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

The case revolves around James Hutchings, Jr., who was convicted of conspiracy to unlawfully traffic and transport firearms. The conviction was based on evidence obtained from Hutchings's iPhone, which was seized during the arrest of suspected firearms and narcotics trafficker Linwood Thorne. The phone was found in Thorne's apartment, and a separate warrant was obtained to search the phone based on its association with Thorne. It was only after the search began that the agents realized the phone belonged to Hutchings.The case was first heard in the United States District Court for the District of Columbia, where Hutchings moved to suppress the evidence from his phone, arguing that the search was unsupported by the warrant because the probable cause finding depended on the phone's association with Thorne. The district court denied Hutchings's motion, stating that the phone was indeed associated with Thorne, regardless of its ownership. Hutchings was found guilty and sentenced to 60 months in prison followed by three years of supervised release.The case was then appealed to the United States Court of Appeals for the District of Columbia Circuit. Hutchings argued that the officers reviewing the report were required to discontinue their search after seeing the notation on its first page that the phone was "James's iPhone." The court disagreed, stating that the validity of the warrant did not depend on who owned the phones, but on their association with Thorne. The court affirmed the judgment of the district court, stating that the label "James's iPhone" did not contradict the facts that supported the warrant application. View "USA v. Hutchings" on Justia Law

The case involves a dispute over the Federal Energy Regulatory Commission's (FERC) certification of the Evangeline Pass Expansion Project, a series of expanded pipelines, compression facilities, and meter stations in the Southeastern United States. Environmental groups, including the Sierra Club and Healthy Gulf, challenged the certification, alleging that FERC improperly applied the National Environmental Policy Act (NEPA). Additionally, the Alabama Municipal Distributors Group, a municipal customer of Southern Natural Gas Company, argued that a new lease from Southern to Tennessee Gas may mean more profits for Southern, so Alabama Municipal should receive a portion of those profits.Prior to reaching the United States Court of Appeals for the District of Columbia Circuit, FERC had unanimously issued a Certificate Order to Tennessee Gas and Southern, denying all objections. FERC reaffirmed its determination on rehearing. The Sierra Club and Alabama Municipal timely petitioned for review.The Court of Appeals for the District of Columbia Circuit upheld FERC's certification of the Evangeline Pass Expansion Project. The court found that FERC's certification was reasonable and reasonably explained, as was its decision to deny a windfall to a pipeline owner's existing customers. The court rejected the Sierra Club's arguments that FERC failed to consider the full scope of environmental effects of the project, erred by failing to account for the environmental impact of two ongoing authorizations to export gas, and was required to use the "social cost of carbon" tool. The court also rejected Alabama Municipal's argument that it should receive a future credit on the existing rates it pays. The court concluded that all of FERC's decisions in this case were reasonable and reasonably explained, and therefore denied the petitions for review. View "Alabama Municipal Distributors Group v. FERC" on Justia Law

In 2020, seven victims of a 2016 terrorist bombing in Afghanistan obtained multi-million-dollar default judgments against the Taliban, Al-Qaeda, and the Haqqani Network. Following the Taliban’s 2021 takeover of Afghanistan, the victims, suing as John Doe plaintiffs, sought to attach assets held by the International Monetary Fund and the International Bank for Reconstruction and Development (commonly known as the “World Bank”). The plaintiffs argued that these assets belonged to the Afghan government or the central bank of Afghanistan, and that the Taliban had become the de facto Afghan government and the Afghan central bank its “instrumentality.”The district court granted the World Bank’s and Fund’s motions to quash the plaintiffs' writs of execution. The court found the Terrorism Risk Insurance Act (TRIA) inapplicable in this case. It expressed doubt that the funds the plaintiffs sought to recover belonged to Afghanistan, and it could not recognize an ownership claim by the Taliban to Afghan assets since the United States had not recognized the Taliban as the legitimate government of Afghanistan. The plaintiffs failed to show that the assets at issue fell under the TRIA, and so they had not shown that an exception to the Fund and the World Bank’s immunity applied. On that basis, the district court found that it lacked jurisdiction in the case and granted the motions to quash.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s decision. The court held that the TRIA does not abrogate the World Bank’s and Fund’s jurisdictional immunity under the International Organizations Immunities Act and Foreign Sovereign Immunities Act. The court concluded that the TRIA applies only to foreign states and international organizations once jurisdiction has been established over them. Because the TRIA leaves the World Bank’s and Fund’s jurisdictional immunity intact, the district court could not entertain the plaintiffs' garnishment action. View "John Does 1-7 v. Taliban" on Justia Law

