Justia Criminal Law Opinion Summaries

During a traffic stop in South Bend, Indiana, in February 2021, police discovered that Jose Reyna was in possession of marijuana, methamphetamine intended for distribution, and a loaded handgun with its serial number obliterated. Reyna admitted to dealing drugs and to having intentionally removed the serial number from the firearm. A grand jury indicted him for possessing a firearm with an altered or obliterated serial number in violation of 18 U.S.C. § 922(k), to which he pleaded guilty without a plea agreement. Shortly before sentencing, Reyna moved to dismiss the indictment, arguing that § 922(k) was unconstitutional under the Second Amendment, relying on the Supreme Court’s decision in New York State Rifle & Pistol Association v. Bruen.The United States District Court for the Northern District of Indiana found good cause to consider Reyna's otherwise untimely motion but denied it on the merits. The district judge ruled that the possession of a firearm with an obliterated serial number was not covered by the plain text of the Second Amendment and therefore rejected the constitutional challenge at the first step of the Bruen framework. The judge did not address whether the statute was consistent with the nation’s historical tradition of firearm regulation.The United States Court of Appeals for the Seventh Circuit reviewed the constitutionality of § 922(k) de novo. While the appellate court was not persuaded that the challenge could be resolved solely on the text of the Second Amendment, it proceeded to Bruen’s second step, as clarified by United States v. Rahimi. The court concluded that although modern serialization lacks a direct historical analogue, historical practices of marking, inventorying, and inspecting firearms for militia purposes provide a relevant tradition. The Seventh Circuit held that § 922(k) is consistent with the principles underlying this tradition and affirmed the judgment of the district court. View "USA v Reyna" on Justia Law

In this case, the defendant was convicted by a jury of third-degree murder in 2002 for the killing of a police officer. At trial, the prosecution presented several witnesses who implicated the defendant, including testimony from an individual who claimed to have observed the shooting and another who reported the defendant’s incriminating statements. The defense was precluded from introducing evidence suggesting that another individual, Tusweet Smith, may have been the perpetrator, including testimony about Smith’s alleged intent and confessions. Over the years, the defendant filed multiple post-conviction petitions, raising claims based on newly discovered evidence and recantations by key prosecution witnesses. These petitions were denied, primarily on timeliness grounds under Pennsylvania’s Post Conviction Relief Act (PCRA), which imposes a one-year filing limit unless specific exceptions are met.The Court of Common Pleas of Beaver County dismissed the defendant’s most recent PCRA petition, finding it untimely and holding that a third-party confession (specifically, Smith’s confession to another inmate, Dorsett) could not qualify as a newly discovered fact because it was deemed inadmissible hearsay. The Superior Court affirmed the dismissal regarding the third-party confession, relying on precedent that inadmissible hearsay cannot support the PCRA’s newly discovered facts exception. However, the Superior Court agreed that the defendant was entitled to an evidentiary hearing on separate statements and affidavits but not on the Dorsett/Smith confession.The Supreme Court of Pennsylvania reversed the Superior Court’s order as to the Dorsett/Smith statement. The Court held that a PCRA petitioner may establish the newly discovered facts exception with evidence that would be admissible at a PCRA hearing, and that a third-party confession to another person can serve as a newly discovered fact under the PCRA if properly pleaded. The Court remanded for an evidentiary hearing to allow the defendant to attempt to prove his allegations with admissible evidence. View "Commonwealth v. Brown" on Justia Law

In this case, the defendant was charged with raping three different women on three separate occasions in Philadelphia, spanning from 2011 to 2015. Each victim underwent a sexual assault examination, and DNA evidence was collected but did not initially match any known profiles. In December 2018, a DNA database search revealed that the same DNA profile was present in all three cases. This profile was subsequently identified as belonging to the defendant, who was then arrested and charged separately for each incident.The prosecution moved to consolidate the three cases for a joint jury trial, arguing that the assaults were sufficiently similar to be admissible under the common plan, scheme, or design exception to Pennsylvania’s rule against propensity evidence. The defendant objected, but the Philadelphia County Court of Common Pleas granted the consolidation and allowed the introduction of rape kit reports prepared by nurse examiners who did not testify at trial. The defendant was convicted on multiple counts, and the court imposed an aggregate sentence. On appeal, the Superior Court of Pennsylvania affirmed the convictions and the admission of the rape kit reports, finding the cases sufficiently similar for consolidation and the reports non-testimonial and admissible under hearsay exceptions.Upon review, the Supreme Court of Pennsylvania concluded that consolidation was improper under the current interpretation of the common plan, scheme, or design exception, holding that such consolidation is permissible only if the offenses are signature crimes or part of a common goal, neither of which applied here. Additionally, the court held that admitting the rape kit reports without the testimony of the nurse examiners violated the defendant’s right to confront witnesses under the Confrontation Clause. Accordingly, the Supreme Court of Pennsylvania vacated the judgment of sentence and remanded for further proceedings. View "Commonwealth v. Walker" on Justia Law

