United States v. Matthew Caniff

United States v. Matthew Caniff, No. 17-12410 (February 15, 2019) The Court affirmed the defendant’s conviction under 18 U.S.C. § 2251(d), holding that the defendant “made a notice” requesting child pornography when he sent a text message soliciting naked pictures from an undercover agent posing as a minor. The Court also found sufficient evidence that…

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United States v. Valois

United States v. Valois, et al., No. 17-13535 (February 12, 2019) Two groups of individuals were intercepted by the Coast Guard and prosecuted separately for drug trafficking on the high seas. The Court affirmed the second group’s convictions, holding that a mistrial was not warranted based on the prosecutor’s references to a conspiracy between the…

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United States v. Enrique Montano-Garcia

United States v. Enrique Montano-Garcia, No. 17-11773 (February 5, 2019), UNPUBLISHED The Court held that the sentencing court erred in attributing to the defendant the entire drug quantity found at his co-conspirator’s apartment because the court failed to make a finding that the defendant, a drug courier, agreed to participate in the co-conspirator’s broader criminal…

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United States v. Matthew Munksgard

United States v. Matthew Munksgard, No. 16-17654 (January 30, 2019) The Court affirmed the defendant’s convictions for bank fraud and aggravated identity theft. Evidence that the bank in question had been federally insured before the fraud offense and shortly thereafter was sufficient to prove the bank was insured at the time of the offense. In…

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Sumnar Brewster v. Gary Hetzel

Sumnar Brewster v. Gary Hetzel, Attorney General, State of Alabama, 2019 WL 272835 (January 22, 2019) The Court reversed the district court’s denial of petitioner’s § 2254 motion, finding that petitioner received ineffective assistance of counsel when trial counsel failed to object or move for a mistrial after the court coerced a deadlocked jury into…

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