Justia Criminal Law Opinion Summaries

In early 2023, investigators conducted six controlled buys of fentanyl pills from Tyran Locure, with Anthony Jackson, Jr. present for two of these buys, which took place in Jackson’s vehicle. A GPS tracker on Jackson’s vehicle showed it frequently parked at an apartment building in Des Moines, Iowa, where both Jackson and Locure were surveilled. A search warrant executed at the apartment found firearms, thousands of fentanyl pills, marijuana, cocaine, cell phones, and a money counter. Jackson’s wallet and documents were also found in the apartment, and $2,263 in cash, including serialized money from a controlled buy, was found on Jackson.The United States District Court for the Southern District of Iowa charged Jackson with conspiracy to distribute controlled substances, possession with intent to distribute fentanyl, possession of firearms in furtherance of a drug trafficking crime, and being a felon in possession of firearms. The jury convicted Jackson on all counts, and the district court sentenced him to 270 months of imprisonment, revoked his supervised release, and added 30 months for violating supervised release terms.The United States Court of Appeals for the Eighth Circuit reviewed Jackson’s appeal, which challenged the admission of a forensic report, evidence of prior bad acts, and the sufficiency of evidence for the conspiracy conviction. The court held that Jackson waived his confrontation rights by stipulating to the forensic report’s findings. The court also found that the admission of evidence of Jackson’s prior conviction and firearm photographs was proper and not unduly prejudicial. Finally, the court concluded that sufficient evidence supported Jackson’s conspiracy conviction, given the controlled buys, GPS data, and items found during the search. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Jackson" on Justia Law

Plaintiff Jere Eaton sued the City of Stamford and police officer Steven Estabrook, alleging that Estabrook used excessive force during a protest on August 8, 2020. Eaton claimed that Estabrook lifted her by her bra strap, drove her backward several feet, and dropped her on the ground without warning, violating her Fourteenth Amendment rights and committing assault and battery under Connecticut state law. Estabrook and the City of Stamford moved for summary judgment on the grounds of qualified immunity and state governmental immunity.The United States District Court for the District of Connecticut granted summary judgment in favor of the defendants. The court found that while there were genuine disputes of material fact regarding whether Estabrook used excessive force, Estabrook was entitled to qualified immunity because it was not clearly established at the time that his actions were unconstitutional. The court also granted summary judgment on Eaton’s state law claims, concluding that Estabrook was entitled to state governmental immunity.The United States Court of Appeals for the Second Circuit reviewed the case and agreed with the district court that there were genuine disputes of material fact regarding the use of excessive force. However, the appellate court concluded that Estabrook was not entitled to qualified immunity at this stage because the same factual disputes also affected whether his actions were clearly established as unconstitutional at the time. The court affirmed the district court’s judgment in part, vacated it in part, and remanded the case for further proceedings. The appellate court upheld the district court’s decision regarding state governmental immunity for the state law claims. View "Eaton v. Estabrook" on Justia Law

From the 1990s through the 2010s, Patrice Runner operated a mass-mailing enterprise that used false and misleading advertising to sell purportedly supernatural objects and psychic services. Customers paid for rare gems and personalized psychic services, but received junk items and generic responses. A jury convicted Runner of mail and wire fraud, among other crimes.Runner appealed, arguing that the Government’s theory of fraud was legally defective, which he claimed affected his indictment, the sufficiency of the evidence, and the jury instructions. The United States District Court for the Eastern District of New York had denied Runner’s motion to dismiss the indictment and rejected his post-trial motions for acquittal or a new trial. The court also sentenced Runner to ten years’ imprisonment, despite a Guidelines recommendation of life imprisonment, based on a loss calculation of over $150,000,000.The United States Court of Appeals for the Second Circuit reviewed the case. The court rejected Runner’s arguments, citing the Supreme Court’s decision in Kousisis v. United States, which supported the Government’s fraudulent-inducement theory. The court found that the indictment sufficiently alleged that Runner used material misstatements to induce customers to pay money. The evidence presented at trial was deemed sufficient to support the jury’s finding of fraudulent intent, as Runner’s promotions contained intentional lies about the origin and nature of the goods and services sold. The jury instructions were also found to be adequate in conveying the intent-to-harm requirement.The Second Circuit affirmed the district court’s judgment, holding that any error in the loss calculation at sentencing was harmless, as the district court would have imposed the same sentence regardless. View "United States v. Runner" on Justia Law

