Justia Criminal Law Opinion Summaries

Sonny Ramdeo, while working as a payroll director for Promise Healthcare, recommended the company hire PayServ Tax, which he falsely claimed was a subsidiary of Ceridian Corporation. In reality, PayServ was Ramdeo’s own company, and he diverted over $20 million from Promise to fund a charter airline service. After Promise’s auditors discovered discrepancies, Ramdeo was arrested and pled guilty to wire fraud and money laundering. He was sentenced to twenty years in prison, followed by three years of supervised release, and ordered to pay $21,442,173 in restitution.Ramdeo challenged his conviction and restitution amount on direct appeal, which was unsuccessful. He then sought a writ of audita querela to contest the restitution amount, which the district court recharacterized as a petition for coram nobis and subsequently denied. The Eleventh Circuit declined to address the merits of his claim. Ramdeo also filed a 28 U.S.C. § 2255 petition, which the district court denied as frivolous and meritless. The Eleventh Circuit affirmed this decision. Ramdeo later filed a pro se petition for a writ of error coram nobis, arguing ineffective assistance of counsel, prosecutorial misconduct, and new financial evidence. The district court denied the petition, stating that prisoners in federal custody are ineligible for coram nobis relief.The United States Court of Appeals for the Eleventh Circuit reviewed the case and determined that being in custody does not categorically bar a petitioner from seeking coram nobis relief for non-custodial aspects of their sentence, such as restitution. The court vacated the district court’s order and remanded the case for further proceedings, emphasizing that coram nobis is an extraordinary remedy available when no other remedy is available, and the petitioner presents sound reasons for not seeking relief earlier. View "Ramdeo v. United States" on Justia Law

The defendant, Laquawn Lewis, was charged with attempted murder, robbery, assault, and obstruction of governmental administration. Leading up to his trial, Lewis expressed dissatisfaction with his appointed counsel and filed various pro se motions. He eventually requested to represent himself, stating his intention to proceed pro se. The court denied his request without conducting the required inquiry into whether his decision was knowing, voluntary, and intelligent.At trial, Lewis reiterated his desire to represent himself, but the court again denied his request and proceeded with jury selection. Lewis later pleaded guilty to avoid a potential life sentence based on an incorrect assumption about his status as a persistent felony offender. After realizing the error, defense counsel moved to withdraw the guilty plea, which the court granted. Lewis renewed his request to represent himself, but the court deferred the decision until the trial date and ultimately denied it again. Lewis was convicted of all charges except attempted murder and sentenced to 25 years' incarceration and 5 years' post-release supervision.The Appellate Division affirmed the judgment, holding that Lewis's requests to proceed pro se were not unequivocal and that his legal sufficiency argument was unpreserved and without merit. A Judge of the Court of Appeals granted Lewis leave to appeal.The New York Court of Appeals concluded that the trial court violated Lewis's constitutional right to self-representation by denying his unequivocal request to proceed pro se without the requisite inquiry. The court held that Lewis's request was clear and timely, and the trial court's failure to conduct an inquiry warranted a new trial. The court also found that Lewis's legal sufficiency argument was unpreserved. Consequently, the Court of Appeals reversed the Appellate Division's order and granted Lewis a new trial. View "People v Lewis" on Justia Law

Lawrence Davonn Foye was placed on court-supervised parole after being convicted of fleeing in a vehicle with reckless indifference. His parole conditions included not violating any laws, avoiding disreputable persons, and abstaining from drug use. In January 2023, his probation officer filed a petition to revoke his parole, alleging three violations: using marijuana, being charged with first-degree murder, and associating with a disreputable person. Following a hearing, the Circuit Court of Kanawha County revoked his parole and imposed the underlying sentence.The Circuit Court found that the State presented sufficient evidence to support the parole violations. Detective Adkins testified about the murder investigation, corroborating information from a cooperating witness with cell phone data and video footage. The court also noted that Foye did not contest the allegations of drug use and associating with a disreputable person. The court applied the "reasonable cause" standard from West Virginia Code § 62-12-10(a)(1) to revoke Foye's parole.The Supreme Court of Appeals of West Virginia reviewed the case and affirmed the Circuit Court's decision. The court clarified that the standard of proof for a final parole or probation revocation hearing under West Virginia Code § 62-12-10(a)(1) is proof by a preponderance of the evidence. The court found that the State met this standard by presenting sufficient evidence of all three parole violations. The court also addressed the procedural due process requirements, ensuring that Foye's rights were protected during the revocation process. View "State v. Foye" on Justia Law

