ventures. After becoming sole owner in 2014, Miller diverted substantial investor funds for personal use, unauthorized business ventures, and payments to friends’ companies, all in violation of the investment agreements. He also misled investors about the nature and use of their funds, including issuing false statements about new business activities. The scheme continued even as the business faltered, and Miller ultimately filed for bankruptcy.A federal grand jury in the Northern District of Indiana indicted Miller on multiple counts, including wire fraud and securities fraud. At trial, the government presented evidence, including testimony from an FBI forensic accountant, showing that Miller misappropriated approximately $4.5 million. The jury convicted Miller on one count of securities fraud and five counts of wire fraud, acquitting him on one wire fraud count and a bankruptcy-related charge. The United States District Court for the Northern District of Indiana sentenced Miller to 97 months’ imprisonment, applying an 18-level sentencing enhancement based on a $4.5 million intended loss, and ordered $2.3 million in restitution to victims.The United States Court of Appeals for the Seventh Circuit reviewed Miller’s appeal, in which he challenged the district court’s loss and restitution calculations. The Seventh Circuit held that the district court reasonably estimated the intended loss at $4.5 million, as this amount reflected the funds Miller placed at risk through his fraudulent scheme, regardless of when the investments were made. The court also upheld the restitution award, finding it properly included all victims harmed by the overall scheme. The Seventh Circuit affirmed the district court’s judgment. View "USA v Miller" on Justia Law

The defendant was charged with making threats against an Assistant United States Attorney (AUSA) in Fort Wayne, Indiana, on two separate occasions: May 20, 2022, and February 15, 2023. The first incident involved in-person threats at the federal courthouse and the Allen County prosecutor’s office, where the defendant made statements suggesting violent intent toward the AUSA. The second incident involved a threatening message sent to the AUSA’s personal Facebook account after she refused to return his calls. The defendant had a history of erratic behavior, including repeated attempts to contact the AUSA, hostile statements to law enforcement, and social media messages referencing the AUSA.The United States District Court for the Northern District of Indiana allowed the government to introduce evidence of the defendant’s other interactions with or about the AUSA under Federal Rule of Evidence 404(b), to show motive, intent, and context. However, the court excluded testimony from mental health professionals who had evaluated the defendant and from police officers who had experienced threats from him, finding that this evidence was not sufficiently probative of his intent or state of mind regarding the charged threats. The court also denied the defendant’s motion for acquittal, rejecting the argument that the Facebook message could not be a threat related to official duties because it was sent to a personal account and received after work hours. The jury convicted the defendant on both counts, though it acquitted him of threatening to murder the AUSA on the first occasion.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the conviction. The court held that the district court did not abuse its discretion in admitting the government’s evidence or excluding the defendant’s proffered testimony. It also found that sufficient evidence supported the jury’s verdict, including the finding that the Facebook message could be intended to interfere with the AUSA’s official duties. View "United States v. Taylor" on Justia Law

Three individuals who worked as precious metals futures traders at major financial institutions were prosecuted for engaging in a market manipulation scheme known as spoofing. This practice involved placing large orders on commodities exchanges with the intent to cancel them before execution, thereby creating a false impression of market supply or demand to benefit their genuine trades. The traders’ conduct was in violation of both exchange rules and their employers’ policies, and the government charged them with various offenses, including wire fraud, commodities fraud, attempted price manipulation, and violating the anti-spoofing provision of the Dodd-Frank Act.The United States District Court for the Northern District of Illinois, Eastern Division, presided over separate trials for the defendants. In the first trial, two defendants were convicted by a jury on all substantive counts except conspiracy, after the court denied their motions for acquittal and a new trial. The third defendant, tried separately, admitted to spoofing but argued he lacked the requisite criminal intent; he was convicted of wire fraud, and his post-trial motions were also denied. The district court made several evidentiary rulings, including admitting lay and investigator testimony, and excluded certain defense exhibits and instructions.The United States Court of Appeals for the Seventh Circuit reviewed the convictions and the district court’s rulings. The appellate court held that spoofing constitutes a scheme to defraud under the federal wire and commodities fraud statutes, and that the anti-spoofing statute is not unconstitutionally vague. The court found sufficient evidence supported all convictions, and that the district court did not abuse its discretion in its evidentiary or jury instruction decisions. The Seventh Circuit affirmed the convictions and the district court’s denial of post-trial motions for all three defendants. View "United States v. Smith" on Justia Law

