Justia Criminal Law Opinion Summaries

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

Shawn Baldwin operated a fraudulent investment scheme over several years, soliciting more than $10 million from over a dozen victims. He convinced individuals—including friends, business contacts, and a European businessman named Luca Tenuta—to invest in what he claimed were legitimate ventures, such as a purported social media platform for traders called Currency Clicks. In reality, Baldwin used the funds for personal expenses and to repay earlier investors, characteristic of a Ponzi scheme. He consistently misrepresented his professional credentials, concealed regulatory actions against him, and fabricated business opportunities to further his scheme.The United States District Court for the Northern District of Illinois, Eastern Division, presided over Baldwin’s trial. A jury convicted him on seven counts of wire fraud, and the court sentenced him to 204 months in prison. During the proceedings, the court allowed the government to present Tenuta’s testimony via a recorded deposition from London, after finding Tenuta was unavailable to testify in person. Baldwin objected to the deposition and its admission, arguing violations of procedural rules and his constitutional rights. He also challenged the joinder of charges, the admission of evidence regarding uncharged victims, and several sentencing enhancements.The United States Court of Appeals for the Seventh Circuit reviewed Baldwin’s conviction and sentence. The court held that the district court did not abuse its discretion in permitting Tenuta’s deposition under Federal Rule of Criminal Procedure 15, nor did it violate Baldwin’s Confrontation Clause rights, as Baldwin had waived his right to be present. The appellate court also found no error in the joinder of offenses, the admission of evidence about uncharged victims, or the application of sentencing enhancements. Accordingly, the Seventh Circuit affirmed Baldwin’s conviction and sentence. View "USA v Baldwin" on Justia Law

Deon Pugh was charged with multiple offenses, including conspiracy to possess with intent to distribute and distribute controlled substances, distribution of controlled substances, and possession of a firearm as a felon. The government alleged that Pugh, along with several co-defendants, participated in a drug distribution conspiracy centered at the home of Jonathan Mason, who was recognized as a leader of the operation. Evidence at trial showed that Pugh regularly visited Mason’s home, brought drugs for preparation and sale, and directed other participants in the conspiracy.After Pugh waived his right to a jury trial, the United States District Court for the Northern District of Illinois, Eastern Division, conducted a bench trial and found him guilty on all counts. The court determined that Pugh conspired with at least six others and that it was reasonably foreseeable to him that the conspiracy involved more than 1,000 grams of heroin. The court denied Pugh’s motions for acquittal and a new trial. At sentencing, the court calculated a base offense level based on a drug quantity of approximately 2,236 grams of heroin, applied a four-level leadership enhancement, and designated Pugh as a career offender, resulting in an advisory guidelines range of 360 months to life. The court ultimately sentenced Pugh to 216 months’ imprisonment and five years of supervised release.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed Pugh’s challenges to his career offender designation, the drug quantity attributed to him, and the leadership enhancement. The court held that the career offender designation was proper under both the current and prior versions of the Sentencing Guidelines, found that Pugh had waived any challenge to the drug quantity calculation, and concluded that the leadership enhancement was supported by the evidence. The Seventh Circuit affirmed the district court’s judgment. View "USA v Pugh" on Justia Law

Jose Farias orchestrated a large-scale drug trafficking operation that brought significant quantities of heroin and cocaine into the Chicago area during 2015 and 2016. He worked with a network of co-conspirators, using tractor-trailers with hidden compartments to transport drugs from Texas to Illinois. Law enforcement, tipped off early by a Texas truck dispatcher, conducted surveillance and seized substantial amounts of drugs at multiple locations. Several co-conspirators were arrested and cooperated with authorities, providing testimony and participating in recorded calls with Farias that further implicated him.The United States District Court for the Northern District of Illinois, Eastern Division, presided over Farias’s trial. The government presented testimony from cooperating witnesses and law enforcement agents, as well as recordings and translated transcripts of Farias’s conversations. The jury convicted Farias of conspiracy to distribute heroin and cocaine and possession of cocaine with intent to distribute. The district court denied Farias’s post-trial motions challenging the sufficiency of the evidence, the admission of voice identification testimony, and the jury instructions regarding translated transcripts. At sentencing, the court attributed 130 kilograms of heroin and 45 kilograms of cocaine to Farias, applied a leadership enhancement, and sentenced him to 300 months in prison.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed Farias’s challenges to the admission of voice identification testimony, the jury instructions on translated transcripts, the sufficiency of the evidence, and the sentencing calculations. The court held that the admission of the agent’s voice identification did not violate Farias’s constitutional rights, that Farias had waived any objection to the jury instructions on translated transcripts, that sufficient evidence supported the convictions, and that the district court did not clearly err in its drug quantity findings or in applying the leadership enhancement. The Seventh Circuit affirmed the judgment of the district court. View "USA v Farias" on Justia Law

Police began investigating a man after a confidential informant, who had been caught with illegal drugs and firearms, provided detailed information about the man’s drug trafficking activities. The informant described prior drug purchases from the man, his connections to a cartel, and provided specific details about the man’s address, vehicle, and communications. Police corroborated much of this information through surveillance and controlled drug buys, and obtained state and federal search warrants. When executing the warrants, officers found large quantities of methamphetamine, fentanyl, firearms, and evidence of drug sales. The man was charged with multiple drug and firearm offenses.In the United States District Court for the Northern District of Indiana, the defendant moved for a Franks hearing, arguing that the affidavits supporting the initial search warrants omitted important information about the informant’s credibility and cooperation agreement. He also sought to suppress evidence obtained from the warrants and challenged the scope of the firearm charge and several sentencing enhancements. The district court denied the motions, finding the omissions immaterial to probable cause and insufficient to warrant a Franks hearing, and concluded that the evidence and enhancements were properly applied. The jury convicted the defendant on all counts, and the court imposed a life sentence.The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that the district court did not err in denying a Franks hearing, as the omitted information about the informant was not material given the corroboration and detail provided. The appellate court also found no constructive amendment of the indictment regarding the firearm charge and upheld the application of the sentencing enhancements. The Seventh Circuit affirmed the district court’s judgment in all respects. View "USA v Hecke" on Justia Law

Israel Isbell pleaded guilty in 2010 to receipt of child pornography and was sentenced to 180 months in prison followed by a lifetime of supervised release. As his prison term ended, Isbell violated several conditions of his supervised release, including unauthorized internet use and unsuccessful participation in sex offender and substance abuse treatment programs. These violations led to the revocation of his supervised release, an additional prison term, and a new term of supervised release with specific conditions.After a prior appeal resulted in a remand for resentencing on an unrelated issue, the United States District Court for the Central District of Illinois resentenced Isbell to 16 months’ imprisonment and 8 years of supervised release. Isbell objected to three conditions: a requirement to participate in a computer and internet monitoring program, a provision regarding medical marijuana use during treatment, and a mandate for substance abuse treatment. The district court overruled his objections and imposed the conditions as proposed.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed Isbell’s challenges de novo. The court held that the computer monitoring condition was neither unconstitutionally vague nor overbroad, as its language and purpose provided sufficient notice and guidance. The court also found that the medical marijuana provision did not improperly delegate judicial authority to treatment providers, as it required Isbell to follow generally applicable program rules rather than allowing providers to determine the existence of the condition. Finally, the court determined that the written judgment requiring substance abuse treatment was consistent with the oral pronouncement and did not violate the non-delegation rule. The Seventh Circuit affirmed the judgment of the district court. View "USA v Isbell" on Justia Law