Justia Criminal Law Opinion Summaries

A man with previous felony drug convictions sold drugs to an individual named Correa at a Pennsylvania gas station. Later that day, Correa was found dead in his car, with toxicology revealing fentanyl-laced heroin and cocaine in his system. An investigation uncovered that Correa had arranged the transaction with the man through text messages and Facebook Messenger, and security footage confirmed their meeting. The man admitted to supplying cocaine but denied selling heroin. A search warrant was obtained for the man’s Facebook records, leading to the discovery of extensive drug-related communications, including evidence of a gun-for-drugs exchange.A federal grand jury indicted the man on multiple counts: conspiracy to possess with intent to distribute narcotics resulting in death or serious bodily injury, possession with intent to distribute drugs, possession of a firearm in furtherance of drug trafficking, and conspiracy to possess a firearm in furtherance of drug trafficking. He was convicted on all counts by a jury. Before trial, he moved to suppress the Facebook evidence, arguing the search warrant was overbroad and lacked particularity, and requested a Franks hearing, alleging falsehoods in the warrant affidavit. The United States District Court for the Middle District of Pennsylvania denied these motions, admitted certain witness testimony, and imposed a mandatory life sentence under 21 U.S.C. § 841(b)(1)(C) based on his prior convictions and the resulting death.The United States Court of Appeals for the Third Circuit affirmed the convictions, holding that the good faith exception shielded the Facebook evidence from suppression, that the evidence was sufficient to support all convictions (including firearm possession via gun-for-drugs trades), and that the evidentiary rulings were not erroneous. However, the Court vacated the life sentence, holding that the District Court erred by not applying the traditional categorical approach to determine whether the prior state drug convictions qualified as “felony drug offenses” under federal law, and remanded for resentencing. View "USA v. Rosario" on Justia Law

DEA investigators received information indicating that an individual was distributing cocaine base with a co-defendant in Monroe County, Pennsylvania. The individual often requested payments from customers via Cash App and either conducted drug transactions personally or sent the co-defendant to do so. Cash App records showed approximately $180,000 in payments. Agents arranged controlled purchases, during which the co-defendant drove the individual's vehicle for several transactions. After executing a search warrant at the individual's residence, agents seized cocaine, paraphernalia, a drug ledger, financial records, and cash. The individual was later charged in a federal superseding indictment with several drug-related counts and pled guilty to conspiracy to distribute and possess with intent to distribute cocaine.The United States District Court for the Middle District of Pennsylvania reviewed the presentence report, which recommended a two-level leadership enhancement under U.S.S.G. § 3B1.1(c) for being a “manager” or “supervisor” of criminal activity. This enhancement resulted in a guideline range of 120 to 135 months, subject to a statutory minimum sentence of ten years. Without the enhancement, the individual would have been eligible for a sentence below the statutory minimum under the safety valve provision. The individual objected, but the District Court relied on Sentencing Guidelines commentary and applied the enhancement, sentencing him to 120 months’ imprisonment. The appeal challenged only the District Court’s application of the leadership enhancement.The United States Court of Appeals for the Third Circuit reviewed the District Court’s interpretation of the Sentencing Guidelines de novo and factual findings for clear error. The Third Circuit held that the District Court erred by deferring to the Guidelines’ commentary without first determining whether the Guideline text was genuinely ambiguous as required by circuit precedent. However, since the terms “manager” and “supervisor” were not genuinely ambiguous, and the factual findings supported the enhancement, the error was harmless. The Third Circuit affirmed the District Court’s judgment of sentence. View "USA v. Riddy" on Justia Law

