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

Plaintiff sued defendant, alleging that defendant had unlawfully discriminated against her in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. Plaintiff, a medical student who was diagnosed with dyslexia and a mild processing-speed disorder, contended on remand that the district court erred by failing to apply the 2008 amendments to the ADA and in relying on her prior academic achievement in assessing whether she suffered from a disability under the ADA. The court held that because plaintiff failed to show legal or clear factual error by the district court, the judgment was affirmed. View "Singh v. GW Univ. School of Medicine, et al." on Justia Law

Appellant and a co-defendant were extradited from Panama following their indictment on one count of conspiracy to distribute five kilograms or more of cocaine, intending or knowing that it would be imported into the United States from Columbia, Panama, Nicaragua, and elsewhere outside of the United States. Appellant challenged his conviction and sentence. The court held that the district court had jurisdiction over the charged conspiracy because appellant's extradition conformed with the governing treaty between the United States and Panama, and appellant waived his venue challenge by not raising it in the district court. Appellant identified no plain error affecting his substantial rights in the district court's acceptance of his guilty plea. Further, appellant failed to show he was denied effective assistance of counsel as would entitle him to reversal of his conviction. Because appellant presented no grounds for setting aside the judgment based on his guilty plea, the waiver of his right to appeal a below-Guidelines sentence set forth in the plea agreement was valid. Accordingly, the court dismissed the appeal of his sentence and affirmed the judgment of conviction View "In Re: Sealed Case" on Justia Law

Defendant sought reversal of his conviction by a jury for unlawful possession with intent to distribute cocaine and aiding and abetting, claiming trial evidentiary errors. Because defendant elicited testimony concerning the officer's law enforcement experience with drug trafficking in an attempt to demonstrate he was conditioned to see the benign items seized from defendant's bedroom as drug paraphernalia, and elicited his opinion regarding one of those items, defendant failed to show prejudice even assuming the testimony was improperly admitted. Circuit precedent confirmed defendant's other contentions were without merit. The district court neither abused its discretion in excluding expert evidence on the ultimate question in the case, nor erred in allowing the prosecutor to ask guilt-assuming hypothetical questions of a character witness testifying about her personal opinion. Accordingly, the court affirmed the conviction. View "United States v. Guerrero" on Justia Law

Defendant was convicted of conspiring with a male accomplice to extort money from an ex-lover, a doctor, by threatening to expose their brief extramarital affair to his wife and the medical licensing board. Defendant appealed her conviction on the grounds that the district court improperly denied her a duress instruction and improperly instructed the jury on venue. The court held that the district court correctly declined to instruct the jury on the affirmative defense of duress where no reasonable juror could have found defendant lacked a legal alternative to committing the crime. Further, the conspiracy instruction given by the district court did not require the jury to find that any overt act occurred in Washington, D.C., and defendant did not ask the district court to have the jury determine venue. Therefore, the district court did not commit plain error of any kind. Accordingly, the conviction was affirmed. View "United States v. Nwoye" on Justia Law

The District of Columbia appealed the denial of its motion to vacate a preliminary injunction pursuant to Rule 60(b)(5) of the Federal Rules of Civil Procedure. The injunction was issued in 1995 in response to a class action complaint alleging that the District of Columbia was violating the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., by failing to timely pay private providers of special education services and thereby jeopardizing students' special education placements. The district court denied the motion on two grounds: (1) dissolving the injunction and subsequent payment orders "would be disruptive to the status quo" and "counter-productive to the goal" of settling the case "in short order," and (2) the District of Columbia had "overstated both the relevance and the significance" of the Supreme Court's recent decision in Horne v. Flores. The court held that the district court failed to address changed circumstances, as Flores instructed, and reversed and remanded the case to the district court to determine whether, in view of changed circumstances, the District of Columbia's Rule 60(b)(5) motion should be granted. View "Petties, et al. v. District of Columbia, et al." on Justia Law

