Justia U.S. 3rd Circuit Court of Appeals Opinion Summaries

The case involves James Peperno, Jr., who was found guilty by a jury of nine counts of conspiracy to commit bribery and wire fraud, among other related charges. Peperno devised a scheme to solicit bribes from Walter Stocki, who was involved in zoning litigation with the borough of Old Forge, Pennsylvania. Peperno, along with Robert Semenza, Jr., the Old Forge Borough Council President, planned to influence the litigation in Stocki's favor in exchange for bribes. Peperno initially approached Stocki in January 2019, asking for a $20,000 upfront payment and a monthly retainer. Stocki recorded their conversations and later contacted the FBI, which led to further recorded interactions and payments facilitated by the FBI.The United States District Court for the Middle District of Pennsylvania presided over the case. At trial, Peperno was found guilty on all counts except for two counts of money laundering. The Presentence Report (PSR) recommended sentencing enhancements for multiple bribes and for the total value of the bribes exceeding $15,000. Peperno objected to these enhancements, but the District Court overruled his objections, finding the recommendations supported by the evidence. The court sentenced Peperno to 72 months’ imprisonment, considering his intent and financial motivations.The United States Court of Appeals for the Third Circuit reviewed the case. Peperno appealed, arguing that the District Court erred in denying his request for a jury instruction on entrapment and in applying the sentencing enhancements. The Third Circuit held that the District Court correctly denied the entrapment instruction, as Peperno failed to show government inducement or lack of predisposition. The court also upheld the sentencing enhancements, agreeing that the evidence supported the finding of multiple bribes and that the total value of the bribes exceeded $15,000. The Third Circuit affirmed the District Court’s judgment of sentence. View "USA v. Peperno" on Justia Law

William Valentin, along with four other men, robbed a jewelry store in New Jersey, during which Valentin pointed a loaded gun at a store employee. The robbers stole nearly $900,000 in jewelry and left behind substantial evidence, including video footage, fingerprints, DNA, and cell phone records. A jury convicted Valentin of Hobbs Act robbery, conspiracy to commit Hobbs Act robbery, use of a firearm during a crime of violence, and conspiracy to use a firearm during a crime of violence. The District Court sentenced him to a term of imprisonment within the applicable sentencing guidelines range.The District Court for the District of New Jersey initially tried Valentin and his cousin Jonathan Arce together, but the jury acquitted Arce and failed to reach a verdict for Valentin, resulting in a mistrial. Valentin was retried a year later, and the jury found him guilty on all counts. The District Court sentenced him as a career offender, calculating the applicable sentencing guidelines range as 360 months to life imprisonment. Valentin did not object to the stated basis for the sentence, and the Court imposed a within-guidelines sentence of 360 months’ imprisonment, 5 years’ supervised release, and $889,844.33 in restitution.The United States Court of Appeals for the Third Circuit reviewed the case. Valentin raised several challenges to his convictions and sentence, including the admission of certain identification testimony, the exclusion of other similar testimony, the admission of evidence of a prior criminal relationship, and the reasonableness of his sentence. The Court of Appeals found that any potential errors in the District Court’s evidentiary rulings were harmless given the overwhelming evidence of Valentin’s guilt. The Court also held that brandishing a firearm during a robbery qualifies as a crime of violence under the sentencing guidelines. Consequently, the Court of Appeals affirmed the District Court’s judgment of conviction and sentence. View "USA v. Valentin" on Justia Law

A criminal defendant, convicted of aggravated manslaughter and sentenced to thirty years in prison, twice instructed his attorney to file a plenary appeal. However, his intake appellate counsel designated the appeal for the expedited sentence-review track (ESOA). The ESOA panel did not transfer the case to the plenary calendar and affirmed the sentence. The defendant's subsequent post-conviction relief applications in state court, which included claims of ineffective assistance of counsel, were unsuccessful.The United States District Court for the District of New Jersey denied the defendant's habeas corpus petition under 28 U.S.C. § 2254, which included claims related to the ESOA designation. The court also denied his Rule 60(b) motion, which specifically challenged the intake appellate counsel's decision to place the appeal on the ESOA calendar.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the Rule 60(b) motion was not a second or successive habeas application because it was filed within 28 days of the underlying judgment. However, the court found that the defendant's claim of ineffective assistance of counsel was procedurally defaulted because it was not exhausted in state court and he could not show the requisite prejudice to overcome the default. The court applied the Strickland standard for prejudice, requiring a reasonable probability that the result of the proceeding would have been different but for counsel's errors, rather than the Flores-Ortega standard, which applies when the entirety of direct appellate review is rendered unavailable. The court affirmed the denial of the habeas petition and the Rule 60(b) motion. View "Ross v. Administrator East Jersey State Prison" on Justia Law

