United States v. Martin Johnson (4th Cir. December 2019)

The Court held that a district court does not plainly err by failing to give a limiting instruction when admitting 404(b) evidence in the absence of a defendant's request for such an instruction. Additionally, the Court held that robbery possession of a controlled substance with intent to distribute under Maryland law are predicate "violent felonies" under the ACCA.

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United States v. Dane Gillis (11th Cir. September 2019)

The Court affirmed the defendant's convictions for enticing a minor under § 2422(b) but reversed his conviction under § 373 for solicitation to commit a crime of violence, holding that kidnapping under § 1201(a) is not a "crime of violence" under the categorical approach applicable to § 373. The Court also held that the defendant's right to a complete defense was not violated by the trial court's proper rulings on the inadmissibility of the defense experts' testimony.

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United States v. John Buncich (7th Cir. June 2019)

The Court held that there was ample evidence that the money paid to the defendant-sheriff's campaign was more than a “campaign contribution,” and that they were in fact made in exchange for “official acts,” where the evidence showed that the awarding and revoking of contracts directly corresponded to the bribes being paid.The Court also held that the district court erred in admitting Rule 404(b) evidence regarding the deposit of a substantial amount of money in the defendant's bank account since this evidence was unduly prejudicial and provided limited probative value, especially since the amount deposited was more than double the amount of bribes taken in.

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United States v. Samir Benamor (9th Cir. June 2019)

The Court held that the “antique firearm defense” was an affirmative defense as opposed to an element of the 922(g). The Court acknowledged that it remains an open question whether the “antique firearm defense” is objective, meaning that the age of the firearm alone determines the availability of the defense, or whether the defense is subjective, meaning the defense applies when a defendant reasonably believes the firearm was manufactured before 1899.

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United States v. Jambulat Tkhilaishvili, et al. (1st Cir. June 2019)

The First Circuit rejected the defendants’ argument that the Government had failed to prove that the defendants had “obtained” property from another because the investor’s interest was intended for a friend and not the defendants. The Court also rejected the defendants’ argument that the investor’s interest in the clinic was not “property” under the Hobbs Act because it was not profitable at the time of the attempted extortion and that a “heightened showing” of an effect on interstate commerce is required when the victim is an individual rather than a business.

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