Justia Criminal Law Opinion Summaries

Appellant was detained at Guantanamo Bay for seven years as an enemy combatant. After the Supreme Court decided that Guantanamo detainees have a constitutional right to challenge the basis of their detentions in Boumediene v. Bush, the district court granted appellant's petition for a writ of habeas corpus. The United States released appellant and he filed a complaint a year later, seeking to recover injuries sustained during his detention. At issue was whether the district court has jurisdiction over appellant's claims. The court held that 28 U.S.C. 2241(e)(2) barred claims brought on behalf of aliens determined by Combatant Status Review Tribunals (CSRTs) to have been properly detained. The court also concluded that the application of section 2241(e)(2) to appellant was constitutional. Accordingly, the court affirmed the dismissal of appellant's claims because Congress has denied the district court jurisdiction to entertain his claims under section 2241(e)(2). View "Janko v. Gates, et al." on Justia Law

Defendants appealed their convictions stemming from a narcotics distribution scheme in Washington D.C. Defendants and six others were indicted, and the district court conducted two trials. The court held that defendants' evidentiary challenges and their contention regarding the submission of unplayed and unredacted phone calls failed to demonstrate that reversal of their convictions was warranted; such errors as occurred were harmless for lack of substantial prejudice; the district court's responses to jury notes impermissibly interfered with the jury's independent role as the finder of fact and the court vacated the convictions on the tainted counts; the government conceded that the district court erred in imposing Defendant Thomas' sentences of life imprisonment in violation of Apprendi v. New Jersey and the court vacated his life sentences for narcotics conspiracy and RICO conspiracy; and the court remanded the case for resentencing and otherwise affirmed the judgments of conviction. View "United States v. Thomas" on Justia Law

Defendants, convicted of various narcotics-related offenses, alleged that numerous errors affected their second trial. Defendants were involved in an extensive drug ring and the government indicted twenty-one defendants in total, subsequently separating defendants for trial in two groups. The court rejected most of defendants' arguments; vacated Defendant Miller's insufficiently supported conviction for his participation in a continuing criminal enterprise and remanded for resentencing; and vacated the fine imposed on Defendant Eiland by the district court and remanded for reconsideration of that portion of Eiland's sentence. View "United States v. Eiland" on Justia Law

This appeal challenged the district court's order authorizing the Government to medicate defendant by force if necessary for the sole purpose of rendering him competent to stand trial. In Sell v. United States, the Supreme Court held that the Government may, on "rare" occasions, forcibly medicate a defendant to restore his competency. The court found no merit in defendant's claim that the district court committed reversible error in failing to consider the prospect that he might face civil confinement; even if defendant was correct that he was not dangerous apart from allegedly threatening the President of the United States with bodily harm, this fact by itself would not render unimportant the Government's interest in prosecuting him for a serious and dangerous crime; and the district court's factual findings have a sound evidentiary basis and were not clearly erroneous. Accordingly, the court affirmed the district court's order authorizing involuntary medication. View "United States v. Dillon" on Justia Law

In these three appeals, enemy combatants held by the United States at Bagram Airfield Military Base in northwest Afghanistan sought access to the writ of habeas corpus. Over three years ago, the court concluded that enemy combatants held at Bagram could not invoke the Suspension Clause to challenge their detentions. In these appeals, the court dismissed the petitions for want of jurisdiction where, because the Suspension Clause did not run to Bagram, section 7 of the 2006 Military Commissions Act, Pub. L. No. 109-366, 120 Stat. 2600, did not effect any unconstitutional suspension of the writ. The court remanded Hamidullah's petition to the district court for the limited purpose of determining whether he is in the sole custody of the government of Pakistan. View "Maqaleh, et al. v. Panetta, et al." on Justia Law

Defendant appealed his convictions for five counts of wire fraud and one count of theft. Defendant, while serving as former Senator Edward M. Kennedy's office manager, awarded himself unauthorized bonuses. The court rejected defendant's evidentiary arguments; remanded his colorable ineffective assistance claims; and vacated and remanded the restitution order because neither the jury nor the district court made factual findings sufficient to support the order. View "United States v. Pole" on Justia Law

Appellant challenged the district court's finding that he was not suffering from a severe mental illness when he represented himself at trial nearly six years ago. The court concluded, consistent with Indiana v. Edwards, that it had no reason to disturb the district court's fine-tuned judgment that appellant did not suffer from severe mental illness to the point where he was not competent to conduct trial proceedings by himself. Accordingly, the court affirmed the judgment of the district court. View "United States v. McKinney" on Justia Law

Abdul Razak Ali was captured in 2002 by U.S. and Pakistani forces and detained as an enemy combatant. When captured at a guesthouse in Pakistan, Ali was with an al Qaeda-associated terrorist leader named Abu Zubaydah. Ali subsequently challenged the district court's denial of his petition for a writ of habeas corpus. Based on Ali's presence at the guesthouse with Abu Zubaydah, his participation in Abu Zubaydah's training program, his admission to traveling to Afghanistan to fight in the war against U.S. and Coalition forces, and other evidence connecting Ali to Abu Zubaydah fighters, the district court concluded that it was more probable than not that Ali was in fact a member of Abu Zubaydah's force. The court concluded that the facts justify the President's decision to detain Ali as an enemy combatant under the 2001 Authorization for Use of Military Force. Pub. L. No. 107-40, section 2(a), 115 Stat. 224. Therefore, the court affirmed the judgment of the district court denying Ali's petition for a writ of habeas corpus. View "Ali v. Obama, et al." on Justia Law

Defendant plead guilty to a charge related to his sexual involvement with a 14 year-old. At issue on appeal are the conditions of supervised release. On the merits, the court found that the district court's own statements, and the sweeping nature of several of the conditions, demonstrated that the court failed to weigh the burden of the conditions on defendant's liberty against their likely effectiveness, as required by 18 U.S.C. 3583(d). Accordingly, the court vacated all the challenged conditions and remanded to the district court to impose special conditions of supervised release in compliance with section 3583(d). View "United States v. Malenya" on Justia Law

Defendant pleaded guilty to a single count of conspiracy to distribute methamphetamine. Defendant did not qualify for safety valve relief under 18 U.S.C. 3553(f) because his criminal history score under the Sentencing Guidelines was more than one point. Because of a prior driving-under-the-influence conviction in Georgia, for which he was on probation at the time of his arrest, his criminal history score was three points. Therefore, the district court found defendant ineligible for a sentence reduction. Defendant argued that at the time of his plea to the DUI charge he was not properly informed of his right to counsel and did not validly waive that right, so that the DUI charge was in violation of the Constitution. The court held that the government had the burden of persuasion, but only once the defendant produced objective evidence sufficient to support a reasonable inference that his right to counsel was not validly waived. Accordingly, the court remanded so that the district court could reexamine the evidence introduced by defendant. If defendant has produced objective evidence sufficient to support a reasonable inference that he did not validly waive the right to counsel, then the government must, by a preponderance of the evidence, persuade the court that the waiver was in fact valid. View "United States v. Martinez-Cruz" on Justia Law