Justia Criminal Law Opinion Summaries

Cledale Caldwell pled guilty to failing to register as a sex offender, a federal offense that spanned 13 months. During this period, he was convicted and sentenced for two separate offenses in Oklahoma. At sentencing for the failure-to-register offense, the district court assessed criminal history points for the Oklahoma offenses. Caldwell objected, arguing that these offenses should be considered relevant conduct, which would result in a lower sentencing range under the United States Sentencing Guidelines. The district court disagreed, leading to this appeal.The United States District Court for the District of Kansas sentenced Caldwell under the 2023 Guidelines Manual. The court included Caldwell’s Oklahoma offenses in his criminal history, resulting in a total of 11 criminal history points and a Guidelines range of 21 to 27 months. Caldwell argued that the Oklahoma offenses should be treated as relevant conduct because they occurred during the commission of the SORNA offense, which would have reduced his criminal history points and the corresponding sentencing range.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that relevant conduct under U.S.S.G. § 1B1.3(a)(1)(A) includes acts or omissions that occurred during the commission of the offense of conviction but must also relate to that offense. The court found that Caldwell’s Oklahoma offenses did not relate to his failure-to-register offense and were therefore correctly included in his criminal history. The Tenth Circuit affirmed the district court’s decision, maintaining Caldwell’s sentence of 21 months in prison. View "United States v. Caldwell" on Justia Law

In 2017, Raymond Lee Goldesberry's daughter, K.G., who was almost 12 years old, entered her parents' bedroom after a nightmare and climbed into bed next to her father, who was asleep. During the night, K.G. awoke to find her father touching her inappropriately. K.G. believed her father was asleep and mistook her for her mother. About four years later, the government prosecuted Goldesberry for aggravated sexual abuse of a minor under 12 in Indian Country.In October 2021, Goldesberry was charged in the United States District Court for the Northern District of Oklahoma. He pleaded not guilty, and the case proceeded to a jury trial in March 2022. The jury found Goldesberry guilty, and the district court denied his motion for acquittal. Goldesberry was sentenced to 30 years' imprisonment, the mandatory minimum under 18 U.S.C. § 2241(c).The United States Court of Appeals for the Tenth Circuit reviewed the case. Goldesberry appealed on the grounds of insufficient evidence and prosecutorial misconduct. The Tenth Circuit focused on the sufficiency of the evidence, particularly the knowledge element of the charged offense. The court concluded that the evidence presented was insufficient to establish beyond a reasonable doubt that Goldesberry knowingly engaged in the sexual act, as the evidence equally supported the theory that the touching occurred by mistake.The Tenth Circuit vacated Goldesberry's conviction and remanded the case for further proceedings, holding that the government failed to prove the knowledge element of the offense beyond a reasonable doubt. View "United States v. Goldesberry" on Justia Law

Defendant Stetson Bruce was convicted of two counts of aggravated sexual abuse in Indian country for sexually abusing his five-year-old son, R.W. The trial included testimony from R.W. and his half-sister, E.R., who witnessed one of the acts. After their testimonies, the United States District Court for the Eastern District of Oklahoma admitted recordings of their forensic interviews, which were consistent with their trial testimonies. These recordings were not played in the courtroom but were available to the jury during deliberations.The district court denied Defendant's pretrial motion to exclude the recordings as hearsay, ruling they would be admitted upon proper foundation testimony. During the trial, the defense suggested that R.W. had been coached by the prosecutor and that E.R.'s memory was faulty. The district court admitted the recordings under Rule 801(d)(1)(B) of the Federal Rules of Evidence, allowing prior consistent statements to rebut charges of recent fabrication or to rehabilitate credibility when attacked on another ground. The jury found Defendant guilty on both counts, and he was sentenced to concurrent life terms.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that the district court did not abuse its discretion in admitting the recordings as prior consistent statements under Rule 801(d)(1)(B)(i) and (ii). The court found that the defense's suggestions of coaching and faulty memory opened the door for the government to use the prior consistent statements to rebut these charges. The court also rejected Defendant's arguments that the district court ruled prematurely on the admission of the recordings and that it committed structural error by sending the recordings to the jury room rather than playing them in court. The Tenth Circuit affirmed the district court's decision. View "U.S. v. Bruce" on Justia Law

