Justia Criminal Law Opinion Summaries

The case involves former President Donald Trump, who was indicted on four counts for conduct that occurred during his presidency following the November 2020 election. The indictment alleged that Trump conspired to overturn the election by spreading knowingly false claims of election fraud. Trump moved to dismiss the indictment based on Presidential immunity, arguing that a President has absolute immunity from criminal prosecution for actions performed within his official responsibilities. The District Court denied Trump’s motion to dismiss, holding that former Presidents do not possess federal criminal immunity for any acts. The D.C. Circuit affirmed this decision.The Supreme Court of the United States held that under the constitutional structure of separated powers, a former President is entitled to absolute immunity from criminal prosecution for actions within his conclusive and preclusive constitutional authority. He is also entitled to at least presumptive immunity from prosecution for all his official acts. However, there is no immunity for unofficial acts. The Court vacated the judgment of the D.C. Circuit and remanded the case for further proceedings consistent with its opinion. The Court emphasized that the President is not above the law, but under the system of separated powers, the President may not be prosecuted for exercising his core constitutional powers. View "Trump v. United States" on Justia Law

The case revolves around the interpretation of the Sarbanes-Oxley Act of 2002, specifically 18 U.S.C. §1512(c)(2), which imposes criminal liability on anyone who corruptly obstructs, influences, or impedes any official proceeding, or attempts to do so. The petitioner, Joseph Fischer, was charged with violating this provision for his actions during the Capitol breach on January 6, 2021. Fischer moved to dismiss the charge, arguing that the provision only criminalizes attempts to impair the availability or integrity of evidence. The District Court granted his motion, but a divided panel of the D.C. Circuit reversed and remanded for further proceedings.The Supreme Court of the United States held that to prove a violation of §1512(c)(2), the Government must establish that the defendant impaired the availability or integrity for use in an official proceeding of records, documents, objects, or other things used in an official proceeding, or attempted to do so. The Court reasoned that the "otherwise" provision of §1512(c)(2) is limited by the list of specific criminal violations that precede it in (c)(1). The Court also considered the broader context of §1512 in the criminal code and found that an unbounded interpretation of subsection (c)(2) would render superfluous the careful delineation of different types of obstructive conduct in §1512 itself. The Court vacated the judgment of the D.C. Circuit and remanded the case for further proceedings consistent with its opinion. View "Fischer v. United States" on Justia Law

The case involves James Snyder, the former mayor of Portage, Indiana, who was convicted of accepting an illegal gratuity in violation of 18 U.S.C. §666(a)(1)(B). In 2013, while Snyder was mayor, Portage awarded two contracts to a local truck company, Great Lakes Peterbilt, and purchased five trash trucks from the company for about $1.1 million. In 2014, Peterbilt paid Snyder $13,000. The FBI and federal prosecutors suspected that the payment was a gratuity for the City’s trash truck contracts, but Snyder claimed that the payment was for his consulting services as a contractor for Peterbilt. A federal jury convicted Snyder, and the District Court sentenced him to 1 year and 9 months in prison. On appeal, Snyder argued that §666 criminalizes only bribes, not gratuities. The Seventh Circuit affirmed Snyder’s conviction.The Supreme Court of the United States reversed the Seventh Circuit's decision. The Court held that 18 U.S.C. §666 proscribes bribes to state and local officials but does not make it a crime for those officials to accept gratuities for their past acts. The Court reasoned that the statutory text, history, structure, punishments, federalism principles, and fair notice considerations all support the conclusion that §666 is a bribery statute and not a gratuities statute. The Court concluded that a state or local official does not violate §666 if the official has taken the official act before any reward is agreed to, much less given. Although a gratuity offered and accepted after the official act may be unethical or illegal under other federal, state, or local laws, the gratuity does not violate §666. The case was remanded for further proceedings consistent with the Court's opinion. View "Snyder v. United States" on Justia Law