Edwin Leo Brown was indicted in October 2016 on four counts of possession with intent to distribute cocaine base and one count of being a felon in possession of a firearm. The government had evidence of Brown selling cocaine base and discovered a firearm upon his arrest. Brown faced up to 90 years in prison. His attorney, Frank Harper, initially advised him that he was likely facing up to 120 months’ imprisonment and presented two plea agreements limiting his prison exposure to ten years. Brown, skeptical of Harper’s advice, did not trust him and Harper withdrew as counsel. Brett Wentz then became Brown’s attorney and erroneously advised him that his sentencing exposure would be the same whether he accepted a plea deal or not. Brown rejected the plea offers and later pleaded guilty to all counts, receiving a 210-month sentence.The United States District Court for the Eastern District of North Carolina found that Brown’s attorney performed deficiently but concluded that Brown failed to demonstrate he was prejudiced by his attorney’s advice. The magistrate judge recommended denying Brown’s motion to vacate his sentence, stating that Brown presented no contemporaneous evidence to support his claim that he would have accepted the plea agreement if properly advised. The district court adopted this recommendation and denied Brown’s motion.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and found that the district court erred in applying the standard from Lee v. United States, which concerns accepted plea deals, to Brown’s case involving a rejected plea deal. The Fourth Circuit held that Brown demonstrated a reasonable probability that he would have accepted the plea offer if properly advised, given the significant disparity between the plea offer and the sentence he received. The court reversed the district court’s denial of relief, remanded the case, and required the government to re-offer Brown the same plea agreements. View "United States v. Brown" on Justia Law

Shakira Martinez was convicted by a jury in the District of Delaware for multiple money laundering offenses related to a drug trafficking operation run by her husband, Omar Morales Colon. The District Court sentenced her to 108 months of imprisonment. After her sentencing, the United States Sentencing Commission enacted a retroactive amendment to the Sentencing Guidelines, allowing certain offenders with no criminal history a two-point reduction in their total offense level. Martinez argued that the appellate court should vacate her sentence and remand for resentencing in light of this amendment.The District Court determined Martinez’s total offense level to be 30, with a criminal history category of I, resulting in a recommended sentencing range of 97 to 121 months. Martinez requested a downward variance due to psychological disorders, but the court denied this request and sentenced her to 108 months. Martinez appealed, and during the appeal process, the Sentencing Commission made amendments to the Guidelines retroactive. Martinez then sought to have her sentence vacated and remanded for resentencing under the new Guidelines.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that it has the discretionary authority under 28 U.S.C. § 2106 to vacate a sentence and remand for resentencing in light of a retroactive Guidelines amendment. The court found that granting this relief would promote judicial economy and serve the interest of justice. Therefore, the court vacated Martinez’s sentence and remanded the case to the District Court for resentencing consistent with the retroactive Guidelines amendment. View "USA v. Martinez" on Justia Law

Chadlen Dewayne Smith was convicted of sexual exploitation of a child by possession of sexually exploitative material. The case began when Smith was arrested for stalking a police dispatcher. Following his arrest, law enforcement impounded his vehicle and conducted an inventory search, during which they seized electronic devices containing sexually exploitative materials. Smith challenged the district court’s denial of his motion to suppress the evidence found on these devices.The District Court of the First Judicial District, Kootenai County, denied Smith’s motion to suppress, concluding that there was probable cause for his arrest for stalking and that the impoundment and subsequent inventory search of his vehicle were reasonable and conducted according to standard police procedures. Smith was convicted by a jury of sexual exploitation of a child but acquitted of distributing obscene material. He appealed the conviction, arguing that the evidence obtained from the inventory search should have been suppressed.The Supreme Court of the State of Idaho reviewed the case and reversed the district court’s decision. The court held that the State did not meet its burden to show that the police officer’s decision to impound Smith’s vehicle served a community caretaking purpose. The impoundment was deemed unreasonable under the Fourth Amendment, making the subsequent inventory search unconstitutional. Consequently, the evidence obtained from the search was inadmissible, leading to the vacating of Smith’s conviction. The court emphasized that the impoundment must be reasonable under all circumstances known to the police at the time and must serve a legitimate community caretaking function. View "State v. Smith" on Justia Law

Eric Brenes-Colon was arrested following an investigation into his co-conspirator's trafficking of firearms and large quantities of cocaine, marijuana, and MDMA. Brenes-Colon obtained cocaine from Puerto Rico and provided it to his co-conspirator for distribution. During a search of the co-conspirator's apartment, where Brenes-Colon was living, agents found drugs, drug paraphernalia, a firearm, cash, and evidence linking Brenes-Colon to the apartment. He was charged with conspiracy to distribute and possess with intent to distribute 500 grams or more of cocaine, possession with intent to distribute 500 grams or more of cocaine, and possession with intent to distribute MDMA. Brenes-Colon pleaded guilty to all charges.The United States District Court for the Middle District of Florida sentenced Brenes-Colon to 108 months’ imprisonment. The court emphasized the seriousness of his criminal activities due to the large volume of drugs trafficked, stating that illegal drugs are the leading cause of death for Americans aged 18 to 35. Brenes-Colon appealed, arguing that the court's statement was a clearly erroneous fact and that it constituted procedural error in determining his sentence.The United States Court of Appeals for the Eleventh Circuit reviewed the case for plain error, as Brenes-Colon did not object to his sentence in the lower court. The appellate court found that the district court did not commit plain error. It held that the district court was entitled to rely on its experience and common sense in sentencing, and that the statement about the deadliness of illegal drugs was not required to be supported by empirical studies in the record. The appellate court affirmed the district court's sentence, concluding that Brenes-Colon did not demonstrate that the alleged error affected his substantial rights or the fairness of the judicial proceedings. View "United States v. Brenes-Colon" on Justia Law

