Justia Criminal Law Opinion Summaries

The case centers on Kristal Glover-Wing, who founded and operated Angel Care Hospice (ACH) in Louisiana, a Medicare-certified hospice provider. ACH’s business model involved recruiting local physicians as medical directors who referred patients and certified them as terminally ill, even when evidence showed many patients maintained active lifestyles inconsistent with terminal illness. Glover-Wing instructed staff to emphasize patients’ worst conditions in records and resisted discharging patients who no longer qualified, sometimes directing staff to falsify records or reenroll patients after hospitalizations. An investigation revealed that, for at least twenty-four patients, hospice services were provided and Medicare reimbursed ACH over $1.5 million, despite the patients not meeting eligibility criteria.Following a whistleblower complaint and investigation, a federal grand jury in the United States District Court for the Western District of Louisiana indicted Glover-Wing and two physicians for conspiracy to commit healthcare fraud and three counts of healthcare fraud. During trial, the jury asked if the conspiracy charge could include ACH employees as coconspirators, leading to a dispute over jury instructions. Glover-Wing requested judicial estoppel to prevent the government from expanding the conspiracy beyond named defendants, arguing she relied on prior government representations. The district court denied her requests, and the jury convicted Glover-Wing on all counts while acquitting the physicians. Post-trial, the district court denied Glover-Wing’s motions for acquittal and a new trial.The United States Court of Appeals for the Fifth Circuit reviewed Glover-Wing’s sufficiency-of-evidence and judicial estoppel claims. The court held that sufficient evidence supported all convictions, as a rational jury could find Glover-Wing knowingly participated in fraud and conspiracy. It further held that judicial estoppel did not apply because the government’s positions were not plainly inconsistent, nor accepted by the court, and Glover-Wing failed to show unfair detriment. The Fifth Circuit affirmed the district court’s judgment. View "United States v. Glover-Wing" on Justia Law

In March 1997, James Garrey was involved in a fatal altercation at a bar in Franklin, Massachusetts, where he stabbed and killed Corey Skog following a dispute. Garrey, who is white, was later convicted of first-degree murder by a Massachusetts jury and sentenced to life imprisonment. During jury selection, the prosecution exercised a peremptory strike to remove a minority-race juror, Juror 6-7. Garrey objected, arguing the strike was improper and motivated by race, referencing Batson v. Kentucky and Powers v. Ohio. The trial judge allowed the strike after the prosecutor cited the juror’s occupation as a guidance counselor as the reason, not her race.Garrey appealed his conviction to the Massachusetts Supreme Judicial Court (SJC), asserting that the trial judge erred by accepting the prosecutor’s justification and by referencing the lack of minority participants in the trial. The SJC affirmed the conviction, finding the prosecutor’s explanation sufficient and not pretextual, and that the trial judge did not improperly rely on racial considerations. Garrey’s subsequent motions for a new trial in state court were denied.He then petitioned the United States District Court for the District of Massachusetts for habeas corpus relief under 28 U.S.C. § 2254, alleging Batson and Powers errors and unreasonable factual findings by the SJC. The District Court denied relief, concluding the SJC’s application of federal law and findings were not unreasonable.On appeal, the United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the District Court. The First Circuit held that the SJC did not unreasonably determine the facts or misapply clearly established federal law under Batson or Powers, and found the prosecutor’s rationale and the trial court’s process constitutionally sufficient. The judgment denying habeas relief was affirmed. View "Garrey v. Kelly" on Justia Law

After entering a no contest plea to charges including willful infliction of corporal injury and dissuading a witness, the petitioner was sentenced to four years’ probation and 60 days in county jail. She was referred to a work release program in lieu of serving her jail time. While participating, she discovered she was pregnant and could not complete her work assignment due to morning sickness. After providing proof of her pregnancy, the sheriff advised her not to return to the worksite because no light duty was available, and her case was sent back to the trial court for further action.The Contra Costa County Superior Court later considered her situation. At a hearing, the court found that she had not willfully violated the terms of the work release program but concluded that the alternative sentence was no longer feasible. The court ordered her to serve the remainder of her jail term in custody, denying her requests for re-referral to the program or a delayed surrender. The petitioner subsequently filed a habeas corpus petition with the California Court of Appeal, First Appellate District, Division Three, asserting that her due process rights had been violated.The California Court of Appeal, First Appellate District, Division Three, held that individuals enrolled in work release programs in lieu of jail time possess a conditional liberty interest that cannot be revoked without due process. The court found that the trial court’s decision to remand the petitioner into custody was based on a factual finding—her unfitness for the program—that was unsupported by the evidence. As a result, the appellate court reversed the trial court’s order and remanded the matter with instructions to re-refer the petitioner to the work release program to complete any remaining days owed. View "In re Riley" on Justia Law