After being arrested following a slow-speed pursuit in November 2020, the defendant was found with a disassembled Glock pistol and ammunition. The firearm contained two serial numbers: one was fully legible on the slide, while the other, located on the pistol frame, was partially visible but mainly scratched off, rendering several characters illegible. As a convicted felon, the defendant was charged with unlawful possession of a firearm and pleaded guilty.Prior to sentencing, the U.S. Probation Office recommended a four-level sentence enhancement under § 2K2.1(b)(4)(B)(i) of the U.S. Sentencing Guidelines, which applies if any firearm involved had a serial number modified to be illegible or unrecognizable to the unaided eye. At the sentencing hearing, the United States District Court for the Middle District of Pennsylvania found that certain characters of the serial number on the pistol frame were not legible, thus applying the four-level enhancement. The District Court ruled that the presence of a separate, legible serial number on the firearm’s slide was irrelevant to the enhancement’s application. The defendant appealed this decision.The United States Court of Appeals for the Third Circuit reviewed the District Court’s interpretation of the Guidelines de novo. The appellate court concluded that the plain language of § 2K2.1(b)(4)(B)(i) requires only that a firearm have at least one serial number rendered illegible or unrecognizable, regardless of whether another serial number on the same firearm remains legible. The court rejected the defendant’s argument that the enhancement should not apply if the firearm retains any complete, legible serial number. The Third Circuit affirmed the judgment of the District Court, holding that the enhancement applies so long as any serial number on the firearm has been modified to be illegible. View "USA v. Craddock" on Justia Law

Between 2011 and 2017, the Internal Revenue Service sought to collect unpaid taxes from an individual and his business. The individual was indicted on two counts of tax evasion. The indictments alleged that, among other acts, he attempted to evade the collection of taxes by using a bank account that was not disclosed to the IRS, and specifically by submitting financial disclosure forms that omitted these accounts when disclosure was required.The case was first heard in the United States District Court for the Middle District of Pennsylvania. The defendant moved to dismiss the indictments, arguing that the government had not alleged or proven an affirmative act of evasion within the applicable six-year statute of limitations. The District Court denied these motions. At trial, the government presented evidence that the defendant had knowingly failed to disclose certain bank accounts on forms submitted to the IRS within the limitations period. After the government’s case, the defendant’s motion for judgment of acquittal was denied. The jury found him guilty on both counts.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s denials. The Third Circuit held that intentionally filing forms with the IRS that omitted required disclosure of bank accounts constitutes an affirmative act of tax evasion under 26 U.S.C. § 7201. The court found that the indictments, together with the bill of particulars, sufficiently identified this conduct within the statute of limitations. It also held that there was sufficient evidence for a rational jury to find guilt beyond a reasonable doubt. The Third Circuit affirmed the judgment of the District Court. View "USA v. Aumiller" on Justia Law

The defendant was arrested after sexually abusing a 13-year-old girl and making and possessing child pornography, having coerced multiple minors into sending him explicit images and meeting him for sex. Law enforcement officers posed as one of the victims to apprehend him, and a grand jury indicted him on five federal charges, including traveling interstate to have sex with a minor, sexual exploitation of a child, coercion and enticement of a minor, and possession of child pornography. Following his arrest, the defendant repeatedly delayed proceedings, changed his mind about legal representation, and ultimately chose to represent himself at trial after several Faretta hearings, during which the District Court misinformed him about the maximum penalty on one count.The U.S. District Court for the District of New Jersey, after thorough Peppers colloquies, allowed the defendant to proceed pro se with standby counsel, despite the sentencing misinformation. During trial, the defendant behaved disruptively and withdrew his pro se status for closing arguments. The jury convicted him on all counts. Before sentencing, the government revealed the sentencing error, and the defendant moved for a new trial, claiming his waivers of counsel were neither knowing nor voluntary, and challenging the admission of certain evidence. The District Court denied the motion, finding the waivers valid based on the overall record, and sentenced him to life imprisonment.The United States Court of Appeals for the Third Circuit reviewed the appeal and affirmed the conviction and sentence. The court held that the defendant’s waivers of his right to counsel were both knowing and voluntary, even in light of the District Court’s error, because he was aware he faced a functional life sentence. It clarified that in cases where a defendant seeks to represent himself for improper purposes, courts may review the entire record to verify waiver validity. The court also rejected the evidentiary challenges to chat messages and evidence of other crimes. View "USA v. Williams" on Justia Law

