Justia Criminal Law Opinion Summaries

Luis Francisco Corona-Montano was arrested after law enforcement officers observed him picking up a group of suspected undocumented immigrants in Fort Hancock, Texas. During the pursuit, two passengers exited the moving vehicle, including a female who was later identified as an unaccompanied minor. Corona-Montano was indicted for conspiracy to transport aliens and transporting aliens, and he pleaded guilty to both counts.The United States District Court for the Western District of Texas prepared a presentence report that recommended a four-level sentencing enhancement under U.S.S.G. § 2L1.1(b)(4), based on the transportation of an unaccompanied minor. Corona-Montano objected to this enhancement, arguing that he had no knowledge that one of the passengers was a minor and that the enhancement should not apply without such knowledge. The district court found that § 2L1.1(b)(4) did not require proof of knowledge or intent, interpreting it as a strict liability provision. The court overruled the objection and imposed the enhancement, sentencing Corona-Montano to 71 months in prison and three years of supervised release.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed de novo the district court’s interpretation of the Sentencing Guidelines. The appellate court held that the plain language of § 2L1.1(b)(4) is unambiguous and does not impose a scienter (knowledge or intent) requirement. It noted that where the Guidelines intend to require knowledge, they do so explicitly, as in a neighboring provision. The court also found that applying strict liability in this context does not lead to an absurd result or violate due process. Thus, the Fifth Circuit affirmed the district court’s order imposing the sentencing enhancement. View "United States v. Corona-Montano" on Justia Law

The case concerns an individual who was convicted in 2004 of murdering his wife, setting fire to their home while several children were present, and related offenses. The evidence at trial included proof of premeditation, physical evidence linking him to the arson and murder, and testimony regarding his motives and actions before and after the crimes. The jury found him guilty of first-degree murder and other charges, and he was sentenced to death and consecutive prison terms. Over the following seventeen years, the defendant pursued a direct appeal and three post-conviction petitions, all of which were unsuccessful.After the United States Supreme Court issued a decision in Shinn v. Ramirez in 2022, which limited the ability to introduce new evidence in federal habeas proceedings where ineffective assistance of post-conviction counsel is alleged, the defendant filed a fourth (third successive) petition for post-conviction relief in Idaho’s Fourth Judicial District Court. He argued that Shinn was a new event justifying another post-conviction proceeding and advanced claims of ineffective assistance of counsel. The district court dismissed the petition as untimely under Idaho Code section 19-2719, finding that the claims were not raised within the statute’s 42-day deadline and did not qualify for any statutory exception. The court also rejected attempts to amend the petition to argue for an “actual innocence” exception, equal protection violations, and separation of powers challenges.On appeal, the Idaho Supreme Court affirmed the district court’s summary dismissal. The court held that Idaho law does not recognize an actual innocence exception to the 42-day time limit for post-conviction relief in capital cases, that Idaho Code section 19-2719 does not violate equal protection principles, and that the statute is a limitation period rather than a jurisdictional bar, thus not violating the separation of powers under the Idaho Constitution. The judgment of the district court was affirmed. View "Abdullah v. State" on Justia Law

In this case, the defendant was convicted in 1989 of first-degree murder and larceny. No DNA evidence was presented at trial, as forensic DNA testing was not generally available at the time. Decades later, the defendant, represented by counsel, requested postconviction DNA testing of crime scene evidence, asserting factual innocence and arguing that another person may have been present with the victim after he left the scene. The Commonwealth did not formally oppose the motion, and an agreed-upon order for DNA testing was entered in June 2022. Shortly after, the defendant died before the testing could be completed due to delays in approval for accessing a DNA database and the transmission of some evidence.Following the defendant’s death, the Commonwealth moved in the Superior Court to vacate the testing order, arguing that the defendant’s death rendered the order void, as only living defendants could seek relief under the relevant statute, G. L. c. 278A. The defendant’s counsel opposed, emphasizing that the delay was not the defendant’s fault, that testing could serve public interests and potentially resolve other unsolved crimes, and that costs would not burden the Commonwealth. The judge denied the Commonwealth's motion to vacate.The Supreme Judicial Court of Massachusetts reviewed the case. It held that while only a living person may initiate a motion for postconviction DNA testing under G. L. c. 278A, the statute does not mandate that a validly issued testing order expires upon the movant’s death. The court concluded that the judge retained inherent authority to reconsider or vacate such an order in light of changed circumstances, including death. The court further held that, under the circumstances, the judge did not abuse his discretion in declining to vacate the order, and affirmed the denial of the Commonwealth’s motion. View "Commonwealth v. Tanner" on Justia Law

