Justia Criminal Law Opinion Summaries

Michelle Rodriguez was arrested after South Pasadena police discovered her in possession of a significant quantity of stolen mail and financial information, including 140 pieces of mail from 110 victims, 19 checks, multiple bank account and social security numbers, credit and debit cards, and two California driver’s licenses. The driver’s licenses were found among the stolen mail and other items in her backpack and a bag in the vehicle. Rodriguez admitted she was seeking mail and acknowledged possession of the items.The United States District Court for the Central District of California charged Rodriguez with three offenses: possession of stolen mail, possession of at least 15 unauthorized access devices, and aggravated identity theft. Rodriguez ultimately pled guilty to possession of unauthorized access devices under 18 U.S.C. § 1029(a)(3), with the government agreeing to drop the other charges. At sentencing, the Probation Office calculated her Guidelines range, applying enhancements for number of victims and possession of authentication features, specifically the two California driver’s licenses. Rodriguez objected to the authentication feature enhancement, arguing it should require proof that she knowingly possessed such features with intent to defraud.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s interpretation of the Sentencing Guidelines de novo and its application for abuse of discretion. The Court held that U.S.S.G. § 2B1.1(b)(11)(A)(ii) applies based on simple possession of an authentication feature and does not require proof of mens rea or intent to defraud. The enhancement was properly applied to Rodriguez’s sentence, as she conceded possession of the driver’s licenses with authentication features. The Ninth Circuit affirmed the district court’s judgment. View "USA V. RODRIGUEZ" on Justia Law

Alfredo Juarez-Perez, a citizen of Mexico, was arrested in Sun Prairie, Wisconsin, after illegally reentering the United States for the third time. His criminal history spans decades, including multiple state convictions for sexual assault, failure to register as a sex offender, operating while intoxicated, and federal convictions for distributing cocaine and illegal reentry. He has repeatedly used aliases to elude law enforcement and violated conditions of release by failing to appear for legal proceedings. Upon his most recent arrest, U.S. Immigration and Customs Enforcement (ICE) lodged a detainer against him, and he was indicted for illegal reentry in October 2025.A magistrate judge in the United States District Court for the Western District of Wisconsin initially ordered Juarez-Perez released pending trial, reasoning that the ICE detainer eliminated the risk of flight because he would remain in government custody. The magistrate judge indicated that, absent the detainer, Juarez-Perez would pose a serious risk of flight under the Bail Reform Act. The government appealed this decision, and the district court revoked the release order, finding that Juarez-Perez’s criminal history, likely incentive to consent to deportation, repeated illegal reentries, and use of fraudulent documents presented a serious risk of flight. The district court concluded that no conditions could reasonably assure his appearance in court.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision and affirmed the denial of Juarez-Perez’s motion for release pending trial. The Seventh Circuit held that the presence of an ICE detainer does not preclude pretrial detention under the Bail Reform Act, and that Juarez-Perez’s history demonstrated a serious risk of flight and non-appearance. The court found that no conditions of release would reasonably assure his appearance, and accordingly denied his motion for release. View "USA v Juarez-Perez" on Justia Law

The defendant was convicted by a jury in Macomb Circuit Court of first-degree criminal sexual conduct for the sexual assault of his five-year-old daughter. He was originally sentenced to 360 to 550 months in prison, along with lifetime electronic monitoring and lifetime registration under Michigan’s Sex Offenders Registration Act (SORA). After an initial appeal, his sentence was vacated for exceeding the statutory minimum without justification, and upon resentencing, he received 300 to 480 months, with the same monitoring and registration requirements.The Michigan Court of Appeals first affirmed the conviction but vacated the original sentence and remanded for resentencing. On remand, the trial court imposed a new sentence, and the defendant again appealed, arguing that lifetime registration under SORA was cruel or unusual punishment, and that lifetime electronic monitoring was both cruel or unusual and constituted an unreasonable search. The Court of Appeals affirmed the revised sentence and rejected his constitutional challenges.The Michigan Supreme Court reviewed the case, focusing on whether the 2021 SORA, as amended, constituted cruel or unusual punishment under the Michigan Constitution, and whether lifetime electronic monitoring posed constitutional issues. The Supreme Court held that the 2021 SORA does constitute punishment but is not cruel or unusual, either facially or as applied to the defendant. The Court found that the statute’s requirements, although burdensome and excessive in some respects, are not grossly disproportionate to the offense for Tier III offenders. The Supreme Court affirmed the Court of Appeals’ judgment regarding SORA but vacated it to the extent that its reasoning was inconsistent with the Supreme Court’s opinion. The Court denied leave on the defendant’s challenges related to lifetime electronic monitoring. View "People Of Michigan v. Kardasz" on Justia Law

