Justia Government & Administrative Law Opinion Summaries

The case involves James Snyder, the former mayor of Portage, Indiana, who was convicted of accepting an illegal gratuity in violation of 18 U.S.C. §666(a)(1)(B). In 2013, while Snyder was mayor, Portage awarded two contracts to a local truck company, Great Lakes Peterbilt, and purchased five trash trucks from the company for about $1.1 million. In 2014, Peterbilt paid Snyder $13,000. The FBI and federal prosecutors suspected that the payment was a gratuity for the City’s trash truck contracts, but Snyder claimed that the payment was for his consulting services as a contractor for Peterbilt. A federal jury convicted Snyder, and the District Court sentenced him to 1 year and 9 months in prison. On appeal, Snyder argued that §666 criminalizes only bribes, not gratuities. The Seventh Circuit affirmed Snyder’s conviction.The Supreme Court of the United States reversed the Seventh Circuit's decision. The Court held that 18 U.S.C. §666 proscribes bribes to state and local officials but does not make it a crime for those officials to accept gratuities for their past acts. The Court reasoned that the statutory text, history, structure, punishments, federalism principles, and fair notice considerations all support the conclusion that §666 is a bribery statute and not a gratuities statute. The Court concluded that a state or local official does not violate §666 if the official has taken the official act before any reward is agreed to, much less given. Although a gratuity offered and accepted after the official act may be unethical or illegal under other federal, state, or local laws, the gratuity does not violate §666. The case was remanded for further proceedings consistent with the Court's opinion. View "Snyder v. United States" on Justia Law

The case revolves around Joseph Brian McElroy, who was charged with criminal possession of dangerous drugs with intent to distribute, a felony. The charge stemmed from a traffic stop initiated by Trooper Adams for speeding. During the stop, Trooper Adams noticed the smell of marijuana from the vehicle and observed signs of "hard travel." After verifying the driver's information and concluding that the driver was not under the influence, Trooper Adams questioned the occupants about the smell of marijuana. When they denied consent to search the vehicle, Trooper Adams deployed a canine for a sniff test, which led to the discovery of drugs and other items. McElroy filed a motion to suppress the evidence, arguing that the traffic stop was unlawfully extended without sufficient particularized suspicion.The District Court denied McElroy's motion to suppress the evidence. The court found that Trooper Adams had sufficient particularized suspicion to conduct the canine sniff based on the smell of marijuana, signs of hard travel, the occupants' nervousness, and their somewhat differing backstories. McElroy then entered a plea agreement, reserving the right to appeal the denial of his motion to suppress.The Supreme Court of the State of Montana reversed the District Court's decision. The court found that Trooper Adams did not have sufficient particularized suspicion to expand the traffic stop into a drug possession investigation. The court held that factors such as signs of hard travel, traveling from a known drug center in a third-party vehicle, and nervous demeanor, even when considered together, do not constitute particularized suspicion. The court also noted that the smell of marijuana itself does not constitute particularized suspicion sufficient to conclude there could be drugs in the vehicle. Therefore, the court concluded that Trooper Adams's further questioning about the marijuana smell and subsequent use of the canine sniff were unlawful. The court reversed the District Court's order denying McElroy's motion to suppress evidence and the resulting judgment of conviction and sentence. View "State v. McElroy" on Justia Law

The defendant, Darnell Tyree-Peppers, was on supervised release after pleading guilty to stealing a firearm from a federally licensed dealer. During his supervised release, his probation officer filed a petition to modify the conditions of his supervision due to alleged violations. Later, the probation officer filed a petition for his arrest and revocation of supervision based on three alleged violations of his supervision conditions. The district court issued the requested warrant. The probation officer later submitted an amended petition alleging that Tyree-Peppers had been arrested by state police officers on charges of first-degree murder, aggravated burglary, and aggravated robbery, potentially violating the condition that he not commit another federal, state, or local crime.The district court for the District of Kansas did not conduct the hearing on the petition until after the expiration of Tyree-Peppers' supervised release term. The court granted the petition in part and ordered an additional one year of supervised release. Tyree-Peppers challenged the district court’s jurisdiction to revoke his supervised release, arguing that the delay in the revocation proceedings was not “reasonably necessary for the adjudication,” as required by 18 U.S.C. § 3583(i).The United States Court of Appeals for the Tenth Circuit disagreed with Tyree-Peppers. The court found that the delay was attributable to an ongoing state prosecution of Tyree-Peppers on the very serious charge of first-degree murder. The outcome of that proceeding was directly related to the question of whether Tyree-Peppers violated the condition of his supervised release forbidding him from committing a state crime. Therefore, the court affirmed the district court’s exercise of jurisdiction. View "United States v. Tyree-Peppers" on Justia Law