Defendant filed a petition for habeas corpus in the district court of the District of Columbia and the district court dismissed the petition for want of jurisdiction, reasoning that defendant was required to pursue his challenge in D.C. Superior Court rather than federal court because his D.C. Code 23-110 remedy was not inadequate or ineffective. Defendant subsequently applied for a certificate of appealability (COA). The court concluded that jurists of reason would not find defendant's claim that the district court had jurisdiction "debatable" because Diamen v. United States could not be reasonably read to bar defendant from bringing his federal constitutional claims in D.C. Superior Court under section 23-110. Accordingly, the court denied the COA. View "Ibrahim v. United States, et al." on Justia Law

Upon remand to the court after affirming one of his convictions, the district court granted a variance from the U.S. Sentencing Guidelines range for career offenders and re-sentenced defendant for unlawfully distributing more than 5 grams of cocaine base. The court held that, although defendant correctly pointed out that the amount of cocaine base of which he stood convicted was 21.1 grams, not the 29.6 grams of cocaine base stated in the Presentence Report and adopted by the district court in re-sentencing him, both amounts fell within the same quantity range under U.S.S.G. 2D1.1(c)(7) and carried a maximum sentence of 40 years. Thus, defendant's Guidelines offense level would have been 34 regardless. The court also held that defendant could not show error, much less plain error, where the district court refused to consider the effect of pending legislation. The court further held that the district court did not plainly err, in violation of defendant's Fifth Amendment right against self-incrimination, by referencing at re-sentencing his failure to express remorse and accept responsibility. The court finally held that defendant's challenge to the reasonableness of his below-Guidelines re-sentencing failed to demonstrate that the district court abused its discretion in applying the career offender guideline provision. Accordingly, the court affirmed the amended judgment. View "United States v. Lawrence" on Justia Law

The United States appealed the district court's grant of the writ of habeas corpus to the detainee. Three errors in the district court's analysis required the court to vacate that decision. First, the court failed to accord an official government record a presumption of regularity. Second, the district court failed to determine the detainee's credibility even though the court relied on his declaration to discredit the Government's key evidence. Third, the court's unduly atomized approach to the evidence was one the court rejected. The court remanded so the district court could evaluate the detainee's credibility as needed in light of the totality of the circumstances. View "Latif, et al. v. Obama, et al." on Justia Law

This suit involved a challenge to the "minimum essential coverage provision," which required all "applicable individual[s]" to purchase and maintain "minimum essential coverage" for each month beginning in January 2014 under the Patient Protection and Affordable Care Act (Act), Pub. L. No. 111-148, 124 Stat. 119. Appellants, four United States citizens and federal taxpayers, sought declaratory and injunctive relief to prevent various U.S. Government officials and agencies from enforcing the minimum essential coverage provisions. They argued that the mandate exceeded Congress's authority under the Commerce Clause and substantially burdened appellants' religious exercise, in violation of the Religious Freedom Restoration Act, 42 U.S.C. 2000bb et seq. The district court rejected appellants' challenge to the Act and they appealed. Despite questions raised as to the court's subject matter jurisdiction, the court concluded that it had jurisdiction and affirmed the district court's conclusion that the Act was constitutional. View "Seven-Sky v. Holder, Jr." on Justia Law

In this case, defendant invoked the Sentencing Commission's reductions in the offense level for certain crack cocaine offenses. The district court denied defendant's motion, noting on the record a host of facts about defendant's criminal record and his disciplinary infractions in prison. Defendant appealed, arguing that the district court failed to determine the extent of the reduction for which he was eligible before denying his motion. In particular, defendant believed that the court could have underestimated the permissible reduction in the sentencing range, and that this hypothetical underestimate could have played a role in the court's refusal to make any reduction at all. Although the court agreed with defendant that a motion under 18 U.S.C. 3582(c)(2) required the court first to compute the sentence reduction available, the court found that the record established that it did so. View "United States v. David" on Justia Law