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2023 U.S. Supreme Court Criminal Law Update

U.S. v. Hansen, Op. No. 22-179 (06/23/2023) (Immigration Offenses)

Because § 1324(a)(1)(A)(iv) forbids only the purposeful solicitation

and facilitation of specific acts known to violate federal law, the clause

is not unconstitutionally overbroad.

Samia v. U.S., Op. No. 22-196 (06/23/2023) (Sixth Amendment/Hearsay)

The Confrontation Clause was not violated by the admission of a

non-testifying co-defendant’s confession that did not directly inculpate

the defendant and was subject to a proper limiting instruction.

Lora v. U.S., Op. No. 22-49 (06/16/2023) (Sentencing)

Section 924(c)(1)(D)(ii)'s bar on concurrent sentences does not govern

a sentence for a § 924(j) conviction. A § 924(j) sentence therefore can

run either concurrently with or consecutively to another sentence.

Smith v. U.S., Op. No. 21-1576 (06/15/2023) (Double Jeopardy)

The Constitution permits the retrial of a defendant following a trial

in an improper venue conducted before a jury drawn from the wrong

district.

Dubin v. U.S., Op. No. 22-10 (06/08/2023) (Identity Theft)

Under § 1028A(a)(1), a defendant “uses” another person's means of

identification “in relation to” a predicate offense when the use is at the

crux of what makes the conduct criminal.

U.S. v. Schutte, et al., Op. No. 21-1326 (06/01/2023) (False Claims Act)

The FCA’s scienter element refers to a defendant’s knowledge and

subjective beliefs—not to what an objectively reasonable person may

have known or believed.

Percoco v. U.S., Op. No. 21-1158 (05/11/2023) (Honest Services Wire Fraud)

Instructing the jury based on the Second Circuit's 1982 decision in

Margiotta on the legal standard for finding that a private citizen owes

the government a duty of honest services was error.

Ciminelli v. U.S., Op. No. 21-1170 (05/11/2023) (Fraud)

Because the right to valuable economic information needed to make

discretionary economic decisions is not a traditional property interest,

the Second Circuit's right-to-control theory cannot form the basis for a

conviction under the federal fraud statutes.

Bittner v. U.S., Op. No. 21-1195 (02/28/2023) (Bank Secrecy Act/Sentencing)

The BSA's $10,000 maximum penalty for the non-willful failure to file

a compliant report accrues on a per-report, not a per-account, basis.

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