In this case, the defendant, Douglass Mackey, was convicted of conspiring to injure citizens in the exercise of their right to vote in violation of 18 U.S.C. § 241. The conviction was based on three memes he posted or reposted on Twitter shortly before the 2016 presidential election, which falsely suggested that supporters of then-candidate Hillary Clinton could vote by text message.The United States District Court for the Eastern District of New York (Donnelly, J.) oversaw the trial, where a jury found Mackey guilty. Mackey appealed, arguing that the evidence was insufficient to prove that he knowingly agreed to join the charged conspiracy. The government presented evidence of Mackey's participation in several private Twitter message groups where members discussed strategies to influence the election, including the creation and distribution of misleading memes. However, Mackey was not a member of these groups during the critical period when the conspiracy was allegedly formed and discussed.The United States Court of Appeals for the Second Circuit reviewed the case. The court found that the government failed to provide sufficient evidence that Mackey knowingly agreed to join the conspiracy. The court noted that while Mackey posted the misleading memes, there was no direct evidence that he viewed or participated in the relevant discussions within the private message groups. The court emphasized that mere association with individuals involved in an unlawful undertaking is not enough to prove knowing involvement in a conspiracy.The Second Circuit concluded that the evidence was insufficient to support Mackey's conviction and reversed the judgment of the district court. The case was remanded with instructions to enter a judgment of acquittal for Mackey. View "United States v. Mackey" on Justia Law

James Coonan, a former leader of the "Westies" gang, was convicted in 1987 for crimes including racketeering, extortion, and murder, committed between the mid-1960s and mid-1980s. He was sentenced to 75 years in prison. Over his 38 years of incarceration, Coonan has unsuccessfully sought parole multiple times. In 2023, he filed a motion for sentence reduction under 18 U.S.C. § 3582(c)(1), which allows for sentence reductions based on "extraordinary and compelling reasons."The United States District Court for the Southern District of New York denied Coonan's motion, ruling that § 3582(c)(1) does not apply to offenses committed before November 1, 1987. The court explained that the Sentencing Reform Act of 1984, which includes § 3582, only applies to offenses committed on or after that date. The First Step Act of 2018, which amended § 3582 to allow inmates to file their own motions for sentence reductions, did not change this limitation.The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court's decision, holding that § 3582(c)(1) does not apply to Coonan's pre-1987 offenses. The court emphasized that the Sentencing Reform Act's effective date and its applicability only to post-November 1, 1987, offenses remain unchanged by the First Step Act. The court also rejected Coonan's arguments based on legislative intent and constitutional avoidance, finding no ambiguity in the statute that would allow for a different interpretation. Thus, Coonan remains ineligible for a sentence reduction under § 3582(c)(1). View "United States v. Coonan" on Justia Law

Three juveniles, Frederick F., Angela A., and Manolo M., were adjudicated delinquent on charges of resisting arrest. The events occurred on October 3, 2019, near Brockton High School, where a large crowd of students had gathered, leading to multiple altercations. Frederick yelled profanities at police officers and refused to leave the area, Angela recorded officers with her cell phone while yelling at them, and Manolo attempted to punch an officer and engaged in a physical struggle.The Juvenile Court denied Frederick's motion to dismiss the complaint for lack of probable cause and denied all three juveniles' motions for required findings of not delinquent. The Appeals Court affirmed the adjudications for resisting arrest but vacated Manolo's adjudication for assault and battery on a police officer due to an error in jury instructions.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the evidence was sufficient to support the adjudications for resisting arrest. For Frederick, the court found that the circumstances provided a basis for a good-faith judgment to arrest him for disorderly conduct. For Angela, the court concluded that her conduct of thrusting her cell phone within inches of officers' faces and resisting arrest by pulling away constituted the use of physical force. For Manolo, the court determined that his physical struggle with officers on the ground, following his aggressive actions, provided sufficient evidence of using physical force to resist arrest.The court affirmed the adjudications of delinquency for resisting arrest for all three juveniles and remanded for further proceedings on Manolo's vacated adjudication for assault and battery on a police officer. View "Commonwealth v. Manolo M." on Justia Law

The defendant was convicted of murder and tampering with or fabricating physical evidence after a trial before a three-judge panel. The trial court suppressed the defendant's station house confession, finding it was not voluntarily made due to the defendant's physical distress and repeated requests to end the interrogation. However, the court admitted the defendant's subsequent hospital confession, deeming it spontaneous and freely made.The defendant appealed, arguing that the prosecutor improperly relied on the suppressed station house confession to secure his murder conviction, and that the admission of the hospital confession violated his due process rights as it was a product of the earlier, involuntary confession.The Connecticut Supreme Court reviewed the case. The court found the record inadequate to review the defendant's claim that the prosecutor and trial court improperly relied on the suppressed confession. The defendant failed to demonstrate that the experts who testified at trial relied on the suppressed confession in forming their opinions. The court also found that the trial court did not rely on the hospital confession in reaching its verdict, and any error in admitting the hospital confession was harmless beyond a reasonable doubt.The Connecticut Supreme Court affirmed the trial court's judgment, upholding the defendant's convictions. View "State v. Maharg" on Justia Law

