Georgia Federal Criminal Lawyer Blog

In a ruling that is all too rare in federal court, a federal district judge presiding here in Atlanta, Georgia declared the mandatory minimum portion of a federal criminal statute unconstitutional. At trial, the defendant was convicted of an offense that required the Court to impose a mandatory minimum sentence of 30 years. Before sentencing, however, the criminal defense attorney who represented the defendant filed a motion with the Court, asking the Judge to declare the mandatory minimum portion of the statute unconstitutional under the Eighth Amendment's prohibition on cruel and unusual punishment.

In a methodical and well-supported decision, the Court agreed with the defendant's position, concluding "that a 30-year mandatory minimum sentence for [the defendant], under the specific facts of his case, is so grossly disproportionate to his crime as to constitute cruel and unusual punishment in violation of the Eighth Amendment to the United States Constitution."

In reaching its decision, the Court recognized "the serious nature of [the defendant's] offense. [The Defendant] believed a ten year old child to exist and took steps to engage in sexual activity with her." However, the Court pointed out that "it is also a fact that [the defendant] never had any contact, sexual or otherwise, with the child. No harm was suffered. Of course, it was not possible for a child to be harmed, because the child was a creation of law enforcement, and no real child exists."

The federal public defenders that handled this case have obviously done an outstanding job. For those of you who want all the details, the full opinion can be found here.

Posted by Carl Lietz | Permalink | Email This Post

Posted In: Federal Criminal Trials

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We are working on a federal criminal case here in Atlanta where one of the issues is whether the police broke the law when a wife gave them her husband's computer and the police then searched through it finding incriminating materials. This is becoming more and more common, questions revolving around whether one person can let the authorities look through a computer belonging to another person.

In our case, the couple were in the middle of a divorce. The husband moved out, but left behind several computers, one for personal use, and others that were apparently for his job. On the personal computer, the wife got her "friend" to hack into it. This is crucial, because when the police showed up, she told them that her husband used a password which previously prevented her from getting into certain parts of the computer. The police took the computers, and later found information that prosecutors want to use in the criminal case. We are in the middle of fighting over whether this was OK.

The general rule is that police can get "consent" from a person who has "common authority" over an area or item, and if the police then seize and search through such an area, their actions are lawful. The United States Court of Appeals for the Eleventh Circuit recently published an opinion on this exact issue. In that case, the Court of Appeals ruled that the police were justified in believing that a motel manager had the authority to allow for the search of a room even though the guest's time had not yet run out. The reason the police should have believed that the manager had authority to consent to the search was because the guest had just been arrested on other charges and it was unlikely he would get out on bond before morning.

Our case is somewhat similar to a decision issued by the U.S. Supreme Court two years ago. That case involved a wife who gave the police permission to search, but the husband objected. The Supreme Court ruled that when a present occupant objects, the police cannot use the consent given to them by the other occupant to justify their entry and seizure of incriminating evidence.

In our case in Atlanta, we will be fighting over whether the wife's statement that her husband had prevented her from getting into certain parts of the computer put the police on notice that she did not have authority to hand over that computer. As said previously, this issue is becoming more and more common, and could have an impact on other cases.

Posted by Paul Kish | Permalink | Email This Post

Posted In: Federal Criminal Trials

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The right to have a lawyer defend a person against federal criminal charges was affirmed yesterday in a major ruling issued by the United States Court of Appeals for the Second Circuit. The case, United States v. Stein, affirmed a decision by a District Judge who dismissed all charges because the prosecutors violated the Sixth Amendment rights of company employees who wanted the company to pay their legal fees. This case is a major development, in that it assures both companies and their employees that it is appropriate to have the employer pay the worker's attorneys.

It has been a standard practice for many years for large companies to pay the defense fees for its high ranking employees. Many companies are regularly investigated, and operate in areas where the law is not always clear. Few people would agree to take high-ranking positions in such companies if they anticipated having to pay huge legal fees every time the company comes under scrutiny. As a result, most companies agree to indemnify the defense expenses for their employees. This is important in that getting qualified counsel is a very expensive proposition, especially when the investigation is far-flung and results in the defense attorney having to cull through millions of documents in order to properly advise his or her client.

