Justia U.S. D.C. Circuit Court of Appeals Opinion Summaries

Defendant was indicted for charges related to a premeditated murder while armed. At issue was whether defendant's statements, which the government conceded the police obtained in violation of his rights under Miranda v. Arizona, were nonetheless admissible for purposes of impeachment should he testify at trial. The court held that the government met its burden in demonstrating that defendant's statements were voluntary where, although it was possible that the police could subtly overcome the will of a 33-year-old man even if he was provided water, had no apparent mental impairment, and generally answered questions intelligently, nothing in this case undermined the record evidence of voluntariness. Accordingly, the court reversed the judgment of the district court. View "United States v. Murdock" on Justia Law

This case arose when Conrail sold its Harsimus Embankment in Jersey City to developers. The City, together with others interested in the historic and environmental value of the Embankment, sued Conrail alleging that the sale was unlawful because Conrail failed to obtain authority from the Surface Transportation Board (STB) to abandon the property. The district court dismissed the case for lack of standing. The court reversed and remanded, concluding that the City enjoyed Article III standing where Conrail's refusal to invoke STB proceedings injured the City by depriving it of the benefits of those proceedings and the City's injury could be redressed by a district court ruling that the Embankment qualified as "railroad line" that Conrail could not abandon without STB approval. View "City of Jersey City, et al. v. Consolidated Rail Corp., et al." on Justia Law

Plaintiff contended that his supervisor at the Department of State gave him negative performance reviews in retaliation for his opposition to discriminatory conduct, in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e. The district court granted the Department's motion for summary judgment and dismissed the case. The court held that because plaintiff failed to offer evidence from which a jury could conclude that he opposed a practice that could "reasonably be thought" to violate Title VII, he failed to satisfy the first element of his cause of action. Plaintiff also failed to establish the third element of a Title VII retaliation claim: that the employer took a materially adverse action against the employee "because" the employee opposed a protected practice. Accordingly, the court affirmed the district court's grant of summary judgment in favor of the Department. View "McGrath v. Clinton" on Justia Law

Defendant pled guilty to a one-count information charging a conspiracy with three objects: bribery of federal officials; money-or-property mail and wire fraud; and honest services mail and wire fraud. Defendant subsequently appealed the district court's denial of his "motion to amend or modify his plea agreement." The court affirmed the denial of the motion because courts were not authorized to order modification or amendment of plea agreements. View "United States v. Scanlon" on Justia Law

Appellant, an African American man employed by the IRS, alleged that the IRS discriminated against him on the basis of race and gender when it awarded a temporary detail and then a permanent promotion to a white female employee. Appellant also claimed that the IRS retaliated against him when he pursued the matter with the Equal Employment Opportunity office. The district court granted summary judgment to the government on all claims. The court agreed that appellant failed to exhaust his claim regarding the temporary detail and so affirmed that portion of the district court's judgment. But because the court concluded a reasonable jury could find that the government's proffered nondiscriminatory reason for denying appellant the permanent promotion was pretextual and that discrimination was the real reason, the court reversed the grant of summary judgment on the discriminatory promotion claim and remanded to allow that claim to proceed to trial. And because the court concluded that appellant established a prima facie case of retaliation, the court remanded that claim for further proceedings. View "Hamilton v. Geithner" on Justia Law

Roger Rudder, two other adults, and two juveniles sued the District of Columbia and two Metropolitan Police officers for using excessive force against them at the 2008 Caribbean Carnival Parade in violation of their civil rights. The district court dismissed their suit with prejudice. The court concluded that, although plaintiffs unambiguously conceded all their common law claims, the juvenile plaintiffs' common law claims should have been dismissed without prejudice because those claims were not time-barred. The complaint also alleged facts stating facially plausible claims against two officers for violations of the Fourth Amendment. Therefore, the judgment of the district court was reversed. View "Rudder, et al. v. Williams, et al." on Justia Law

Defendant was convicted of illegally possessing a firearm as a convicted felon. Defendant subsequently appealed the district court's dismissal of his habeas petition seeking relief for ineffective assistance of counsel. The court concluded that the district court did not err in finding that counsel told defendant of the plea offer and therefore that counsel made no error on which to base a Strickland claim. View "United States v. Lathern" on Justia Law

Defendant was tried for various crimes arising from his involvement with the M Street Crew, a gang in Washington D.C., and was found guilty of narcotics conspiracy, participation in a Racketeer Influenced Corrupt Organization (RICO), 18 U.S.C. 1961, drug dealing, four felony murders, assault with intent to kill while armed, assault on a police officer, three violent crimes in aid of racketeering activity (VICAR), 18 U.S.C. 1959, and various gun charges. Defendant raised several issues on appeal, claiming error in the government's use of peremptory challenges, in rejecting his challenge to the joinder of local and federal charges, in denying his motion for severance, and in denying his motion for judgment of acquittal. The court held that there was no reversible error and rejected defendant's claims, affirming the judgment of the court. View "United States v. Gooch" on Justia Law

Defendant appealed her sentence of 60 months' imprisonment resulting from her convictions of possession of stolen mail and aggravated identity theft. On appeal, defendant contended that the district court failed to consider two mitigating arguments she advanced. The court affirmed the judgment of the district court because the record reflected that the district court in fact considered both arguments and provided a reasoned basis for defendant's sentence. View "United States v. Locke" on Justia Law

Defendant pleaded guilty to conspiracy to distribute and possess with intent to distribute 100 grams or more of a mixture and substance containing heroin. At issue was whether defendant could qualify under 18 U.S.C. 3553(f)(5) without disclosing the fate of the sample provided by the seller but not delivered in the transaction, or the origin of the sample that he did deliver to the buyer. The court agreed with the district court that defendant did not qualify for safety-valve relief where defendant's omission of the information at issue concerned his offense of conviction and was essential to safety-valve relief. View "United States v. Danso" on Justia Law