Justia Criminal Law Opinion Summaries

Rodney Higgins pled guilty to possession with intent to distribute methamphetamine and fentanyl. He appealed, challenging the search that led to his arrest, arguing that the search warrant lacked probable cause. From June to August 2021, Higgins was involved in a drug distribution ring. Officers used a confidential source to conduct two controlled buys from Higgins. A Drug Enforcement Administration task force officer prepared an affidavit for a search warrant for Higgins’s apartment, detailing the officer’s training, the confidential source’s knowledge of Higgins’s drug activities, Higgins’s criminal history, and the controlled buys. The affidavit also included a text exchange where Higgins used coded language to indicate he had more drugs.The magistrate judge found probable cause and issued a search warrant. The search of Higgins’s apartment yielded 370 grams of methamphetamine and over 200 grams of fentanyl. Higgins was indicted for conspiracy to distribute and possession with intent to distribute methamphetamine and fentanyl. He moved to suppress the evidence, but the district court denied the motion. Higgins pled guilty but reserved the right to appeal the denial of his suppression motion, raising three issues: the nexus between his drug trafficking and residence, entitlement to a hearing based on alleged misrepresentations or omissions in the affidavit, and the applicability of the good-faith exception to the exclusionary rule.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the affidavit provided sufficient probable cause, establishing a fair probability that contraband would be found in Higgins’s apartment. The court also found that Higgins was not entitled to a Franks hearing, as he failed to make a substantial preliminary showing of a knowing, intentional, or reckless falsehood in the affidavit. The court affirmed the district court’s denial of Higgins’s motion to suppress. View "United States v. Higgins" on Justia Law

The defendants, Richard Maike, Doyce Barnes, and Faraday Hosseinipour, were involved in a company called Infinity 2 Global (I2G), which the FBI determined to be a pyramid scheme. The company collected approximately $34 million from investors, most of whom lost money. After a 25-day trial, a jury convicted the defendants of conspiracy to commit mail fraud and conspiracy to commit securities fraud. The defendants appealed their convictions, presenting numerous arguments for reversal.The United States District Court for the Western District of Kentucky initially handled the case, where the jury found the defendants guilty on both counts. The defendants were sentenced to varying prison terms: Maike received 120 months, Barnes 48 months, and Hosseinipour 30 months. The defendants then appealed to the United States Court of Appeals for the Sixth Circuit, challenging the sufficiency of the evidence and the jury instructions, among other issues.The United States Court of Appeals for the Sixth Circuit reviewed the case and rejected all the defendants' arguments. The court found that there was sufficient evidence to support the jury's verdicts on both counts. The court also determined that the jury instructions were appropriate and did not mislead the jury. The court affirmed the criminal judgments of Maike and Barnes. For Hosseinipour, the court affirmed her criminal judgment but vacated the district court's denial of her Rule 33 motion for a new trial, remanding her case for reconsideration of that motion. View "United States v. Maike" on Justia Law

Edwin Tavarez acted as a courier for his brother's illegal cocaine business, delivering cocaine to a restaurant in Lakewood, Ohio. After his brother's death, Tavarez continued the operation until he was arrested in February 2019. Authorities found him in possession of two kilograms of cocaine. In July 2019, Tavarez was charged with conspiracy to possess with intent to distribute cocaine, possession with intent to distribute, and use of a communications facility in furtherance of a drug trafficking crime. He pled guilty to the first two charges, and the third was dismissed. Tavarez was sentenced to 18 months in prison and four years of supervised release, including one year of home detention.The United States District Court for the Northern District of Ohio granted Tavarez's motions for compassionate release in September 2021, reducing his sentence to time served and extending his home detention. In June 2022, the court terminated the special condition of home detention. In June 2023, Tavarez filed a pro se motion for early termination of supervised release, citing good behavior and mishandling of his earned time credit. The district court denied the motion in a summary order and also denied his subsequent motion for access to the underlying documents.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that 18 U.S.C. § 3742(a) does not impede their review of the district court's denial of Tavarez's early termination motion. The court found that the district court abused its discretion by not demonstrating that it considered the relevant § 3553(a) factors when denying the motion. The Sixth Circuit vacated the district court's order denying early termination of supervised release and remanded for further proceedings. However, the court affirmed the district court's denial of Tavarez's motion for access to documents, as there was no obligation to disclose the supervision report or its content. View "United States v. Tavarez" on Justia Law