About 7 years ago the Department of Justice (DOJ) began taking the position that companies which pay the legal fees for their employees are less deserving of a break when it came to resolving potential criminal charges. In 2004, the massive accounting firm KPMG was under investigation. The company then worked out its own deal through which no charges would be brought (although KPMG agreed to pay over $450 million in fines, etc.) but DOJ then indicted 13 employees.Under pressure from DOJ, the company restricted its usual practice of paying the legal fees for its employees under investigation who actually got indicted. The case was massive, and the attorneys for the defendants pointed out there was no way they could ever get paid unless the company adhered to its usual practice of indemnifying legal expenses.

The District Judge agreed with the defendants. He found that DOJ pressure was the reason the company changed its usual practice of paying legal fees. He determined that there was no way to put the clients back into their previous status, and that dismissing the indictment was the only remedy. The prosecutors appealed, and yesterday the Court of Appeals agreed that the dismissal was appropriate.

This case is based on the idea under the Sixth Amendment that a person is entitled to get the lawyer of his or her choosing in order to defend against criminal charges. When the government forces a company to change its usual practice of indemnifying for legal expenses, that is the same as government action that infringes on the constitutional right to counsel of one's own choice.

Posted by Paul Kish | Permalink | Email This Post

Posted In: Federal Criminal Trials , White Collar Crime

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The United States Court of Appeals for the Tenth Circuit recently issued a very lengthy opinion that covers a variety of sentencing issues we see quite often in federal white collar cases. Although this case came out of the appellate court that covers Denver, we see similar issues in cases here in Atlanta, the rest of Georgia, as well as in Alabama and Florida.

The case out in Denver involved charges of fraud against some bankers. They were convicted, and on appeal both the defendants and the prosecutors argued that the trial judge made mistakes when imposing the sentences.

The main sentencing issue on appeal involved the question of "loss" under the Federal Sentencing Guidelines. I have written at length on the Guidelines in other posts. The "loss" calculation is especially tricky. The defendants in the Denver case, through their very able lawyers, made the rather sensical argument that what they got out of the crime is the same as the "loss." Unfortunately, a lot of lawyers who do not get into federal court all that often mistakenly believe that this is the law. It is not. The concept of "loss" under the Sentencing Guidelines is far greater than what a person gets. It also covers "intended loss", along with losses caused by other people who did the same thing.

The court in the Denver case sent it back for a new sentencing hearing. The defendants' attorneys did a good job for their clients the first time. They will have a rougher road the second time around.

Posted by Paul Kish | Permalink | Email This Post

Posted In: Federal Criminal Trials , Fraud , White Collar Crime

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Federal prosecutors are more and more fond of trying to seize assets from people who are prosecuted for federal crimes. We see this quite a bit in money laundering and white collar crime cases. However, a recent federal case that started in South Florida shows that the details are always important, and a good lawyer who keeps the feds on their toes can sometimes prevent such asset forfeitures.

The recent decision by the Eleventh Circuit Court of Appeals here in Atlanta in the case of United States v. De la Mata is a perfect example of this principle. Many years ago, the feds prosecuted Mr. De La Mata and others, and got convictions and lengthy sentences. Significantly, some of the defendants included corporations owned and controlled by De La Mata and others. The prosecutors also wanted to forfeit assets owned by the people and by the corporations. However, and here's the important part, the prosecutors tried to use a short cut, and got the individual defendants to agree to turn over a large quantity of assets. The prosecutors forgot that the corporations were separate entities. As a result, the order entered by the judge turned over assets owned by the corporations, without ever hearing from the corporations themselves.

Several years passed, and the corporations asked for a return of their property. The government refused, and the judge also would not give back the assets. The court of Appeals recently agreed with the corporations. The opinion notes how the prosecutors could not use the shortcut of an agreement with the individual defendants to get property owned by the corporations.

In many of our cases, we negotiate with prosecutors about assets they want to seize from our clients. This recent decision shows how important it is to do our homework in this area.

Posted by Paul Kish | Permalink | Email This Post

Posted In: Federal Criminal Trials

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In a federal criminal case involving a sentencing issue, the United States Supreme Court ruled that a federal appellate court cannot increase a defendant's sentence in the absence of a Government request to do so. In Greenlaw v. United States, the defendant was convicted of various drug and firearms offenses. At his sentencing hearing, the district court sentenced Greenlaw to a term of imprisonment of 442 months. This sentence, however, was in direct contravention of Supreme Court law (and 15 years too low), because the district court failed to impose a 25 year mandatory minimum term of imprisonment on Greenlaw's second and subsequent conviction for a 924(c) offense.

