Justia Criminal Law Opinion Summaries

The appellant joined two friends at a Las Vegas recording studio to make music, but an argument ensued. After being asked to leave, the appellant returned outside, and another dispute occurred. Surveillance footage showed the appellant firing nine shots at the two men, resulting in one fatality and serious injuries to the other. The appellant then demanded a vehicle and left the scene, later discarding firearms in the desert. He was charged with multiple offenses including murder, attempted murder, robbery, and grand larceny auto.The case was first heard in the Eighth Judicial District Court, Clark County. Prior to trial, several delays occurred, including competency evaluations and changes in counsel, mostly prompted by the appellant or for his benefit. The appellant sought to suppress evidence, filed a petition for a writ of habeas corpus, and eventually requested to represent himself. After multiple competency assessments, the district court found him competent, allowed self-representation, and provided an investigator for assistance. After an eight-day trial, a jury found the appellant guilty of all charged offenses. The district court denied his motion to dismiss for violation of speedy trial rights and sentenced him to life imprisonment with parole eligibility after twenty-eight years.On appeal, the Supreme Court of the State of Nevada reviewed claims that the appellant was not competent to represent himself, his waiver of counsel was not valid, his speedy trial rights were violated, evidence was improperly destroyed, compulsory process was denied, and jury instructions were erroneous. The court held that the district court properly found the appellant competent to waive counsel and represent himself, rejected claims of speedy trial violations as the delays were attributable to the appellant, found no bad faith or undue prejudice in evidence destruction, determined compulsory process was satisfied, and concluded any jury instruction error was harmless. The Supreme Court of Nevada affirmed the convictions. View "DUCKKET VS. STATE" on Justia Law

Paul Engstrom pleaded guilty to conspiracy to distribute a controlled substance and money laundering conspiracy, admitting to involvement in distributing 500 grams or more of cocaine—an offense carrying a five-year mandatory minimum sentence. In his plea agreement, Engstrom acknowledged he was ineligible for safety valve relief under 18 U.S.C. § 3553(f) and agreed not to seek such relief. At sentencing in the United States District Court for the District of Nevada, the court imposed a 70-month sentence, below the guideline range but above the statutory minimum, citing Engstrom’s difficult pretrial detention and his coconspirators’ similar sentences.Following sentencing, the district court held a resentencing hearing pursuant to Federal Rule of Criminal Procedure 35, aiming to correct a perceived technical error in considering the mandatory minimum after granting Engstrom safety valve relief. The court concluded that Engstrom was eligible for safety valve relief, finding that his statements in open court were sufficient, and imposed a 46-month sentence, below the statutory minimum. The government moved for reconsideration, arguing Engstrom had not satisfied the statutory debrief requirement and was ineligible under the Supreme Court’s decision in Pulsifer v. United States, issued during the appeal, which interpreted § 3553(f)(1) to preclude safety valve relief if any one of three criminal history criteria applied.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s resentencing decision for plain error and found no error in holding the Rule 35 hearing. However, the Ninth Circuit held that Engstrom was not eligible for safety valve relief because he did not provide a complete debrief to the government as required by § 3553(f)(5), and, under Pulsifer, his prior three-point conviction categorically precluded relief. The court reversed the district court, vacated Engstrom’s sentence, and remanded for resentencing without safety valve relief. View "USA V. ENGSTROM" on Justia Law

