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

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

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

Defendant was convicted of serious drug offenses and sentenced to life imprisonment. On appeal, defendant contended that he received ineffective assistance of counsel when he declined the prosecution's plea deal proposal and instead went to trial. The court concluded that defendant could not show a reasonable probability that he would have pled guilty if he had been fully informed of the sentencing permutations and therefore could not show the required reasonable probability that the result of the proceeding would have been different. Accordingly, the court found no basis in the record to disturb the district court's credibility finding and affirmed the judgment. View "United States v. Franklin" 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