In 2015, Eddie Williams was prosecuted in Pennsylvania for crimes related to a dispute over illegal drug profits, resulting in one death and one serious injury. Williams, along with Rick Cannon and Akeita Harden, was implicated in the incident. Cannon pleaded guilty to multiple charges, including homicide, and Williams was tried jointly with Harden. During the trial, the judge read Cannon's Criminal Information, which included charges naming Williams as a co-conspirator, to the jury. Williams was found guilty on all counts and sentenced to life imprisonment plus additional years.Williams filed a Post-Conviction Relief Act (PCRA) petition in 2017, arguing ineffective assistance of counsel due to his attorney's failure to object to the reading of Cannon's Criminal Information. The PCRA court denied the petition, and the Pennsylvania Superior Court affirmed. The Pennsylvania Supreme Court denied further appeal. Williams then filed a habeas corpus petition in the United States District Court for the Middle District of Pennsylvania, which granted relief, finding a violation of the Confrontation Clause and ineffective assistance of counsel.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the reading of Cannon's Criminal Information, which included testimonial statements implicating Williams, violated the Confrontation Clause. The court also found that Williams's counsel was ineffective for failing to object to the reading, which prejudiced Williams's defense. The Third Circuit affirmed the District Court's decision to grant habeas relief, concluding that the errors had a substantial and injurious effect on the jury's verdict. The case was remanded for the District Court to issue a writ of habeas corpus. View "Williams v. District Attorney Lebanon County" on Justia Law

Michael Hughes and Nashadeem Henderson committed two armed robberies in 2016. In the first incident, they robbed a drug dealer, with Hughes pulling a gun and demanding drugs and cash. When the dealer resisted, Henderson shot him in the leg. Four days later, they robbed a pizza delivery driver, with Henderson shooting the driver in the leg while Hughes took cash from his pockets. Hughes was convicted of two counts of Hobbs Act robbery and two gun charges under 18 U.S.C. § 924(c).The United States District Court for the Eastern District of Pennsylvania instructed the jury that Hughes could be convicted under § 924(c) if he had either completed or attempted the robberies. Hughes did not object to this instruction at trial. The jury found Hughes guilty on all counts. Hughes appealed, arguing that the jury instructions were incorrect and that there was insufficient evidence to support his convictions.The United States Court of Appeals for the Third Circuit reviewed the case. The court acknowledged that the District Court erred by instructing the jury that attempted Hobbs Act robbery could support a § 924(c) charge, as the Supreme Court had later clarified in United States v. Taylor that attempted Hobbs Act robbery is not a crime of violence. However, the Third Circuit found that this error did not prejudice Hughes because the evidence overwhelmingly showed that he completed the robberies. The court also found sufficient evidence to support Hughes's involvement in both robberies and the impact on interstate commerce.The Third Circuit held that the erroneous jury instruction did not affect the trial's outcome and affirmed Hughes's convictions and sentence. View "USA v. Hughes" on Justia Law

In 2020, Christopher Lamont Stimpson, Jr. contacted Benuel Stoltzfus, an Amish man in Lancaster County, Pennsylvania, to purchase five French bulldog puppies for $23,500. On the day of the sale, Stimpson and his associate, Wilbert Artis, visited the Stoltzfus home. After inspecting the puppies, Stimpson agreed to the purchase, but before the money count was complete, Artis took the puppies to their vehicle. A struggle ensued when Stimpson attempted to leave with the cash, during which he allegedly brandished a handgun. Stimpson and Artis fled with the puppies and most of the cash, leaving the Stoltzfus family with $4,140.The United States District Court for the Eastern District of Pennsylvania convicted Stimpson of Hobbs Act robbery and interstate transportation of stolen goods. Stimpson filed a motion to suppress evidence obtained from search warrants on social media accounts, arguing they were overbroad and lacked probable cause. The District Court denied the motion, but the government did not use the evidence obtained from the warrants at trial. Stimpson was convicted by a jury without the suppressed evidence.The United States Court of Appeals for the Third Circuit reviewed the case. Stimpson appealed the denial of his suppression motion and the application of a sentencing enhancement under USSG §2B3.1(b)(2)(D) for using a dangerous weapon. The Third Circuit found the suppression issue moot since the evidence was not used at trial. The court also upheld the sentencing enhancement, concluding that the District Court did not err in finding by a preponderance of the evidence that Stimpson used a dangerous weapon during the robbery.The Third Circuit affirmed Stimpson’s conviction and sentence. View "USA v. Stimpson" on Justia Law

A man was convicted of first-degree murder and sentenced to death for the killing of a police officer. The incident occurred during a traffic stop, where the officer was shot multiple times. The defendant was apprehended shortly after the shooting, and a firearm matching the bullets found at the scene was recovered from his vehicle. The defendant claimed he acted in self-defense, believing the officer was about to shoot him.The trial court, the Superior Court of California, found the defendant guilty and imposed the death penalty. The defendant appealed the conviction and sentence, arguing that the trial court made several errors, including improper jury instructions and the exclusion of certain evidence that could have supported his self-defense claim. The California Court of Appeal affirmed the conviction and sentence, rejecting the defendant's arguments. The defendant then sought review from the California Supreme Court.The California Supreme Court reviewed the case and upheld the lower court's decision. The court found that the trial court did not err in its jury instructions and that the exclusion of the evidence in question did not prejudice the defendant's case. The court also held that the evidence presented at trial was sufficient to support the conviction and the imposition of the death penalty. The court concluded that the defendant's actions were not justified as self-defense and that the killing of the officer was premeditated and deliberate. The conviction and death sentence were affirmed. View "USA v. Clark" on Justia Law