Importantly, although the United States objected to the imposition of this sentence in the lower court, it failed to raise this issue in the court of appeals. On its own initiative, however, the court of appeals addressed this issue. According to the court of appeals, since Greenlaw's sentence directly conflicted with Supreme Court law, the court ordered the district court to enlarge Greenlaw's sentence by 15 years, yielding a total prison term of 662 months.

Earlier today, the Supreme Court vacated and remanded the ruling of the court of appeals. According to the Supreme Court, absent a Government appeal or cross-appeal, a federal court of appeals cannot, on its own initiative, order an increase in an individual's sentence.

Posted by Carl Lietz | Permalink | Email This Post

Posted In: Federal Criminal Trials

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Federal agents who work for the FBI, DEA, ATF and the like can sometimes be very crafty in trying to get a suspect to make a statement that later will be used in court. There is an old saying in my business that it's mighty hard to catch a fish that won't open its mouth. A recent set of cases from the United States Court of Appeals for the Eleventh Circuit gives more power to federal agents when they are investigating suspects who are still in state custody. These decisions allow federal agents to basically ingore the Sixth Amendment rights of suspects who are in state jails while awaiting later federal charges.

The Sixth Amendment to the United States Constitution includes one of our most cherished personal rights. This amendment says that "in all criminal prosecutions the accused shall enjoy the right...to have the assistance of counsel for his defense." However, over the past two decades the courts have been slowly but surely chipping away at our personal freedoms, and the Sixth Amendment's promise of "the right...to have the assistance of counsel" is one more casualty in this process. One way that the courts have been restricting this right is by ruling that the Sixth Amendment is "offense specific." Another method for restricting this right is when the courts have ruled that the right to counsel only starts at the "initiation of adversary judicial criminal proceedings", which means that if the police want to speak to you before a criminal prosecution has begun, they basically can do so even if you have a lawyer already. However, once a case has started, and you have a lawyer, the police or investigators cannot talk with the defendant, and if they do, any statements are generally inadmissible in court.

In a recent decision, the Eleventh Circuit continued the unfortunate trend of chopping away at the right to counsel. The defendant was arrested by state authorities and charged with possession of cocaine. He hired a lawyer, thereby asserting his Sixth Amendment right to have an attorney whenever some agents wanted to question him. After he hired his lawyer, some federal agents went to visit this defendant at the jail, and they got him to confess. Later, federal prosecutors brought a case for the same incident, but charged it slightly differently. In the federal case, the defendant's lawyer argued that the statement to the federal agents was obtained in violation of his client's Siixth Amendment right, in that the defendant had already hired an attorney for the charges at the point when the federal agents went to the state jail.

The Court of Appeals ruled that this questioning by the federal agents was permissible, and therefore, that the confession could be used as evidence. They got around the Sixth Amendment by relying on the "dual sovereignty" fiction. It goes like this: the United States is made up of a single national government along with 50 separate state governments. Each government (the national one and each state) is a separate "sovereign", just like a king back in the Middle Ages. Therefore, just because a person has exercised his right to have a defense lawyer fight against one sovereign, that person needs to again say he wants a lawyer when other investigators come to talk with him about a case that will be brought by a different government.

Obviously, this is merely a charade to let the police get around people's right to defend themselves with the help of a lawyer. Courts regularly help the police, but they dress this help up in flowery language supposedly based on an "interpretation" of our Constitution. The bottom line is that people suspected of a crime should generally only speak with their lawyer about the facts, and should remember that they have the right to have their attorney with them whenever they are confronted by the police or investigators.

Posted by Paul Kish | Permalink | Email This Post

Posted In: Federal Criminal Trials

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The final step of dismissing federal criminal charges against a medical doctor took place today in Atlanta when we got word that the United States Attorney's office agrees that our client fulfilled his part of a pretrial diversion agreement. This case is a lesson in several aspects of federal criminal cases: 1) the feds will always try to use a new law if they get the opportunity, 2) clients need criminal defense attorneys who will fight like crazy against new statutes, 3) reasonable prosecutors can usually be convinced to do the right thing.