Dr. Lawrence Sherman, a physician, was employed one day per week at Tranquility Wellness Center in Southeastern Michigan, a clinic operated by individuals later convicted for their roles in an illegal prescription scheme. The clinic accepted only cash, did not bill insurance, and routinely provided opioid prescriptions, often based on questionable or fake medical records. Dr. Sherman prescribed large quantities of Schedule II controlled substances, sometimes without adequate patient evaluation or verification of medical histories, and was paid per prescription. After an investigation, Sherman was indicted for conspiracy to possess with intent to distribute and to distribute controlled substances, along with multiple counts of unlawful distribution.In the United States District Court for the Eastern District of Michigan, Sherman went to trial while his co-defendants pleaded guilty and testified against him. The jury found Sherman guilty on all counts, and he was sentenced to 144 months in prison. Sherman subsequently moved for a judgment of acquittal and a new trial, both of which the district court denied.The United States Court of Appeals for the Sixth Circuit reviewed Sherman’s conviction and the denial of his post-trial motions. The court held that sufficient evidence supported the convictions, as a rational jury could find Sherman knowingly issued unauthorized prescriptions based on circumstantial evidence, including expert testimony on deviations from standard medical practice. The appellate court also found no reversible error in the district court’s jury instructions, evidentiary rulings, admission of summary charts, or handling of alleged judicial bias. Any errors identified were deemed harmless in light of overwhelming evidence. The court affirmed both Sherman’s conviction and the denial of his motion for a new trial. View "United States v. Sherman" on Justia Law

Steven Jamerson was on supervised release in Western North Carolina after serving a sentence for a federal conviction. He violated the terms of his supervised release, prompting the initiation of revocation proceedings. In November 2023, a magistrate judge released him pending the outcome of these proceedings, under the condition that he remain in the custody of his mother, Connie Jamerson, who agreed to act as his third-party custodian and ensure his compliance with all release conditions, including self-surrender if sentenced to imprisonment.At the February 2024 revocation hearing, the United States District Court for the Western District of North Carolina revoked Steven Jamerson’s supervised release and imposed a four-month prison sentence. Rather than remanding him immediately, the court allowed him to self-surrender at a later date, maintaining the same release conditions, including his mother’s custodial responsibility. Both Steven Jamerson and Connie Jamerson received notice of the surrender date. When Steven failed to report as directed in March 2024, Connie Jamerson took no action to ensure his compliance, later stating that her son was responsible for himself. Steven was apprehended nearly a month later.The government moved for an order to show cause why Connie Jamerson should not be held in indirect criminal contempt. Following a bench trial, the District Court found that the November 2023 Release Order—and the custodial relationship it established—remained in effect through the self-surrender date. The court found beyond a reasonable doubt that Connie Jamerson willfully violated this order by failing to ensure her son’s surrender and sentenced her to three days’ imprisonment.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the District Court’s judgment, holding that a valid and sufficiently clear court order existed and that Connie Jamerson willfully violated it. View "United States v. Jamerson" on Justia Law

A student with autism, Y.A., reported to his family that he had been sexually assaulted by fellow students at his middle school. The family’s report to the school prompted an investigation led by Detective Jonathan Graham. Another student, A.D., claimed to have witnessed the assault and identified three perpetrators, including a boy with the same first name as L.M. Although A.D. could not pick L.M. out of a photo lineup, the school later identified L.M. as the individual A.D. had previously accused of bullying. Based on the forensic interviews and supporting evidence, Graham submitted his findings to the Loudoun County Juvenile Intake Office, which determined that probable cause existed for a juvenile petition and issued a detention order for L.M. The charges against L.M. were later dropped when inconsistencies in A.D.’s statements came to light.L.M., joined by other plaintiffs, filed a lawsuit in the United States District Court for the Eastern District of Virginia, asserting a malicious prosecution claim under 42 U.S.C. § 1983 against Graham and others, alleging violations of Virginia law and the Fourth Amendment. The district court dismissed the complaint with prejudice for failure to state a claim, concluding that L.M. had not plausibly alleged that his seizure was unsupported by probable cause or that Graham was the cause of his detention, given the independent determination by the Juvenile Intake Officer.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal. The court held that the facts alleged did not support a plausible claim for malicious prosecution under federal or state law because probable cause existed and there were no allegations that Graham withheld material information or misled the Juvenile Intake Officer. The decision of the district court was affirmed. View "L.M. v. Graham" on Justia Law

The case concerns a mother whose children were removed from her care by the Iowa Department of Health and Human Services (HHS), resulting in a child welfare hearing scheduled for August 9, 2024. In conversation with her adult son, who was caring for her children, the mother expressed explicit intentions to torture the HHS worker assigned to her case and to shoot both the worker and the judge at the upcoming court hearing. The son reported these threats to another HHS worker, who found them credible and promptly notified law enforcement. The responding officer, aware of the mother’s prior hostile behavior and history of carrying firearms during government interactions, investigated the threats, eventually arresting the mother and searching her residence, where ammunition—but no firearms—was found.The Iowa District Court for Guthrie County presided over the case after the defendant waived her right to a jury trial and stipulated to a trial on the minutes of testimony. The district court found her guilty of making a threat of terrorism under Iowa Code section 708A.5, concluding that her statements constituted threats that caused a reasonable expectation or fear of their imminent commission.The Iowa Supreme Court reviewed the conviction for errors at law, applying the substantial evidence standard and examining whether the defendant’s statements met the statutory requirements for a threat of terrorism. The court held that the explicit threats, tied to a specific court date and directed at identifiable targets, created a reasonable expectation or fear of imminent commission. The court clarified that “imminent” does not require immediate action but encompasses threats closely linked to a future event. The court also determined that the threats constituted terrorism as defined by Iowa law, even though they were communicated to a third party. The Iowa Supreme Court affirmed the conviction. View "State of Iowa v. Fredericksen" on Justia Law

