ALERT UPDATE 2020 – WEEKLY REPORT U.S. Supreme Court and Circuit Court Wins
Edition: Week of June 9-13, 2025
SUPREME COURT WATCH
The Justices held their June 12, 2025, conference yesterday. We expect Orders on Monday, June 16, 2025.
On Thursday, the Supreme Court's released a unanimous ruling in Rivers v. Guerrero, (No. 23-1345) (S. Ct. June 12, 2025). Authored by Justice
Jackson, the opinion begins this way:
Authored by Justice Jackson, the opinion begins this way:
Incarcerated individuals who seek to challenge their imprisonment through a federal habeas petition are generally afforded one opportunity to do so. See 28 U.S.C. §§ 2254, 2244. Before a
federal court can address a petitioner’s second or successive federal habeas filing on the merits, the incarcerated filer must clear strict procedural hurdles that the Antiterrorism and
Effective Death Penalty Act of 1996 (AEDPA) erects. See § 2244(b). This case presents the question of how to classify a second-in-time habeas filing when the judgment denying the first
application is under review on appeal. Does that second habeas-related submission qualify as a second or successive application, thereby triggering § 2244(b)’s stringent gatekeeping
requirements?
We hold that, in general, once the district court has entered its judgment with respect to the first habeas petition, a second-in-time application qualifies as “second or successive” and is
thus properly subject to the requirements of §2244(b).
The Court also released five more opinions, nearly all also unanimous and dealing with mostly procedural issues. A couple of these might be viewed as criminal adjacent, but the wait continues for the two biggest argued sentencing cases still pending, Hewitt v. United States, (No. 23-1002) (argued Jan 13, 2025), and Esteras v. United States, (No. 23-7483) (argued Feb 25, 2025).Based on the Court's announced opinion days, June 18, would appear to be the earliest we can hope for Hewitt and Esteras. Stay tuned.
CIRCUIT COURT VICTORIES: 1st, 4th, 7th and DC Circuits Deliver Big Wins--United States v. Matta-Quones, (Nos. 23-1132, 23-1134)(1st Cir. June 9, 2025)– Luis Javier Matta Quiñones ("Matta") appealed his convictions for possession of firearms and ammunition as a prohibited person and possession of a machinegun. At trial, Matta claimed that he was simply in the wrong place at the wrong time and that police officers looking for a success story pinned nearby contraband on him. To boost his claim, he attempted to cast doubt on police officers' testimony that he threw a feed sack containing guns and ammunition, among other items, onto the roof of a building as he fled. On appeal, Matta argued the district court prevented him from effectively advancing his defense case in myriad ways. Because the Court agreed the district court erred in permitting the government's case agent to be a participating presence during jury deliberations, the Court vacated Matta's convictions and remanded for a new trial. And because his revocation of supervised release sentence was based on those convictions, the Court also vacate that sentence and remand for re- sentencing.
United States v. Garrett, (No. 22-4407)(4th Cir. June 13, 2025)– Dashawn Leonard Garrett withdrew his pending suppression motion, accepted a plea deal, and pled guilty to three charges arising from a drug trafficking investigation in Wilson County, North Carolina. After he was sentenced, he learned about information in a Government disclosure that, he contends, unearthed evidence of egregious police misconduct that affected the prosecution’s integrity, and prosecutorial misconduct that blocked his ability to understand the case against him. This appeal asks the Court to decide whether the newly discovered information renders Garrett’s plea involuntary. The Court found that a reasonable defendant standing in Garrett’s shoes would not have pled guilty had he or she known all the relevant information. Therefore, Garrett’s plea was involuntary and was vacated.
United States v. Clark and Mesner, (Nos. 24-1320 & 24-1321)(7th Cir. June 10, 2025)– Derrick Clark and Shawn Mesner worked for Didion Milling, Inc. (“Didion”), a corn milling company. In May 2017, Didion’s grain mill exploded, killing five employees. The Occupational Health and Safety Administration (“OSHA”) investigated the explosion and ultimately referred Didion for criminal prosecution. The government charged Didion and several of its employees with federal crimes relating to their work at the mill. Three of the defendants, including Clark and Mesner, proceeded to trial. In this appeal, Clark and Mesner challenged the district court’s evidentiary rulings and jury instructions, the indictment, the sufficiency of the evidence underlying their convictions, and the constitutionality of their convictions. The Court vacated Mesner’s conviction on Count 4. For this count as to Mesner, the Court remanded for an entry of judgment of acquittal and for further proceedings consistent with this opinion.
Rudometkin v. United States, (No. 23-5180)(DC Cir. June 10, 2025)– In 2018, Appellant David Rudometkin was convicted by military judge Lt. Col. Richard Henry and sentenced to 17 years. After Henry was later suspended for misconduct, Rudometkin sought a mistrial, which was denied by another military judge, Col. Douglas Watkins—who was subsequently appointed Chief Trial Judge of the Military Commissions. Rudometkin filed FOIA requests to obtain records on Henry’s disciplinary proceedings and Watkins’s appointment. The Government either rejected these requests or withheld records under FOIA Exemption 5, which protects deliberative process and other privileges. In 2020, Rudometkin sued pro se to challenge the withholdings. His amended complaint focused solely on the Department of Defense records about Watkins. The Government later released some redacted documents. The District Court granted summary judgment to the Government, finding its search sufficient and its withholdings proper under Exemption 5, rejecting Rudometkin’s argument that alleged misconduct negated the privilege. It also denied his motions to reintroduce claims about the Henry records. On appeal, the Court reversed in part. The Government had not shown it released all reasonably segregable, non- exempt material under Exemption 5. The Court therefore remanded for further proceedings on that issue.
IS YOUR CONVICTION OR SENTENCE CHALLENGEABLE?Recent Executive Orders and circuit rulings have reopened the door for:
- § 922(g) firearm convictions (non-violent, non-drug priors); and
- Compassionate release motions based on non-retroactive § 403(a) stacking reforms.
Recent wins in the 3rd, 6th, 8th, 9th, and 10th Circuits show courts are rethinking prior convictions and excessive sentencing on § 922(g) convictions.
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