Correspondent
Capitol Hill correspondent, covers legislative and political stories.
The Sixth Circuit affirmed a 37-month prison sentence for drug possession with intent to distribute, rejecting the defendant's claim that the district court improperly prioritized Sentencing Guidelines over statutory factors. The court held that the district judge conducted a thorough review of the defendant's history and the nature of the offense, finding no abuse of discretion.
The Sixth Circuit reversed a defendant's Tier II sex offender classification under SORNA, holding that her underlying Florida conviction did not meet the federal mens rea requirements for heightened tier status. The court also vacated a twenty-year supervised release sentence, finding the district court procedurally erred by miscalculating the applicable sentencing guidelines.
The Third Circuit affirmed summary judgment for law enforcement and prosecutors in a civil rights suit alleging a conspiracy to manufacture false charges. The court held that the plaintiff failed to provide persuasive evidence that the government fabricated evidence or lacked probable cause for his prosecution.
The Third Circuit denied a petition for review seeking withholding of removal and Convention Against Torture protection for a Ghanaian national convicted of federal fraud and money laundering crimes. The court upheld the Board of Immigration Appeals' finding that the petitioner failed to provide substantial evidence that he faced a clear probability of future persecution or torture upon return to Ghana.
The First Circuit affirmed the dismissal of Boston's public nuisance lawsuit against pharmacy benefit managers, ruling the claims were barred by the three-year statute of limitations. The court held that the City had actual knowledge of the alleged wrongdoing well before 2021, precluding tolling under the fraudulent concealment doctrine.
The Eighth Circuit affirmed the district court's revocation of supervised release and imposition of a 21-month prison sentence. The court held that the district court properly considered statutory sentencing factors and acted within its authority to require residence in a residential reentry center.
The Third Circuit affirmed the denial of Eric Hafner's motion to withdraw his guilty plea, ruling that he failed to prove ineffective assistance of counsel or a fair and just reason for withdrawal. The court also upheld a 240-month sentence, finding no error in the application of sentencing enhancements for threatening conduct and obstruction of justice.
The Third Circuit affirmed the denial of Eric Hafner's motion to withdraw his guilty plea, finding he failed to prove ineffective assistance of counsel or a fair and just reason for withdrawal. The court also upheld a 240-month sentence that exceeded the advisory Guidelines range, ruling that the District Court properly applied enhancements for threatening conduct and obstruction.
The First Circuit affirmed a 144-month sentence for a defendant convicted of possessing a firearm in furtherance of a drug trafficking crime and marijuana distribution. The court held that the district court properly weighed sentencing factors without needing to explicitly address every mitigating fact or explain why recommended sentences were rejected.
The Eleventh Circuit affirmed convictions for Hobbs Act robbery, holding that federal courts have jurisdiction over generally applicable federal crimes committed by Indians against Indians in Indian country. The court also ruled that while the district court erred by failing to perform an on-the-record balancing test before admitting prior conviction evidence, the error was harmless given the strength of the remaining evidence.
