Case Summaries

Criminal Law & Procedure

[12/31] US v. House
Defendant's sentence of 188 months for distribution of crack cocaine is affirmed where the district court: 1) properly adjusted base offense level due to defendant's obstruction of justice in asking defense witness not to testify; 2) did not abuse its discretion in declining to reduce sentence based on the disparity in the sentencing guidelines for powder cocaine versus crack cocaine; and 3) properly considered all the requisite factors under sentencing law.

[12/31] US v. Hill
Conviction for bank robbery is affirmed where the district court committed harmless error in admitting evidence that defendant bought a luxury car shortly after the bank robbery. Defendant's challenge to the impartiality of his jury is also rejected because the court's method of questioning potential jurors was sufficient to assure that any prejudice would have been discovered and, in any event, defendant had failed to use all his peremptory challenges.

[12/31] Corcoran v. Buss
District court's grant of death row inmate's habeas petition is reversed because prosecutor's offer to forego seeking the death penalty if defendant would agree to a bench trial did not penalize defendant for exercising his constitutional right to a jury trial. State supreme court properly examined and rejected defendant's claim that he was incompetent to waive post-conviction proceedings.

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