Charles Christopher, while on supervised release for a prior conviction of attempting to entice a minor, engaged in online communications with someone he believed to be a 15-year-old girl. The individual was actually an undercover law enforcement agent. Christopher made explicit sexual advances, arranged to meet the supposed minor, and brought alcohol to the meeting location, where he was arrested. He was charged with attempted enticement of a minor under 18 U.S.C. § 2422(b) and with committing a felony involving a minor while under a sex offender registration requirement, in violation of 18 U.S.C. § 2260A.After pleading guilty to both counts in the United States District Court for the Central District of Illinois, Christopher was sentenced to consecutive terms totaling 264 months’ imprisonment. He later filed a motion under 28 U.S.C. § 2255, arguing, among other things, that his counsel was ineffective for not challenging the § 2260A charge on the basis that it did not involve a real minor, but rather a government agent. The district court denied the motion without an evidentiary hearing, finding that counsel’s performance was not constitutionally deficient and that Christopher was not entitled to relief.The United States Court of Appeals for the Seventh Circuit reviewed the case, focusing on whether counsel was ineffective for failing to argue that § 2260A requires the involvement of an actual minor. The court assumed, without deciding, that counsel’s performance was deficient, but held that Christopher was not prejudiced because § 2260A applies to predicate offenses under § 2422(b) even when the “minor” is an undercover agent. The court affirmed the district court’s denial of Christopher’s § 2255 petition. View "Christopher v USA" on Justia Law

Jorge Diaz was charged with conspiracy to possess and attempted possession of five kilograms or more of cocaine with intent to distribute, based on events in late 2016. The government’s case relied heavily on Maria Bonilla, a cooperating witness who had previously identified Diaz as a drug-trafficking associate and provided audio recordings of their meetings. At trial, however, Bonilla claimed to have no memory of her involvement, her cooperation, or her prior testimony. The government introduced her grand jury testimony as a prior inconsistent statement and played the audio recordings for the jury, with a DEA agent identifying Diaz’s voice on the tapes. Diaz was convicted by a jury on both counts.The United States District Court for the Northern District of Illinois, Eastern Division, overruled Diaz’s objections to the admission of Bonilla’s grand jury testimony and the audio recordings. Diaz argued that the admission of the grand jury testimony violated his rights under the Confrontation Clause, that the recordings lacked proper foundation, and, for the first time on appeal, that the voice identification was unduly suggestive in violation of due process. The district court found that the requirements for admitting prior inconsistent statements and authenticating the recordings were met, and that Diaz had the opportunity to cross-examine Bonilla.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s judgment. The court held that admitting Bonilla’s grand jury testimony did not violate the Confrontation Clause because Diaz had the opportunity for effective cross-examination. The court also held that the foundation for the audio recordings was sufficient under Federal Rule of Evidence 901, and that the voice identification was not unduly suggestive or unreliable under due process standards. The convictions were affirmed. View "United States v. Diaz" on Justia Law

A man living with his partner and her two young children in Indiana was convicted of murdering the children and setting fire to their home. Prior to the incident, he exhibited suspicious behavior, including quitting his job, withdrawing his savings, and making threatening statements. On the night of the crime, he bound one child, gathered belongings, and fled the state. The children’s bodies were found after the house fire, and he was apprehended in Kentucky following a police chase. After being read his rights in the hospital, he gave a brief, largely uninformative statement to police.He was charged with two counts of murder and arson. At trial, the jury found him guilty and recommended the death penalty, which the judge imposed. During the trial, a juror brought a note and cookies from his wife, referencing the victims, but the court found this did not prejudice the jury after questioning them and dismissed the juror. The Indiana Supreme Court affirmed the convictions and sentence. The defendant then sought postconviction relief in Indiana state court, arguing ineffective assistance of counsel, but the trial court denied relief, and the Indiana Supreme Court affirmed, with some justices partially dissenting on the prejudice issue.The defendant filed a federal habeas petition in the United States District Court for the Southern District of Indiana, raising over 30 claims, including ineffective assistance of counsel, juror bias, and evidentiary issues. The district court denied most claims as procedurally defaulted and found the rest without merit, also denying requests for stays and additional funding. On appeal, the United States Court of Appeals for the Seventh Circuit held that most claims were procedurally defaulted, the district court did not abuse its discretion in denying stays or funding, and the Indiana Supreme Court’s decisions were neither unreasonable applications of federal law nor based on unreasonable factual determinations. The Seventh Circuit affirmed the district court’s denial of habeas relief and related motions. View "Weisheit v Neal" on Justia Law