Justia Criminal Law Opinion Summaries

Cruz Torres-Gonzalez was convicted in 2014 for illegal reentry into the United States and for making false statements to federal officers. He received concurrent 35-month sentences for these offenses. In 2024, he was again convicted of illegal reentry. During sentencing for the 2024 conviction, the district court considered his prior convictions and applied sentencing enhancements under the United States Sentencing Guidelines, including an eight-level enhancement based on the 35-month sentence for his prior false-statement conviction.After his 2024 conviction in the United States District Court for the Southern District of California, Torres-Gonzalez objected to the eight-level enhancement. He argued that the sentence for his false-statement offense was not truly independent, as it had been grouped with his illegal reentry conviction in 2014, which carried the highest offense level. He asserted that this grouping made it impossible to determine the appropriate enhancement, and asked the court to apply a lesser, four-level enhancement instead. The district court acknowledged that the grouped sentence likely affected the length of the false-statement sentence but concluded that the guidelines, as written, required the eight-level enhancement. The court imposed a sentence of 51 months.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s interpretation of the Sentencing Guidelines de novo. The appellate court held that the district court correctly applied the guidelines. It found no ambiguity in the relevant guideline provisions and determined that the length of the prior sentence, even if grouped, was the proper basis for the enhancement. The Ninth Circuit affirmed the sentence imposed by the district court. View "USA V. TORRES-GONZALEZ" on Justia Law

Mohamed Ibrahim Hassan, a lawful permanent resident, pleaded guilty in Kentucky to attempting to receive stolen property, in violation of state law. Several years later, federal immigration authorities initiated removal proceedings against him, asserting that his state conviction qualified as an “aggravated felony” under federal immigration law, specifically for receipt of stolen property. Hassan challenged this, arguing that the Kentucky statute criminalizes some conduct that would not be considered an aggravated felony under federal law, which requires proof that the defendant had a subjective knowledge or belief that the property was stolen.The immigration judge agreed with Hassan, determining that the Kentucky statute was broader than the federal definition and granting his motion to terminate the removal proceedings. The Board of Immigration Appeals reversed that decision, concluding that the Kentucky conviction did count as an aggravated felony for immigration purposes. Hassan then sought review of the Board’s decision in the United States Court of Appeals for the Seventh Circuit.Upon review, the United States Court of Appeals for the Seventh Circuit found that it was not clear whether Kentucky law requires subjective knowledge or belief, or whether a conviction could be based merely on what a reasonable person would have known (“constructive knowledge”). Because Kentucky case law was ambiguous on this point, the court declined to decide the issue itself. Instead, the Seventh Circuit certified the question to the Kentucky Supreme Court, specifically asking whether Section 514.110 of the Kentucky Revised Statutes requires subjective knowledge or belief that property is stolen, or if a conviction could be based solely on an objective standard. The Seventh Circuit held the case in abeyance pending guidance from the Kentucky Supreme Court. View "Hassan v. Bondi" on Justia Law

A group of men, including the defendants, robbed a man named Cabral at gunpoint in his garage. During the incident, one of the participants, Tyrone Lampley, was found dead near the scene. Police recovered Lampley’s cell phone from his body, and after informing Lampley’s mother of his death, obtained her consent to search the phone. The search revealed text messages implicating one defendant, which led to further evidence connecting both defendants to the crime.The prosecution charged Milo William Anderson and Edward Lee Allen, Jr. in Santa Clara County Superior Court. Prior to trial, the defendants moved to suppress the evidence obtained from Lampley’s phone, arguing that the search violated the California Electronic Communications Privacy Act (CalECPA) because law enforcement did not obtain a warrant and Lampley’s mother was not an “authorized possessor” of the phone under the statute. The magistrate denied the suppression motion, and the trial court upheld that ruling, finding that Lampley’s mother was reasonably believed by police to be the authorized possessor. Both defendants then pleaded no contest to their respective charges and were sentenced to prison.On appeal, the Court of Appeal of the State of California, Sixth Appellate District, reviewed the denial of the suppression motion. The court held that even if law enforcement violated CalECPA by searching the phone without a warrant, the good faith exception to the exclusionary rule applied. The court reasoned that officers reasonably believed Lampley’s mother, as next of kin, could consent to the search, and there was no case law at the time clarifying who was an “authorized possessor” after a device owner’s death. The court affirmed the judgments, concluding that suppression of the evidence was not required. View "People v. Anderson" on Justia Law