In December 2019, Zackey Rahimi, the respondent, had a violent altercation with his girlfriend, C. M., who is also the mother of his child. Rahimi grabbed C. M., dragged her back to his car, and shoved her in, causing her to hit her head. When a bystander witnessed the incident, Rahimi retrieved a gun from his car. C. M. managed to escape, and Rahimi fired his gun, though it is unclear whether he was aiming at C. M. or the witness. Following this incident, C. M. sought a restraining order against Rahimi, which was granted by a state court in Texas. The order included a finding that Rahimi had committed “family violence” and posed “a credible threat” to the “physical safety” of C. M. or their child. The order also suspended Rahimi’s gun license for two years. Despite the order, Rahimi violated it by approaching C. M.’s home and contacting her through social media. He was later charged with aggravated assault with a deadly weapon for threatening another woman with a gun.Rahimi was indicted for possessing a firearm while subject to a domestic violence restraining order, in violation of 18 U. S. C. §922(g)(8). Rahimi moved to dismiss the indictment, arguing that Section 922(g)(8) violated his Second Amendment right to keep and bear arms. The District Court denied his motion, and Rahimi pleaded guilty. On appeal, he again raised his Second Amendment challenge, which was denied. Rahimi petitioned for rehearing en banc.The Supreme Court of the United States held that when a restraining order contains a finding that an individual poses a credible threat to the physical safety of an intimate partner, that individual may—consistent with the Second Amendment—be banned from possessing firearms while the order is in effect. The Court found that since the founding, the nation's firearm laws have included provisions preventing individuals who threaten physical harm to others from misusing firearms. As applied to the facts of this case, Section 922(g)(8) fits comfortably within this tradition. The Court reversed the judgment of the Court of Appeals for the Fifth Circuit and remanded the case for further proceedings consistent with its opinion. View "United States v. Rahimi" on Justia Law

Paul Erlinger pleaded guilty to being a felon in possession of a firearm, a violation of 18 U.S.C. §922(g). At sentencing, the judge found Erlinger eligible for an enhanced sentence under the Armed Career Criminal Act (ACCA), which increases the penalty for a §922(g) conviction from a maximum of 10 years to a mandatory minimum of 15 years when the defendant has three or more qualifying convictions for offenses committed on different occasions. The Seventh Circuit later ruled that two of the offenses used for Erlinger’s sentence enhancement no longer qualified as ACCA predicate offenses. The District Court vacated Erlinger’s sentence and scheduled resentencing. At the resentencing hearing, prosecutors pursued an ACCA sentence enhancement based on a new set of 26-year-old convictions for burglaries committed by Erlinger over several days. Erlinger argued that the burglaries were part of a single criminal episode and did not occur on separate occasions, as required by ACCA. He also argued that the Fifth and Sixth Amendments required that a jury make that assessment. The District Court rejected Erlinger’s request for a jury and issued a 15-year enhanced sentence. On appeal, the government confessed error, admitting that the Constitution requires a jury to decide unanimously and beyond a reasonable doubt whether Erlinger’s prior offenses were committed on different occasions.The Supreme Court of the United States held that the Fifth and Sixth Amendments require a unanimous jury to make the determination beyond a reasonable doubt that a defendant’s past offenses were committed on separate occasions for ACCA purposes. The Court noted that the Sixth Amendment promises that in all criminal prosecutions, the accused has the right to a speedy and public trial, by an impartial jury. The Fifth Amendment further promises that the government may not deprive individuals of their liberty without due process of law. The Court has repeatedly cautioned that trial and sentencing practices must remain within the guardrails provided by these two Amendments. The Court vacated the judgment of the Court of Appeals for the Seventh Circuit and remanded the case for further proceedings consistent with its opinion. View "Erlinger v. United States" on Justia Law