An individual was indicted in Oregon for unauthorized use and possession of a stolen vehicle, alleged to have occurred in August 2021. After the charges were initially dismissed without prejudice in October 2022 due to the state's inability to appoint counsel, the same charges were refiled in April 2024. Upon arraignment, the defendant requested appointed counsel and was found eligible, but no attorney was available. Despite multiple hearings over several months to appoint counsel, the defendant remained unrepresented and subject to pretrial release conditions, including mandatory court appearances and restrictions on travel.In December 2024, a volunteer attorney entered a limited appearance to file a motion to dismiss based on the lack of counsel, arguing violations of Oregon's constitutional right to counsel. The Multnomah County Circuit Court denied the motion, noting the case was in "suspended animation" due to the absence of counsel. The defendant then petitioned the Supreme Court of Oregon for mandamus relief. While briefing was ongoing, the trial court ultimately dismissed the criminal case without prejudice in April 2025, citing lack of available attorneys.The Supreme Court of Oregon reviewed the mandamus petition and found the case was moot since the underlying criminal charges had already been dismissed. However, the court exercised its discretion under ORS 14.175 to address the recurring legal issue. On the merits, the court held that the state violated the defendant's right to counsel under Article I, section 11 of the Oregon Constitution by failing to appoint counsel post-arraignment for an extended period. The court determined that dismissal without prejudice is an appropriate remedy for such violations and established a general rule: if an eligible defendant is unrepresented for more than 60 consecutive days in a misdemeanor case or 90 consecutive days in a felony case post-arraignment, dismissal without prejudice is required. The alternative writ of mandamus was dismissed as moot. View "State v. Roberts" on Justia Law

The case concerns an altercation in Sheridan, Wyoming, during which Cody McCalla and his friend encountered Patrick Mudd and Mudd's girlfriend over a parking dispute. After a verbal confrontation, McCalla and his friend moved their vehicle and proceeded toward the fairgrounds. Mudd stood on the sidewalk, and a second confrontation ensued between McCalla and Mudd, escalating into physical violence. After several exchanges, McCalla ultimately punched Mudd, causing him to fall, hit his head, and later die from his injuries. McCalla was charged with involuntary manslaughter.The District Court of Sheridan County reviewed several pretrial motions. McCalla moved to compel production of unredacted law enforcement reports, which the district court denied, finding the redacted portions exempt from disclosure under Wyoming Rule of Criminal Procedure 16. McCalla also moved to dismiss the charge, claiming immunity from prosecution under Wyoming Statute § 6-2-602(f) on grounds of self-defense. The district court held an evidentiary hearing, requiring McCalla to proceed first, as his motion alone did not establish a prima facie case. After testimony, the district court found McCalla met his prima facie burden, but the State proved by a preponderance of evidence that McCalla was the initial aggressor in the second altercation and did not use reasonable defensive force, denying immunity.The Supreme Court of Wyoming reviewed the appeal. It held the district court did not err in requiring McCalla to proceed first at the evidentiary hearing, found no error in the district court’s determination that McCalla was the initial aggressor and thus not entitled to self-defense immunity under Wyoming Statute § 6-2-602(f), and declined to address the discovery issue, as it was not properly preserved for appeal. The Supreme Court affirmed the district court’s rulings. View "Mccalla v. The State of Wyoming" on Justia Law

The case involves a defendant who was charged with first-degree murder after the fatal shooting of an individual at a bar. The investigation initially yielded no suspect, but the defendant voluntarily approached police, admitted being present at the scene, and expressed concern about possibly doing something “bad.” Over several days, police recovered relevant evidence, including a firearm and clothing linked to the defendant, and conducted multiple interviews. After a polygraph test indicated deception, detectives confronted the defendant, leading to a confession. The defendant was subsequently indicted, and his counsel moved to suppress the confession, arguing it was coerced and a false confession.The Circuit Court of the Seventh Judicial Circuit, Pennington County, South Dakota, denied the suppression motion, finding the confession was not the result of improper coercion. Defense counsel then disclosed a forensic psychiatrist, Dr. Manlove, as an expert on false confessions. The State objected to the admissibility of Dr. Manlove’s testimony under Daubert v. Merrell Dow Pharmaceuticals, Inc., and requested a Daubert hearing. After the hearing, the circuit court allowed Dr. Manlove’s testimony on certain general topics related to false confessions but imposed restrictions prohibiting him from relating his testimony to the specific facts of the case or opining that the defendant’s confession was coerced.The Supreme Court of the State of South Dakota reviewed the circuit court’s evidentiary ruling. Applying the abuse of discretion standard, the Court held the circuit court erred by admitting Dr. Manlove’s testimony. The Court found the proffered expert opinions lacked reliability and relevance under Rule 702 and Daubert, and that the testimony was not helpful to the jury given the restrictions imposed and absence of a reliable methodology. The Supreme Court reversed the circuit court’s order permitting the expert testimony and remanded for further proceedings. View "State V. Huante" on Justia Law

