Justia Criminal Law Opinion Summaries

Kenneth Evans was observed by police engaging in a hand-to-hand transaction in a vehicle. Upon approaching the vehicle, officers detected the smell of marijuana, searched the car, and found a loaded pistol. Evans admitted to handling the firearm and being on parole. He was subsequently indicted by a federal grand jury for being a felon in possession of a firearm and ammunition, to which he pleaded guilty. Evans had prior felony convictions, including one for aggravated robbery under Ohio law.The United States District Court for the Northern District of Ohio determined that Evans’s prior aggravated robbery conviction qualified as a “crime of violence” under the United States Sentencing Guidelines. This finding increased his advisory sentencing range from 24–30 months to 46–57 months, and the court sentenced him to 57 months’ imprisonment. Evans appealed, arguing that his aggravated robbery conviction should not be considered a crime of violence for sentencing purposes.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s legal determination de novo. The appellate court applied the categorical and modified categorical approaches to compare the elements of Ohio’s aggravated robbery statute, as applied to Evans’s conviction, with the definition of “extortion” in the Sentencing Guidelines. The court concluded that aggravated robbery under Ohio Revised Code § 2911.01(A)(1), when predicated on theft, categorically matches the Guidelines’ definition of extortion and therefore constitutes a crime of violence. The court rejected Evans’s arguments to the contrary and affirmed the district court’s judgment, upholding the increased sentence. The court also granted the government’s motion to take judicial notice. View "United States v. Evans" on Justia Law

Four defendants were members of a Detroit-based gang involved in drug distribution and violent crimes, including homicides, during the 1980s and 1990s. They were indicted in 1995 for conspiracy to distribute cocaine and crack cocaine, intentional killings in furtherance of a continuing criminal enterprise, and firearms offenses. Juries convicted all four on all counts in two separate trials. The district court sentenced each to concurrent life terms for the drug and homicide convictions, plus consecutive terms for the firearms offenses, following the then-mandatory Sentencing Guidelines. Their convictions and sentences were affirmed on appeal.Years later, after Congress enacted the Fair Sentencing Act and the First Step Act, which allowed for reduced sentences for certain crack cocaine offenses, the defendants moved for sentence reductions under the First Step Act. The United States District Court for the Eastern District of Michigan initially denied some motions, reasoning that the homicide convictions were not “covered offenses” under the Act. On appeal, the United States Court of Appeals for the Sixth Circuit vacated the denial as to the drug conspiracy count for one defendant, holding he was eligible for a reduction on that count. On remand, the district court reduced the sentences for both the drug and homicide convictions for all four defendants, concluding it had discretion to do so under the First Step Act and the sentencing-package doctrine.The United States Court of Appeals for the Sixth Circuit held that the First Step Act authorizes a district court to reduce a sentence for a non-covered offense only if it was part of a sentencing package with a covered offense. The court vacated the reduced sentences and remanded for the district court to determine whether the homicide sentences were truly part of such a sentencing package with the covered drug offense, and to proceed accordingly. View "United States v. Dale" on Justia Law

The petitioner, who was previously sentenced to death in Ohio, obtained a conditional writ of habeas corpus from the United States Court of Appeals for the Sixth Circuit, which required the State of Ohio to conduct a new penalty-phase proceeding within 180 days or have the death sentence vacated. The state failed to meet this deadline, even after receiving several extensions due to complications such as judicial recusals, defense preparations, and questions regarding the petitioner’s competency. As a result, the United States District Court for the Northern District of Ohio converted the conditional writ into an unconditional writ, ordering the state to vacate the death sentence and release the petitioner within five business days. The state did not fully comply until nearly three months later, when the state court formally vacated the sentence.After the state’s delayed compliance, the petitioner moved for relief from the unconditional writ, seeking as a sanction an order barring the state from reprosecuting the death penalty. The district court denied this request, finding that although there were significant delays, many were attributable to the petitioner, and the state’s conduct did not rise to the level of bad faith or substantial inequitable conduct that would justify barring reprosecution.On appeal, the United States Court of Appeals for the Sixth Circuit held that it had jurisdiction to review both the unconditional writ and the denial of the Rule 60(b) motion for sanctions, even after the state’s eventual compliance. The court affirmed the district court’s judgment, holding that the delays and procedural complications did not constitute extraordinary circumstances or substantial inequitable conduct warranting a bar on reprosecution of the death penalty. The court also found no abuse of discretion in the district court’s denial of further relief under Rule 60(b). View "Allah-U-Akbar v. Bradshaw" on Justia Law