Here is what happened. We have been representing a medical doctor for several years who was hauled off an airplane in Atlanta, and accused of making hoax statements about something in his luggage. Here is a web site created by his supporters that lays out some of what happened. Through numerous mistakes, airline and security personnel allowed the doctor to get on the wrong flight, and when the mistake was discovered, he was asked to leave. The doctor was understandably angry, and insisted that his bags be removed as well. Airline personnel refused, and he said that was a very bad idea. By virtue of his work, the doctor was trained about terrorism matters, and it was foolish to let his bags stay on theplane. He explained that for all the airline people knew, there COULD be something in his bag that COULD explode. He was arrested, and for the past two and one-half years Paul Kish has been trying to get this matter concluded.

The major problem with the case was that the government decided to try and use a brand new criminal statute, 18 U.S.C. section 1038. This law basically makes it a crime to make a false statement, which if true, would cause another person to think that an act of terrorism was about to take place. The law is way out there, an example of governmental overreaching after the horrible events of September 11, 2001.

We filed a whole bunch of challenges to the statute, pointing out that it was extremely vague, and arguing that the prosecution infringed on the doctor's First Amendment right to say the obvious: namely, that it was a damn stupid idea to allow bags to remain on a flight when the passenger has been removed. This is a know terrorism tactic, to check baggage and then not take the flight. For over a year, we had a legal battle over the statute, and the first judge who looked at it almost, but not quite, agreed with us.

On the eve of trial, I met with the prosecutors who were in charge of the case. We convinced them to dismiss, in return for an agreement by the doctor to perform community service. This was no problem, in that the doctor is a very civic minded person anyway, and was glad to give back to his community. Today, I got the official word that the prosecutors concede that the doctor has done all he was obligated to do, and therefore the case is completely finished.

As I said above, this case shows the dangers of when new laws are handed down. There always is a danger that investigators and prosecutors will want to try it out, to see how far they can push it. The case also demonstrates that attorneys need to fight long and hard, but if they are facing reasonable prosecutors, they usually can convince everybody to do the right thing.

Posted by Paul Kish | Permalink | Email This Post

Posted In: Federal Criminal Trials

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Most folks who know me or who might stumble across this blog recognize that I practice mostly federal criminal law here in Atlanta. I have been doing this for about 23 years now, and still enjoy my work immensely. Nevertheless, there are some aspects of being a criminal defense lawyer here in Georgia (or anywhere else for that matter) which are downright weird, scary and at times depressing. Let me explain a recent example of this.

My law partner Carl and I recently represented a very good and honorable family man in a large mortgage fraud prosecution. Our client was one of the least involved people in the whole scheme. He had nothing to do with the actual fraudulent transactions with the lending institution. After we talked the case over for a long time, this man decided that the best option for himself and his family was to enter a guilty plea, even though we had some serious doubts as to whether a jury would find him guilty at a trial.

Anyone who has ever read this blog knows how I ramble on about the Sentencing Guidelines and the spate of decisions in the past 7 years from the Supreme Court. One part of the Guidelines allows for a judge to consider a lower sentence if a defendant cooperates in the investigation or prosecution of other people. However, this reduction for cooperation only can happen when the prosecutor asks for it, in what we call a "5K" motion or a "Rule 35" proceeding. Individual prosecutors need to get approval from their supervisors as to how much of a reduction they can request for a particular defendant. Most U.S. Attorney's offices have groups of senior prosecutors who screen these 5K requests, supposedly to make sure that they are handled uniformly.

Here's the weird part. The Sentencing Guidelines are based on a table, which sets out ranges of potential sentences. The higher the number (and the greater the criminal history), the higher the range. However, the table is not a straight arithmetic progression, which is a fancy way of saying that a difference of one level up at the top end of the Guidelines results is far greater than a one level change at the bottom end. For example, a much more involved defendant might be at offense level 30, and if he gets a 2 level reduction for cooperating, his Guideline range is reduced by almost two years. On the other hand, a client barely involved in a case (like our recent client) who is down at level 15, will also get a 2 level reduction for cooperating, but this results in a mere 6 month reduction in his sentencing range.

In our recent case, we argued strenuously that this was unfair, that our client should get an even better reduction, in return for his cooperation (he had testified at trial against some other people). We did get a significant reduction in other areas of the sentencing process, but this case highlights some of the truly weird and unfair aspects of sentencing in federal court.