The case involves Calvin Woodmore, who was convicted for his role in a methamphetamine-trafficking ring in eastern Oklahoma. Woodmore was found guilty of conspiracy to commit drug trafficking, conspiracy to commit money laundering, and money laundering. He appealed his convictions and sentence, arguing that the district court made several errors during his trial and sentencing.In the lower court, the United States District Court for the Eastern District of Oklahoma handled the case. Woodmore was convicted by a jury on all counts. He then moved for a judgment of acquittal, arguing that the government had not provided sufficient evidence to support the money laundering charges. The district court denied his motion and sentenced him to 324 months in prison for the drug trafficking conspiracy and 240 months for the money laundering charges, to be served concurrently.The United States Court of Appeals for the Tenth Circuit reviewed the case. Woodmore raised several issues on appeal, including the district court's failure to properly instruct the jury on the definition of "methamphetamine (actual)" and the right of attorneys to interview witnesses. He also challenged the sufficiency of the evidence supporting his money laundering convictions and the district court's calculation of his sentence.The Tenth Circuit affirmed the district court's decisions. The appellate court found that the jury instructions were adequate and that the evidence presented at trial was sufficient to support Woodmore's convictions. The court also upheld the district court's calculation of the drug quantity attributable to Woodmore and the application of sentencing enhancements. Consequently, the Tenth Circuit affirmed Woodmore's convictions and sentence. View "United States v. Woodmore" on Justia Law

Law enforcement identified the defendant as a supplier of methamphetamine and fentanyl in a drug-trafficking conspiracy in Kansas City. After seizing three pounds of methamphetamine from a car en route to the defendant, DEA agents enlisted the driver to continue the delivery to the defendant. The defendant was arrested upon arrival to collect the drugs. During custody, the defendant made incriminating statements and consented to a search of his cell phone. He later moved to suppress these statements and the phone's contents.The United States District Court for the District of Kansas denied the suppression motions. The court ruled that the defendant's pre-Miranda statement about his cell phone number was admissible under the inevitable-discovery doctrine. It also found that the defendant voluntarily and knowingly waived his Miranda rights and that his post-Miranda statements were not coerced. The court concluded that the defendant's consent to the cell phone search was voluntary.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's decision, agreeing that the inevitable-discovery doctrine applied to the pre-Miranda statement. It found that the defendant voluntarily and knowingly waived his Miranda rights, and his statements were not coerced. The court also held that the defendant's consent to the cell phone search was voluntary. The Tenth Circuit concluded that the totality of the circumstances supported the district court's findings and affirmed the denial of suppression. View "United States v. Perez" on Justia Law

Wendy Johnson pleaded guilty to involuntary manslaughter after causing the death of Stephanie Heneha-Roubidoux in a drunk-driving accident. The government sought criminal restitution for Stephanie’s lost income, presenting testimony from an expert and Stephanie’s wife, Kristi Heneha-Roubidoux. Johnson argued for zero lost-income restitution, citing the government’s expert who stated Stephanie would have consumed all her income personally. The district court declined to deduct personal consumption from the restitution award.The United States District Court for the Eastern District of Oklahoma sentenced Johnson to 36 months in prison and three years of supervised release, without imposing a fine due to her lack of financial resources. The court ordered restitution of $158,009, based on the government’s reduced request of $208,009 minus a $50,000 insurance settlement received by Kristi. The court found Kristi’s testimony about Stephanie’s income credible and relied on it, despite the defense expert’s criticism of the government’s expert for not applying a personal-consumption deduction.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court concluded that the district court erred in rejecting the personal-consumption deduction for a legally incorrect reason, as household contributions do not fall within “lost income” under the Victim and Witness Protection Act (VWPA). The appellate court vacated the restitution award and remanded the case for the district court to reconsider the personal-consumption deduction and the payment schedule. The appellate court also addressed the sealing of certain documents, granting the parties' request to redact specific private information and keep the district court’s statement of reasons under seal. View "United States v. Johnson" on Justia Law