In 1995, a man was convicted by a jury in the Dauphin County Court of Common Pleas for first-degree murder following the shooting death of another individual related to a drug deal. Two key prosecution witnesses, both facing pending charges themselves, testified against him in exchange for plea agreements. The prosecution did not disclose all pending charges against these witnesses, though defense counsel was able to impeach their credibility based on other known charges. Despite this, the jury convicted the defendant, who was sentenced to life imprisonment. He unsuccessfully challenged his conviction on direct appeal and through multiple post-conviction proceedings in state court.After eventually discovering the full extent of the witnesses' pending charges, the petitioner filed a federal habeas petition under 28 U.S.C. § 2254 in the United States District Court for the Middle District of Pennsylvania, asserting a Brady violation. The District Court denied the petition as untimely under the statute of limitations, and subsequent requests for a certificate of appealability were also denied. Following a significant change in Third Circuit law announced in Dennis v. Secretary, Pennsylvania Department of Corrections, the petitioner sought to reopen his federal habeas case under Federal Rule of Civil Procedure 60(b)(6). After a remand for further analysis, the District Court again denied the Rule 60(b)(6) motion, finding that the factors for extraordinary relief were not met.The United States Court of Appeals for the Third Circuit reviewed the denial, applying an abuse-of-discretion standard and weighing the Cox factors. The Court held that, although the materiality and diligence factors favored the petitioner, the remaining factors—likelihood of success, finality and comity, lack of actual innocence, and non-capital sentence—strongly disfavored relief. The Third Circuit affirmed the District Court’s denial of the Rule 60(b)(6) motion. View "Bracey v. Superintendent Rockview SCI" on Justia Law

Richardson Dangleben, Jr. was initially charged in Virgin Islands Superior Court with first-degree murder and using a firearm during a violent crime. While released on pretrial conditions, Dangleben was involved in a shootout with police, resulting in the death of Detective Phipps. Following these events, a federal grand jury indicted Dangleben on several charges, including using a firearm during a crime of violence resulting in death, making him eligible for the death penalty. The predicate crimes for these charges were all Virgin Islands territorial offenses.After indictment, the Federal Public Defender inquired about the government's intent to seek the death penalty. The U.S. Attorney’s Office indicated it would not recommend the death penalty, though the final decision rested with the Attorney General. By agreement of the parties, the District Court of the Virgin Islands set a deadline for the government to file any notice of intent to seek the death penalty. The government missed the deadline, later changing its position and seeking to pursue the death penalty after a change in federal policy. The District Court struck the government’s death penalty notice as untimely and, in a separate order, dismissed counts that relied on territorial offenses as predicates for federal firearm charges, concluding only federal crimes could serve as predicate offenses under 18 U.S.C. § 924(c).The United States Court of Appeals for the Third Circuit reviewed both rulings. It held that a district court has authority to set and enforce a deadline for the government to file its notice of intent to seek the death penalty under 18 U.S.C. § 3593(a), and affirmed the District Court’s striking of the government’s late notice. However, the Third Circuit reversed the District Court’s ruling on predicate crimes, holding that Virgin Islands territorial offenses can serve as predicate “crimes of violence” under 18 U.S.C. § 924(c)(1)(A), and remanded with instructions to reinstate the dismissed counts. View "USA v. Dangleben" on Justia Law