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Posted In: Federal Criminal Trials

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I spoke recently on the topic of Federal Firearms Offenses to a group of lawyers in Birmingham, Alabama. My law partner Carl Lietz and I each periodically speak to attorneys in various parts of the country, usually in the South but occasionally in other regions as well. Carl also spoke to the same group about Internet Sex Crimes, a growing segment of crimes we now see prosecuted in federal court.

My presentation about gun cases in federal court focused on the two major crimes in this area: possession by a "prohibited person" (such as a previously convicted felon) and use of a gun during another federal crime (such as bank robbery or drug dealing). Many people are shocked as to how much time they can get for weapons offenses in federal court. In my speech to the Alabama attorneys, I focused on the law, but also discussed some tricks and tips for either winning their case altogether or at least to reduce their client's potential jail sentence.

We also discussed how gun crimes are often among the dumbest criminal episodes we ever encounter. For some reason, people seem to forget how dangerous a weapon can be. These same people are shocked when their lawyer tells them that they are facing an incredibly longer jail sentence because they brought a gun into the bank.

Finally, we discussed how the Second Amendment to the Constitution impacts federal firearms cases. Remember that the Second Amendment to the United States Constitution in some ways prevents the federal government from regulating the possession and use of firearms. The Supreme Court currently has taken a case involving a Washington D.C. law that completely prohibits law-abiding citizens from even possession certain weapons in their homes. This should be an interesting decision, although it likely will not have a real big impact on the vast majority of gun crimes prosecuted in federal court.

Posted by Paul Kish | Permalink | Email This Post

Posted In: Federal Criminal Trials

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The high profile prosecution of actor Wesley Snipes in Orlando, Florida seems to be an example of the "perfect storm" phenomenon. The combination of publicity, taxes and race has led to a variety of interesting rulings and tactics in this federal criminal tax case. These factors are a lesson to other potential high profile targets who fall into the sights of aggressive federal prosecutors. The main lesson: get good accounting, legal and public relations advice very early on.

Mr. Snipes was indicted in federal court in Orlando, and charged with two other men with a complicated scheme to avoid paying taxes, and also with improperly requesting a $12 million dollar refund. Prosecutors claim that Mr. Snipes asked for a refund, and then later stopped filing tax returns altogether based on a legal theory created by the other two defendants.

Criminal tax cases are in some sense very complicated, yet in other ways, they are simple. Too many people believe they need a lawyer well-schooled in the intricacies of the Internal Revenue Code when the feds bring a criminal tax case. While the lawyer obviously needs to understand the tax law, it is very important to remember that it still is a criminal case, the sort of legal proceeding best handled by experienced criminal defense attorneys. It appears that some of this confusion between the two types of lawyers has come up in the Snipes case. For example, Mr. Snipes asked the trial judge to let him switch lawyers on the eve of trial, supposedly because the first lawyer simply did not understand what was going on in a criminal case. The trial judge believed this tactic was merely a ploy, but later delayed the trial because an insurmountable conflict developed between Snipes and the attorney.

In another development, Mr. Snipes claims that race played a role in which charges were brought against him. He contended that he was indicted on more charges than his white co-defendants, and that prosecutors used his race as a reason for charging him more harshly than the others.

The defense team also tried to get a change of venue, to remove the case from Orlando, a request rejected by the trial judge. Mr. Snipes's lawyers then tried to raise this issue to a higher court right away, what we call an "interlocutory appeal." Yesterday, the Eleventh Circuit Court of Appeals rejected this interlocutory appeal. As a result, Mr. Snipes's case will be back on the docket in Orlando soon, and he will either have to go to trial or work out some kind of deal.

Again, this case is another example of a perfect storm: a combination of factors that makes it very difficult for a defendant to get a fair trial. Status, race, publicity and tax concerns always make it difficult to defend such cases.

