Justia Criminal Law Opinion Summaries

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

An attorney based in Oklahoma developed a business model to help out-of-state clients enter the state’s medical marijuana industry, which is governed by strict residency and disclosure requirements. He created a two-entity structure: one company, with nominal Oklahoma-resident owners, obtained the necessary state licenses, while a second company, owned and operated by out-of-state clients, ran the actual marijuana operations. The attorney did not disclose the true ownership structure to state authorities, and in some cases, marijuana was grown before the required state registrations were obtained. State authorities began investigating after noticing irregularities, such as multiple licenses listing the same address and repeated use of the same Oklahoma residents as owners, many of whom had little or no involvement in the businesses.Oklahoma state prosecutors charged the attorney with multiple felonies related to his business practices, including conspiracy and submitting false documents. While those charges were pending, a federal grand jury indicted him for drug conspiracy and maintaining drug-involved premises, based on the same conduct. In the United States District Court for the Western District of Oklahoma, the attorney moved to enjoin his federal prosecution, arguing that a congressional appropriations rider barred the Department of Justice from spending funds to prosecute individuals complying with state medical marijuana laws. The district court held an evidentiary hearing and denied the motion, finding that the attorney had not substantially complied with Oklahoma law, particularly due to nondisclosure of ownership interests and failure to obtain required registrations.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed. The court held that the appropriations rider does bar the Department of Justice from spending funds to prosecute private individuals who comply with state medical marijuana laws. However, the court found that the attorney failed to substantially comply with Oklahoma’s requirements, so the rider did not protect him. The court concluded that the district court did not abuse its discretion in denying the injunction. View "United States v. Stacy" on Justia Law

A man was convicted by a jury of aggravated sexual abuse of a minor under twelve years of age in Indian Country. The events leading to the charges occurred during his brief marriage to the child’s mother, when he often cared for her seven-year-old daughter while the mother worked night shifts. The child later disclosed the alleged abuse to family members, which was recorded and reported to authorities. During the investigation, law enforcement also received information suggesting the defendant may have abused other young girls, and three additional children testified at trial about similar conduct. The defendant denied all allegations and presented evidence of his good character, medical issues, and the nature of his relationship with the child and her mother.The United States District Court for the Northern District of Oklahoma denied the defendant’s pretrial motion to suppress statements made during a custodial interrogation, finding no coercion or involuntariness. At trial, the court admitted testimony from other alleged victims under Federal Rule of Evidence 414 and allowed certain statements by the defendant’s ex-wife. The court also gave a jury instruction stating that child witnesses are presumed competent and declined to instruct the jury that it must unanimously find, by a preponderance of the evidence, that the defendant committed the other alleged acts before considering them. The jury found the defendant guilty, and he was sentenced to life imprisonment.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the defendant’s claims of instructional and evidentiary error, the denial of his suppression motion, and the alleged cumulative effect of any errors. The court held that a jury need not unanimously find by a preponderance that a defendant committed Rule 414 acts before individual jurors may consider such evidence. The court found no reversible error in the evidentiary rulings, jury instructions, or suppression decision, and affirmed the conviction. View "United States v. Paycer" on Justia Law

The defendant was apprehended after driving a vehicle containing nearly 50 pounds of methamphetamine and was convicted of possessing methamphetamine with intent to distribute. In seeking a reduced sentence, he argued that he played only a minor role as a courier in the drug operation, submitting a proffer that identified three other individuals allegedly involved in the scheme. The district court considered the sentencing guidelines, which allow for a downward adjustment if the defendant is a minor participant, but declined to apply the adjustment, finding insufficient evidence to support the claim.Prior to this appeal, the United States District Court for the Eastern District of Oklahoma reviewed the case. The defendant objected to the presentence report’s recommendation against the minor-role adjustment, but did not specifically object to the district court’s explanation for denying the adjustment at sentencing. The district court imposed a sentence of 235 months, at the bottom of the applicable guideline range, without the downward adjustment.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed whether the district court plainly erred in denying the minor-role adjustment and whether the sentence was procedurally or substantively unreasonable. Applying the plain-error standard, the appellate court held that the district court did not err in its explanation or in its consideration of the defendant’s proffer, and that any ambiguity in the district court’s statements should be interpreted in a legally correct manner. The court further held that the sentence was both procedurally and substantively reasonable, as it fell within the guideline range and the district court was not required to explicitly address every statutory factor. The Tenth Circuit affirmed the sentence. View "United States v. Naranjo-Aguilar" on Justia Law

Lawrence Rudolph was convicted for the fatal shooting of his wife, Bianca Rudolph, during a 2016 hunting trip in Zambia. The couple, married for nearly thirty-five years, had substantial marital assets and maintained significant life insurance policies. Their marriage was troubled by infidelity, including Mr. Rudolph’s long-term affair with Lori Milliron, a partner at his dental practice. After Bianca’s death, which Mr. Rudolph claimed was accidental, he collected nearly $4.8 million in life insurance proceeds and purchased several high-value assets. Less than two weeks after returning to the United States, he arranged for Ms. Milliron to join him in Arizona, and they began living together.The Federal Bureau of Investigation in Denver initiated an investigation in 2019, reviewing the Zambian authorities’ findings and conducting its own forensic analysis. In December 2021, Mr. Rudolph was arrested in Denver after being deported from Mexico, and indicted by a grand jury in the United States District Court for the District of Colorado on charges of foreign murder and mail fraud. He moved to dismiss for improper venue and to sever his trial from Ms. Milliron’s, arguing that the government engaged in forum shopping and that a joint trial would prejudice his defense. The district court denied both motions, admitted certain statements by Bianca under the forfeiture-by-wrongdoing exception, and ordered forfeiture of assets purchased with the insurance proceeds.The United States Court of Appeals for the Tenth Circuit reviewed the case. It held that venue in Colorado was proper under 18 U.S.C. § 3238, as Mr. Rudolph was both “arrested” and “first brought” to the district in connection with the charges. The court found no abuse of discretion in denying severance, admitting Bianca’s statements under Rule 804(b)(6), or ordering forfeiture of the assets, including interest and appreciation. The Tenth Circuit affirmed the district court’s judgment and forfeiture order. View "United States v. Rudolph" on Justia Law