While serving a term of supervised release following a conviction for conspiring to distribute cocaine, the defendant engaged in multiple serious violations. He defrauded an elderly woman, convincing her through repeated false kidnapping stories to send him approximately $300,000. He also faked drug tests to conceal ongoing substance use and was convicted in municipal court for driving with a suspended license. These violations were discovered through the probation officer’s investigation, including review of text messages and admissions by the defendant.The United States District Court for the Northern District of Ohio found that the defendant had breached several conditions of his supervised release. After a hearing, the court revoked his supervised release, imposed an above-Guidelines sentence of 30 months’ imprisonment, followed by five additional years of supervised release, and added a special condition prohibiting contact with his longtime girlfriend who had assisted in the fraud. The defendant objected to both the length of his sentence and the no-contact condition.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s judgment. The appellate court held that the district court did not err by considering the seriousness of the defendant’s violation in fashioning the revocation sentence, as the law permits consideration of deterrence, public protection, and breach of trust. The sentence was found substantively reasonable, with the district court acting within its discretion. The appellate court also concluded the restriction on communication with the girlfriend was reasonably related to the goals of supervised release and did not impose an undue burden on the defendant’s constitutional rights, as it was tailored to prevent further criminal activity and protect both the victim and the girlfriend. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Williams" on Justia Law

A former employee of a pharmaceutical manufacturer brought a qui tam lawsuit under the False Claims Act, alleging that the company improperly calculated and reported its “Best Price” for certain drugs to the Centers for Medicare and Medicaid Services (CMS), as required under the Medicaid Rebate Statute. The plaintiff claimed that, during a period from 2005 to 2014, the company failed to aggregate multiple rebates and discounts given to different entities on the same drug, resulting in inflated “Best Price” reports and underpayment of rebates owed to Medicaid. The complaint asserted that the company was subjectively aware that CMS interpreted the statute to require aggregation of all such discounts, especially after the company’s communications with CMS during a 2006–2007 rulemaking process and the company’s subsequent internal audit.After the government and several states declined to intervene, the United States District Court for the District of Maryland dismissed the amended complaint, finding that, even under the subjective scienter standard established in United States ex rel. Schutte v. SuperValu Inc., the plaintiff had not plausibly alleged that the company acted with actual knowledge, deliberate ignorance, or reckless disregard as to the truth or falsity of its reports. The district court also suggested that ambiguity in the statute precluded a finding of falsity.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the dismissal de novo. The Fourth Circuit held that the plaintiff’s allegations—including the company’s awareness of CMS’s interpretation of the rule, its targeted audit and compliance efforts, and its continued use of non-aggregated reporting—plausibly alleged the requisite subjective scienter under the False Claims Act. The court clarified that statutory ambiguity does not, at the pleading stage, negate scienter or falsity, and remanded for the district court to address other elements, including falsity, in the first instance. The Fourth Circuit reversed the dismissal and remanded for further proceedings. View "United States ex rel. Sheldon v. Allergan Sales, LLC" on Justia Law

A federal prisoner was incarcerated at a federal prison camp after spending 543 days at a facility in Texas. Under the First Step Act, eligible prisoners can earn time credits for participating in recidivism reduction programs, which can be applied to reduce their term of imprisonment or expedite transfer to prerelease custody, such as a halfway house or home confinement. The prisoner earned and was credited with a twelve-month reduction but claimed that the Bureau of Prisons (BOP) wrongfully failed to apply additional earned time credits from his time in Texas, which would have made him eligible for earlier transfer to prerelease custody.The United States District Court for the District of Minnesota dismissed the prisoner’s pro se habeas petition filed under 28 U.S.C. § 2241, concluding it lacked jurisdiction. The district court reasoned that the claim challenged the conditions of confinement, not the validity or duration of the sentence, making it not cognizable in habeas corpus under Eighth Circuit precedent. The district court declined to recast the petition as a civil rights action due to failure to exhaust administrative remedies and dismissed the case without prejudice.The United States Court of Appeals for the Eighth Circuit reviewed the appeal. After briefing and submission, the government notified the court that the prisoner had been transferred to a halfway house, providing the exact relief sought. The court determined that the appeal was now moot because it could no longer grant effective relief. The court dismissed the appeal as moot and, following its standard practice when a civil case becomes moot pending appeal, vacated the district court’s order and remanded with instructions to vacate the judgment. The court did not reach the underlying jurisdictional issue regarding habeas claims for conditions of confinement. View "Fortner v. Eischen" on Justia Law

The defendant was involved in a long-term relationship with the adult victim, with whom he shared an eight-year-old daughter. In March 2020, both the woman and her daughter were found dead from gunshot wounds in their home. Law enforcement determined that the defendant was responsible for the shootings, which occurred while he was on probation for unrelated offenses. The State initially charged him with capital murder and other offenses, intending to seek the death penalty. The parties reached a plea agreement in which the defendant pleaded guilty to first-degree premeditated murder and reckless second-degree murder. In exchange, the State dismissed other charges and agreed not to pursue the death penalty, recommending consecutive sentences totaling a minimum of 65 years.After entering his pleas, the defendant requested a downward departure from the mandatory hard 50 sentence for first-degree murder and sought concurrent rather than consecutive sentences. He argued that his acceptance of responsibility, mental disorders, history of nonviolent offenses, impaired brain function due to substance abuse, low risk for future violence, and rehabilitative efforts constituted substantial and compelling reasons for a lesser sentence. The Sedgwick District Court denied his motion, finding that the mitigating factors presented did not justify departure given the extreme violence of the crimes, the breach of trust involved, and their impact on the victims’ family and community. The court imposed a hard 50 sentence for first-degree murder, consecutive to the sentence for second-degree murder and his prior probation violation.On direct appeal, the Supreme Court of the State of Kansas reviewed whether the district court abused its discretion in denying the departure motion. The Supreme Court held that the lower court did not abuse its discretion, as a reasonable person could agree that the defendant failed to present substantial and compelling reasons to justify a departure from the presumptive sentence. The judgment of the district court was affirmed. View "State v. Lopez " on Justia Law