A man was apprehended after leading police on a high-speed chase in a stolen vehicle. When the vehicle was stopped, law enforcement found an AR-style firearm with an overall length of less than 30 inches on the passenger-side floorboard. The man was charged with several offenses, including driving or taking a vehicle without consent, fleeing a police officer while driving recklessly, possession of a firearm by a felon, and possession of an assault weapon. The information also alleged several aggravating factors related to his criminal history and conduct.In Contra Costa County Superior Court, a jury found the defendant guilty of all charges except receiving a stolen vehicle. The court, after a hearing, found true several aggravating factors and sentenced him to three years and four months, including concurrent terms for some offenses. The sentence for possession of an assault weapon was stayed under Penal Code section 654.The California Court of Appeal, First Appellate District, Division Five, reviewed three issues raised by the defendant: whether California’s ban on assault weapon possession violated the Second Amendment; whether sentences for taking a vehicle without consent and fleeing an officer should have been stayed as based on the same act; and whether the abstract of judgment accurately reflected custody credits. The court held that Penal Code section 30605 does not violate the Second Amendment because there was no evidence in the record that assault weapons covered by the statute are in common use by law-abiding citizens, as required by relevant Supreme Court precedent. The court also held that the two vehicle-related offenses involved separate criminal objectives and thus did not require a stay under section 654. However, the court agreed that the custody credits were miscalculated and directed the trial court to correct the abstract of judgment accordingly. The judgment was otherwise affirmed. View "People v. Crenshaw" on Justia Law

Troy Williams pleaded guilty to various federal offenses, including drug trafficking, firearm possession by a felon, and money laundering, and was sentenced to 198 months in prison, which was below the applicable sentencing guideline range. Williams has a history of serious medical conditions—thrombophilia and recurrent deep vein thrombosis—that require ongoing management, including regular blood testing and medication. Nearly ten years into his sentence, Williams sought compassionate release, asserting that inadequate medical care at his current facility placed him at risk of severe health complications or death.After Williams filed his pro se motion for compassionate release in the United States District Court for the Northern District of Ohio, counsel was appointed to supplement his arguments. Williams claimed the Bureau of Prisons was not providing sufficient medical care, particularly after his transfer to FCI Coleman, where he alleged infrequent blood testing and interruptions in medication. He also argued the sentencing factors under 18 U.S.C. § 3553(a) favored his release. The district court reviewed his medical records and expert testimony from the prison’s clinical director, ultimately finding that Williams’s care was not so deficient as to amount to extraordinary and compelling circumstances. The district court further concluded that, even if such circumstances were present, the sentencing factors did not support early release. Williams timely appealed.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial for abuse of discretion, considering legal questions de novo and factual findings for clear error. The Sixth Circuit held that the district court did not clearly err in finding that Williams’s medical care was adequate and that his situation did not present extraordinary and compelling circumstances under the relevant Sentencing Commission policy statement. Accordingly, the Sixth Circuit affirmed the denial of Williams’s motion for compassionate release. View "United States v. Williams" on Justia Law

The defendant pleaded guilty in 2020 to two counts of distributing a mixture containing heroin and fentanyl, in violation of federal drug laws. At sentencing, the United States District Court for the Eastern District of Virginia determined he qualified as a career offender, which substantially increased his advisory sentencing range under the Guidelines. The court ultimately imposed a below-Guidelines sentence of 96 months’ imprisonment, followed by a five-year term of supervised release.Subsequently, the defendant moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), arguing that changes in the law meant he would not now be classified as a career offender, and, therefore, his Guidelines range would be much lower if sentenced today. He asked the court to reduce his sentence to time served. The district court found that the significant difference between his original and recalculated Guidelines ranges constituted an “extraordinary and compelling” reason for a sentence reduction. However, the court ultimately denied the motion, concluding that the factors outlined in 18 U.S.C. § 3553(a)—particularly the defendant’s lengthy and serious criminal history and the need to promote respect for the law—outweighed his arguments for release. The court also noted his rehabilitative efforts but found them insufficient to demonstrate a reduced danger to the public.The United States Court of Appeals for the Fourth Circuit reviewed only whether the district court abused its discretion in denying the motion for compassionate release. Applying a deferential standard, the Fourth Circuit held that the district court had considered all relevant arguments and provided sufficient reasoning for its decision. The appellate court affirmed the denial of compassionate release, holding that the district court did not act arbitrarily or irrationally and satisfied all statutory requirements in its analysis. View "United States v. Washington" on Justia Law

During a traffic stop in Hidalgo County, Texas, a sheriff’s deputy pulled over Gerardo Villarreal for driving with a partially obscured license plate. The deputy discovered Villarreal did not have a driver’s license or insurance. After a canine sniff alerted to an item in the vehicle, officers searched the car, finding a handgun and a small amount of cocaine. Villarreal was later indicted for being a felon in possession of a firearm under federal law. He moved to suppress the handgun as evidence, arguing the search violated his Fourth Amendment rights.The United States District Court for the Southern District of Texas held a hearing on the motion to suppress. The court heard testimony from the arresting deputy, who explained that department policy generally required impounding vehicles when the driver lacked a license or insurance, with certain exceptions. The deputy testified he would have impounded Villarreal’s vehicle and performed an inventory search, which would have revealed the handgun. Villarreal attempted to impeach this testimony, referencing another incident where the deputy did not impound a vehicle under similar circumstances, but the deputy explained possible exceptions. The district court found the deputy credible and denied the motion to suppress, applying the inevitable-discovery doctrine.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The Fifth Circuit held that the inevitable-discovery doctrine applied because the government showed by a preponderance of the evidence that an inventory search, conducted pursuant to standard department policy, would have discovered the handgun. The court found that the impounding and inventory search were imminent before any alleged misconduct, and the department’s policy sufficiently limited officer discretion. The Fifth Circuit affirmed the district court’s judgment, upholding denial of the motion to suppress. View "USA v. Villarreal" on Justia Law

