Justia Criminal Law Opinion Summaries

Benjamin Carpenter was accused of providing translation and related services to ISIS, a designated foreign terrorist organization. He founded Ahlud-Tawhid Publications (ATP), which translated and published ISIS propaganda in multiple languages. Carpenter personally translated ISIS materials into English, wrote original content, and managed an ATP group on Telegram, where he coordinated translation projects. An undercover FBI agent, posing as an ISIS affiliate, joined the group and interacted with Carpenter, who recommended and facilitated the translation of ISIS propaganda videos at the agent’s request. Carpenter was arrested before completing a second translation assignment.The United States District Court for the Eastern District of Tennessee charged Carpenter with attempting to provide material support to a foreign terrorist organization under 18 U.S.C. § 2339B. After a five-day trial, a jury convicted him, and the district court sentenced him to 240 months in prison. Carpenter appealed, challenging the statute’s application to his conduct, evidentiary rulings, a protective order allowing an FBI agent to use a pseudonym, jury instructions, and the reasonableness of his sentence.The United States Court of Appeals for the Sixth Circuit reviewed Carpenter’s arguments and affirmed the district court’s judgment. The court held that translation services constitute “material support” as a “service” under the statute, consistent with Supreme Court precedent. The court found no abuse of discretion in the district court’s evidentiary rulings, including the admission of evidence related to Carpenter’s involvement with ATP and ISIS, the use of a pseudonym for the FBI agent, and the denial of Carpenter’s proposed jury instructions. The court also upheld the application of the terrorism sentencing enhancement and found the sentence both procedurally and substantively reasonable. The conviction and sentence were affirmed. View "United States v. Carpenter" on Justia Law

Over several months, the defendant participated in four carjackings targeting Lyft drivers in Detroit. In each incident, two assailants, including the defendant, brandished firearms, demanded money and property, and forced the victims to remove their clothing before fleeing in the stolen vehicles. One victim was pistol-whipped and sustained bodily injury. Extensive evidence, including phone records, cell site data, and identification by a victim, linked the defendant to each carjacking. A search of his residence uncovered multiple firearms and stolen vehicles. The defendant pleaded guilty to four counts of carjacking, aiding and abetting, admitting involvement but attempting to minimize his role in some attacks.The United States District Court for the Eastern District of Michigan prepared a presentence report recommending several offense level enhancements under the Sentencing Guidelines, including increases for brandishing and using firearms and for causing bodily injury. The defendant objected, arguing for a mitigating role reduction based on his claimed minor participation. The district court rejected his arguments, found by a preponderance of the evidence that he was a principal in each carjacking, and applied all recommended enhancements. The court imposed an above-Guidelines sentence of 180 months, citing the severity and humiliating nature of the crimes, the defendant’s prior criminal history, and his lack of respect for the law.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the procedural and substantive reasonableness of the sentence. The court held that the district court did not clearly err in its factual findings or in applying the offense level enhancements, nor did it plainly err in denying a mitigating role reduction or in considering the defendant’s age and rehabilitation potential. The appellate court found the upward variance substantively reasonable, given the egregious nature of the offenses and the impact on the victims. The sentence was affirmed. View "United States v. Haile" on Justia Law

The defendant was apprehended after two separate incidents in which he was found in possession of firearms and drugs. In the first incident, after a car accident, he attempted to dissuade the other driver from calling the police due to the presence of contraband in his vehicle, then fled but was quickly caught. In the second incident, a traffic stop led to the discovery of additional firearms, ammunition, and drugs. He was charged with two counts of possessing a firearm as a convicted felon and pleaded guilty.The United States District Court for the Eastern District of Kentucky calculated his base offense level under the Sentencing Guidelines as twenty-two, based in part on a prior Kentucky conviction for second-degree manslaughter, which the court classified as a “crime of violence.” The defendant did not object to this calculation at sentencing and was sentenced to 145 months in prison.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether Kentucky’s second-degree manslaughter qualifies as a “crime of violence” under the Sentencing Guidelines, applying plain error review because the issue was not raised below. The court held that the Kentucky statute’s “wantonness” mens rea is functionally equivalent to “recklessness” as defined in Borden v. United States, 593 U.S. 420 (2021), and does not meet the standard for a “crime of violence,” which requires purposeful or knowing conduct. The court found that the district court’s reliance on this conviction to enhance the sentence was plain error, affected the defendant’s substantial rights, and undermined the fairness of the proceedings. Accordingly, the Sixth Circuit vacated the sentence and remanded for resentencing. View "United States v. Tooley" on Justia Law

