Justia Criminal Law Opinion Summaries

A New York State Police trooper stopped Daniel Delgado for erratic driving and discovered that his license was suspended. During an inventory search of his vehicle, the trooper found a loaded “ghost gun” and ammunition, which Delgado admitted belonged to him. Delgado had several prior convictions, including a felony conviction for attempted second-degree murder in Florida, where he had shot a man in the back. Delgado was indicted for possessing ammunition after a felony conviction, in violation of 18 U.S.C. § 922(g)(1), and pleaded guilty without a plea agreement.The United States District Court for the Southern District of New York denied Delgado’s motion to withdraw his guilty plea and to dismiss the indictment, finding that § 922(g)(1) did not violate the Second Amendment. At sentencing, the court determined that Delgado’s prior Florida conviction for attempted second-degree murder was a “crime of violence” under U.S.S.G. § 2K2.1(a), resulting in a higher base offense level. Delgado was sentenced to thirty months’ imprisonment and three years of supervised release. He timely appealed, challenging both the constitutionality of § 922(g)(1) and the classification of his prior conviction.The United States Court of Appeals for the Second Circuit reviewed the case. It held that Delgado’s constitutional challenge to § 922(g)(1) was foreclosed by its recent decision in Zherka v. Bondi, which reaffirmed the statute’s constitutionality after New York State Rifle & Pistol Ass’n v. Bruen. The court also held that Florida’s offense of attempted second-degree murder is categorically a crime of violence under the Sentencing Guidelines, as it requires an intentional act imminently dangerous to another and demonstrating a depraved mind. The Second Circuit affirmed the judgment of the district court. View "United States v. Delgado" on Justia Law

A police officer in East Bridgewater observed two men riding a moped without helmets and initiated a traffic stop. The operator, John Pena, had a suspended license and an outstanding warrant, while the passenger, Erik Ferrara, also lacked a driver’s license. Unable to secure the moped, the officer arranged for it to be towed and conducted an inventory search, discovering a backpack in the storage compartment. Inside the backpack, the officer found a loaded handgun with its serial number removed, along with Ferrara’s identification card and other personal items. Ferrara was arrested and later claimed ownership of some items in the backpack but denied knowledge of the firearm.In the Brockton Division of the District Court Department, Ferrara moved to suppress the evidence from the search, arguing that the impoundment and inventory search violated departmental policy. The motion was denied, and Ferrara proceeded to trial, where a jury found him guilty of carrying a firearm without a license, carrying a loaded firearm without a license, and defacement of a firearm’s serial number. Other charges were dismissed at the Commonwealth’s request. Ferrara appealed, challenging the denial of his suppression motion and the sufficiency of evidence for the defacement conviction.The Supreme Judicial Court of Massachusetts reviewed the case. It held that the motion to suppress was properly denied, finding the impoundment and inventory search consistent with departmental policy and constitutional requirements. However, the court vacated Ferrara’s firearm possession convictions and ordered a new trial, as the jury had not been properly instructed that the Commonwealth must prove beyond a reasonable doubt that Ferrara did not possess a firearms license. The court also reversed the conviction for intentional defacement of a firearm, concluding that the evidence was insufficient to support that charge under the theory presented to the jury. View "Commonwealth v. Ferrara" on Justia Law