The defendant, Aaron Moore, was arrested in January 2025 for his involvement in the death of John Williams. He was charged with conspiracy to commit murder, criminal possession of a pistol or revolver, criminal possession of a firearm, and carrying a pistol without a permit. The arrest warrant affidavit alleged that Moore and his friend, Eric Diaz, were in a feud with Williams, leading to a car chase and subsequent shooting where Moore and Diaz fired multiple shots at Williams, resulting in his death.The trial court set Moore's bond at $1 million and required that 30 percent of it be posted in cash, based on the state's petition. Moore moved to vacate this decision, arguing that none of the charges against him constituted a "serious firearm offense" as defined by the relevant statutes, which require that an essential element of the crime involves the use or threat of a firearm. The trial court denied Moore's motion, focusing on the serious safety risk he posed rather than whether the charges met the statutory definition of a serious firearm offense.The Connecticut Supreme Court reviewed the case and concluded that the phrase "essential element" refers to the basic legal requirements of an offense, not the factual allegations in the arrest warrant. The court found that none of the charges against Moore required proof that he used or threatened the use of a firearm as an essential element. Therefore, the trial court's imposition of the 30 percent cash bond requirement was incorrect. The Connecticut Supreme Court vacated the trial court's order. View "State v. Moore" on Justia Law

Ryan Patrick Donahue, a DEA agent, met Marcus Joshlin at a bar in Bozeman on November 21, 2021. After a night of drinking, Donahue suspected Joshlin had drugs in his bag and demanded to see it while brandishing a firearm. Finding no drugs, they continued to another bar where Donahue's aggressive behavior led to an altercation. Donahue shoved a gun into Joshlin's neck, leading to his disarmament and arrest. Donahue was charged with Assault with a Weapon and Carrying a Concealed Weapon While Under Influence. He claimed self-defense, asserting Joshlin threatened him.The Eighteenth Judicial District Court excluded evidence of Joshlin's post-incident statements about being a fighter and his unresolved criminal case. The court allowed some evidence of Joshlin's untruthfulness but denied Donahue's motion for a new trial, finding substantial compliance with jury summons procedures. The jury found Donahue guilty on both counts, and the court deferred his sentence for three years on the assault charge and issued a suspended six-month sentence for the concealed weapon charge.The Supreme Court of the State of Montana reviewed the case. It held that the District Court did not err in excluding Joshlin's post-incident statements as they were not known to Donahue at the time and thus irrelevant to his self-defense claim. The court also found that Donahue failed to preserve his argument regarding the unresolved criminal case for appeal. Lastly, the court affirmed the District Court's denial of a new trial, concluding that any technical violations in the jury summons process did not affect the randomness or objectivity of the jury selection. The Supreme Court affirmed the lower court's decisions. View "State v. Donahue" on Justia Law

The case concerns a defendant who responded to an online advertisement posted by an undercover law enforcement officer posing as a woman offering sexual services, including access to two fictitious underage girls, one purportedly 12 years old. The defendant agreed to meet at a hotel to engage in sexual conduct with the supposed minors and was arrested upon arrival. He was charged with two counts of Sexual Abuse of Children under Montana law, with enhanced penalties based on the alleged ages of the victims.The Thirteenth Judicial District Court, Yellowstone County, denied the defendant’s motion to strike the mandatory sentencing enhancements, which imposed a 25-year parole restriction for offenses involving victims 12 years old or younger. The defendant subsequently pleaded guilty to one count of Attempted Sexual Abuse of Children, reserving the right to appeal the denial of his motion regarding the sentencing enhancement. The court imposed the State’s recommended sentence, including the mandatory enhancement, and dismissed the second count.The Supreme Court of the State of Montana reviewed whether the mandatory minimum sentence enhancement for sexual child abuse applies when the “victim” is a fictitious child created by law enforcement in a sting operation. The court held that the statutory language requiring enhanced penalties based on the age of “the victim” refers to actual, specified child victims, not to fictional or simulated victims. The court concluded that the Legislature’s use of different language in the statute—distinguishing between “a child” in defining the offense and “the victim” in penalty enhancements—demonstrates an intent to limit enhanced penalties to cases involving real children. The Supreme Court reversed the district court’s imposition of the mandatory enhancement and remanded for resentencing under the general penalty provision. View "State v. Schultz" on Justia Law