Cornelius Green, a member of the Infamous Ryders motorcycle club, was involved in an incident where Ishmael Snowell, who had declined membership in the club, was allegedly kidnapped. Green, along with co-defendant William Murphy and Steven Wong, met Snowell at the club's clubhouse. A fight ensued between Snowell and Murphy, with Green refereeing. Wong discovered photos of money on Snowell’s phone and demanded to know its location. Snowell claimed the money was at his aunt’s house in Reading, Pennsylvania. Murphy drove Snowell and Green, who was armed, to the house. Testimonies diverged on whether Murphy and Snowell could have escaped during a stop at a gas station. Upon arrival, they searched for the money, and Snowell claimed Wong ordered Green to shoot him. Snowell attempted to escape, leading to a fight with Green, which ended when neighbors called the police.The grand jury indicted Green, Murphy, and Wong for kidnapping and robbery. Green moved to sever his trial from Murphy and Wong, but the District Court denied the motion. Wong’s trial was later severed due to a change in attorneys, and he was acquitted. During the joint trial of Green and Murphy, Murphy testified that Wong coerced him into the kidnapping and that Green threatened Snowell with a gun. Green renewed his motion to sever, arguing that Murphy’s defense was antagonistic to his own, but the District Court denied it.The United States Court of Appeals for the Third Circuit reviewed the case and found that Green and Murphy presented mutually antagonistic defenses, which prejudiced Green’s right to a fair trial. The court held that the District Court abused its discretion in denying Green’s motion to sever. Consequently, the Third Circuit reversed the denial of the motion to sever, vacated Green’s conviction and sentence, and remanded for further proceedings. View "USA v. Green" on Justia Law

In 2001, the Commonwealth charged Robert Gene Rega with first-degree murder and other crimes for shooting a security guard, Christopher Lauth, during a robbery at the Gateway Lodge in Jefferson County, Pennsylvania. Rega, along with Shawn Bair, Raymond Fishel, and Stanford Jones, planned the robbery, while Jones’s wife, Susan, stayed at Rega’s home. During the robbery, Lauth was killed. The prosecution's case relied heavily on the testimonies of Bair, Fishel, and the Joneses, who identified Rega as the shooter. Additional evidence included a video of Rega purchasing ammunition and testimony from a friend that Rega asked for a false alibi.The Pennsylvania state court convicted Rega of first-degree murder and sentenced him to death. Rega's conviction and sentence were upheld on direct appeal and in a Post-Conviction Relief Act (PCRA) proceeding. Rega then filed a federal habeas petition. The United States District Court for the Western District of Pennsylvania denied his guilt-phase claims but granted relief from his death sentence, ordering a new sentencing hearing or life imprisonment.The United States Court of Appeals for the Third Circuit reviewed the case. Rega raised claims that the prosecutor withheld evidence in violation of Brady v. Maryland and presented false testimony in violation of Giglio v. United States and Napue v. Illinois. The Third Circuit affirmed the denial of relief on these claims, concluding that the evidence and testimony in question were not material to Rega’s murder conviction. The court found that the prosecutor’s noncommittal statements to witnesses about considering their cooperation in future plea deals did not significantly undermine their credibility, as the jury was already aware of their potential motives. Additionally, evidence of Susan Jones’s memory problems was deemed not material, as it did not sufficiently undermine her testimony or the overall case against Rega. View "Rega v. Secretary Pennsylvania Department of Corrections" on Justia Law

A Philadelphia police officer stopped Sunny Sok for making an illegal right turn. During the stop, the officer discovered that Sok's vehicle had an expired registration and mistakenly believed there was an active arrest warrant for Sok. The officer arrested Sok and claimed to smell marijuana from the vehicle, leading to a search that uncovered narcotics and a firearm. Sok was charged with drug and firearm offenses and moved to suppress the evidence, arguing the search was unlawful.The United States District Court for the Eastern District of Pennsylvania held a suppression hearing and found the officer's testimony about the marijuana odor not credible, thus ruling there was no probable cause for the search. However, the court denied Sok's motion to suppress, concluding that the evidence would have been inevitably discovered under Philadelphia’s Live Stop Policy, which mandates impounding unregistered vehicles and conducting inventory searches.Sok appealed to the United States Court of Appeals for the Third Circuit, arguing that the inevitable-discovery doctrine should not apply because the Government did not prove that impoundment of his vehicle was lawful or inevitable under the Live Stop Policy. The Third Circuit noted that Sok failed to raise these arguments in the District Court and thus could not consider them unless Sok showed good cause for the failure. The court found that Sok did not demonstrate good cause, as his counsel's misunderstanding of the law did not suffice. Consequently, the Third Circuit affirmed the District Court's judgment, upholding Sok's conviction and sentence. View "United States v. Sok" on Justia Law