Correspondent
Capitol Hill correspondent, covers legislative and political stories.
The Eleventh Circuit affirmed the denial of safety-valve relief to a defendant convicted of drug trafficking, holding that his possession of firearms was in connection with the offense. The court found that a pattern of mixed drug and firearm sales from the same location facilitated the drug enterprise, precluding relief under 18 U.S.C. § 3553(f).
The Eighth Circuit vacates Paul Parrow's conviction for possession with intent to distribute controlled substances due to a district court's erroneous exclusion of evidence regarding a co-owner's drug history. The court affirmed the conspiracy conviction, finding the evidentiary error harmless for that count, but ordered a new trial on the possession charge where the excluded evidence was critical to the defense.
The Eleventh Circuit affirmed Jermaine Campbell's 144-month sentence, rejecting his claim that the district court acted unreasonably by limiting its review of sentencing comparators to the Middle District of Florida. The court held that the geographic limitation did not preclude a proper assessment of sentencing disparities or render the sentence procedurally or substantively unreasonable.
The Tenth Circuit affirmed Thomas Fairbanks's securities fraud convictions, ruling that the district court properly denied his motion to sever the counts and that sufficient evidence supported the verdict. The court found the joint trial did not prejudice the defendant and that the evidence established a unified fraudulent scheme against multiple victims.
The Tenth Circuit affirmed the dismissal of claims against Texas officials but reversed the dismissal of claims against a Colorado social services worker. The court held that while the Rooker-Feldman doctrine bars challenges to the underlying Texas child support order, it does not preclude a due process claim regarding the refusal to hold a hearing on modified financial circumstances.
The Eleventh Circuit affirmed Christopher Holloway's conviction and 120-month sentence, ruling that his guilty plea was entered knowingly and voluntarily. The court further held that a valid appeal waiver in his plea agreement barred him from challenging the substantive reasonableness of his sentence.
The Eleventh Circuit dismissed Daniel Kesneck's appeal sua sponte because his notice of appeal was filed after the statutory deadline. The court held that under Federal Rule of Civil Procedure 58, the district court's order became a final judgment 150 days after entry, making the filing deadline December 29, 2025.
The Tenth Circuit affirmed a supervised release revocation sentence, clarifying that while courts cannot consider retributive factors under 18 U.S.C. § 3553(a)(2)(A), they may properly consider offense circumstances for deterrence and public safety. The court held that the district judge's references to the defendant's repeated criminal conduct were aimed at assessing future risk rather than punishing past acts.
The Eleventh Circuit granted appointed counsel's motion to withdraw from representation after an independent review found no arguable issues of merit in the appeal. Consequently, the court affirmed the defendant's conviction and sentence without addressing specific legal arguments.
The Tenth Circuit reversed a district court's restitution order against a child sex trafficking defendant, holding that the government failed to prove the victims' losses would not have occurred but for his specific conduct. The court vacated the awards and remanded the case solely to remove the restitution mandate, as the evidence did not isolate losses attributable to the defendant from those caused by other abusers.
