Justia Criminal Law Opinion Summaries

In 2023, Boima Collins was convicted by a jury of carrying a firearm without a license and other charges. The Commonwealth introduced evidence of Collins' 1998 felony conviction to prove he did not have a license to carry a firearm, as a prior felony conviction bars one from obtaining such a license. The trial judge admitted the redacted court record over Collins' objection and instructed the jury to consider this evidence only for determining whether Collins had a license.Collins appealed, arguing that the trial judge abused her discretion by admitting the prior conviction evidence, claiming it was more prejudicial than probative and that the Commonwealth had less prejudicial means to prove lack of licensure. He also contended that the jury should have been instructed to consider the prior conviction evidence only if the Commonwealth proved beyond a reasonable doubt that he was the person named in the record. Additionally, Collins argued that the evidence was insufficient to prove he lacked a license because the Commonwealth did not prove he was the same person named in the record.The Supreme Judicial Court of Massachusetts reviewed the case and found no prejudicial error in admitting the evidence of Collins' prior conviction. The court held that the trial judge correctly weighed the evidence's probative value against the risk of unfair prejudice, provided robust limiting instructions to the jury, and noted that the prior conviction was for a dissimilar offense, reducing the risk of improper propensity reasoning. The court also concluded that the judge's instructions to the jury were not erroneous and that the evidence was sufficient to prove Collins lacked a firearms license. Consequently, the court affirmed Collins' convictions. View "Commonwealth v. Collins" on Justia Law

In this case, the defendant, Louis Vernon Jackson, was involved in two separate drug busts in Louisiana in April and May 2020. During these busts, law enforcement found significant quantities of drugs, firearms, and drug paraphernalia in motel rooms linked to Jackson. Following these incidents, Jackson was indicted on multiple charges, including conspiracy to distribute methamphetamine, possession with intent to distribute Tramadol, possession of firearms in furtherance of drug trafficking, possession of a firearm by a convicted felon, and possession with intent to distribute methamphetamine.Jackson chose to represent himself throughout the trial process. The magistrate judge conducted a Faretta colloquy to ensure Jackson's waiver of his right to counsel was made knowingly and voluntarily. Despite repeated warnings about the dangers and disadvantages of self-representation, Jackson insisted on proceeding pro se. Before the trial, the district judge conducted another Faretta colloquy to reaffirm Jackson's decision.The jury convicted Jackson on three counts: conspiracy to distribute methamphetamine, possession with intent to distribute methamphetamine, and possession of a firearm by a convicted felon. He was acquitted on the charges of possession with intent to distribute Tramadol and possession of firearms in furtherance of drug trafficking. Jackson was sentenced to 360 months of imprisonment and subsequently appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case. Jackson argued that the district court erred by not conducting a competency hearing sua sponte to determine his ability to represent himself. The Fifth Circuit found no abuse of discretion by the district court, noting that Jackson had been repeatedly warned about the challenges of self-representation and had demonstrated a rational understanding of the proceedings. The court affirmed the district court's decision, concluding that Jackson was competent to represent himself. View "United States v. Jackson" on Justia Law

Rodney Crawley was sentenced in December 2016 to 188 months in prison for a federal drug-trafficking conviction, with an enhancement under U.S.S.G. § 4B1.1(a) for being a career offender due to two prior felony convictions: a 2007 Virginia drug distribution conviction and a 2009 Virginia robbery conviction. Without the enhancement, his sentencing range would have been 84 to 105 months. In 2022, the Fourth Circuit held in United States v. White that Virginia robbery did not qualify as a “violent felony” under the Armed Career Criminal Act (ACCA).Crawley filed a motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A), arguing that the White decision meant he no longer qualified as a career offender, creating a significant sentencing disparity. He also cited a medical condition increasing his risk for COVID-19 complications and his rehabilitation efforts. The district court denied his motion, finding that the change in law, his medical condition, and his rehabilitation did not constitute extraordinary and compelling reasons for a sentence reduction.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court concluded that the Sentencing Commission’s amended policy statement in U.S.S.G. § 1B1.13, effective November 1, 2023, applied to Crawley’s motion. The court agreed that the White decision created a gross disparity between Crawley’s original sentence and the sentence he would likely receive now. However, Crawley had not served at least 10 years of his term of imprisonment, as required by § 1B1.13(b)(6). Therefore, the court affirmed the district court’s denial of Crawley’s motion for compassionate release. View "US v. Crawley" on Justia Law