In 2002, the Department of Housing and Urban Development (HUD) advertised job openings with a promotion potential to grade thirteen, while existing employees in comparable positions could only be promoted to grade twelve. The American Federation of Government Employees, National Council of HUD Locals Council 222, AFL-CIO, representing the existing employees, filed a grievance arguing that this violated their collective bargaining agreement with HUD. The grievance proceeded to arbitration.The Federal Labor Relations Authority (FLRA) initially declined to resolve the jurisdictional issue of whether the grievance involved classification, which is generally non-arbitrable, or reassignment, which could be resolved in arbitration. The arbitrator determined that the grievance was arbitrable and found that HUD had violated the collective bargaining agreement. The FLRA agreed with HUD's exceptions that the arbitrator's remedy required reclassification and therefore violated the Federal Service Labor-Management Relations Statute (FSLMRS). The FLRA vacated the arbitrator’s remedial award and remanded for an alternative remedy.In 2018, the FLRA held that the grievance concerned classification and that the arbitrator had always lacked jurisdiction over the grievance. The FLRA vacated all of the arbitrator’s pronouncements and its own prior decisions. The union then filed a complaint in district court claiming that the FLRA’s decision was “ultra vires.” The district court rejected the union’s Administrative Procedure Act claim but denied the FLRA’s motion to dismiss the entire complaint for lack of subject matter jurisdiction. The court later granted the union’s motion for summary judgment.On appeal, the United States Court of Appeals for the District of Columbia Circuit held that the district court lacked jurisdiction to review the FLRA's decision. The court found that the Federal Service Labor-Management Relations Statute (FSLMRS) clearly precluded judicial review of FLRA arbitration decisions in both the courts of appeals and the district courts. The court also held that the FLRA did not violate a clear statutory prohibition by vacating the arbitrator's award and its own prior decisions. The court vacated the district court's orders and instructed it to dismiss the complaint. View "American Federation of Government Employees v. FLRA" on Justia Law

Johannes and Linda Lamprecht, Swiss citizens who lived in the United States in 2006 and 2007, underreported their taxable income by falsely claiming they had no foreign bank accounts. In reality, they had millions in a Swiss bank, UBS. The couple amended their tax returns for 2006 and 2007 in 2010, after the United States served a John Doe Summons on UBS in 2008, seeking information about unknown taxpayers who might have failed to report taxable income in UBS accounts. The amended returns reported taxable income in the previously undisclosed UBS accounts, increasing their tax liability by approximately $2.5 million. The couple paid these back taxes, but in 2014, the IRS informed them they would be penalized for their original inaccuracies, and in 2015, issued a formal “notice of deficiency” assessing about $500,000 in penalties.The Lamprechts challenged these penalties in the United States Tax Court, arguing that the IRS didn’t follow the tax code’s procedures when it first decided to penalize them, that they deserved protections for voluntarily fixing their own mistake before the IRS acted, and that the statute of limitations for assessing accuracy penalties had run on the two tax years. The tax court granted summary judgment to the IRS.The United States Court of Appeals for the District of Columbia Circuit affirmed the tax court's decision. The court found that the IRS had complied with the statutory requirement for a supervisor's written approval for the penalty assessment. The court also ruled that the Lamprechts' corrected returns did not protect them from penalties because they were filed after a John Doe Summons was issued. Lastly, the court held that the statute of limitations did not bar the assessment of penalties because the John Doe Summons extended the statute-of-limitations period. View "Lamprecht v. Cmsnr. IRS" on Justia Law

In 2016, Jesse Benton, a political operative, received funds from Roman Vasilenko, a foreign national, and contributed those funds to a fundraiser supporting then-Presidential candidate Donald Trump. Benton was subsequently convicted of six felonies related to the unlawful contribution and related campaign finance filings. Benton appealed his conviction on several grounds, including challenges to the government’s decision to prosecute campaign finance crimes under the Sarbanes-Oxley Act, the admissibility of an earlier pardoned conviction, the sufficiency of the evidence, and the jury charge.The District Court denied Benton's motion to dismiss the charges, ruling that the Sarbanes-Oxley Act could be applied to false campaign finance filings. The court also allowed the admission of Benton's earlier pardoned conviction under Federal Rule of Evidence 404(b) and its use at sentencing. After a three-day jury trial, Benton was found guilty on all counts. He was sentenced to eighteen months' incarceration and twenty-four months' supervised release.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the district court's decision. The court held that the government had discretion to prosecute under either the Sarbanes-Oxley Act or the Federal Election Campaign Act (FECA). The court also found no error in the district court's admission of Benton's pardoned conviction under Rule 404(b) and declined to review Benton's challenge to the use of the pardoned conviction at sentencing. Finally, the court rejected Benton's challenges to the jury instructions, finding that any error was invited by Benton himself. View "United States v. Benton" on Justia Law

