Justia Criminal Law Opinion Summaries

While conducting a routine vehicle stop, police arrested petitioner, a passenger of the vehicle, for giving a false name. After handcuffing him and securing the scene, the police searched the vehicle and found petitioner's revolver. Petitioner was subsequently indicted on charges of being a felon in possession of a firearm. In a suppression motion, petitioner acknowledged that the search of the vehicle complied with existing Eleventh Circuit precedent interpreting New York v. Belton, but he raised a Fourth Amendment challenge to preserve the issue on appeal. The District Court denied the motion and petitioner was convicted. While his appeal was pending, the Court announced, in Arizona v. Gant, a new rule governing automobile searches incident to arrests of recent occupants. At issue was whether to apply the exclusionary rule when the police conducted a search in compliance with binding precedent that was later overruled. Because the suppression would do nothing to deter police misconduct in these circumstances, and because it would come at a high cost to both the truth and the public safety, the Court held that the searches conducted in objectionable reliance on binding appellate precedent were not subject to the exclusionary rule. Accordingly, the Court affirmed the suppression of the revolver and petitioner's conviction.

J.D.B., a thirteen-year-old seventh-grade student, was taken from his classroom to a closed-door conference room where uniformed police and school administrators questioned him for at least 30 minutes regarding two home break-ins nearby. Before beginning, they did not give J.D.B. Miranda warnings, the opportunity to call his legal guardian, or tell him he was free to leave the room. After J.D.B. subsequently confessed to the break-ins and wrote a statement at the request of police, two juvenile petitions were filed against him. J.D.B.'s public defender moved to suppress his statements and the evidence derived therefrom, arguing that he had been interrogated in a custodial setting without being afforded Miranda warnings and that his statements were involuntary. At issue was whether the age of a child subjected to police questioning was relevant to the custody analysis of Miranda v. Arizona. The Court held that it was beyond dispute that children would often feel bound to submit to police questioning when an adult in the same circumstances would feel free to leave. Seeing no reason for police officers or courts to blind themselves to that commonsense reality, the Court held that a child's age group properly informed the Miranda custody analysis. Accordingly, the Court reversed and remanded to the state courts to address whether J.D.B. was in custody when he was interrogated, taking account of all of the relevant circumstances of the interrogation, including his age at the time.

Petitioner was convicted of, inter alia, smuggling unauthorized aliens into the United States. The District Court imposed a 51 month prison sentence, reasoning that petitioner should serve that long in order to qualify for and complete the Bureau of Prisons' Residential Drug Abuse Program ("RDAP"). At issue was whether the Sentencing Reform Act ("SRA"), 18 U.S.C. 3582(a), precluded federal courts from imposing or lengthening a prison term in order to promote a criminal defendant's rehabilitation. The Court held that the text, context, and history of section 3582(a) precluded sentencing courts from imposing or lengthening a prison term to promote an offender's rehabilitation. The Court also held that Amicus' attempts to recast what the SRA said about rehabilitation were unavailing. The court further held that the record indicated that the District Court may have increased the length of petitioner's sentence to ensure her completion of RDAP, something a court could not do. Accordingly, the Court reversed and remanded for further proceedings and held that the Ninth Circuit was left to consider on remand the effect of petitioner's failure to object to the sentence when imposed.

Petitioner was convicted for distribution of 50 grams or more of cocaine base under section 841(a)(1) and (b)(1)(A)(iii) of the Anti-Drug Abuse Act of 1986 ("ADAA"), 21 U.S.C. 841(a)(1) and (b)(1)(A)(iii), and sentenced to the 120 months prison term mandated by the statute. At issue was whether the term "cocaine base" as used in the statute referred generally to cocaine in its chemically basic form or exclusively to what was colloquially known as "crack cocaine." The court held that "cocaine base," as used in section 841(b)(1), meant not just "crack cocaine," but cocaine in its chemically basic form where, at the time the statute was enacted, "cocaine" was commonly used to refer to powder cocaine, and the scientific and medical literature often used "cocaine" to refer to all cocaine-related substances, including ones that were not chemically basic; where Congress had good reason to include the term "cocaine" in clause (ii), and the slight inconsistency created by its use of "cocaine base" in clause (iii) was insufficient reason to adopt petitioner's interpretation of the statute; and where petitioner's additional arguments were unpersuasive. Accordingly, the court affirmed the judgment of the First Circuit adhering to its precedent holding that "cocaine base" referred to all forms of cocaine.

When petitioner pleaded guilty to being a felon in possession of a firearm, he had prior convictions for at least three felonies, including the state-law crime of "using a vehicle" to "knowingly or intentionally" "flee from a law enforcement officer" after being ordered to stop pursuant to Ind. Code 35-44-3-3(b)(1)(A). The Federal District Court decided that the prior convictions subjected petitioner to the 15-year mandatory minimum prison term that the Armed Career Criminal Act ("ACCT"), 18 U.S.C. 924(e), provided for an armed defendant who had three prior "violent felony" convictions. Rejecting petitioner's argument that his vehicle flight felony was not "violent" under the ACCA, the Seventh Circuit affirmed. The Court held that felony vehicle flight, as proscribed by Indiana law, was a violent felony for purposes of the ACCA where felony vehicle flight presented a serious potential risk of physical injury to another; where, because felony vehicle flight was not a strict-liability, negligence, or recklessness crime and was, as a categorical matter, similar in risk to the crimes listed in the residual clause, it was a violent felony; where Indiana treated subsection 35-44-3-3(b)(1)(A) and 35-44-3-3(b)(1)(B) as felonies of the same magnitude carrying similar prison terms; and where Congress had power to enact the residual clause to impose enhanced punishment for unlawful firearm possession when the relevant prior offenses involved a potential risk of physical injury similar to that presented by several enumerated offenses. Accordingly, the court affirmed the judgment of the Seventh Circuit.