The case concerns the murder of Melinda Sprague, whose body was found in the trunk of her car two days after she disappeared. Her boyfriend, Ahmad K. Bey, had begun a relationship with her after being paroled from prison. In the months leading up to her death, Sprague told multiple people—including family members and coworkers—that Bey was physically and emotionally abusive, had threatened to kill her, and possessed a firearm. Physical evidence, witness accounts, and phone records all connected Bey and another woman, Vanessa Waner, to Sprague’s home and car around the time of the murder.A jury in the Sedgwick District Court found Bey guilty of first-degree premeditated murder and criminal possession of a firearm. The court admitted extensive testimony regarding Sprague’s out-of-court statements describing Bey’s threats and violence, over Bey’s objection. The district court found these statements admissible under the necessity exception to the hearsay rule and also determined that prior bad acts evidence was relevant to several disputed material facts, including motive, intent, premeditation, and the nature of the relationship.On direct appeal to the Supreme Court of the State of Kansas, Bey argued that Sprague’s statements were inadmissible hearsay and improper prior bad acts evidence, that the prosecutor committed error by using a puzzle analogy in closing argument, and that cumulative error deprived him of a fair trial. The Kansas Supreme Court held that the district court did not abuse its discretion in admitting the statements under the necessity exception to hearsay, nor did it err in admitting the statements as relevant prior bad acts evidence. The court also found the prosecutor’s analogy permissible and rejected the cumulative error claim, finding no errors to aggregate. The judgment of the district court was affirmed. View "State v. Bey " on Justia Law

The defendant was charged with failure to comply with the sex offender registry as a habitual offender. At the plea hearing, the parties reached an agreement that the State would recommend a suspended sentence with probation if the defendant contracted to buy a house before sentencing, but would recommend a prison sentence otherwise. The defendant, who had limited financial resources, was unable to purchase a home within the seventy-day period between the plea and sentencing, despite significant efforts such as changing jobs and working extra hours. At sentencing, the State recommended prison, and the district court imposed a prison sentence, citing both the defendant’s criminal history and the terms of the plea agreement.After sentencing by the Iowa District Court for Dallas County, the defendant appealed, arguing that his sentence was unconstitutional because it resulted from his inability to meet a financial obligation. The Iowa Court of Appeals found it lacked jurisdiction to review his sentence and did not address his constitutional arguments. The defendant then sought, and was granted, further review by the Supreme Court of Iowa.The Supreme Court of Iowa concluded that sentencing a defendant to prison because of an inability to meet a financial condition—despite good faith efforts—violates due process and equal protection principles, as articulated in Bearden v. Georgia, 461 U.S. 660 (1983). The court held that a sentencing court may not impose or lengthen incarceration due to a defendant’s failure to satisfy a financial obligation unless the court finds that failure was willful or the defendant did not make best efforts. The Supreme Court of Iowa vacated the sentence and remanded for resentencing, directing the district court not to consider the plea agreement’s prison recommendation unless it finds the defendant did not use best efforts to satisfy the condition. View "State of Iowa v. Hidlebaugh" on Justia Law

A woman called 911 to request a welfare check on her elderly neighbors’ home after noticing an unfamiliar vehicle and a young Black male there while the neighbors were out of town. When Officer Smith of the Childersburg Police Department arrived, he found a man watering flowers and asked if he lived at the house. The man, who identified himself as Pastor Jennings and said he lived across the street, explained he was watching the house for the neighbors. When asked for identification, Jennings became agitated and refused to provide any. Other officers arrived, and after Jennings repeatedly refused to further identify himself, he was arrested and charged with obstructing a governmental function.After the charge was dismissed, Jennings sued the officers and the City of Childersburg in the United States District Court for the Northern District of Alabama, alleging unlawful and retaliatory arrest under federal law and false arrest under state law. The district court granted summary judgment and dismissal in favor of the officers and the City, finding that Jennings violated Alabama’s stop-and-identify statute, Ala. Code § 15-5-30, by refusing to give his complete name. The United States Court of Appeals for the Eleventh Circuit reversed, relying on a prior interpretation of the statute that prohibited officers from demanding physical identification. On remand, the district court found the law’s interpretation uncertain and certified a question to the Supreme Court of Alabama.The Supreme Court of Alabama held that Ala. Code § 15-5-30 does not prohibit law enforcement officers, during a valid Terry stop, from requesting physical identification if a suspect gives an incomplete or unsatisfactory oral response regarding their name and address. The court clarified that suspects must provide sufficient identifying information and that failure to do so can constitute a violation of Alabama law. View "Jennings v. Smith" on Justia Law