Justia Criminal Law Opinion Summaries

In this case, the defendant was stopped by police officers in Aurora, Colorado, for speeding. During the stop, the officers observed the defendant make a dramatic movement toward the passenger side of his vehicle, to the extent that he was no longer visible to them. The officers recognized the defendant as a member of a local violent gang and learned from him that he was on parole for robbery. After asking the defendant to exit the vehicle and conducting a pat-down that revealed no weapons, the officers searched the passenger seat area and found a firearm. The defendant was subsequently charged with being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1).The United States District Court for the District of Colorado held an evidentiary hearing on the defendant’s motion to suppress the firearm evidence, which argued that the warrantless vehicle search violated the Fourth Amendment. The district court denied the motion, finding that the officers had reasonable suspicion to believe the defendant was armed and dangerous, based on his furtive movement, gang affiliation, and parole status for a violent crime. The defendant entered a conditional guilty plea, reserving his right to appeal the suppression ruling, and was sentenced to thirty-seven months in prison.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the denial of the motion to suppress de novo, considering the totality of the circumstances. The court held that the combination of the defendant’s dramatic movement, his recognized gang membership, and his parole for robbery provided reasonable suspicion that he was armed and dangerous, justifying the protective vehicle search under the officer safety exception to the Fourth Amendment. The court also rejected the defendant’s constitutional challenge to § 922(g)(1), finding it foreclosed by circuit precedent. The Tenth Circuit affirmed the district court’s judgment. View "United States v. McGregor" on Justia Law

The defendant, an enrolled member of a Native American tribe, was charged with multiple counts of sexual abuse against his minor stepdaughter, D.P., occurring over several years in Indian Country. The alleged abuse began when D.P. was about six years old and continued until she was over twelve, with a brief pause when her mother was more frequently present. D.P. disclosed the abuse following a suicide attempt at age twelve, and her mother and medical professionals testified about her outcry. The prosecution’s case relied heavily on D.P.’s credibility, as there was no physical evidence corroborating her allegations. The defense sought to challenge D.P.’s credibility, highlighting her mental health history, medication use, and possible suggestibility, and attempted to introduce four sexually suggestive, fictionalized YouTube videos created by D.P. at age eleven.The United States District Court for the Eastern District of Oklahoma granted the government’s motion in limine under Federal Rule of Evidence 412, excluding any mention or introduction of the YouTube videos at trial. The court found the videos constituted evidence of “other sexual behavior” or “sexual predisposition” and did not fall within any of Rule 412’s exceptions. The defense argued the videos were relevant to impeach D.P.’s credibility, not to prove sexual behavior or predisposition, and that exclusion violated the defendant’s constitutional rights to confrontation and due process.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s evidentiary ruling and constitutional claims. The Tenth Circuit held that Rule 412’s bar applies to evidence offered to prove a victim’s sexual behavior or predisposition, even if the purpose is impeachment, and that no exception for general impeachment exists. The court further held that exclusion of the videos did not violate the defendant’s constitutional rights, as the Constitution does not mandate admission of general impeachment evidence absent a showing of bias or motive to lie. The judgment of the district court was affirmed. View "United States v. Baker" on Justia Law

The case concerns a dispute between two brothers, Matthew and Shane, involving a $445,000 debt that Matthew owed to Shane. After learning that the government intended to recover over $1 million from him due to unrelated criminal charges, Matthew convinced Shane to allow him to create a company in Shane’s name to shield assets. Later, Matthew orchestrated a real estate transaction through this company, Cap Fund 783, LLC, resulting in a $767,000 assignment fee. Matthew attempted to divert these proceeds to himself by lying to the escrow agent and falsifying business records online to make it appear he controlled Cap Fund, thereby concealing the asset from Shane.The United States District Court for the District of Utah presided over Matthew’s trial. A jury convicted him on two counts of wire fraud, based on his phone call to the escrow agent and his online alteration of Cap Fund’s records. The district court also found him guilty, after a bench trial, of criminal contempt and possession of ammunition by a felon. Matthew was sentenced to imprisonment and ordered to pay restitution. He appealed, arguing that his actions did not deprive Shane or the escrow agent of property, that the district court erred by not admitting a state-court judgment, and that the government failed to prove the interstate element for one wire fraud count.The United States Court of Appeals for the Tenth Circuit affirmed the conviction for wire fraud related to the phone call, holding that a creditor’s right to collect a debt is a property interest under the wire fraud statute, and that the escrow agent also had a property interest in the funds. The court reversed the conviction on the count involving the online alteration, finding insufficient evidence that the communication crossed state lines. The court affirmed the convictions for criminal contempt and felon-in-possession, and remanded for resentencing. View "United States v. Baker" on Justia Law