Three business entities and individuals associated with the operation of a retail store in Cedar Park, Texas, were subject to enforcement under a city ordinance banning “head shops”—stores selling items commonly used to ingest or inhale illegal substances. After receiving notices from the City, two of the appellants were charged in municipal court and fined for violating the ordinance, while the third appellant, a related business entity, was not charged. Following the municipal court’s judgment, the two charged parties appealed for a trial de novo in the county court, which annulled the municipal court’s judgment and began new criminal proceedings. They also pursued state habeas relief, which was still ongoing at the time of this appeal.Separately, the appellants filed a lawsuit in the United States District Court for the Western District of Texas, challenging the ordinance’s validity and constitutionality under federal and state law, and seeking declaratory and injunctive relief. The district court dismissed all claims as barred by the doctrine announced in Heck v. Humphrey, which precludes certain civil claims that would imply the invalidity of existing criminal convictions. The district court also dismissed a distinct claim related to termination of utility services.On appeal, the United States Court of Appeals for the Fifth Circuit held that because the municipal court’s judgments were annulled by the trial de novo and criminal proceedings were still pending under Texas law, there were no outstanding convictions to trigger the Heck bar. Thus, the Fifth Circuit reversed the district court’s dismissal of the claims challenging the ordinance and remanded for further proceedings. The court affirmed the district court’s dismissal of the standalone water termination claim, as the appellants had disclaimed any intent to pursue it. View "Kleinman v. City of Cedar Park" on Justia Law

Alvin Beasley was charged with being a felon in possession of a firearm after police responded to gunshots at his ex-girlfriend’s house in Danville, Illinois. Officers saw a car fleeing the scene, found Beasley inside, and recovered a discarded firearm. As Beasley was on parole for a felony conviction, he could not lawfully possess a firearm. After a jury found him guilty, a presentence investigation identified three prior felony convictions: armed robbery in 2004, aggravated battery in 2005, and second-degree murder in 2011. The probation office concluded that Beasley qualified for enhanced sentencing under the Armed Career Criminal Act (ACCA).The United States District Court for the Central District of Illinois overruled Beasley’s objection that a jury should decide whether his prior convictions occurred on “different occasions,” and sentenced him to 300 months’ imprisonment. The court relied on then-controlling Seventh Circuit precedent, which permitted judges to make this finding. Beasley appealed, arguing that recent Supreme Court decisions (Wooden v. United States and Alleyne v. United States) required that this factual question be determined by a jury.While the appeal was pending, the Supreme Court decided Erlinger v. United States, holding that the Fifth and Sixth Amendments require a jury to decide whether prior offenses occurred on different occasions under ACCA. The United States Court of Appeals for the Seventh Circuit agreed that the district court erred under Erlinger, but concluded the error was harmless. The appellate court found, beyond a reasonable doubt, that a properly instructed jury would have reached the same result, given the substantial gaps in time and the distinct nature of the offenses. The Seventh Circuit affirmed the district court’s judgment. View "United States v. Beasley" on Justia Law

Kevin Clay and his associate founded a pharmaceutical sales company that marketed compounded prescriptions directly to patients, promising them a share of the insurance reimbursements for each prescription filled. The company partnered with a pharmacy willing to pay a portion of the insurance proceeds and recruited employees from a local business whose health plan covered these prescriptions. Patients were directed to a doctor who readily prescribed the creams, resulting in millions of dollars in reimbursements over two years. Clay established a public charity to reduce his tax burden but used its funds for personal expenses and failed to comply with nonprofit requirements.The United States District Court for the Northern District of Ohio oversaw Clay’s trial. A jury convicted him of conspiracy to commit healthcare fraud, healthcare fraud, and making a false statement to the IRS, but acquitted him of a separate tax charge. The court sentenced Clay to 51 months’ imprisonment and ordered restitution totaling nearly $7 million to both Fiat Chrysler and the IRS. Clay appealed his convictions, sentence, and restitution orders.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed Clay’s convictions and rejected his challenges to the jury instructions and evidentiary rulings. However, it found error in the district court’s restitution orders and the application of a sentencing enhancement. Specifically, the Sixth Circuit held that restitution should not include payments for medically necessary prescriptions and that the apportionment of restitution must consider each defendant’s contribution and economic circumstances. The court also determined the restitution order to the IRS was not properly substantiated and included acquitted conduct. Finally, the case was remanded for further proceedings on restitution and for clarification or reconsideration of the leadership sentencing enhancement. View "United States v. Clay" on Justia Law

Two Massachusetts State Police officers, Lieutenant Daniel Griffin and Sergeant William Robertson, were implicated in a years-long scheme involving fraudulent overtime billing between 2015 and 2017. Both routinely claimed pay for hours they did not work, either by arriving late, leaving early, or “double-dipping” by billing overtime for tasks performed during regular hours. They also encouraged subordinates to engage in the same practices. The overtime funds in question were supplied through federal grants meant to support highway safety initiatives. In addition to the overtime fraud, Griffin separately engaged in wire fraud relating to private school financial aid and tax fraud connected to a private security business.The United States District Court for the District of Massachusetts presided over a jury trial, which resulted in convictions for both defendants on all counts related to wire fraud, theft of federal funds, and conspiracy. Griffin pled guilty to additional charges of wire fraud and tax falsification before trial. Sentences were imposed: Griffin received 60 months’ imprisonment, three years’ supervised release, substantial restitution, and forfeiture; Robertson received 36 months’ imprisonment, three years’ supervised release, joint and several liability for restitution, and forfeiture.Upon appeal to the United States Court of Appeals for the First Circuit, the court reviewed a broad array of challenges. The First Circuit largely affirmed the convictions, sentences, and restitution orders. It found no reversible error in the district court’s handling of the constitutional challenge, sufficiency of the evidence, guidelines calculations, sentencing disparities, and restitution. However, the Circuit Court vacated and remanded the forfeiture order against Griffin, holding that the government failed to prove by a preponderance of the evidence that the full amount of financial aid received was “traceable to” fraud, as required by statute. All other aspects of the district court’s judgment were affirmed. View "United States v. Robertson" on Justia Law