Daniel Lockridge, a decorated combat Marine, was involved in methamphetamine trafficking after returning to the U.S. in 2009. He initially used methamphetamine to manage his PTSD and later began selling it, eventually becoming a significant supplier in Chattanooga, Tennessee. Lockridge pleaded guilty to aiding and abetting possession with intent to distribute methamphetamine and was sentenced to 210 months in prison followed by three years of supervised release. His supervised release conditions included mandatory mental-health and substance-abuse treatment, as directed by a probation officer.The United States District Court for the Eastern District of Tennessee imposed these conditions, and Lockridge objected, arguing that the court must preauthorize any inpatient treatment and set a frequency for drug testing, rather than delegating these decisions to a probation officer. The district court overruled his objections, leading to Lockridge's appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court did not relinquish its authority by not specifying the details of the treatment programs at sentencing. Instead, it retained the discretion to make these decisions closer to the time of Lockridge's supervised release, allowing the probation officer to assess his needs and recommend appropriate treatment. The court emphasized that the ultimate authority to modify or enforce the conditions of supervised release remains with the district court, ensuring compliance with Article III of the U.S. Constitution.The Sixth Circuit affirmed the district court's decision, concluding that the delegation of certain responsibilities to the probation officer did not violate constitutional principles, as the district court retained the final decision-making authority. View "United States v. Lockridge" on Justia Law

From 2016 to 2021, Irene Michelle Fike worked at an accounting firm and later as an independent contractor for a client, J.M., and J.M.'s family. Fike used her access to J.M.'s financial accounts to pay her personal credit card bills and make purchases from online retailers. She concealed her fraud by misrepresenting J.M.'s expenditures in financial reports. Fike defrauded J.M. of $363,657.67 between April 2018 and September 2022.Fike pleaded guilty to wire fraud and aggravated identity theft in 2024. The United States District Court for the Eastern District of Kentucky sentenced her to thirty-six months' imprisonment and three years of supervised release. The court also ordered her to pay $405,867.08 in restitution, which included the principal amount stolen and $42,209.41 in prejudgment interest. Fike appealed, arguing that the Mandatory Victims Restitution Act (MVRA) does not authorize prejudgment interest and that the interest calculation was speculative.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the MVRA allows for prejudgment interest to ensure full compensation for the victim's losses. The court found that the district court did not abuse its discretion in awarding prejudgment interest, as it was necessary to make J.M. whole. The court also determined that the district court had a sufficient basis for calculating the interest, relying on J.M.'s declaration of losses, which was submitted under penalty of perjury and provided a reliable basis for the award. The Sixth Circuit affirmed the district court's decision. View "United States v. Fike" on Justia Law

Lavonce Makiri Smith was stopped by police in Grand Rapids, Michigan, and a gun was found in his pocket. Smith moved to suppress the evidence, arguing that the police lacked reasonable suspicion to stop and frisk him. The incident began when Detective Garza was involved in a car accident, and Lt. Jonathan Wu, who was also at the scene, noticed a silver Chrysler that matched a stolen vehicle report. The Chrysler circled the area multiple times, and Wu observed three young Black men, including Smith, walking towards his car from the direction of the Chrysler. Wu suspected they were associated with the stolen car and might be planning a carjacking or robbery.The United States District Court for the Western District of Michigan held an evidentiary hearing where Wu testified. The court found Wu's testimony credible and concluded that the officers had reasonable suspicion to stop and frisk Smith. The court ruled that the stop was lawful due to the reasonable suspicion of criminal activity, and the frisk was justified based on the totality of the circumstances suggesting Smith was armed and dangerous. Smith entered a conditional guilty plea, preserving his right to appeal the suppression decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's decision, holding that the stop was supported by reasonable suspicion. The court found that Wu's observations and the behavior of Smith and his companions, combined with the context of the stolen vehicle and the high-crime area, provided a particularized and objective basis for suspecting criminal activity. The court also rejected Smith's arguments challenging the district court's factual findings and application of the law, concluding that the totality of the circumstances justified the stop and frisk. View "United States v. Smith" on Justia Law

The plaintiffs, a group of consumers, filed a lawsuit against General Motors (GM) and Robert Bosch LLC, alleging that the companies misled consumers about the emissions produced by certain Chevrolet Cruze vehicles. They claimed that the vehicles emitted higher levels of nitrogen oxides (NOx) than advertised and that the emissions control systems were manipulated to pass regulatory tests. The plaintiffs sought damages under various state fraud laws and the Racketeer Influenced and Corrupt Organizations (RICO) Act.The United States District Court for the Eastern District of Michigan initially dismissed some of the plaintiffs' claims, ruling that those based on the Environmental Protection Agency (EPA) standards were preempted by the Clean Air Act. The court allowed other claims to proceed, particularly those alleging that GM's advertising misled consumers about the vehicles' emissions. However, after the Sixth Circuit's decision in a similar case (In re Ford Motor Company F-150 and Ranger Truck Fuel Economy Marketing and Sales Practices Litigation), the district court revisited its decision and dismissed the remaining fraud claims, concluding they were preempted by federal law. The court also granted summary judgment to the defendants on the RICO claims.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court should determine whether the plaintiffs' remaining claims could proceed without relying on a disagreement with the EPA's determinations. The court remanded the case for the district court to decide if the claims were preempted under the analysis described. The court affirmed the dismissal of the RICO claims and the denial of the plaintiffs' post-judgment motion to vacate the judgment in part and approve a preliminary settlement agreement. The case was remanded for further proceedings consistent with the opinion. View "Counts v. General Motors, LLC" on Justia Law