The defendant was convicted of manslaughter in the first degree with a firearm, criminal possession of a firearm, criminal possession of ammunition, and carrying a pistol without a permit. The incident involved the defendant shooting and killing a bystander while returning fire at an individual who had shot at him first. The defendant argued that the trial court improperly declined to instruct the jury on self-defense for the manslaughter charge and that his convictions for both criminal possession of a firearm and ammunition violated double jeopardy.The trial court instructed the jury on self-defense for the murder charge but not for the manslaughter charge. The jury found the defendant not guilty of murder but guilty of manslaughter in the first degree with a firearm. The court found the defendant guilty of the remaining charges in a bench trial.The Connecticut Supreme Court reviewed the case and concluded that the trial court erred in not providing a self-defense instruction for the manslaughter charge. The court held that self-defense is a justification defense applicable to reckless manslaughter, regardless of whether the victim is a bystander or the aggressor. The court emphasized that the jury should have been allowed to consider whether the defendant's actions were justified under the circumstances. The court also found that the trial court's failure to provide a self-defense instruction was not harmless beyond a reasonable doubt, as it was the sole issue in the case.Additionally, the court held that the defendant's conviction for both criminal possession of a firearm and criminal possession of ammunition violated double jeopardy. The court concluded that the legislature did not intend to treat the possession of a firearm and the ammunition within it as separate crimes when both are used during a single incident. Therefore, the court vacated the defendant's conviction for criminal possession of ammunition.The Connecticut Supreme Court reversed the conviction for manslaughter in the first degree with a firearm and remanded the case for a new trial on that charge. The court vacated the conviction for criminal possession of ammunition and affirmed the judgment in all other respects. View "State v. Williams" on Justia Law

The defendant, a citizen of El Salvador, was apprehended in New Mexico in May 2023 and entered a blind plea to reentry of a removed alien subsequent to a conviction for an aggravated felony, violating 8 U.S.C. § 1326(a)(1), (b)(2). His criminal history includes multiple convictions for violent crimes, including manslaughter and battery with intent to commit a crime. The Presentence Investigation Report (PSR) calculated his advisory guidelines range as 21 to 27 months’ imprisonment, but the district court varied upward and sentenced him to 60 months.The United States District Court for the District of New Mexico held a sentencing hearing where both the Government and the defendant requested a within-guidelines sentence. However, the court expressed concern about the defendant's violent criminal history and recent reentry into the United States. The court adopted the PSR's undisputed factual recitations and considered the defendant's arguments regarding his past alcohol and drug consumption, rehabilitation, and medical needs. Ultimately, the court found that an above-guidelines sentence was necessary to reflect the seriousness of the offense, promote respect for the law, provide just punishment, afford adequate deterrence, and protect the public.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the district court did not commit procedural error by relying on the PSR's undisputed facts and that the 60-month sentence was substantively reasonable given the defendant's violent criminal history and the need to protect the public. The court also found that the district court did not abuse its discretion in varying upward from the guidelines range, as the defendant's criminal history and the seriousness of his reentry offense justified the variance. View "United States v. Cortez" on Justia Law

The case involves an ancillary proceeding under Federal Rule of Criminal Procedure 32.2(c) and 21 U.S.C. § 853(n). Jesse Dunn filed a third-party petition claiming ownership of a parcel of land in West Jordan, Utah, which the government sought to forfeit in Justin Peck’s criminal case. Peck was convicted of operating an unlicensed money transmitting business. The government alleged Peck held an ownership interest in the land. The district court agreed with Dunn and blocked the forfeiture, leading to the government's appeal.The United States District Court for the District of Utah initially found the land forfeitable based on Peck’s plea agreement. However, during the ancillary proceeding, the district court determined that Dunn had a superior interest in the property. Dunn had purchased the land with untainted funds and later paid off a loan using funds authorized by Peck. The court found that Dunn’s interest in the property was superior to Peck’s at all relevant times under Utah law.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Dunn’s interest in the property was superior to Peck’s and the government’s under 21 U.S.C. § 853(n)(6)(A). The court noted that the government had only sought to forfeit the land and had not pursued other potentially forfeitable property or substitute property. The court also emphasized that the government did not challenge the district court’s findings under Utah law, which governed the determination of property interests in federal forfeiture proceedings. The Tenth Circuit concluded that the district court correctly vacated the preliminary forfeiture order and granted Dunn’s third-party petition. View "United States v. Peck" on Justia Law