The defendant pled guilty in 2016 to conspiracy to possess with intent to distribute controlled substances, receiving a sentence of 160 months based on his criminal history and offense level. In 2023, a retroactive amendment to the Sentencing Guidelines reduced his criminal history category, lowering his guideline range. The defendant, through appointed counsel, and the government stipulated to a new recommended sentence of 144 months, which the district court imposed.After resentencing, the defendant filed a pro se motion for reconsideration, asserting that his counsel had agreed to the stipulation without his knowledge or consent and that he wished to argue for a lower sentence. The United States District Court for the Eastern District of Michigan denied the motion, reasoning that because the defendant was represented by counsel, his pro se filing constituted improper hybrid representation. The court instructed that any motion for reconsideration should be filed through counsel.On appeal, the United States Court of Appeals for the Sixth Circuit held that when a defendant raises a specific and serious allegation that counsel acted without his knowledge or against his wishes on a fundamental matter, the district court is obligated to inquire into the nature of the attorney-client relationship, regardless of whether the defendant used “magic words” or filed through counsel. The Sixth Circuit found that the district court erred by denying the motion solely on the basis of hybrid representation without conducting such an inquiry. The court vacated the district court’s judgment on the motion for reconsideration and remanded for further proceedings, instructing the district court to determine whether the defendant wishes to dismiss his counsel and whether he is entitled to do so, and then to address the merits of his motion. View "United States v. Riley" on Justia Law

Federal authorities investigated a man in Michigan after receiving a tip that he was distributing methamphetamine sourced from Las Vegas. Over several months, law enforcement gathered evidence, including intercepting a package containing nearly seven pounds of methamphetamine sent to his uncle’s home. Upon executing search warrants, officers seized drugs, cash, and firearms from both the uncle’s residence and the defendant’s home. The defendant admitted his involvement during a post-arrest interview. After serving a short state sentence for probation violations, he moved to Atlanta, where he was employed and had no further criminal incidents for about a year. In 2023, a federal grand jury indicted him for drug and firearm offenses. He was arrested in Michigan several months later, and while out on bond, he violated conditions and was re-arrested. While in jail, he attempted to smuggle synthetic drugs and was caught with contraband.The United States District Court for the Western District of Michigan denied the defendant a reduction for acceptance of responsibility, citing his continued drug-related conduct and false denials during the presentence investigation. The court also denied his request for a downward variance based on his period of lawful behavior in Atlanta, but did grant a downward variance due to his lack of youthful guidance, sentencing him to 300 months, below the guideline range. Defense counsel did not object to the court’s handling of non-frivolous arguments at sentencing.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of the acceptance-of-responsibility reduction for clear error and affirmed, holding that post-offense drug activity and false denials were relevant to assessing acceptance of responsibility under U.S.S.G. § 3E1.1(a). The appellate court also declined to review the procedural reasonableness of the sentence, finding that the defendant had either waived or invited any error by affirming that all arguments had been addressed. The judgment of the district court was affirmed. View "United States v. Jett" on Justia Law

Daniel Jackson was stopped by sheriff’s deputies in Kentucky after they observed his truck with an obscured license plate and learned he was driving without a valid license or registration. After arresting Jackson, deputies searched his truck and found methamphetamine, marijuana, syringes, and digital scales. A subsequent search of the police cruiser’s back seat, where Jackson had been placed, revealed a bag containing fentanyl. Jackson was charged with possession of fentanyl and methamphetamine with intent to distribute.The United States District Court for the Eastern District of Kentucky presided over Jackson’s trial. At trial, Jackson testified that he had been framed by a deputy who allegedly planted the drugs in both his truck and the police cruiser. The jury rejected Jackson’s account and convicted him. At sentencing, the district court found that Jackson’s testimony constituted perjury and applied a two-level obstruction-of-justice enhancement under the Sentencing Guidelines. The court also imposed a five-year term of supervised release, including a condition permitting searches of Jackson’s electronic devices by the probation office. Jackson did not object to this condition at sentencing.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed Jackson’s challenges to both the obstruction-of-justice enhancement and the supervised-release search condition. The court held that the district court’s findings of perjury—falsity, willfulness, and materiality—were not clearly erroneous and that the enhancement was mandatory under the Guidelines. The appellate court also found no plain error in the imposition or explanation of the electronic-device search condition, given the district court’s stated concerns about officer safety and recidivism. Accordingly, the Sixth Circuit affirmed the judgment of the district court. View "United States v. Jackson" on Justia Law

After being released from federal prison, an individual began a term of supervised release that required him to comply with several conditions, including avoiding new criminal conduct, truthfully answering his probation officer’s questions, and participating in mental health and substance abuse treatment programs. Within two months, the probation office alleged that he violated four conditions: failing to enroll in required treatment, lying to his probation officer about receiving services, missing a scheduled drug test, and committing a new state misdemeanor offense involving assault and stalking.The United States District Court for the Eastern District of Tennessee held a revocation hearing. The individual admitted to three of the violations—lying to his probation officer, failing to enroll in treatment, and missing the drug test—and contested only the allegation that he committed a new state crime. After hearing testimony and reviewing evidence, the district court found by a preponderance of the evidence that he had committed the misdemeanor, in addition to the three admitted violations. The court revoked his supervised release and imposed a 14-month prison sentence, at the top of the applicable guidelines range. The individual appealed, challenging only the finding that he committed the new state offense.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s factual findings for clear error. The appellate court concluded that even if the district court erred in finding the new state offense, any such error was harmless because the three uncontested violations independently justified revocation and the sentence imposed. The court held that a single violation is sufficient to support revocation, and the guidelines range and sentence would have been the same regardless of the contested finding. Accordingly, the Sixth Circuit affirmed the district court’s judgment. View "United States v. Kidd" on Justia Law