Pascual A. Ruiz Jr. was convicted after pleading guilty to one count of possession of ammunition by a prohibited person in violation of 18 U.S.C. § 922(g)(1). In his plea agreement, the government promised to recommend a sentence at the low end of the applicable Guidelines range, which was 51 months. At sentencing, the prosecutor recommended 51 months but also discussed Ruiz’s criminal history. The district court relied on Ruiz’s criminal history to depart upward and imposed a 70-month sentence. Ruiz appealed, arguing the government breached the plea agreement by undermining its recommendation.The United States District Court for the District of Kansas accepted Ruiz’s guilty plea and calculated his offense level and criminal history, resulting in a Guidelines range of 51 to 63 months. The Presentence Investigation Report (PSR) suggested an upward departure might be warranted due to Ruiz’s extensive criminal history. At sentencing, the district court expressed concern about Ruiz’s criminal history and imposed a 70-month sentence, classifying it as an upward departure.The United States Court of Appeals for the Tenth Circuit reviewed the case. Ruiz argued the government breached the plea agreement by emphasizing his criminal history at sentencing. The court assumed, without deciding, that a plain error occurred but found Ruiz failed to show a reasonable probability that the outcome would have been different absent the alleged breach. The court noted the district court’s independent concern about Ruiz’s criminal history, expressed before the prosecutor’s remarks, and concluded the district court would have likely imposed the same sentence regardless. The Tenth Circuit affirmed the 70-month sentence. View "United States v. Ruiz" on Justia Law

Defendant Alexander Pauler was convicted of possessing a firearm after having previously been convicted of a misdemeanor crime of domestic violence. The district court denied Defendant’s motion to dismiss the indictment for failure to state an offense, holding that Defendant violated the applicable statute because he possessed a firearm in 2014 after having been convicted in 2009 of violating a Wichita, Kansas municipal domestic battery ordinance by punching his girlfriend. The sole issue for the Tenth Circuit's review was whether a misdemeanor violation of a municipal ordinance qualified as a “misdemeanor under . . . State . . . law” when viewed in the context of a statutory scheme that clearly and consistently differentiated between state and local governments and between state statutes and municipal ordinances. Applying well-established principles of statutory interpretation, the Tenth Circuit held that it did not, and the Court accordingly reversed and remanded for the district court to vacate Defendant’s federal conviction. View "United States v. Pauler" on Justia Law

The test applied in evaluating the constitutionality of a reasonable doubt jury instruction instruction is not whether a court finds it exemplary. Rather, the proper inquiry requires a court to consider the instructions in their entirety and ask whether a “reasonable likelihood” exists that the jury “understood the instructions to allow conviction based on proof insufficient to meet the [reasonable doubt] standard.” The Government charged Defendant Ishmael Petty with assaulting three employees at the federal correctional facility in Florence, Colorado. At Defendant’s trial, the district court tendered the jury a reasonable doubt instruction that tracked verbatim the Tenth Circuit’s Pattern Jury Instruction on reasonable doubt. The district court overruled Defendant’s objections to the instruction, and a jury found Defendant guilty. Defendant contended the district court’s instruction diluted the Government’s burden of proof contrary to his Fifth Amendment right to due process and his Sixth Amendment right to a fair trial. After review, the Tenth Circuit rejected Defendant’s argument that the reasonable doubt instruction as tendered was unconstitutional, and affirmed. View "United States v. Petty" on Justia Law

This appeal involved a criminal defendant’s obligation to pay restitution to his victims. Kapelle Simpson-El was convicted of crimes involving the sale of stolen cars. His sentence included a restitution obligation of $432,930.00. Since obtaining release, Simpson-El has paid at least 5% of his gross monthly income toward restitution. Simpson-El was injured while serving his prison sentence at a federal prison. The injury was allegedly exacerbated by inadequate medical attention and a lack of treatment, leading Simpson-El to sue the federal government under the Federal Tort Claims Act. After obtaining release from prison, Simpson-El settled with the government for $200,000. The government sought modification of the restitution order based on a material change in economic circumstances, requesting an order for Simpson-El to pay the entire $200,000 as restitution. The district court granted the motion in part, applying $145,640 of the settlement funds toward restitution. The Tenth Circuit found a restitution payment schedule could be modified when the defendant’s economic circumstances materially change. Simpson-El appealed, arguing the settlement funds were not a “material change in economic circumstances.” Finding no reversible error in the district court’s restitution order, the Tenth Circuit affirmed. View "United States v. Simpson-El" on Justia Law