Justia Criminal Law Opinion Summaries

The DC Circuit affirmed defendant's 172 month sentence after he pleaded guilty to distribution of child pornography. The court held that the government's recidivism comment was only that—a comment—and appeared to have had no influence on the length of imprisonment to which defendant was sentenced. Defendant's sentence was also procedurally reasonable. However, the court vacated two conditions of supervised release: notifying the probation office when he establishes a significant romantic relationship and informing the other party of his prior criminal sex offenses, and penile plethysmograph testing. View "United States v. Rock" on Justia Law

Precedent requires the district court to consider each and every non-frivolous argument for mitigation, but does not require the judge to address expressly each argument on the record when pronouncing the sentence. The D.C. Circuit affirmed defendant's 132 month sentence after he was convicted of criminal conduct involving child pornography, holding that the district court committed no obvious or plain error. In this case, defendant failed to show that it was an obvious error for the district court to fail to expressly state that all of defendant's mitigation arguments were appropriately considered but nonetheless rejected. View "United States v. Pyles" on Justia Law

Appellant appealed the district court's dismissal of his habeas petition as time-barred, seeking a certificate of appealability (COA) from the DC Circuit. Because the petition was plainly time-barred and no jurist of reason could take issue with the procedural ruling by the district court, the court denied his request for a COA without having to reach his constitutional claim. View "Blount v. United States" on Justia Law

Defendant was convicted of unlawful possession with intent to distribute 100 grams or more of PCP (Count 1), unlawful possession of a firearm or ammunition by a person convicted of a felony (Count 2), and using, carrying, and possessing a firearm during a drug trafficking offense (Count 3). The DC Circuit reversed defendant's conviction on Counts 1 and 3, holding that the evidence was equivocal about his relationship to the PCP and his ability to exercise dominion and control over it. Therefore, the evidence was insufficient to show that he constructively possessed the PCP and thus insufficient to show a drug trafficking offense. The court affirmed defendant's conviction on Count 2, holding that his evidentiary and constitutional challenges did not warrant a reversal of his conviction for unlawful possession of a firearm by a convicted felon. View "United States v. Dorman" on Justia Law

Plaintiff, a federal prisoner, filed a pro se petition seeking relief by way of writ from what he alleged to be an illegally imposed sentence. The DC Circuit rejected plaintiff's claims under the international doctrine of specialty and the international doctrine of dual criminality. Even assuming that 18 U.S.C. 3192 created an implied individual claim for relief and that the district court would have the authority to compel the President to perform this duty, the only relief that plaintiff seeks is release from a conviction and sentence which he claims were imposed in violation of the Constitution and laws of the United States. The court explained that plaintiff's arguments classically described habeas relief. The court rejected plaintiff's remaining arguments and affirmed the district court's dismissal based on lack of jurisdiction. View "Day v. Trump" on Justia Law

The DC Circuit reversed the district court's grant of summary judgment in favor of the government based on claimants' lack of Article III standing in a civil forfeiture case. The court held that claimants met their burden of making an assertion of ownership and provided some evidence of ownership to establish standing. The court explained that credibility determinations, the weighing of the evidence, and the drawing of legitimate inferences from the facts were jury functions and not those of a judge. In this case, the record was devoid of contradictory evidence, claimants consistently maintained that the money was theirs, nothing in their account was physically impossible, and the couple explained how they came to own the money in considerable detail. Accordingly, the court reversed and remanded. View "United States v. $17,900.00" on Justia Law

Plaintiff filed suit against defendant, the former chair of the United States Parole Commission, alleging that plaintiff's denials of parole were infected by unconstitutional decisionmaking. The district court dismissed the case sua sponte, concluding that parole commissioners were entitled to absolute immunity from such lawsuits. The DC Circuit affirmed on the ground that defendant was entitled to qualified immunity. The court explained that, even under the most generous reading of the complaint, defendant was entitled to qualified immunity as to each of the five claims alleged against him. View "Redmond v. Fulwood, Jr." on Justia Law