After being released from a psychiatric hold, Reginald Humbles traveled from Lafayette to New Orleans, Louisiana, with little money and a firearm. When he ran out of gas, he encountered a waste removal truck and, after allegedly receiving a message from God, took the truck at gunpoint from its driver. Humbles then led police on a lengthy chase, which ended after officers deployed spike strips. Upon arrest, a loaded revolver was found in his possession. Humbles, a U.S. Army veteran with a history of mental illness, was indicted for being a felon in possession of a firearm.The United States District Court for the Eastern District of Louisiana accepted Humbles’s guilty plea. During sentencing, the court adopted a presentence report that cross-referenced the robbery Sentencing Guideline, applied an enhancement for reckless endangerment during flight, and included a criminal history point for an uncounseled misdemeanor DUI conviction. The court denied Humbles’s motions for a downward variance and departure based on mental health and military service, and sentenced him to 92 months’ imprisonment. Humbles appealed, challenging the application of the robbery Guideline, the enhancements, the inclusion of his DUI conviction, and the denial of his motions for a lower sentence.The United States Court of Appeals for the Fifth Circuit reviewed the case and found no reversible error. The court held that the district court did not err in cross-referencing the robbery Guideline, as Humbles failed to meet his burden to prove legal insanity at the time of the offense. The court also upheld the enhancements for reckless endangerment and the inclusion of the uncounseled DUI conviction, finding that Humbles knowingly waived his right to counsel. The Fifth Circuit affirmed the district court’s judgment and denied the request to reassign the case to a different judge. View "United States v. Humbles" on Justia Law

A man was stopped by police in Lawton, Oklahoma, for a traffic violation. During the stop, officers smelled marijuana and, after searching his car, found a loaded revolver and various marijuana products. The man did not have a medical marijuana card and was arrested on state charges for marijuana possession, paraphernalia, and a traffic offense. Subsequently, a federal grand jury indicted him for violating 18 U.S.C. § 922(g)(3), which prohibits firearm possession by anyone who is an unlawful user of or addicted to a controlled substance.The United States District Court for the Western District of Oklahoma granted the defendant’s motion to dismiss the indictment. The district court found that the Second Amendment’s text covered the defendant’s conduct and held that applying § 922(g)(3) to non-intoxicated marijuana users was inconsistent with the nation’s historical tradition of firearm regulation. The court reasoned that historical regulations only permitted disarming those who had acted dangerously in the past, not those merely believed to pose a risk of future danger. The government appealed this decision.The United States Court of Appeals for the Tenth Circuit reviewed the case. After the Supreme Court’s decision in United States v. Rahimi clarified the methodology for Second Amendment challenges, the Tenth Circuit concluded that the historical tradition supports disarming individuals believed to pose a risk of future danger, not just those who have acted dangerously before. However, the appellate court found that the government must show that non-intoxicated marijuana users pose such a risk. The Tenth Circuit reversed the district court’s dismissal and remanded the case for further proceedings to determine whether the government can meet this burden. View "United States v. Harrison" on Justia Law

The defendant was charged with multiple felony and misdemeanor violations for repeatedly contacting his estranged wife in violation of a temporary order of protection issued in May 2022. After the order was dismissed due to the protected party’s absence at a hearing, the defendant continued his prohibited communications, including sending over 100 text messages in a short period. He was arrested and later entered into a plea agreement, acknowledging the State’s intent to seek Persistent Felony Offender (PFO) status but securing a promise that the State would not pursue the PFO designation if he complied with certain conditions, including not committing further offenses or violating bail.The Eighth Judicial District Court, Cascade County, presided over the case. After the defendant pled guilty, he was released on his own recognizance. However, prior to sentencing, the State alleged that the defendant violated release conditions by continuing to contact the protected party. The State then sought to pursue the PFO designation, arguing that the defendant’s breach of the plea agreement allowed it to deviate from its original sentencing recommendation. The District Court continued the sentencing hearing to allow briefing and argument on whether the State’s PFO notice was timely and whether the defendant had breached the agreement. The District Court found that the State’s notice, although sent two minutes after the deadline, was sufficient and that the defendant suffered no prejudice from the timing.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court abused its discretion in accepting the State’s PFO notice and imposing a PFO sentence, and whether plain error review should be conducted regarding the court’s omnibus hearing procedure. The Supreme Court held that the State’s PFO notice was compliant and timely for statutory purposes, and that the defendant was not prejudiced by the minor delay. The Court also declined to exercise plain error review over the omnibus hearing procedure. The judgment of the District Court was affirmed. View "State v. Anderson" on Justia Law

