Justia Criminal Law Opinion Summaries

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

The case concerns two individuals who previously worked for a consulting firm that provided proprietary software to several state agencies. After leaving the company, they joined a competitor and helped secure a contract to develop similar software for other states. In 2016, a whistleblower alleged that the defendants' new employer was using materials misappropriated from their former company. This triggered a multi-agency federal investigation that lasted approximately six years. By the time charges were brought, two potentially significant witnesses had died, and several state agencies had destroyed documents that might have been relevant to the defense.The United States District Court for the Southern District of West Virginia, after the defendants moved to dismiss, found that the loss of the witnesses' testimony and the destruction of documents resulted in substantial prejudice to the defendants. The district court concluded that the government's lengthy investigation did not sufficiently justify the preindictment delay, given the prejudice to the defense, and dismissed ten out of fourteen counts in the superseding indictment on due process grounds. The government appealed this dismissal.The United States Court of Appeals for the Fourth Circuit reviewed the case and held that, even assuming the defendants suffered actual and substantial prejudice, the government's preindictment delay was the result of a good faith, ongoing investigation and not motivated by bad faith or an attempt to gain a tactical advantage. The Fourth Circuit clarified that investigative delay, without improper motive, does not violate due process, even if it results in prejudice to the defendant. The court reversed the district court’s dismissal of the counts and remanded the case for further proceedings on all counts. View "US v. Minkkinen" on Justia Law

A cable company employee discovered the appellant at his apartment with blood on his face, neck, and clothing, requesting police assistance after an incident involving his girlfriend. When officers arrived, they found the victim, Debra Shirron, dead in bed with visible injuries. The appellant was charged with first-degree murder of a victim 60 years of age or older and abuse of an older/vulnerable person resulting in substantial bodily or mental harm or death. At trial, the appellant claimed legal insanity and self-defense, citing a recent traumatic brain injury and consumption of marijuana brownies prior to the incident. Expert testimony presented conflicting views on whether the appellant’s delusions and violent behavior were caused by his brain injury, voluntary intoxication, or a combination of both.The Eighth Judicial District Court in Clark County presided over the trial. During the proceedings, the court allowed a replacement medical examiner to testify to possible causes of death beyond blunt force trauma, including asphyxiation and strangulation, without prior notice to the defense. The appellant objected to jury instruction 17, which addressed voluntary intoxication in relation to the insanity defense, arguing it conflicted with the legal definition of insanity. The objection was preserved, but the court overruled it. The jury convicted the appellant on both counts.The Supreme Court of the State of Nevada reviewed the case. The Court held that the district court erred by instructing the jury that voluntary intoxication could not be considered as part of an insanity defense unless it was not a contributing factor, which contradicted statutory law. The error was not harmless, as it likely had a substantial effect on the verdict. The Court reversed the conviction and remanded the case for further proceedings. It also clarified that expert testimony at trial must be disclosed in accordance with statutory requirements. View "AUBRY VS. STATE" on Justia Law

Law enforcement responded to an incident where the defendant, after brandishing a machete and robbing a 76-year-old man of his car, led police on a dangerous high-speed chase. He drove on the wrong side of major roads and ignored traffic signals before being apprehended. At the time, he had deliberately stopped taking prescribed mental health medication. He was charged with robbery of an elderly person, grand larceny of a motor vehicle, and driver evading or failing to stop for a police signal in a manner endangering others.A jury in the Second Judicial District Court in Washoe County found him not guilty by reason of insanity (NGRI) for the robbery and grand larceny counts but guilty but mentally ill (GBMI) for the driver-evading count. Following the verdicts, the district court ordered a mental health evaluation and held a hearing pursuant to NRS 175.539. The defendant argued that the court was required to commit him to a forensic mental health facility for treatment before sentencing on the GBMI conviction, or at minimum, impose probation conditioned on such treatment. The district court rejected this argument, concluding that the statutes did not require commitment before sentencing and that it retained discretion to impose a prison sentence for the GBMI conviction, with treatment during incarceration and civil commitment following release if necessary.On appeal, the Supreme Court of Nevada affirmed the district court’s judgment. The Court held that Nevada statutes do not specify the sequence of civil commitment and criminal sentencing in cases with both NGRI acquittals and a GBMI conviction. Therefore, the district court retains discretion to sentence a defendant to prison for a GBMI conviction, with appropriate mental health treatment during incarceration, and to order evaluation for civil commitment after release. Probation is not mandatory in split-verdict cases. The judgment of conviction was affirmed. View "SILVANUS VS. STATE" on Justia Law