A seventeen-year-old defendant was charged with murder after stabbing another individual during an altercation in a Grand Forks, North Dakota apartment parking lot. The victim died from the stab wound. With the assistance of counsel, the defendant entered into a plea agreement, pleading guilty to murder. The agreement stipulated a sixty-year sentence with twenty years suspended, and permitted the defendant to request a downward departure to as low as fifteen years. During the plea hearing, the court confirmed the defendant’s understanding of the plea and its consequences, and accepted the plea as voluntary.The District Court of Grand Forks County, Northeast Central Judicial District, presided over the case. At sentencing, the court reviewed investigative reports, victim impact statements, and arguments from both sides. The court considered the defendant’s age and behavior, including social media posts related to the incident. Ultimately, the court imposed a sixty-year sentence with twenty years suspended, consistent with the plea agreement, without granting a downward departure. The defendant did not object to the adequacy of the plea colloquy or move to withdraw the guilty plea before sentencing.The Supreme Court of North Dakota reviewed the appeal. The defendant argued that the plea was not knowing, voluntary, or intelligent due to an insufficient Rule 11 colloquy, and that the forty-year sentence was cruel and unusual punishment. The court applied the obvious error standard, finding that the District Court erred by not adequately establishing a factual basis for the plea, but concluded the error did not affect the defendant’s substantial rights. The court further held that the forty-year sentence was not grossly disproportionate to the offense and did not violate the Eighth Amendment. The Supreme Court affirmed the amended criminal judgment. View "State v. Haskins" on Justia Law

A driver backed her car into a pedestrian in a bar parking lot shortly after the bar’s closing time. When police arrived, she admitted to drinking three beers before driving. The responding officers did not observe any signs of physical impairment, and the driver successfully completed an initial horizontal gaze nystagmus (HGN) test. Both officers expressed that they did not believe the driver was impaired, and one officer sought to administer a preliminary breath test (PBT) primarily to document his investigation. The driver initially declined the PBT but later consented after additional field sobriety tests indicated impairment; the PBT and a subsequent DataMaster test showed an alcohol concentration above the legal limit. The Commissioner of Public Safety revoked her driver’s license.The revocation was challenged in the District Court through an implied consent hearing. The court weighed all circumstances and found that, despite the absence of physical signs of impairment and the minor nature of the accident, the driver’s admission to drinking, the timing and location, and the fact she struck a pedestrian provided reasonable suspicion to request the PBT. The District Court upheld the license revocation. The Minnesota Court of Appeals reversed, reasoning that the initial reasonable suspicion was dispelled by the driver’s satisfactory HGN test and lack of physical indications of impairment.The Minnesota Supreme Court reviewed the case and applied a de novo standard to the District Court’s legal conclusion. The Supreme Court held that, under the totality of circumstances, the officer’s request for the PBT was supported by reasonable suspicion of impaired driving, which was not dispelled by other factors that diminished but did not conclusively negate suspicion. The Court reversed the decision of the Court of Appeals, reinstating the revocation. View "Lorsung vs. Commissioner of Public Safety" on Justia Law

Following a single-vehicle accident in Lino Lakes, Minnesota, law enforcement officers encountered the driver, who displayed signs consistent with alcohol consumption, including slurred speech and bloodshot eyes. After a preliminary breath test yielded insufficient samples but indicated alcohol presence, the driver was transported to a hospital. A trooper obtained a search warrant and requested blood or urine samples from the driver, but none were provided. The driver was subsequently charged with second-degree test refusal and third-degree driving while impaired.The Anoka County District Court held a jury trial where both officers and the driver testified with conflicting accounts regarding the hospital interaction. At the close of trial, the driver requested a jury instruction clarifying that the State must prove actual unwillingness to submit to testing, citing precedent from State v. Ferrier. The district court denied this request, instructing the jury only that refusal must be proven. The jury convicted the driver of test refusal but acquitted on the DWI charge. On appeal, the Minnesota Court of Appeals affirmed the conviction, holding that the district court’s instructions adequately stated the law and, even if erroneous, any error was harmless because of substantial evidence supporting refusal.The Minnesota Supreme Court reviewed whether the district court abused its discretion by denying the requested instruction. The Court held that when the jury is instructed that refusal must be proven, the district court does not abuse its discretion by declining to further instruct on “actual unwillingness.” The Court reasoned that the term “refuse” is commonly understood and does not require additional definition for jurors. Accordingly, the Supreme Court affirmed the Court of Appeals’ decision. View "State of Minnesota vs. Schmeichel" on Justia Law