Malachi Moon Seals, at age eighteen, posted graphic and violent threats against federal officials and their families on official websites, causing some recipients to request security protection. A grand jury indicted him on twelve counts: six for threatening or retaliating against federal officials under 18 U.S.C. § 115(a)(1), and six for transmitting threats via interstate communications under 18 U.S.C. § 875(c). Seals pleaded guilty to all charges. The probation office calculated an advisory sentencing range of 33 to 41 months’ imprisonment, which made him ineligible for straight probation under the guidelines. Nevertheless, both parties advocated for probation, and the United States District Court for the District of Colorado, with hesitation, sentenced Seals to five years’ probation with special conditions.Shortly after beginning probation, Seals violated its terms by posting new threats online. The probation office petitioned for his arrest, and Seals admitted to the violations. The district court revoked his probation and proceeded to resentence him. At the resentencing hearing, the probation office recommended a sentence at the low end of the original guideline range, and the government supported this recommendation. Defense counsel referenced the Tenth Circuit’s decision in United States v. Moore, but suggested its holding might be reversed. The district court did not apply the Moore framework and instead sentenced Seals to 36 months’ imprisonment under the original guideline range.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed whether the district court erred by not applying the two-step resentencing procedure required by Moore I. The court held that, although the district court plainly erred by not following Moore I’s framework, Seals failed to show that the court was required to impose a 0-month sentence at the first step or that this error was plain. Therefore, the Tenth Circuit affirmed the post-revocation sentence. View "United States v. Seals" on Justia Law

Law enforcement discovered that an individual had stored child pornography in a Dropbox account, including videos of him sexually abusing two minor girls and other illicit material. The investigation revealed that the Dropbox account was used for personal file storage, with no evidence of sharing or distribution. The defendant was charged with two counts of sexual exploitation of a child and two counts of possession of child pornography, each count corresponding to a different victim. He pleaded guilty to all charges before trial, and the United States Probation Office prepared a pre-sentence report recommending a lengthy prison term.The United States District Court for the Eastern District of Oklahoma adopted the pre-sentence report and sentenced the defendant to concurrent prison terms totaling 292 months, followed by a lifetime of supervised release. Among the special conditions imposed was a restriction prohibiting the defendant from using the Internet or any online computer services without prior written approval from his probation officer. The court did not provide a specific explanation or analysis for imposing this Internet use condition. The defendant did not object to this condition at sentencing but appealed, arguing that the district court erred by failing to analyze whether the condition satisfied the statutory requirements under 18 U.S.C. § 3583(d).The United States Court of Appeals for the Tenth Circuit reviewed the case for plain error. The court held that the district court plainly erred by imposing the Internet use condition without providing any explanation or analysis as required by law. The Tenth Circuit found that this error was clear under established precedent, affected the defendant’s substantial rights, and seriously affected the fairness and integrity of the proceedings. Accordingly, the Tenth Circuit vacated the sentence and remanded the case for resentencing consistent with its opinion. View "United States v. Bycroft" on Justia Law

Police officers investigating a recent carjacking and kidnapping at an Oklahoma City motel received information from the motel manager that a man matching the suspect’s description was staying in a particular room. Upon arrival, one officer looked through a one-inch gap in the window curtains from an open-air walkway outside the room and saw the defendant, Cameron Watkins, sitting on a bed next to a handgun with an extended magazine. This observation led to Watkins’s arrest and the subsequent discovery of a firearm and ammunition in the room. Watkins was later charged with being a felon in possession of a firearm and, in a superseding indictment, with being a felon in possession of ammunition found at a separate crime scene.The United States District Court for the Western District of Oklahoma denied Watkins’s motion to suppress the evidence, finding that the officer’s observation was made from a public area—the motel’s exterior walkway—which was accessible to other guests and staff, and not part of the room’s curtilage. The court concluded there was no Fourth Amendment violation because the officer did not intrude upon a protected area or the defendant’s reasonable expectation of privacy. Watkins pleaded guilty to the firearm charge, reserving his right to appeal the suppression ruling, and was convicted by a jury on the ammunition charge.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed both convictions. The court held that the officer’s visual observation through the window gap, made from a public walkway using only his unaided senses, did not constitute a search under the Fourth Amendment. The walkway was not curtilage, and the defendant did not have a reasonable expectation of privacy against such observation. The court therefore upheld the district court’s denial of the suppression motion and affirmed the convictions. View "United States v. Watkins" on Justia Law

John Doe, a Native American juvenile and member of the Eastern Shoshone Tribe, was charged in federal court with multiple offenses, including kidnapping a minor on tribal land for the purpose of physical assault. The government filed a six-count juvenile information, and Doe admitted to certain charges, including kidnapping, assault with a dangerous weapon, and provided a factual basis for his admissions. The events occurred in a trailer on the Wind River Indian Reservation, where Doe assaulted two minor victims and instructed one to remain in a closet as he left the scene.The United States District Court for the District of Wyoming held an admission hearing, where Doe, with counsel, admitted to the relevant charges. The court found a sufficient factual basis and conditionally accepted the admissions. After a delinquency hearing, Doe was adjudicated delinquent on several counts and committed to detention and supervision. Following the district court’s judgment, the Tenth Circuit decided United States v. Murphy, which clarified that the “holds” element of federal kidnapping requires proof the victim was detained for an appreciable period beyond that necessary to commit any related offense. Doe appealed, arguing his admission was not knowing or voluntary because he was not informed of this temporal requirement.The United States Court of Appeals for the Tenth Circuit reviewed the case under the plain error standard. The court held that Murphy did not clearly establish the temporal requirement as an essential element of kidnapping, nor did Doe demonstrate that the district court’s failure to inform him of this requirement was a plain error under well-settled law. The court affirmed the district court’s judgment of delinquency. View "United States v. Doe" on Justia Law