Victor Yoel Perez Cremades was indicted for conspiracy to possess with intent to distribute, and possession with intent to distribute, large quantities of methamphetamine and fentanyl. Law enforcement intercepted a FedEx package containing nearly four pounds of methamphetamine and over 1,200 fentanyl-laced pills, addressed to a Tampa residence linked to Cremades. Upon searching the home, agents found additional drugs, cash, receipts for wire transfers to Nogales, Arizona (the package's origin), and a handwritten note referencing the transfer. Most identifying documents and mail within the house belonged to Cremades, and only he and his daughter were known to reside there.Following trial in the United States District Court for the Middle District of Florida, the jury found Cremades guilty on both counts. The district court denied his motion for judgment of acquittal based on insufficiency of the evidence and sentenced him to 180 months’ imprisonment on each count, to run concurrently. Cremades appealed, arguing the evidence was insufficient to support his convictions and that the district court abused its discretion by admitting a “drug ledger” into evidence without proper foundation or relevance.The United States Court of Appeals for the Eleventh Circuit reviewed the case. Applying the de novo standard for sufficiency of evidence and abuse of discretion for evidentiary rulings, the court held that the evidence was sufficient for a reasonable jury to convict Cremades on both possession and conspiracy counts. The court further determined that, even if admitting the drug ledger was error, it was harmless given the overwhelming evidence of guilt. The Eleventh Circuit affirmed both convictions and the district court’s rulings. View "USA v. Cremades" on Justia Law

The defendant was involved in a series of crimes that began when he picked up an acquaintance from a motel and, instead of taking her home, brought her to his house where he and his girlfriend assaulted her. During the assault, the defendant’s girlfriend held the victim at gunpoint with the defendant’s shotgun. The defendant subsequently forced the victim into the trunk of his car, drove her to the motel, and confronted another individual in a motel room, threatening him and stealing his possessions as well as his car keys. The defendant and his girlfriend then left the scene, with the stolen items and the shotgun in the original car, and the defendant driving the stolen car. During their flight, the victim managed to escape, and law enforcement later apprehended the defendant and recovered both the shotgun and the stolen property.The United States District Court for the Eastern District of Oklahoma held a jury trial in which the defendant was convicted of several offenses, including carjacking, robbery in Indian Country, and using and carrying a firearm during and in relation to a crime of violence under 18 U.S.C. § 924(c)(1)(A). The defendant moved for acquittal on the § 924(c)(1)(A) count, arguing insufficient evidence that he carried a firearm during the robberies because he did not have the shotgun on his person during the “taking” phase of the offenses. The district court denied the motion, and the jury found the defendant guilty, specifying that he carried (but did not use) the firearm during the robberies.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the sufficiency of the evidence de novo. The court held that “carrying” under § 924(c)(1)(A) includes constructive possession and transportation of a firearm during the commission or flight from a continuing offense such as robbery. The court concluded that evidence supported the jury’s verdict, as the defendant constructively carried the firearm during his escape from the robberies. The Tenth Circuit affirmed the conviction. View "United States v. McHenry" on Justia Law

The case concerns a defendant who was observed by law enforcement in the parking lot of a hotel known for illegal activity. The officer identified the defendant as the owner of a station wagon and a convicted felon with outstanding arrest warrants. Upon seeing the officers, the defendant refused to exit his vehicle and attempted to hide items, then fled at high speed, leading police on a dangerous chase before crashing and fleeing on foot. After his arrest, officers found a holster in the car and, following a search, discovered a loaded .38 Special revolver hidden behind a loose dashboard panel. The gun was determined to be stolen. The defendant was charged with fleeing to elude arrest, possession of a firearm by a felon, and possession of a stolen firearm.At trial in the Superior Court of Brunswick County, the defendant moved to dismiss the firearm charges for insufficient evidence, arguing that the State had not shown he knew or had reasonable grounds to believe the gun was stolen. The trial court denied the motion, and the jury convicted the defendant on all charges. On appeal, the North Carolina Court of Appeals affirmed the conviction, holding that the evidence—specifically the defendant’s flight, the gun’s concealment, and his misrepresentations about the firearm—was sufficient for a rational juror to infer knowledge or reasonable grounds to believe the gun was stolen. A dissenting judge disagreed, viewing the evidence as insufficient on the knowledge element.The Supreme Court of North Carolina reviewed the issue of whether substantial evidence supported the defendant’s knowledge or reasonable grounds to believe the firearm was stolen. The Supreme Court held that, when viewed in the light most favorable to the State, the evidence presented met the substantial evidence standard, and affirmed the Court of Appeals’ decision upholding the denial of the motion to dismiss. View "State v. Bracey" on Justia Law