Erin Holcomb was convicted of deliberate homicide following an incident at a friend’s house near Fairfield, Montana. On the night in question, Holcomb and two friends arrived at the home after drinking and shooting guns earlier in the day. Holcomb brought a handgun into the house and was seen handling it repeatedly. After a dispute over driving due to intoxication, Holcomb refused to leave the driver’s seat of a truck, leading to a heated argument with the host, Trysten Fellers. Later, Fellers called his father for help, and after further attempts to get the guests home, Fellers drove his farm truck out to where Holcomb was in a field. Fellers stopped the truck, illuminating Holcomb, and a gunshot was heard. Fellers was found with a fatal gunshot wound, and Holcomb was arrested the next morning.The State of Montana charged Holcomb with deliberate homicide in the Ninth Judicial District Court. At trial, Holcomb’s defense requested a jury instruction on justifiable use of force, arguing that evidence showed Holcomb feared imminent harm from Fellers, who allegedly assaulted and pursued him. The District Court denied this request, finding insufficient evidence that Holcomb was in imminent danger of death or serious bodily injury. After a five-day trial, the jury found Holcomb guilty.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court abused its discretion in refusing the justifiable use of force instruction. The Supreme Court held that the trial record did not support the instruction, as there was no evidence that Fellers physically assaulted Holcomb, drove threateningly, or fired a weapon at him. The Court concluded that Holcomb’s fear was not reasonable or supported by the evidence, and affirmed the conviction. View "State v. Holcomb" on Justia Law

Two employees of a debt-collection firm, one of whom was out sick with COVID-19, collaborated to resolve an urgent licensing issue for their employer. The employee at home, unable to access her work computer, asked her colleague to log in using her credentials and retrieve a spreadsheet containing passwords for various company systems. The colleague, with express permission, accessed the computer and emailed the spreadsheet to the employee’s personal and work email accounts. Both actions violated the employer’s internal computer-use policies. Separately, the employee at home had, over several years, moved accounts into her workgroup to receive performance bonuses, believing she was eligible for them. Both employees also alleged persistent sexual harassment at work, which led to internal complaints, one employee’s resignation, and the other’s termination.After these events, the employer, National Recovery Agency (NRA), sued both employees in the United States District Court for the Middle District of Pennsylvania, alleging violations of the Computer Fraud and Abuse Act (CFAA), federal and state trade secrets laws, civil conspiracy, breach of fiduciary duty, and fraud. The employees counterclaimed for sexual harassment and related employment claims. On cross-motions for summary judgment, the District Court entered judgment for the employees on all claims brought by NRA, finding no violations of the CFAA or trade secrets laws, and stayed the employees’ harassment claims pending appeal.The United States Court of Appeals for the Third Circuit reviewed the case. It affirmed the District Court’s judgment in full. The Third Circuit held, first, that the CFAA does not criminalize violations of workplace computer-use policies by employees with authorized access, absent evidence of hacking or code-based circumvention. Second, it held that passwords protecting proprietary business information do not, by themselves, constitute trade secrets under federal or Pennsylvania law. The court also affirmed the dismissal of the state-law tort claims. View "NRA Group LLC v. Durenleau" on Justia Law