The case revolves around Katherine Harris, who was convicted for aggravated DUI. While driving with a blood-alcohol concentration (BAC) twice the legal limit, Harris crashed into a deputy sheriff and his patrol vehicle, causing severe injuries to the deputy. Before trial, Harris requested public funds to hire her own experts, a toxicologist and an accident reconstructionist, to counter the State’s evidence. However, her blood sample, which she had not requested to be preserved, had been destroyed according to routine procedure nine months after testing. The judge denied her requests for expert funding, finding them broad and theoretical, and Harris failed to articulate concrete reasons how these proposed independent experts would specifically assist her defense.In Mississippi, the discretion to grant or deny an indigent defendant funds to retain an independent expert lies with the trial court. The court found that Harris failed to articulate how her own experts would actually assist her defense. Furthermore, the State’s case did not rely exclusively on these two experts and her BAC. The State called additional witnesses who established the patrol car was clearly visible with its blue lights flashing, and multiple other vehicles successfully passed the patrol car before Harris slammed into it. Witnesses also testified Harris smelled like alcohol, failed a field sobriety test, admitted she had been drinking, and tested positive for alcohol on a portable breathalyzer at the scene.The Supreme Court of Mississippi affirmed Harris’s conviction and sentence, discerning no abuse of discretion in the judge’s denial of Harris’s request for expert funds. Based on the overwhelming evidence supporting Harris’s aggravated DUI conviction, the judge’s discretionary denial, even if erroneous, was not so prejudicial as to render her trial fundamentally unfair. View "Harris v. State of Mississippi" on Justia Law

The case involves Roland Black, who was convicted of attempting to possess with intent to distribute a controlled substance, specifically furanyl fentanyl. Law enforcement intercepted a package addressed to Black, believing it contained narcotics. After obtaining a warrant, they found the substance, replaced it with sham narcotics, and delivered the package to Black's residence. Black was arrested after the package was opened and he was found with luminescent powder from the sham narcotics on his hands.Prior to his trial, Black had unsuccessfully moved to dismiss the indictment and suppress all evidence derived from the seizure of the package. He argued that the officers lacked reasonable suspicion to seize the package and requested an evidentiary hearing to resolve related factual disputes. The district court denied these motions, ruling that the totality of the circumstances supported the officers' reasonable suspicion determination.In the United States Court of Appeals for the Seventh Circuit, Black appealed his conviction, raising four arguments. He contended that the officers lacked reasonable suspicion to seize the package, the jury instruction about his requisite mens rea was erroneous, the jury’s verdict was not supported by sufficient evidence, and the court erred in denying his motion to dismiss based on the court’s treatment of furanyl fentanyl as an analogue of fentanyl.The Court of Appeals affirmed the lower court's decision. It found that the officers had reasonable suspicion to seize the package, the jury instruction accurately stated the law, the jury’s verdict was supported by more than sufficient evidence, and Black's motion to dismiss argument was foreclosed by precedent. View "USA v. Black" on Justia Law

Mario Giannini and Robert Czernek were involved in a series of fraudulent schemes in Bloomingdale Township, Illinois. Giannini worked for Bulldog Earth Movers, a contractor owned by his girlfriend, Debra Fazio. Czernek, the Township's Highway Commissioner, approved inflated invoices from Bulldog, and the excess funds were split between Czernek and Bulldog. Giannini, Czernek, and Fazio were indicted on counts of wire and honest services fraud. Czernek cooperated with the government and pleaded guilty, while Giannini and Fazio proceeded to trial. However, Fazio was acquitted on all counts after the government's case-in-chief.The district court had previously denied Giannini's motion for a mistrial based on the government's late disclosure of investigating agents' notes regarding an inculpatory statement he made to Czernek. Giannini also argued that the court erred in allowing the prosecutors to discuss Fazio's conduct in closing arguments, despite her acquittal.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court found that the district court did not abuse its discretion in denying the motion for a mistrial, as the late disclosure of the agents' notes did not sufficiently prejudice Giannini. The court also found no error in allowing the prosecutors to discuss Fazio's conduct, as it was highly relevant to the charges against Giannini. The court concluded that even if it was error to allow the comments, it was harmless given the overwhelming evidence against Giannini. View "United States v. Giannini" on Justia Law