Police arrested the defendant after stopping a car in which he was a passenger and finding a loaded handgun, drugs, and cash. Subsequent searches yielded further incriminating evidence, including text messages, videos, and images related to drug trafficking on his cellphone, as well as additional firearms, ammunition, and drugs at his apartment. Officers also discovered a large quantity of marijuana in his girlfriend’s car. The government charged him with five counts: two related to drug distribution, two for illegal firearm possession, and one for possessing a firearm in furtherance of a drug-trafficking crime.The United States District Court for the Southern District of Alabama conducted a jury trial. The government introduced all seized evidence, including digital content and rap music videos. The prosecutor, during closing argument, referred jurors to an exhibit containing Instagram messages that had not been admitted into evidence. The jury convicted the defendant on all counts, with a 45-year sentence imposed, including a 30-year mandatory minimum for the firearm-in-furtherance count. The defendant appealed, raising issues of insufficient evidence, prosecutorial misconduct, the improper admission of rap videos, improper comment on his invocation of Miranda rights, and cumulative error.The United States Court of Appeals for the Eleventh Circuit held that the prosecutor’s reference to the unadmitted exhibit during closing argument constituted plain error that affected the defendant’s substantial rights. The court vacated the conviction and sentence on the count for possession of a firearm in furtherance of a drug-trafficking crime (Count 3) and remanded for a new trial on that count. The court affirmed the district court’s judgment on all other counts, finding no reversible error regarding sufficiency of the evidence, admission of the rap videos, the Miranda issue, or cumulative error. View "United States v. Jones" on Justia Law

The defendant pled guilty to possessing methamphetamine with intent to distribute, in violation of federal law. At sentencing, he received a prison term of 151 months, followed by three years of supervised release. The court also imposed a $1,000 fine and a $100 special assessment, stating they were “due immediately.” However, given the defendant’s indigency, the court established a payment schedule requiring him to make minimal payments while incarcerated and while on supervised release, including participation in the Bureau of Prisons’ Inmate Financial Responsibility Program.After judgment was entered reflecting both the immediate due date and the payment plan, the government sent a letter demanding immediate payment but also referencing the payment schedule. The defendant appealed, arguing that under 18 U.S.C. § 3572(d)(1), the court could either require the penalties to be due immediately or set a payment schedule, but not both simultaneously. He sought vacatur of the monetary penalties and resentencing.The United States Court of Appeals for the Ninth Circuit reviewed the statutory interpretation issue de novo. The court held that the district court did not violate 18 U.S.C. § 3572(d)(1) by declaring the penalties due immediately while also establishing a payment plan. The Ninth Circuit explained that the statute’s language and relevant precedent allow for the entire monetary obligation to be due immediately, with a payment schedule set in recognition of the defendant’s financial circumstances. The holding is consistent with similar approaches adopted by other circuits in analogous situations. Accordingly, the Ninth Circuit affirmed the district court’s judgment. View "USA V. PATRICK" on Justia Law

The case involves Todd Marshall Frandsen, who was charged with three counts of lewd conduct with minors under sixteen, based on allegations from his three sons. The boys reported that Frandsen engaged in lewd and abusive conduct, including fondling and other forms of mistreatment, over many years. Each son described similar patterns of abuse, which included threats and psychological intimidation. Frandsen was tried before a jury in Bannock County, Idaho, in March 2023.After a four-day trial, the jury convicted Frandsen of two counts related to the older boys and acquitted him of the charge involving the youngest. Frandsen was sentenced to two concurrent life sentences with 25-year fixed terms, later reduced to 20 years fixed upon his motion for reconsideration. He filed timely appeals, arguing that the district court erred by not removing a juror who recalled knowing one of the victims, admitting certain text messages between a victim and their mother, permitting a forensic interviewer to offer expert-like testimony without proper disclosure, and imposing an excessive sentence.The Supreme Court of the State of Idaho reviewed the case. It held that the district court did not abuse its discretion in retaining the juror, as she provided unequivocal assurances of impartiality and her past acquaintance with a victim did not establish actual or implied bias. The Court found the text messages were relevant and non-hearsay, though it did identify harmless error in admitting references to uncharged physical abuse without required Rule 404(b) notice. Similarly, it determined that the forensic interviewer’s limited expert testimony, though improper due to non-disclosure, was harmless given the acquittal on the related charge. The Court also found that the sentence imposed was not excessive. Accordingly, the Idaho Supreme Court affirmed the convictions and sentences. View "State v. Frandsen" on Justia Law