Detectives from the Metropolitan Nashville Police Department observed Edwin Santiago arriving at a car dealership in a vehicle emitting a strong odor of marijuana. Santiago exited the car, and the detectives noticed a pistol on his waistband. Suspecting Santiago of possessing a firearm while under the influence of marijuana, the detectives detained him. During the detention, they discovered Santiago was a felon, leading to his arrest and subsequent indictment for being a felon in possession of a firearm.The United States District Court for the Middle District of Tennessee held a suppression hearing where the detectives and a witness testified about the marijuana odor. The court found the detectives' testimony credible and ruled that the odor provided reasonable suspicion for the stop and probable cause for the arrest. Consequently, the court denied Santiago's motion to suppress the evidence obtained during the arrest. Santiago, representing himself at trial, was convicted by a jury and sentenced to 56 months' imprisonment.The United States Court of Appeals for the Sixth Circuit reviewed Santiago's appeal, which challenged the denial of his motion to suppress and the substantive reasonableness of his sentence. The court affirmed the district court's decision, holding that the smell of marijuana provided reasonable suspicion for the stop and probable cause for the arrest. The court also found Santiago's within-Guidelines sentence to be substantively reasonable, considering his criminal history and the circumstances of the offense. Santiago's additional pro se claims were not considered, as he was represented by counsel on appeal. View "United States v. Santiago" on Justia Law

Tracey Shaw was indicted in January 2023 for knowingly possessing a firearm as a convicted felon, violating 18 U.S.C. § 922(g)(1). Shaw pleaded guilty and, as part of his plea agreement, waived his right to appeal any sentence within the applicable guideline range. At the sentencing hearing, the district court determined Shaw’s guideline range to be 87 to 108 months and sentenced him to 92 months in prison and three years of supervised release. The court did not make a recommendation about substance-abuse treatment during incarceration but left it to the Bureau of Prisons. For supervised release, the court stated that Shaw might be required to participate in substance-abuse treatment if directed by the probation office.The United States District Court for the Western District of Tennessee issued a written judgment stating that Shaw must participate in substance-abuse testing and treatment as directed by the probation officer. Shaw appealed, arguing that the written judgment conflicted with the oral pronouncement, which he interpreted as delegating the decision to the probation office.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Shaw’s appeal was not barred by his plea agreement’s appeal waiver because he was challenging the written judgment, not the sentence itself. The court found that the oral sentence was ambiguous regarding the substance-abuse treatment condition. The written judgment clarified this ambiguity by specifying that Shaw must participate in substance-abuse treatment as directed by the probation officer. The court concluded that this language met constitutional requirements by mandating treatment while allowing the probation officer to handle the details. Therefore, the Sixth Circuit affirmed the district court’s written judgment. View "United States v. Shaw" on Justia Law

Leonel Hinojosa was originally sentenced to 240 months in prison for shooting a man during a robbery. The sentence was vacated by the United States Court of Appeals for the Sixth Circuit because it was unclear whether the district court properly used one of Hinojosa’s prior convictions to calculate his guidelines range. The court could only rely on this prior conviction if it resulted in Hinojosa’s incarceration during any time in the 15 years before he committed his current offenses.On remand, the government presented additional evidence about Hinojosa’s criminal history. The district court found that the prior conviction met the guideline’s standards for inclusion in the criminal history score. This resulted in a guidelines range of 120 to 150 months for his robbery and felon-in-possession offenses, plus a consecutive 120-month minimum sentence for discharging a firearm during a crime of violence. The district court reimposed the same 240-month sentence.The United States Court of Appeals for the Sixth Circuit reviewed the case and held that the “but for” causal connection between the prior conviction and the extra incarceration satisfied the guideline’s “resulted in” language. The court also found that the district court reasonably sentenced Hinojosa to 240 months due to his history of violence. The Sixth Circuit affirmed the sentence, rejecting Hinojosa’s procedural and substantive challenges. The court concluded that the district court properly calculated the guidelines range and reasonably balanced the sentencing factors, including the seriousness of the offense and Hinojosa’s history of violent behavior. View "United States v. Hinojosa" on Justia Law