Defendant pleaded guilty to unlawful possession of a firearm by a felon, 18 U.S.C. 922(g)(1), and possession with intent to distribute cocaine base, 21 U.S.C. 841(a)(1). At sentencing, the district court determined that defendant qualified for the Armed Career Criminal Act's ("ACCA") sentencing enhancement and defendant conceded that two of his prior convictions were for "violent felonies." Defendant argued, however, that none of his six state drug trafficking convictions were for "serious drug offenses" because those crimes no longer carried a "maximum term of imprisonment of ten years or more" pursuant to 18 U.S.C. 924(e)(1). At issue was how a federal court should determine the maximum sentence for a prior state drug offense for ACCA purposes. The Court held that the "maximum term of imprisonment" for a defendant's prior state drug offense was the maximum sentence applicable to his offense when he was convicted of it where the ACCA's plain text required this result by mandating that the court determine whether a "previous conviction" was for a serious drug offense and where the ACCA's broader context confirmed this interpretation. Accordingly, the district court properly applied ACCA's sentencing enhancement to defendant because all of his six prior drug convictions were for "serious drug offenses."

Respondent alleged that, after the September 11th terrorist attacks, then-Attorney General Ashcroft authorized federal officials to detain terrorism suspects using the federal material-witness statute, 18 U.S.C. 3144. Respondent claimed that this pretextual detention policy led to his material-witness arrest as he was boarding a plane to Saudi Arabia. Respondent filed suit pursuant to Bivens v. Six Unknown Fed. Narcotics Agents challenging the constitutionality of Ashcroft's alleged policy. At issue was whether the former Attorney General enjoyed immunity from suit for allegedly authorizing federal prosecutors to obtain valid material-witness warrants for detention of terrorism suspects whom they would otherwise lack probable cause to arrest. The Court held that an objectively reasonable arrest and detention of a material witness pursuant to a validly obtained warrant could not be challenged as unconstitutional on the basis of allegations that the arresting authority had an improper motive. Because Ashcroft did not violate clearly established law, the Court need not address the more difficult question of whether he enjoyed absolute immunity. The judgment of the Court of Appeals was reversed and the case remanded for further proceedings.

Respondent's trial on federal drug and gun charges began 287 days after his arraignment. The Sixth Circuit agreed with the District Court that many of the 287 days were excludable under the lists of exclusions from the 70 day speedy trial period set forth in the Speedy Trial Act of 1974 ("Act"), 18 U.S.C. 3161(c)(1). However, the Sixth Circuit concluded that 9 days, during which three pretrial motions were pending, were not excludable because the motions did not actually cause a delay, or the expectation of delay, at trial. Since these 9 days were sufficient to bring the number of nonexcludable days above 70, the court found a violation of the Act. And given respondent had already served his prison sentence, the Sixth Circuit ordered the indictment dismissed with prejudice. The Court granted certiorari at the Government's request in order to review the Sixth Circuit's motion-by-motion causation test. The Court reversed the Sixth Circuit's determination and held that the Act contained no requirements that the filing of a pretrial motion actually caused, or was expected to cause, delay of a trial. Rather, section 3161(h)(1)(D) stopped the Speedy Trial clock from running automatically upon the filing of a pretrial motion irrespective of whether the motion had any impact on when the trial began. The Sixth Circuit also misinterpreted section 3161(h)(1)(F), which excluded from the 70 day calculation "delay resulting from transportation of any defendant... to and from places of examination... except that any time consumed in excess of ten days... shall be presumed to be unreasonable." Although the Sixth Circuit's interpretations of subparagraphs (D) and (F) were both mistaken, the conclusions the Court drew from its interpretations in relevant part canceled each other out, such that the Court's ultimate conclusion that respondent's trial failed to comply with the Act's deadline was correct.

While preparing to rob a bank, petitioner and others were discovered by a local police officer, whom petitioner killed. Petitioner was convicted of violating the federal witness tampering statute, 18 U.S.C. 1512(a)(1)(C). At issue was how the language of the statute applied when a defendant killed a victim, with an intent to prevent a communication about the commission or possible commission of a federal offense, but to law enforcement officers in general rather than to some specific law enforcement officer or set of officers which defendant had in mind. The Court held that in such circumstances, the Government must establish a section 1512(a)(1)(C) violation by showing there was a reasonable likelihood that a relevant communication would have been made to a federal officer. The Court also held that, because petitioner's argument that the evidence was insufficient to satisfy a "reasonable likelihood" standard was not raised at trial, the lower courts must determine whether, and how, the standard applied in this case.

The State appealed a three-judge district court order directing California to remedy two ongoing violations of the Cruel and Unusual Punishments Clause, a guarantee binding on the States by the Due Process Clause of the Fourteenth Amendment, by reducing the prison system population where the violations were the subject of two class actions involving a class of prisoners with serious mental disorders and a class of prisoners with serious medical conditions. At issue was whether the remedial order issued by the three-judge court was consistent with requirements and procedures set forth in a congressional statute, the Prison Litigation Reform Act of 1995 ("PLRA"), 18 U.S.C. 3626. The Court held that the court-mandated population limit was necessary to remedy the violation of prisoners' constitutional rights and was authorized by the PLRA.