The case involves the Sixth Amendment's Confrontation Clause, which guarantees a criminal defendant the right to confront the witnesses against him. The defendant, Jason Smith, was charged with various drug offenses after law enforcement officers found him with a large quantity of what appeared to be drugs and drug-related items. The seized items were sent to a crime lab for scientific analysis. Analyst Elizabeth Rast ran forensic tests on the items and concluded that they contained usable quantities of methamphetamine, marijuana, and cannabis. Rast prepared a set of typed notes and a signed report about the testing. However, Rast stopped working at the lab prior to trial, so the State substituted another analyst, Greggory Longoni, to provide an independent opinion on the drug testing performed by Rast. At trial, Longoni conveyed to the jury what Rast’s records revealed about her testing, before offering his “independent opinion” of each item’s identity. Smith was convicted. On appeal, he argued that the State’s use of a substitute expert to convey the substance of Rast’s materials violated his Confrontation Clause rights. The Arizona Court of Appeals rejected Smith’s challenge.The Supreme Court of the United States held that when an expert conveys an absent analyst’s statements in support of the expert’s opinion, and the statements provide that support only if true, then the statements come into evidence for their truth. The Court vacated the judgment of the Arizona Court of Appeals and remanded the case for further proceedings. The Court clarified that the Confrontation Clause still allows forensic experts to play a useful role in criminal trials. However, a state may not introduce the testimonial out-of-court statements of a forensic analyst at trial, unless she is unavailable and the defendant has had a prior chance to cross-examine her. The Court concluded that the State used Longoni to relay what Rast wrote down about how she identified the seized substances, and thus Longoni effectively became Rast’s mouthpiece. If the out-of-court statements were also testimonial, their admission violated the Confrontation Clause. View "Smith v. Arizona" on Justia Law

This case involves a dispute between Jascha Chiaverini, a jewelry store owner, and police officers from Napoleon, Ohio. The officers charged Chiaverini with three crimes: receiving stolen property, dealing in precious metals without a license, both misdemeanors, and money laundering, a felony. After obtaining a warrant, the police arrested Chiaverini and detained him for three days. However, county prosecutors later dropped the case. Chiaverini, believing that his arrest and detention were unjustified, sued the officers, alleging a Fourth Amendment malicious-prosecution claim under 42 U.S.C. §1983. To win this claim, he had to show that the officers brought criminal charges against him without probable cause, leading to an unreasonable seizure of his person.The District Court granted summary judgment to the officers, and the Court of Appeals for the Sixth Circuit affirmed. The Court of Appeals held that Chiaverini’s prosecution was supported by probable cause. In its decision, the court did not address whether the officers had probable cause to bring the money-laundering charge. The court believed that there was clearly probable cause to charge Chiaverini with the two misdemeanors. As long as one charge was supported by probable cause, it thought, a malicious-prosecution claim based on any other charge must fail.The Supreme Court of the United States held that the presence of probable cause for one charge in a criminal proceeding does not categorically defeat a Fourth Amendment malicious-prosecution claim relating to another, baseless charge. The parties, and the United States as amicus curiae, all agreed with this conclusion, which follows from both the Fourth Amendment and traditional common-law practice. The Supreme Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings consistent with its opinion. View "Chiaverini v. City of Napoleon" on Justia Law

Delilah Diaz was stopped at a U.S.-Mexico border port of entry, where border patrol officers discovered over 54 pounds of methamphetamine hidden in the car she was driving. Diaz was charged with importing methamphetamine, a charge that required the government to prove that Diaz knowingly transported the drugs. Diaz claimed she was unaware of the drugs in the car. To counter this claim, the government planned to call an expert witness, Homeland Security Investigations Special Agent Andrew Flood, to testify that drug traffickers generally do not entrust large quantities of drugs to people who are unaware they are transporting them. Diaz objected to this testimony under Federal Rule of Evidence 704(b), which prohibits an expert witness from stating an opinion about whether the defendant did or did not have a mental state or condition that constitutes an element of the crime charged or of a defense. The court ruled that Agent Flood could testify that most couriers know they are transporting drugs. Diaz was found guilty and appealed, challenging Agent Flood’s testimony under Rule 704(b).The Court of Appeals held that because Agent Flood did not explicitly opine that Diaz knowingly transported methamphetamine, his testimony did not violate Rule 704(b). Diaz appealed this decision to the Supreme Court of the United States.The Supreme Court affirmed the decision of the Court of Appeals. The Court held that expert testimony that "most people" in a group have a particular mental state is not an opinion about "the defendant" and thus does not violate Rule 704(b). The Court reasoned that Agent Flood did not express an opinion about whether Diaz herself knowingly transported methamphetamine. Instead, he testified about the knowledge of most drug couriers, which does not necessarily describe Diaz’s mental state. The Court concluded that because Agent Flood did not express an opinion about whether Diaz herself knowingly transported methamphetamine, his testimony did not violate Rule 704(b). View "Diaz v. United States" on Justia Law