Andrew Maurice Randolph was convicted in Michigan state court of second-degree murder and weapons offenses after a shooting at his former girlfriend’s home resulted in the death of her mother. The prosecution’s case relied heavily on ammunition found in Randolph’s bags at his father’s house and a firearm discovered at his brother’s residence, which was identified as the murder weapon. Randolph’s trial counsel did not move to suppress this evidence, and Randolph argued that this failure, among other alleged deficiencies, constituted ineffective assistance of counsel.Following his conviction, Randolph appealed to the Michigan Court of Appeals, which rejected his ineffective assistance claim without explanation. The Supreme Court of Michigan reversed in part for unrelated reasons and remanded. On remand, the Michigan Court of Appeals affirmed the conviction, finding Randolph did not demonstrate a reasonable expectation of privacy in the searched belongings. The Supreme Court of Michigan denied leave to appeal. Randolph then sought federal habeas relief in the United States District Court for the Eastern District of Michigan, raising four ineffective assistance claims. The district court denied the petition, concluding that the suppression motion would have failed and that counsel’s other actions were either strategically reasonable or not prejudicial. The district court also denied a certificate of appealability (COA).On appeal, the United States Court of Appeals for the Sixth Circuit reviewed only the claim that trial counsel was ineffective for failing to move to suppress evidence obtained from the search of Randolph’s belongings, as this was the sole issue for which a COA was granted. The Sixth Circuit held that the state court’s factual findings and legal conclusions were reasonable under the Antiterrorism and Effective Death Penalty Act (AEDPA) and affirmed the district court’s denial of habeas relief. The court also denied Randolph’s request to expand the COA, holding that a merits panel lacks authority to do so. View "Randolph v. Macauley" on Justia Law

Two individuals were involved in a drug-trafficking operation distributing fentanyl and methamphetamine in the Lexington, Kentucky area. One supplied the drugs, which were pressed to resemble oxycodone pills, to the other, who then sold them to others. Both were apprehended after law enforcement used confidential informants and controlled buys. The supplier pleaded guilty to drug and firearm offenses, while the other pleaded guilty to conspiracy to distribute drugs.The United States District Court for the Eastern District of Kentucky sentenced the supplier to 228 months in prison and the other individual to 74 months, also imposing supervised release conditions. Both defendants challenged the procedural reasonableness of their sentences, specifically contesting the application of a sentencing enhancement under U.S.S.G. § 2D1.1(b)(13) for knowingly misrepresenting or marketing fentanyl as another substance. The second defendant also argued ineffective assistance of counsel, improper denial of a downward departure for reduced mental capacity, and an improper special condition of supervised release.The United States Court of Appeals for the Sixth Circuit reviewed the case. It held that the district court properly applied the sentencing enhancement: the supplier knowingly misrepresented fentanyl as oxycodone, and the other knowingly marketed fentanyl as another substance, given the pills’ appearance and his knowledge of their contents. The court found no error in the district court’s reliance on a cooperating witness’s statement or in its findings regarding the defendants’ knowledge. The appellate court declined to address the ineffective assistance claim on direct appeal due to an insufficient record, found the denial of a downward departure unreviewable, and upheld the special condition of supervised release. The Sixth Circuit affirmed the district court’s judgments. View "United States v. Matthews" on Justia Law

Officers investigating a drug trafficking ring observed Devin Long engaging in several suspected drug transactions, including controlled buys involving other individuals. Surveillance revealed Long’s repeated visits to known stash houses and his own registered residence, where officers witnessed activity consistent with drug dealing. Based on these observations and information from a confidential source, officers obtained a warrant to search Long’s home. The search uncovered illegal drugs, firearms, and related paraphernalia, leading to Long’s indictment on federal drug and firearm charges.The United States District Court for the Northern District of Ohio reviewed Long’s motion to suppress the evidence seized from his home, which argued that the affidavit supporting the search warrant failed to establish a sufficient nexus between his alleged criminal activity and the residence. The district court denied the motion, finding that the affidavit provided probable cause for the search. Long subsequently pleaded guilty to four charges but preserved his right to appeal the suppression ruling.On appeal, the United States Court of Appeals for the Sixth Circuit considered whether the search warrant for Long’s home was supported by probable cause. Applying a deferential standard to the issuing magistrate judge’s determination, the Sixth Circuit held that the affidavit established both that Long’s home was his residence and that he was engaged in ongoing drug trafficking. The court further found that even a single drug transaction observed outside Long’s home provided an independent basis for probable cause. The court affirmed the district court’s denial of Long’s motion to suppress, concluding that the warrant was properly issued under the Fourth Amendment. View "United States v. Long" on Justia Law

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