The case involves the conviction of a defendant for murder following the stabbing death of Kimberly Neptune, who was found in her apartment with 484 sharp force injuries. The defendant, Kailie Brackett, and a co-defendant, Donnell Dana, Jr., were indicted for intentional, knowing, or depraved indifference murder. The prosecution presented evidence including surveillance footage, testimony from witnesses about Brackett’s relationship with the victim and usage of the victim’s bank card, as well as forensic evidence from the crime scene. Notably, the prosecution relied on expert testimony comparing partial, sock-clad bloody footprints found at the scene to prints taken from Brackett in prison.The Washington County Unified Criminal Docket conducted the jury trial. Brackett objected to the admission of the forensic podiatry evidence, arguing it lacked scientific reliability. The trial court admitted the expert testimony over her objections, and the jury ultimately found Brackett guilty, but deadlocked as to Dana. Brackett was sentenced to fifty-five years in prison and appealed her conviction and sentence, challenging the sufficiency of the evidence, admission of the expert testimony, and prosecutorial conduct.The Maine Supreme Judicial Court reviewed the case. It held that the trial court erred in admitting the forensic podiatry testimony comparing the partial, sock-clad footprints. The expert’s methodology lacked scientific reliability and was not sufficiently grounded in recognized standards, and the prosecutor’s closing arguments improperly characterized this evidence as definitive proof of Brackett’s presence at the scene. Because this error was likely to have affected the jury’s verdict, the Court vacated Brackett’s conviction and remanded for a new trial, holding that the State may retry Brackett but must exclude the challenged footprint comparison testimony. View "State of Maine v. Brackett" on Justia Law

Aaron Aldrich was convicted of two counts of intentional or knowing murder and possession of a firearm by a prohibited person. The evidence at trial showed that Aldrich went to a trailer in Poland, Maine, carrying a nine-millimeter rifle. He entered the trailer, shot both an adult and a teenager multiple times, and took a handgun and cash before leaving. Afterward, Aldrich told his friend he had killed the residents and instructed his girlfriend to dispose of evidence. The police later found forensic evidence linking Aldrich to the crime scene and recovered the murder weapon. He was apprehended in New Hampshire after fleeing in a stolen van.The Androscoggin County Unified Criminal Docket conducted a jury trial. Aldrich moved to suppress his post-arrest statements, claiming Miranda violations and improper questioning after requesting counsel; this motion was denied after an evidentiary hearing. The trial court made several evidentiary rulings, including admitting images of the victims, evidence of Aldrich’s theft and flight, testimony about his prior acts, and limiting cross-examination of witnesses. Aldrich testified, claiming self-defense. The jury found him guilty on all counts. He was sentenced to concurrent life terms for the murder convictions and five years for the firearm-possession count. Aldrich appealed both his convictions and sentences, arguing errors in suppression, evidentiary rulings, jury instructions, and sentencing analysis.The Maine Supreme Judicial Court reviewed all claims. The court held that the denial of the motion to suppress was correct because Aldrich was not subjected to custodial interrogation under Miranda. Most evidentiary rulings were proper; the few errors identified, including admission of hearsay and exclusion of certain defense evidence, were harmless and did not cumulatively deprive Aldrich of a fair trial. The jury instructions and sentencing analysis were found to be legally sound. The court affirmed the convictions and sentences. View "State of Maine v. Aldrich" on Justia Law