Two individuals were prosecuted for their roles in a violent drug-trafficking organization in the U.S. Virgin Islands. One defendant was identified as the leader, convicted by a jury of 22 counts including drug, firearm, and racketeering charges; the other, an armorer, was convicted of seven counts relating to racketeering and firearms. Their trial occurred in March 2022, shortly after the District Court resumed in-person proceedings following COVID-19 restrictions. Initially, all public spectators were required to observe the proceedings from an overflow room via audiovisual feed, rather than in the courtroom itself. After the first day, some spectators, including family members, were permitted into the courtroom, but for several days, court security personnel prevented the defendants’ mothers from entering, even when seats were available.Following their convictions, the defendants moved for a new trial in the District Court of the Virgin Islands, arguing that their Sixth Amendment right to a public trial was violated by these restrictions. After an evidentiary hearing, the court found that some seating was always available on a first-come basis and that any interruptions in the audiovisual feed were brief. The District Court denied the motions, concluding that the public was not excluded from the trial.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s factual findings for clear error and legal conclusions de novo, but applied plain error review due to the defendants’ failure to make timely objections. The Third Circuit held that there were errors: the initial exclusion of all public spectators and the subsequent exclusion of the defendants’ mothers were unjustified. However, the court also held that these errors did not seriously affect the fairness, integrity, or public reputation of judicial proceedings and therefore did not warrant reversal. The judgments of conviction were affirmed. View "USA v. Harry" on Justia Law

After being convicted in 2007 of kidnapping, corruption of a minor, and various drug offenses, a Pennsylvania prisoner was sentenced to fifteen to thirty years in state prison. He argued that he deserved additional credit for time served, which led him through a series of challenges in both Pennsylvania and federal courts. The Pennsylvania Superior Court remanded his case for a hearing on the time-credit issue, resulting in a modified sentence from the Court of Common Pleas granting him three months and twelve days of additional credit. His appeal for further credit was denied, and subsequent collateral challenges, including a federal habeas petition contesting his convictions and sentence enhancement, were unsuccessful.The United States District Court for the Western District of Pennsylvania dismissed his 2013 federal habeas petition as an unauthorized second or successive petition, finding that the revised sentence did not constitute a “new judgment” under Magwood v. Patterson. He did not appeal that decision, but later filed additional habeas petitions and applications for certificates of appealability, which were all denied. In 2022, nearly eight years after the dismissal, he moved under Federal Rule of Civil Procedure 60(b) to reopen the prior judgment, arguing that later precedent (Lesko v. Secretary, Pa. Dep’t of Corr.) justified relief. The District Court denied the motion, finding no extraordinary circumstances.The United States Court of Appeals for the Third Circuit reviewed whether the District Court abused its discretion in denying relief under Rule 60(b)(6). The Court of Appeals held that a change in procedural law alone does not constitute an extraordinary circumstance justifying reopening a final judgment absent additional equitable factors. Because the petitioner failed to present any facts showing extreme or unexpected hardship or other supporting circumstances, the Third Circuit affirmed the District Court’s denial of the Rule 60(b) motion. View "Williams v. Superintendent Rockview SCI" on Justia Law

The case centers on a defendant who was initially charged in the Virgin Islands Superior Court with first-degree murder and a firearm offense, and released pretrial with a condition not to possess weapons. Several months later, the defendant became involved in a shootout with police, resulting in the death of a detective. Upon investigation, authorities found a firearm, ammunition, and drugs in his vehicle. A federal grand jury subsequently indicted the defendant on charges including using a firearm during a crime of violence resulting in death, which made him eligible for the federal death penalty. The predicate crimes underlying these charges were all violations of Virgin Islands territorial law.After indictment, the prosecution indicated it would not recommend the death penalty but acknowledged that only the Attorney General could make the final decision. At the defendant’s request, and with the government’s agreement, the United States District Court of the Virgin Islands set a deadline for the government to provide notice if it intended to seek the death penalty. The government missed this deadline but ultimately filed a notice to seek the death penalty over a year later, after a change in federal policy. The District Court struck the notice as untimely and dismissed several counts relying on territorial offenses as predicate crimes of violence under federal firearm law.The United States Court of Appeals for the Third Circuit reviewed the case. It held that a district court has the authority to set and enforce deadlines for the government to provide notice of intent to seek the death penalty under 18 U.S.C. § 3593(a), and found no abuse of discretion in enforcing the deadline set. The court also held that Virgin Islands territorial offenses qualify as predicate crimes of violence for purposes of 18 U.S.C. § 924(c)(1)(A). The court affirmed the order striking the death penalty notice, but reversed and remanded the dismissal of counts based on territorial predicates. View "USA v. Dangleben" on Justia Law