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

Defendant challenged his conviction on one count of conspiracy to distribute and possess with intent to distribute five or more kilograms of cocaine. The court rejected defendant's claims of improper venue; ineffective assistance of counsel; inadmissible evidence seized as the fruit of an illegal vehicle stop; and inadmissible expert testimony of a non-expert witness. Accordingly, the court affirmed the conviction. View "United States v. Watson" on Justia Law

Appellant, sentenced to prison for crimes involving powder and crack cocaine before Congress and the Sentencing Commission took steps to reduce the disparity in sentencing ranges between the two, sought declaratory and injunctive relief and possible damages after these efforts were directed at crimes involving lesser amounts of cocaine than his. The district court dismissed his suit on the ground that the only relief available to appellant was in habeas. Adopting Wilkinson v. Dotson's habeas-channeling rule, the court held that a federal prisoner need bring his claim in habeas only if success on the merits would "necessarily imply the invalidity of confinement or shorten its duration." Appellant's claim for declaratory relief avoided the habeas-channeling rule the court announced and its dismissal was improper. The court also concluded that the district court had jurisdiction to take up the merits of appellant's Bivens v. Six Unknown Named Agents of the Federal Bureau of Narcotics claim because it was not based on plainly fictitious allegations and his pleading errors could be corrected through the liberal construction or amendment the court was accustomed to providing a pro se prisoner. Accordingly, the court reversed the district court's dismissal of appellant's complaint and remanded for further proceedings. View "Davis v. U.S. Sentencing Commission" on Justia Law

Appellant, a Guantanamo detainee, appealed from a judgment of the district court denying his petition for a writ of habeas corpus. On appeal, appellant argued that the district court erred in not affording him protection due "medical personnel" under the First Geneva Convention. Because appellant had not established that he was "medical personnel" as defined by the Geneva Conventions, and because all other issues have been determined in the previous proceedings, the court affirmed the judgment of the district court denying the petition for writ of habeas corpus. View "Al-Warafi v. Obama" on Justia Law

Defendant pled guilty to crossing state lines to have sex with a minor. On appeal, defendant challenged his sentence. Defendant argued that the district court erred when it applied a sentencing enhancement based on his use of a computer to facilitate his crime. The court held that defendant waived this challenge when he stipulated to the enhancement in his plea agreement and raised no objection to its inclusion in the district court's calculation of his sentence. Accordingly, the court affirmed the district court's judgment. View "United States v. Laslie" on Justia Law

Defendant appealed his conviction and sentence on one count of possession of powder cocaine with intent to distribute. Defendant contended that the arresting officers violated his right against self-incrimination; that he was deprived of effective assistance of counsel; and that the district court failed to comply with certain procedural requirements at sentencing. The court concluded that, even assuming the admission of defendant's statement and head nod was error, the error was harmless; even if defendant's counsel's failure to renew the suppression motion was deficient under Strickland v. Washington, defendant could not show a substantial likelihood of a different result; and defendant's sentence was not procedurally unreasonable. Accordingly, the court affirmed the judgment. View "United States v. Brinson-Scott" on Justia Law

Appellant pled guilty to persuading a person to travel in interstate commerce to engage in criminal sexual activity. On appeal, appellant challenged all of the computer- and Internet-related conditions of his supervised release. In the district court, however, he objected to only one of those conditions: the single-device restriction. The court held that the district court did not plainly err in imposing the unobjected-to conditions. The court also held that the district court did not abuse its discretion in imposing the single-device restriction on the record that court had before it. The district court explained that the one-device limit was necessary to ensure that the probation officer would be able to effectively monitor appellant's Internet use at a reasonable cost. Given that the Internet was appellant's avenue of choice for seeking out a victim, there was no doubt that such monitoring was itself reasonably related to the nature and circumstances of his offense, to deterring criminal conduct, and to protecting the public from further crimes. Accordingly, the court affirmed the judgment. View "United States v. Legg" on Justia Law

Defendant moved to suppress evidence found in his apartment after police officers executed a search warrant and seized drugs, firearms, cash, and a variety of drug paraphernalia. Defendant argued that the police officer who prepared the search warrant affidavit made false statements in the affidavit and did so with reckless disregard for the truth. The court reversed the district court's grant of the motion to suppress and concluded that, even with the contested statements excised, the remaining portions of the officer's affidavit demonstrated probable cause for the search warrant. View "United States v. Cardoza" on Justia Law

Defendant pled guilty to one count of mail fraud and was sentenced to 8 years and 9 months of imprisonment, as well as ordered to pay restitution to his victims. Defendant appealed. The court held that defendant could challenge the application of the vulnerable victim enhancement but, under the due deference standard, the court upheld the enhancement where it was reasonable for the district court to conclude that the combination of the victims' characteristics made them particularly susceptible to defendant's fraud. The court remanded defendant's ineffective-assistance claim that his trial counsel made errors relating to the amount-of-loss calculation because it required further factual development. Finally, the court remanded to the district court to correct the specific amounts of restitution owed to each of defendant's victim so that the amounts added up to total $3,646,747.83. View "United States v. Fareri" on Justia Law

Plaintiff filed a complaint against the District of Columbia and others regarding the pretrial conditions of his confinement. The District agreed that the the Prison Litigation Reform Act (PLRA), 42 U.S.C. 1997e(a), requirement did not apply to plaintiff but urged the court to affirm the grant of summary judgment on his federal claims for failure to exhaust. The court joined its sister circuits and held that the PLRA exhaustion requirement did not apply because plaintiff was not a "prisoner" at the time he filed his complaint. Summary judgment was therefore inappropriately granted on his federal claims. As to his intentional infliction of emotional distress (IIED) claim, the court held that it had been abandoned because neither plaintiff's proposed amended complaint nor amicus brief, which he adopted, referenced that claim, and his pro se appellate brief provided no argument why the dismissal should be reversed. Accordingly, the court reversed in part and remanded plaintiff's federal claims to the district court. The court otherwise affirmed the judgment. View "Lesesne v. Doe, et al" on Justia Law

Defendant, the former national treasurer of the Phi Beta Sigma fraternity, pled guilty to a single count of bank fraud and received a sentence of the time he had already served on earlier convictions, plus five years of supervised release. Defendant had successfully appealed his convictions of multiple counts of bank fraud because the district court erred in admitting certain of his statements in evidence. On appeal, defendant contended that his term of supervised release should be calculated as having commenced when he was ordered released on his own recognizance pending his ultimately successful appeal. The court disagreed and concluded that defendant's term of supervised release did not commence until he was sentenced, on the charge to which he pled guilty, to time served plus five years of supervised release. Accordingly, the court affirmed the judgment. View "United States v. Davis" on Justia Law