Posted by Paul Kish | Permalink | Email This Post

Posted In: Appeals , Federal Criminal Trials , White Collar Crime

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One of the hardest questions lawyers need to answer in a federal criminal case is whether the prosecutor can use "similar act" or "other crime" evidence. Sometimes, the law permits the prosecutor to introduce evidence that on a time OTHER than the one charged in the indictment, the defendant did something similar to what he or she is charged with. I discussed this issue a little bit the other day in an article in the Atlanta Journal and Constitution. There are three major problems in this area: 1) many lawyers do not really know the law, 2) the judge lets the prosecutor introduce such evidence, but the prosecutor then makes improper use of the "similar act," and 3) the lawyer fails adequately object to the evidence, which is a shame because many times the court of appeals will reverse a conviction if the evidence was either improperly admitted or incorrectly used.

In federal court, this issue for the most part is controlled by Federal Rule of Evidence 404(b). Under this rule, evidence of "other crimes" is NOT admissible to show the defendants character. This part of the Rule prohibits "propensity" evidence, which is a fancy way of saying that just because a person did something on one occasion this does not mean he did it again another time. However, the prosecutor CAN use "other crimes" evidence to show intent, motive, identity or lack of accident. In other words, if the defendant intended to sell drugs one day, this makes it more likely he intended to do so on another occasion he had drugs in his possession. If the defendant knew he was carrying a gun one day, this makes it more likely that is was not some sort of mistake he had a gun in his vehicle on another occasion. Unfortunately, too many lawyers are not familiar with the ins and outs of the Federal Rules, and they make mistakes that can harm their clients.

Besides not knowing the rules, some lawyers fail to recognize when the prosecutor makes improper use of such evidence. For example, if a judge allow evidence of another occasion when the defendant had a gun in his car, this does not allow the prosecutor to argue that the defendant is a gun dealer. Remember, in the examples set out above, there are limited uses for "other crimes" evidence, and such evidence cannot be used to show "propensity."

When a prosecutor is making improper use of such evidence, the defense attorney needs to recognize it, object, and then most importantly, the lawyer needs to "perfect" his objection. This means that the attorney has taken the proper steps to preserve this issue for appeal. This is extremely important, in that the courts of appeals sometimes reverse convictions when prosecutors make improper use of "other crime" evidence. Our lawyers regularly take over cases where these issues have not been adequately "perfected" by the first attorney, which makes it even more difficult to assist the client.

Posted by Paul Kish | Permalink | Email This Post

Posted In: Federal Criminal Trials

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Trials of Federal criminal cases are difficult enough to defend, but helping the client figure out whether to testify in his or her defense might be the single hardest job for the lawyer. In an earlier post, I described some rules by which the courts say that the defendant's testimony can "fix" the holes in an otherwise insufficient prosecution case. Today, I want to go over a few other issues that can affect whether the client should or should not testify.

The Sentencing Guidelines control much of the potential sentence that our clients are facing in Federal court, but these Guidelines also have a huge impact on the trial itself. First, a Defendant who pleads guilty can earn up to three points off the Guideline score, while a defendant who goes to trial will almost never get this reduction. In other words, the Guidelines punish a defendant who wants his or her day in court.This seems manifestly unfair when we explain it to many of our clients, and I basically agree with them.

However, the Guidelines have a second, and even more dangerous, effect on trials. Under the Sentencing Guidelines, a defendant who engages in "obstruction of justice" gets two more points added to his or her score. When a defendant testifies yet is found guilty by the jury, prosecutors always claim that the defendant lied on the witness stand, and therefore should get these two extra points for obstruction of justice. The United States Supreme Court has said that it is OK to do this, and these two points are not an unconstitutional infringement of a person's right to defend him or herself.

What this means in effect is that whether to have a trial and whether the client should testify in his own defense can result in as much as a five point swing under the Sentencing Guidelines. These five points can make the difference between many years in prison as opposed to a much shorter sentence. Clients need an attorney who knows these rules, and who can assist in determining whether it is worth the risk to have a trial and testify. My law partner Carl Lietz and I regularly go over these risks with all our clients who have been charged with federal crimes.

I often talk with or sometimes even represent people who had other lawyers in their federal cases. The vast majority of lawyers know these rules, or at the very least, they learn about the rules from more experienced attorneys. People who are charged with crimes need to make sure they select an attorney who not only knows the law, but who is capable of helping the client with these difficult decisions. Here at Kish & Lietz, we pride ourselves on working with our clients to come up with the best decision about whether or not to testify.

Posted by Paul Kish | Permalink | Email This Post

Posted In: Federal Criminal Trials

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