Malgum Whiteside, Jr. was charged with being a felon in possession of firearms after police found the weapons during a search of his residence. The search was conducted while officers were looking for evidence related to stalking charges against Whiteside. Whiteside moved to suppress the firearms, arguing that the search warrant was invalid and no warrant exception applied. The district court denied the motion, and Whiteside pleaded guilty while reserving the right to appeal the suppression ruling.The United States District Court for the Western District of Michigan denied Whiteside's motion to suppress, finding that the warrant was valid despite the judge not signing the warrant itself, only the affidavit. The court also found that there was a sufficient nexus between the place to be searched and the evidence sought. Additionally, the court ruled that even if the warrant was invalid, the good-faith exception to the warrant requirement would apply, and the firearms were in plain view.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The Sixth Circuit held that the warrant was validly issued despite the lack of a signature on the warrant itself, as there was clear and contemporaneous evidence that the judge made the necessary probable cause determination. The court also found that the warrant affidavit established a sufficient nexus between Whiteside's residence and the evidence of stalking. Furthermore, the court concluded that the plain-view doctrine applied to the seizure of the firearms, as the incriminating character of the firearms was immediately apparent to the officers, who knew Whiteside was a felon. Therefore, the seizure of the firearms was valid, and the district court's denial of the motion to suppress was affirmed. View "United States v. Whiteside" on Justia Law

Freddie Knipp, Jr. was convicted of two counts of distributing methamphetamine and one count of knowingly selling a firearm to a felon. The convictions stemmed from controlled drug buys and a firearm purchase facilitated by law enforcement, with Knipp selling methamphetamine to Larry Eldridge and purchasing a firearm for him, knowing Eldridge was a felon. Eldridge cooperated with law enforcement, leading to Knipp's arrest and subsequent trial.The United States District Court for the Eastern District of Kentucky denied Knipp's motion to dismiss the firearm charge, which he argued violated the Second Amendment. Knipp was found guilty on all counts by a jury and sentenced to 138 months in prison for the drug charges and 120 months for the firearm charge, to be served concurrently.The United States Court of Appeals for the Sixth Circuit reviewed the case. Knipp challenged the constitutionality of 18 U.S.C. § 922(d)(1), which prohibits selling firearms to felons, arguing it violated the Second Amendment. The court applied the two-step framework from N.Y. State Rifle & Pistol Ass’n, Inc. v. Bruen and found that while the Second Amendment covers the right to acquire firearms, historical precedent supports disarming dangerous individuals, including felons. Thus, the court upheld the statute's constitutionality.Knipp also contested the admission of Eldridge's testimony about prior drug transactions, arguing it was impermissible propensity evidence. The court found any potential error in admitting this evidence to be harmless, given the substantial other evidence of Knipp's guilt.Finally, Knipp argued that the district court erred in calculating his sentence by including drug quantities from prior transactions based on Eldridge's testimony. The appellate court found no clear error in the district court's credibility determination and upheld the sentence.The Sixth Circuit affirmed Knipp's conviction and sentence. View "United States v. Knipp" on Justia Law

Petitioner Jayden Demarko McDaniel, a Black individual, was charged with multiple felonies, including attempted first-degree murder and gang-related offenses. McDaniel alleged that he was disparately charged with gang enhancements due to his race, in violation of the California Racial Justice Act of 2020 (RJA). He sought discovery of evidence from the prosecution to support his claim, arguing that statistical evidence indicated a racial disparity in the application of gang enhancements in San Mateo County.The San Mateo County Superior Court denied McDaniel's motion for discovery, concluding that he failed to demonstrate "good cause" as required by the RJA. The court found that McDaniel's statistical evidence lacked context and did not provide specific facts about his case or other similar cases involving non-Black defendants. McDaniel then filed a petition for writ of mandate with the Court of Appeal, which was initially denied without prejudice. He subsequently refiled his petition, which was again denied by the superior court.The California Court of Appeal, First Appellate District, Division Three, reviewed the case and concluded that McDaniel had met the low threshold for demonstrating good cause for discovery under the RJA. The court held that McDaniel's county-specific statistical evidence, supported by an expert declaration, presented a plausible factual foundation for his claim of racial bias in charging decisions. The court emphasized that the RJA's discovery standard is intended to be broad and flexible, allowing for various types of evidence, including statistical data, to support a claim of racial disparity.The Court of Appeal vacated the trial court's order and remanded the case for a new hearing to reconsider McDaniel's discovery motion, directing the trial court to weigh the potential probative value of the requested information against the burdens of gathering it. View "McDaniel v. Superior Court" on Justia Law