Anthony Buntyn, an employee of a private company that transported detainees for law enforcement agencies, was charged with willfully violating the detainees' rights under the Fourteenth Amendment's due process clause due to inhumane conditions of confinement. The conditions developed while Buntyn transported the detainees in a van to various detention facilities. The government alleged that Buntyn had violated the Fourteenth Amendment's due process clause through deliberate indifference to intolerable conditions of confinement and that this indifference had resulted in bodily injury to three detainees. The jury found Buntyn guilty of depriving the detainees of humane conditions, acting willfully and with deliberate indifference, and causing bodily injury to one detainee.Buntyn appealed his conviction to the United States Court of Appeals for the Tenth Circuit, arguing that the evidence was insufficient for a finding of guilt, that the district court erred in preventing his attorney from using the term malice in closing argument, and that the court coerced the jury to reach a verdict. The Tenth Circuit rejected Buntyn's arguments and affirmed his conviction. The court found that the evidence was sufficient to support the jury's findings of inhumane conditions, deliberate indifference, and willfulness. The court also found that the district court did not err in prohibiting the use of the term malice in closing argument, and that Buntyn had waived his challenge to the district court's instruction for the jury to continue deliberating. View "United States v. Buntyn" on Justia Law

The defendant, Kevin L. Thomas, was on lifetime parole for prior narcotics offenses. An off-duty police officer, familiar with Thomas, observed him driving outside his county of residence, which was a violation of his parole conditions. The officer contacted an on-duty officer who initiated a traffic stop after observing Thomas commit a traffic infraction. During the stop, Thomas provided inconsistent responses and refused to consent to a search of his vehicle. The police contacted Thomas's parole officer, who arrived at the scene and conducted a warrantless search of Thomas's vehicle, discovering a large quantity of heroin.The County Court denied Thomas's motion to suppress the evidence, finding that the initial stop was justified and that the police had a founded suspicion of criminality justifying the continued detention of Thomas to contact his parole officer. The court also found that the parole officer's search was rationally and reasonably related to his parole duties. Thomas was convicted of criminal possession of a controlled substance in the third degree. The Appellate Division affirmed the decision, with two Justices dissenting, arguing that Thomas was detained beyond what was reasonable under the circumstances.The Court of Appeals reversed the decision, stating that the lower courts applied an incorrect legal standard in analyzing whether the traffic stop was unreasonably prolonged. The court held that the proper standard for detaining an individual beyond the time reasonably required to complete a traffic stop is reasonable suspicion. The court found that the traffic stop was justified at its inception, but the courts below evaluated whether the traffic stop was prolonged beyond the time reasonably required for its completion under the founded suspicion standard, a lesser standard than the reasonable suspicion necessary to prolong a traffic stop. The case was remitted to the County Court for further proceedings under the correct standard. View "People v Thomas" on Justia Law

The case revolves around a defendant, Melissa Fay, who was prosecuted for driving under the influence and other related charges. She entered a plea agreement, which did not include imprisonment or probation, but agreed to pay a freestanding order of restitution. The District Court of the Second Circuit followed the plea deal and ordered indefinite compliance hearings to monitor Fay's restitution payments. Fay protested, arguing that Hawai'i's restitution enforcement statute, Hawai'i Revised Statutes (HRS) § 706-644, limits the court's authority.Fay's appeal was unsuccessful in the Intermediate Court of Appeals, which agreed with the district court's decision. The Intermediate Court of Appeals held that an independent order of restitution empowers a criminal court to retain jurisdiction over a person who owes restitution. The court ruled that setting recurrent proof of compliance hearings fell within a court's general power to enforce its orders.The Supreme Court of the State of Hawai'i, however, concluded that the district court exceeded its statutory authority. The Supreme Court held that HRS § 706-644, the specific law relating to restitution enforcement, controls over the court's general powers to enforce judgments. The court ruled that a compliance hearing regarding restitution payments can only be ordered if a defendant is on probation or the defendant "defaults" on payment per HRS § 706-644(1). The Supreme Court vacated the Intermediate Court of Appeals' judgment on appeal. View "State v. Fay" on Justia Law

The case involves Earl Johnson, a former inmate of the Maryland Correctional Training Center, who alleged that corrections officer Chad Zimmerman sexually harassed and abused him during strip searches, in violation of his Fourth and Eighth Amendment rights. Johnson also sued Zimmerman’s supervisor, Lt. Richard Robinette, alleging supervisory and bystander liability. The district court dismissed Johnson’s claims against Robinette due to failure to exhaust administrative remedies but held that Johnson’s claims against Zimmerman were exempt from this requirement. The court also granted summary judgment to Zimmerman and Robinette on the merits of Johnson’s claims.The United States Court of Appeals for the Fourth Circuit held that the district court erred in concluding that Johnson’s claims against Robinette were subject to exhaustion requirements. However, the court affirmed the district court’s decision to grant summary judgment to both defendants. The court found that the strip searches, including those involving momentary touchings of Johnson’s genitalia or buttocks, did not rise to the level of an unreasonable search under the Fourth Amendment. The court also found that Johnson failed to present sufficient evidence to prove that Zimmerman had the requisite malicious intent to sexually abuse him, sexually arouse him or himself, or otherwise gratify sexual desire. Furthermore, the court found that Johnson’s evidence fell short of establishing supervisory or bystander liability against Robinette. View "Johnson v. Robinette" on Justia Law