Three former members of a religious organization alleged that the organization intentionally misrepresented its history and the use of member tithing payments. They claimed that, had they known the true facts, they would not have joined or contributed financially. The plaintiffs asserted two main theories under the Racketeer Influenced and Corrupt Organizations Act (RICO): first, that the organization’s leaders made fraudulent statements about the group’s history and beliefs that they did not sincerely hold; and second, that the organization misrepresented how tithing funds would be used, including using them for commercial purposes contrary to representations.The United States District Court for the District of Utah initially dismissed the complaint, finding that the First Amendment’s Religion Clauses and the church autonomy doctrine barred adjudication of claims requiring inquiry into the truth or falsity of religious beliefs. After amendments to the complaint, the district court allowed a RICO claim based on the tithing theory to proceed, viewing it as a secular dispute. However, after further amendments and additional plaintiffs, the district court ultimately dismissed all claims, holding that the church autonomy doctrine barred claims based on religious misrepresentations and that the plaintiffs failed to adequately plead reliance or a pattern of predicate acts for the tithing-based RICO claim.The United States Court of Appeals for the Tenth Circuit affirmed. It held that the church autonomy doctrine bars civil RICO claims premised on alleged misrepresentations about religious history or doctrine, as such claims would require courts to adjudicate ecclesiastical questions. Regarding the tithing theory, the court held that the plaintiffs failed to plausibly allege a causal link between the organization’s statements about tithing and their own financial contributions, as required for a civil RICO claim. The court therefore affirmed the dismissal of all claims. View "Gaddy v. Corp. of the President of the Church of Jesus" on Justia Law

A man was accused of picking up a woman in El Paso, Texas, under the pretense of giving her a ride, then driving her across state lines to his home in Anthony, New Mexico, where he violently sexually assaulted her. The woman testified that she was handcuffed, physically assaulted, and raped multiple times before escaping at a stoplight in El Paso and seeking help. The defendant’s adopted daughter also testified that he had sexually assaulted her repeatedly when she was a minor and again as an adult.A federal grand jury in the United States District Court for the District of New Mexico indicted the defendant for kidnapping and transporting an individual across state lines with intent to engage in illegal sexual activity. At trial, the defendant argued that the encounter with the woman was consensual and related to commercial sex, and he sought to introduce evidence of her prior prostitution to support his consent defense. The district court excluded this evidence under Federal Rule of Evidence 412, finding it irrelevant to consent. The court also allowed the adopted daughter’s testimony under Rule 413, concluding that her allegations of prior sexual assault by the defendant were admissible and not unduly prejudicial under Rule 403. The jury convicted the defendant on both counts.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s evidentiary rulings. The court held that excluding evidence of the victim’s prior prostitution did not violate the defendant’s constitutional rights, as such evidence is not probative of consent under established precedent. The court also affirmed the admission of the adopted daughter’s testimony, holding that Rule 413 applies based on the conduct underlying the charges, not the statutory elements, and that the district court did not abuse its discretion under Rule 403. The court further found that the defendant had waived arguments regarding limitations on cross-examination of the adopted daughter. The convictions were affirmed. View "United States v. Clay" on Justia Law

A police officer in Pittsfield, Maine, stopped Michael L. Kilgore for speeding and discovered possible license restrictions. During the stop, Kilgore became agitated, drove away while the officer was standing next to his vehicle, and ran over her foot. After a pursuit, Kilgore was apprehended following a physical altercation with the officer, during which he kicked and punched her before being subdued. The officer suffered injuries requiring medical attention. Kilgore was charged with multiple offenses, including aggravated assault, assault on an officer, and several related charges.The Somerset County Unified Criminal Docket held a jury trial. The jury found Kilgore guilty of assault on an officer (Class C) and the lesser included offense of assault (Class D), but acquitted him of aggravated assault and other charges. The trial court merged the assault conviction into the assault on an officer conviction and sentenced Kilgore to forty-two months in prison, with all but nine months suspended, followed by probation. Kilgore appealed, arguing that the jury instructions were flawed because they failed to properly inform the jury of the State’s burden to disprove the defenses of self-defense, duress, and competing harms beyond a reasonable doubt, and did not instruct the jury to acquit if the State failed to meet that burden.The Maine Supreme Judicial Court reviewed the case for obvious error. The Court found that the trial court’s jury instructions contained two significant errors: they allowed the jury to find Kilgore guilty based solely on the elements of the offenses without considering the generated defenses, and they failed to instruct the jury to acquit if the State did not disprove duress and competing harms. The Court held that these errors were plain, affected Kilgore’s substantial rights, and undermined the fairness of the proceedings. The judgment was vacated and the case remanded for a new trial. View "State of Maine v. Kilgore" on Justia Law