In this case, the defendant was found in possession of a firearm after having previously been convicted of multiple felonies, including several burglaries. When law enforcement approached his girlfriend’s home, he cooperated and led them to a pistol hidden in the woods, which bore his fingerprints. He was indicted on one count of being a felon in possession of a firearm. The presentence report listed twenty-two prior felony convictions, eleven of which were for burglary, with the offenses occurring over several years and involving different victims.The United States District Court for the Eastern District of Tennessee accepted the defendant’s guilty plea. At sentencing, the court determined, based on the presentence report, that the defendant qualified as an Armed Career Criminal under the Armed Career Criminal Act (ACCA), which mandates a minimum sentence for those with three prior violent felony convictions committed on different occasions. The court imposed a 180-month sentence. The defendant did not object to the factual accuracy of the presentence report but later challenged the application of the ACCA enhancement, arguing that the determination of whether his prior offenses were committed on different occasions should have been made by a jury, as clarified by the Supreme Court in Erlinger v. United States.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the failure to submit the “different occasions” question to a jury was not structural error and that, under harmless error review, no reasonable jury could have found that the defendant’s predicate burglaries occurred on the same occasion, given the significant gaps in time and different victims. The court also rejected the defendant’s double jeopardy argument, finding no plain error. The Sixth Circuit affirmed the enhanced sentence under the ACCA. View "United States v. Ballinger" on Justia Law

Timothy Baker, a registered sex offender, was in a relationship with Shaelyn Fann and expressed sexual interest in Fann’s eleven-year-old daughter, S.H. Over several months, Baker and Fann groomed S.H. for sexual activity, with Fann sending Baker sexually explicit photographs of S.H. at his request. Baker provided detailed instructions to Fann on how to obtain these images and discussed plans to sexually abuse S.H. Law enforcement discovered Baker’s activities while investigating him for another alleged sexual assault involving a minor.A grand jury in the United States District Court for the Western District of Michigan indicted Baker on three counts: conspiracy to sexually exploit a minor, coercion and enticement of a minor, and committing these offenses while required to register as a sex offender. The indictment also alleged that Baker had two prior convictions for sexually exploiting minors under Michigan law. Before trial, Baker moved to strike the sentencing enhancement based on his prior convictions, arguing they were juvenile adjudications, not convictions. He also sought to sever the count related to his sex offender status and to exclude testimony from two other minors, L.H. and I.B., who alleged prior sexual assaults by Baker. The district court denied all these motions, admitted the testimony under Federal Rule of Evidence 413, and the jury convicted Baker on all counts. The court imposed a total sentence of 600 months’ imprisonment.On appeal, the United States Court of Appeals for the Sixth Circuit held that Baker’s prior Michigan offenses constituted convictions under federal law, supporting the enhanced sentence. The court also found that cumulative punishments under 18 U.S.C. §§ 2251(e) and 2260A did not violate the Double Jeopardy Clause, as Congress clearly intended such cumulative sentences. Finally, the court concluded that the district court did not abuse its discretion in admitting the testimony of L.H. and I.B. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Baker" on Justia Law

The case concerns an individual who was sentenced in 2006 to a term of imprisonment and supervised release for drug trafficking offenses. After his initial release, his supervised release was revoked due to a new drug offense, resulting in additional imprisonment and a new term of supervised release. While incarcerated, he sought to earn and apply time credits under the First Step Act, arguing that the Bureau of Prisons (BOP) unlawfully denied him these credits despite his eligibility.The United States District Court for the Northern District of Ohio reviewed his habeas corpus petition under 28 U.S.C. § 2241. The warden moved to dismiss, contending that the petitioner had not exhausted administrative remedies and was ineligible for time credits due to a disqualifying offense. The district court agreed, finding both a failure to exhaust and statutory ineligibility, and denied the petition. The petitioner appealed to the United States Court of Appeals for the Sixth Circuit. While the appeal was pending, he was released from BOP custody and began serving his supervised release.The United States Court of Appeals for the Sixth Circuit addressed whether First Step Act time credits could be used to reduce a term of supervised release, as opposed to only reducing a term of imprisonment. The court held that such credits may only be applied to reduce a prison term, not a supervised-release term. Because the petitioner was no longer incarcerated and the credits could not affect his supervised release, the court determined that the case was moot and dismissed the appeal. The court did not address other arguments regarding exhaustion or the merits of the underlying claim. View "Hargrove v. Healy" on Justia Law