An individual was arrested in Sioux City in 2021 for allegedly assaulting a relative with a knife during a domestic disturbance. He pleaded guilty to assault while displaying a dangerous weapon, an aggravated misdemeanor, and was sentenced to sixty days in jail with credit for time served. He did not appeal his conviction. About a year and a half later, while incarcerated, he filed a pro se postconviction relief (PCR) application using a standard form, asserting that the court lacked jurisdiction and that he was falsely charged, but provided minimal factual explanation. He also separately applied for appointment of counsel, but due to a clerical error, this request was not considered and no counsel was appointed.The State answered the PCR application and filed a motion for summary judgment, but did not serve the motion on the applicant. The district court for Woodbury County, after noticing the unaddressed motion, granted summary judgment to the State and dismissed the PCR application, finding no genuine issues of material fact and concluding that the State was entitled to judgment as a matter of law. On appeal, the Iowa Court of Appeals affirmed in a split decision, with the majority finding that the applicant had notice and opportunity to respond, while the dissent disagreed, arguing that the record did not support that finding.The Supreme Court of Iowa reviewed the case, holding that the district court erred in granting summary judgment without the applicant having been served with the motion or given an opportunity to respond, as required by Iowa law and rules of civil procedure. The court vacated the Iowa Court of Appeals’ decision, reversed the district court judgment, and remanded the case for further proceedings, including consideration of the request for appointment of counsel and proper service of the summary judgment motion. View "Smith v. State of Iowa" on Justia Law

A thirteen-year-old girl, Diya (a pseudonym), went to a local supermarket to run an errand for her father. While in the store, she noticed a seventy-one-year-old man, later identified as Rodney Dee Brown, watching her, following her through the aisles, and repeatedly attempting to engage her in conversation despite her efforts to avoid him. After Diya checked out and left the store, Brown drove his car up to her in the parking lot and offered her a ride, which she refused. Diya relayed Brown’s license plate to her mother over a FaceTime call, and she ran home as instructed. Brown was later located by police and admitted to interacting with Diya, stating he thought she was older but acknowledging his conduct would be inappropriate if she were thirteen.Brown was charged in the Iowa District Court for Clinton County with attempting to entice a minor under Iowa Code section 710.10(4). At trial, the State introduced Diya’s testimony and police bodycam footage of Brown’s statements. Brown did not testify and argued the State failed to prove he intended to commit an illegal act. Brown objected to the jury instructions, specifically the failure to define “illegal act” as “illegal sexual act,” but the court declined to alter the standard instruction. The jury found Brown guilty.Brown appealed to the Iowa Court of Appeals, challenging the sufficiency of the evidence and the jury instructions. The Court of Appeals affirmed the conviction. On further review, the Supreme Court of Iowa held that the district court correctly instructed the jury, as Iowa Code section 710.10(4) does not require the “illegal act” to be sexual in nature, and found the evidence sufficient to support Brown’s conviction. The Supreme Court of Iowa affirmed both the decision of the Court of Appeals and the district court’s judgment. View "State of Iowa v. Brown" on Justia Law

Three individuals were involved in a conspiracy to rob a marijuana dealer at his home on the Big Cypress Seminole Indian Reservation. During the attempted robbery, a bystander was shot and killed, and the perpetrators fled without obtaining money or drugs. One of the defendants later discussed the crime with a third party, who reported the information to law enforcement and recorded a conversation, further implicating the participants. Additional evidence, including surveillance footage, cell site records, and ballistics, corroborated the involvement of the defendants.The United States District Court for the Middle District of Florida heard the case. One defendant moved to dismiss the indictment, arguing that because both he and the victim were enrolled members of Indian tribes and the offense occurred in Indian country, and since the charged crimes were not listed in the Major Crimes Act, the court lacked jurisdiction. The district court disagreed and denied the motion, allowing the prosecution to proceed. During trial, another defendant objected to the admission of prior convictions without an explicit balancing of probative value and prejudicial effect. The court admitted the evidence without making such a finding. The jury ultimately found the defendants guilty on various counts, and the defendants appealed.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that federal courts possess jurisdiction over generally applicable federal crimes, such as Hobbs Act robbery, even when committed by an Indian against another Indian in Indian country. The court also found that the district court erred by not conducting an on-the-record balancing before admitting evidence of prior convictions, but deemed this error harmless given the strength of the government’s case. The convictions of all three defendants were affirmed. View "USA v. Brice" on Justia Law