The defendant, who had been receiving disability insurance benefits due to a medical diagnosis, operated a jewelry business while collecting these benefits. The Social Security Administration (SSA) began investigating after suspecting that the defendant was earning income that could affect his eligibility. The SSA asked the defendant whether he had worked or received income since his diagnosis, to which he responded negatively. However, evidence showed that he had significant gross income from jewelry sales, and the SSA determined that his countable income likely exceeded regulatory caps, making him ineligible for benefits. The defendant was subsequently charged with taking government property and making false statements.The United States District Court for the District of New Mexico presided over the trial. The government presented evidence of substantial gross income and efforts by the defendant to conceal earnings. The defendant did not provide information about business expenses that could have reduced his countable income. The jury convicted him on multiple counts related to theft of government property and false statements. At sentencing, the district court calculated the loss amount, including benefits paid to the defendant’s children and payments made outside the charged period, resulting in a 15-month prison sentence.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that the evidence was sufficient for a reasonable jury to find that the defendant’s countable income exceeded the regulatory caps, even without detailed expense information, given the high gross income and lack of contrary evidence. The court also found no reversible error in the jury instructions, as the defendant failed to timely challenge the district court’s reasoning. Regarding sentencing, the court held that it was proper to include reasonably foreseeable payments to the defendant’s children and payments outside the charged period in the loss calculation. Any error in including Medicare premiums was deemed harmless. The convictions and sentence were affirmed. View "United States v. Sandoval" on Justia Law

In this case, the defendant was charged with abusive sexual contact of a minor in Indian Country, based on conduct that occurred between 1998 and 2000, when the victim was approximately 15 or 16 years old. The victim reported the abuse to the FBI in 2021, stating that she had previously disclosed it to a therapist at a rape crisis center, but no action was taken at that time. The alleged abuse took place within the Navajo Nation, and the defendant did not contest his status as an enrolled member of the Navajo Nation or the location of the offense.The United States District Court for the District of New Mexico denied the defendant’s motion to dismiss the superseding indictment, which argued that the prosecution was barred by the statute of limitations. The district court found that the extended statute of limitations for sexual offenses against children under 18, as set forth in 18 U.S.C. § 3283, applied to the case. The defendant then entered a conditional guilty plea to a lesser offense—abusive sexual contact in Indian Country—reserving his right to appeal the statute of limitations issue.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed de novo whether the categorical approach or a case-specific analysis should be used to determine the applicability of § 3283’s extended statute of limitations. The court held that the categorical approach, typically used in sentencing and immigration contexts, does not apply to pretrial statute of limitations challenges under § 3283. Instead, a case-specific approach is appropriate, focusing on the facts and charges in the indictment. The court concluded that the offense charged involved the sexual abuse of a minor, so § 3283’s extended limitations period applied. The Tenth Circuit affirmed the district court’s denial of the motion to dismiss. View "United States v. Tso" on Justia Law

Late one night, a homeowner called 911 to report that her security camera showed a Black man and woman taking items from her back porch. Within minutes, a police officer arrived and encountered Michael Campbell near the reported location. Campbell claimed to live at the residence and was uncooperative with the officer’s instructions, repeatedly dropping his hands and reaching for his wallet despite being told not to. The officer noticed what appeared to be a gun magazine in Campbell’s waistband and, after a brief exchange, frisked Campbell, discovering a firearm and a knife. Campbell was subsequently indicted for being a felon in possession of a firearm.The United States District Court for the Western District of Oklahoma denied Campbell’s motion to suppress the firearm, finding that the officer had reasonable suspicion to detain and frisk Campbell and that this suspicion had not dissipated before the frisk. Campbell was convicted at trial. At sentencing, the district court determined that Campbell’s five prior Oklahoma armed robbery convictions qualified as violent felonies under the Armed Career Criminal Act (ACCA), subjecting him to a 15-year mandatory minimum sentence. Campbell was sentenced to 240 months, above the statutory maximum for the felon-in-possession offense but below the Guidelines range.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s denial of the suppression motion and upheld the constitutionality of the felon-in-possession statute. However, the Tenth Circuit held that Oklahoma armed robbery can be committed with a reckless state of mind and therefore does not categorically qualify as a violent felony under the ACCA’s elements clause. The court vacated Campbell’s sentence and remanded for resentencing, while affirming his conviction. View "United States v. Campbell" on Justia Law