The case revolves around Wayne Holroyd, who pleaded guilty to conspiracy to distribute and possess with intent to distribute more than 280 grams of crack cocaine. After his plea but before his sentencing, Congress amended the "safety valve" provision of the statute used to compute Holroyd's sentence, expanding the eligibility of a drug offender to be sentenced without regard to the statutory mandatory minimum. However, the district court sentenced Holroyd to the statutory minimum of 120 months' imprisonment. Holroyd argued that his counsel should have contended that he was eligible for sentencing without regard to the statutory minimum under the recently revised safety valve provision.The district court sentenced Holroyd to the mandatory minimum of 120 months' imprisonment. Holroyd's counsel did not move for reconsideration. Holroyd contended that his counsel was constitutionally ineffective in representing him at sentencing because counsel failed to give the correct interpretation to the safety valve provision. He argued that his two past convictions did not exclude him from the safety valve under the provision because the word "and" between subparagraphs must be read conjunctively so that only a defendant who has convictions satisfying all subparagraphs cumulatively is ineligible.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court's sentence. The court held that Holroyd's counsel's decision not to argue at sentencing or to move for reconsideration on the basis of Holroyd's eligibility for the safety valve was not deficient representation. The court noted that the Supreme Court recently adopted a different construction of the safety valve provision, which held that a defendant satisfies the criminal-history requirement only when he does not meet any of the disqualifying criteria. As Holroyd had a 6-point criminal history based on two previous 3-point offenses, he did not satisfy the criteria and was therefore ineligible for the safety valve. View "United States v. Holroyd" on Justia Law

Deangelo Evans, a passenger in a car pulled over for traffic violations, was subjected to a pat-down search by the United States Park Police officers during the stop. The search revealed a firearm in his waistband, leading to his arrest and subsequent charge for being a felon in possession of a firearm. Evans moved to suppress the firearm as evidence, arguing that it was obtained through an unlawful search. The district court denied his motion, ruling that the pat-down search was justified due to the bulge in his pants that the officers believed might be a gun.The case was tried in the United States District Court for the District of Columbia, where Evans was convicted following a stipulated trial. He preserved his right to appeal the district court's denial of his motion to suppress the firearm as evidence.The case was then brought before the United States Court of Appeals for the District of Columbia Circuit. The court reviewed the district court's findings of fact for clear error. The sole issue on appeal was whether the district court erred in crediting the police officers' testimony that they initiated a Terry frisk only after they saw a bulge in Mr. Evans’s pants that they believed might be a gun. Evans argued that the officers' testimony was inconsistent and implausible. However, the appellate court found that the inconsistencies Evans identified were not so glaring that the police officers' testimony must be a fabrication. Therefore, the court affirmed the district court's decision, ruling that the protective pat-down search was justified and the firearm was admissible as evidence. View "USA v. Evans" on Justia Law

The case involves Lucas Denney, a former U.S. Army specialist and president of a Texas-based militia, who was arrested and indicted for assaulting a federal officer with a dangerous weapon during the January 6, 2021, riot at the U.S. Capitol. Denney pleaded guilty and was sentenced to fifty-two months in prison. The district court applied a two-level enhancement for "more than minimal planning" and a four-level enhancement for use of "a dangerous weapon" under the United States Sentencing Guidelines.Prior to the appeal, Denney had been found guilty in the United States District Court for the District of Columbia. He challenged the application of the two enhancements in his sentence, arguing that his planning was for a political protest, not an assault, and that he did not intend to cause bodily harm with the weapon.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court's decision. The court found ample evidence supporting the district court's conclusion that Denney had engaged in more than minimal planning for violent altercations with law enforcement officers. The court also found that Denney had admitted in open court to intentionally and forcibly hitting an officer with a PVC pipe, which was considered a dangerous weapon. The court concluded that the enhancements were correctly applied, and Denney's sentence was upheld. View "United States v. Denney" on Justia Law

The case involves John Maron Nassif, who was convicted of four misdemeanor offenses for his role in the January 6, 2021, riot at the United States Capitol. He was sentenced to seven months in prison. On appeal, Nassif challenged one of his convictions and his sentence. The challenged conviction was for demonstrating in a United States Capitol building. Nassif argued that the statute’s prohibition against parading, demonstrating, or picketing in Capitol buildings is facially overbroad and void for vagueness in violation of the First Amendment and the Due Process Clause.The district court rejected Nassif’s overbreadth claim, holding that the interior of the Capitol building is a nonpublic forum where the government may limit First Amendment activities so long as the restrictions are reasonable in light of the purpose served by the forum and are viewpoint neutral. The court reasoned that, in enacting section 5104(e)(2)(G), Congress permissibly determined that its institutional interest in peaceful space in which to do its lawmaking work supports the challenged limitation on demonstrating inside the Capitol buildings.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the district court's decision. The court concluded that the prohibition is reasonable and that it clearly applies to Nassif’s conduct, so it rejected his facial challenges and affirmed the conviction. The court also rejected Nassif’s challenges to his sentence and affirmed it. View "United States v. Nassif" on Justia Law