Derrick Clark and Shawn Mesner worked for Didion Milling, Inc., a corn milling company. In May 2017, Didion’s grain mill exploded, killing five employees. The Occupational Health and Safety Administration (OSHA) investigated and referred Didion for criminal prosecution. The government charged Didion and several employees with federal crimes related to their work at the mill. Clark and Mesner proceeded to trial, challenging the district court’s evidentiary rulings, jury instructions, the indictment, the sufficiency of the evidence, and the constitutionality of their convictions.The United States District Court for the Western District of Wisconsin convicted Clark on four counts and Mesner on two counts. Clark was found guilty of conspiracy to commit federal offenses, false entries in records, using false documents within the EPA’s jurisdiction, and obstruction of agency proceedings. Mesner was found guilty of conspiracy to commit mail and wire fraud and conspiracy to commit federal offenses. Both defendants were sentenced to 24 months’ imprisonment and one year of supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court vacated Mesner’s conviction on Count 4, remanding for an entry of judgment of acquittal and further proceedings consistent with the opinion. The court affirmed the district court’s evidentiary rulings and jury instructions, as well as Clark’s convictions and Mesner’s conviction on Count 1. The court found sufficient evidence to support the convictions and determined that the jury instructions, when considered as a whole, accurately reflected the law. The court also rejected challenges to the constitutionality of the OSHA regulation involved. View "USA v Mesner" on Justia Law

From 2016 to 2021, Irene Michelle Fike worked at an accounting firm and later as an independent contractor for a client, J.M., and J.M.'s family. Fike used her access to J.M.'s financial accounts to pay her personal credit card bills and make purchases from online retailers. She concealed her fraud by misrepresenting J.M.'s expenditures in financial reports. Fike defrauded J.M. of $363,657.67 between April 2018 and September 2022.Fike pleaded guilty to wire fraud and aggravated identity theft in 2024. The United States District Court for the Eastern District of Kentucky sentenced her to thirty-six months' imprisonment and three years of supervised release. The court also ordered her to pay $405,867.08 in restitution, which included the principal amount stolen and $42,209.41 in prejudgment interest. Fike appealed, arguing that the Mandatory Victims Restitution Act (MVRA) does not authorize prejudgment interest and that the interest calculation was speculative.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the MVRA allows for prejudgment interest to ensure full compensation for the victim's losses. The court found that the district court did not abuse its discretion in awarding prejudgment interest, as it was necessary to make J.M. whole. The court also determined that the district court had a sufficient basis for calculating the interest, relying on J.M.'s declaration of losses, which was submitted under penalty of perjury and provided a reliable basis for the award. The Sixth Circuit affirmed the district court's decision. View "United States v. Fike" on Justia Law

Nicholas Nesdahl, posing as a teenager, used social media to contact several minor girls and solicit sexually explicit images and videos. In one instance, he directed a 13-year-old girl to record herself sexually abusing her 6-year-old stepsister. The abuse was discovered by the older girl’s mother, who notified authorities. Law enforcement identified Nesdahl as the recipient and found he had received similar material from at least seven other minors across the country. Nesdahl was indicted in both the District of North Dakota and the Western District of Pennsylvania, with the latter case transferred to North Dakota. He entered a plea agreement, pleading guilty to two counts from the Pennsylvania indictment (involving receipt of child pornography and sexual exploitation of a minor) and seven counts from the North Dakota indictment (all for sexual exploitation of a minor).The United States District Court for the District of North Dakota adopted the Presentence Investigation Report, which recommended the statutory maximum sentence and identified nine victims, triggering mandatory restitution under 18 U.S.C. § 2259(b)(2). Nesdahl did not object to the restitution order. At sentencing, the court imposed 600 months’ imprisonment and ordered $3,000 in restitution for each of the nine victims.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the restitution order for plain error and found that mandatory restitution under § 2259(b)(2) applies only to certain trafficking offenses, not to convictions under 18 U.S.C. § 2251(a). The court held that restitution was only authorized for the two victims associated with the § 2252(a)(2) conviction, not for the other seven victims. The Eighth Circuit vacated the restitution award and remanded for a new order reflecting only the two qualifying victims. The court affirmed the 600-month sentence, finding it substantively reasonable and within the district court’s discretion. View "United States v. Nesdahl" on Justia Law

Heath G. Demerchant was convicted of domestic violence assault (Class C) after a jury trial. The incident involved Demerchant grabbing his wife's throat and hitting her during an argument about a debit card. The State presented testimony from the victim, witnesses, and police officers. Demerchant argued that his actions were justified under the competing harms justification, claiming he was preventing imminent harm to another person.The trial court denied Demerchant's request for a jury instruction on the competing harms justification, finding insufficient evidence of imminent physical harm to another. The jury found Demerchant guilty, and he was sentenced to five years in prison, with all but three years suspended, and four years of probation.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's decision. The court held that there was no evidence of a specific and imminent threat of physical harm to justify the competing harms instruction. The court emphasized that the justification requires evidence of an imminent threat, which was not present in this case. Therefore, the trial court did not err in denying the requested jury instruction. View "State of Maine v. Demerchant" on Justia Law