The case revolves around the legality of bump stocks, accessories that allow semi-automatic rifles to fire at a rate similar to machine guns. The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) had long held that semi-automatic rifles equipped with bump stocks were not machine guns under the statute. However, following a mass shooting in Las Vegas, Nevada, where the shooter used bump stocks, the ATF reversed its position and issued a rule classifying bump stocks as machine guns.The case was first heard in the District Court, where Michael Cargill, who had surrendered two bump stocks to the ATF under protest, challenged the rule. Cargill argued that the ATF lacked statutory authority to classify bump stocks as machine guns because they did not meet the definition of a machine gun under §5845(b). The District Court ruled in favor of the ATF, concluding that a bump stock fits the statutory definition of a machine gun.The case was then taken to the Court of Appeals, which initially affirmed the District Court's decision but later reversed it after rehearing en banc. The majority of the Court of Appeals agreed that §5845(b) was ambiguous as to whether a semi-automatic rifle equipped with a bump stock fits the statutory definition of a machine gun. They concluded that the rule of lenity required resolving that ambiguity in Cargill's favor.The Supreme Court of the United States affirmed the decision of the Court of Appeals. The Court held that a semi-automatic rifle equipped with a bump stock is not a machine gun because it cannot fire more than one shot by a single function of the trigger. Furthermore, even if it could, it would not do so automatically. Therefore, the ATF exceeded its statutory authority by issuing a rule that classifies bump stocks as machine guns. View "Garland v. Cargill" on Justia Law

The case involves Danny Lee Jones, who was convicted of three murders committed with the intent to steal a gun collection. Jones brutally killed a man, his 7-year-old daughter, and his grandmother. After being found guilty, the trial court proceeded to sentencing. Under Arizona law, the court was required to impose a death sentence if it found one or more aggravating circumstances and no mitigating circumstances sufficiently substantial to call for leniency. The court found three aggravating circumstances and sentenced Jones to death. The Arizona Supreme Court affirmed the decision.Jones sought postconviction review, arguing that his attorney was ineffective. He claimed that his attorney should have retained an independent neuropsychologist, rather than relying on a court-appointed psychiatrist. The state court denied this claim. Jones then filed a habeas petition in Federal District Court, reasserting his ineffective-assistance-of-counsel claims. The District Court held an evidentiary hearing but concluded that Jones could not show prejudice because the additional information he presented barely altered the sentencing profile presented to the sentencing judge. The Ninth Circuit reversed, but the Supreme Court vacated that judgment and remanded for the Ninth Circuit to determine whether it had been proper to consider the new evidence presented at the federal evidentiary hearing.On reconsideration, the Ninth Circuit again granted habeas relief. The panel held that it was permissible to consider the new evidence and concluded that there was a reasonable probability that Jones would not have received a death sentence if that evidence had been presented at sentencing. The Supreme Court granted certiorari to review the Ninth Circuit’s interpretation and application of Strickland.The Supreme Court reversed the Ninth Circuit's decision, stating that it had departed from the well-established rules in at least three ways. The Supreme Court found that the Ninth Circuit failed to adequately take into account the weighty aggravating circumstances in this case, applied a strange Circuit rule that prohibits a court in a Strickland case from assessing the relative strength of expert witness testimony, and held that the District Court erred by attaching diminished persuasive value to Jones’s mental health conditions because it saw no link between those conditions and Jones’s conduct when he committed the three murders. The Supreme Court concluded that there was no reasonable probability that the evidence on which Jones relies would have altered the outcome at sentencing. View "Thornell v. Jones" on Justia Law