The case concerned a man charged with multiple offenses, including aggravated domestic battery, based on an incident involving his former partner. The relationship between the two was characterized by recurring conflicts and accusations, leading to several prior incidents of alleged domestic violence. At trial, the prosecution presented evidence of four prior incidents of defendant's alleged violence, one of which resulted in defendant's acquittal in an earlier criminal proceeding. The defendant claimed self-defense and sought to introduce evidence of the complainant’s violent conduct occurring after the charged offenses, as well as evidence of his earlier acquittal.The Circuit Court of Kankakee County allowed the prosecution to introduce evidence of the four earlier incidents but barred the defendant from presenting evidence of the complainant’s subsequent violent conduct, reasoning that such conduct postdated the charged offenses. The court also excluded evidence of the defendant's prior acquittal, concluding that a not-guilty verdict did not equate to innocence. The jury convicted the defendant on several charges, and he was sentenced to prison. On appeal, the Illinois Appellate Court vacated the convictions, holding that evidence of the complainant's subsequent conduct was admissible and that it was an abuse of discretion to exclude the acquittal evidence.The Supreme Court of Illinois held that under Illinois Rule of Evidence 405(b)(2), only evidence of the alleged victim’s violent conduct that occurred prior to the charged offense is admissible in battery or homicide cases where self-defense is raised. The court also held that while it was an abuse of discretion to bar evidence of the prior acquittal, the error was harmless given the overall evidence. The appellate court’s judgment was reversed, and the case remanded for consideration of remaining claims. View "People v. Heintz" on Justia Law

In this case, the defendant was sentenced in 1995 to mandatory natural life imprisonment after being convicted of a third Class X felony, as required by the habitual criminal statute then in effect. His first Class X felony was committed at age 17. In 2021, the Illinois legislature amended the relevant statute to require that a person’s first Class X felony must have been committed at age 21 or older for a mandatory natural life sentence to apply. The defendant sought postconviction relief, arguing that the amended statute should apply to him because his first offense was committed when he was under 21.After his conviction and direct appeal—which was affirmed by the Illinois Appellate Court—the defendant filed several unsuccessful collateral attacks on his conviction and sentence. Following the 2021 statutory amendment, he filed motions for leave to file successive postconviction petitions in the Circuit Court of Cook County, seeking resentencing under the new law. The circuit court denied the motions, holding that the amendment applied only prospectively and did not impact his sentence.On appeal, the Illinois Appellate Court reversed, concluding that the 2021 amendment should be interpreted as a clarification of the original statute and thus applied retroactively, rendering the defendant’s mandatory life sentence invalid since his first offense was committed before age 21.The Supreme Court of the State of Illinois reviewed the case and disagreed with the appellate court. The court held that the 2021 amendment to section 5-4.5-95(a) of the Unified Code of Corrections neither applies retroactively nor constitutes a clarification of the law as it existed in 1995. The court concluded that the circuit court properly denied the defendant’s motions for leave to file successive postconviction petitions. The Supreme Court of Illinois reversed the appellate court’s judgment and affirmed the circuit court’s decision. View "People v. Brown" on Justia Law

The defendant pleaded guilty to traveling with the intent to engage in illicit sexual conduct, specifically traveling from Vermont to New York to have sexual intercourse with someone he believed to be a 15-year-old girl. The case involved extensive online communications, with the defendant sending explicit images and discussing plans that included showing pornography to the minor. At sentencing, the district court imposed fifteen years of supervised release with various standard and special conditions, some of which were not explicitly discussed or justified at the sentencing hearing.Following his conviction in the United States District Court for the Northern District of New York, the defendant appealed four discretionary conditions of supervised release. Two of these conditions (providing financial information to probation and submitting to suspicion-based searches), were added as “standard conditions” under a local standing order (General Order #23), but were not discussed in the presentence report or at the hearing. The remaining two challenged conditions prohibited access to adult pornography and imposed strict internet monitoring, including a provision allowing probation to limit the defendant to one internet-capable device.The United States Court of Appeals for the Second Circuit found that the district court erred by imposing the financial disclosure and suspicion-based search conditions without making an individualized assessment or providing reasons for their necessity, as required for special conditions of supervised release. These conditions were therefore vacated. The court affirmed the prohibitions on access to pornography and the general internet monitoring condition, but struck the provision allowing the probation office to limit the defendant to a single device, as this constituted an improper delegation of judicial authority. The case was remanded to the District of Vermont, which now has jurisdiction, for further proceedings consistent with this opinion. View "United States v. McAdam" on Justia Law

After a high school basketball game, a confrontation occurred between two groups of rival fans, leading to the stabbing death of Da'Von Capers. The defendant, Kierin Marcellus Dennis, was indicted for murder. Dennis claimed he acted in self-defense and sought immunity from prosecution under the Protection of Persons and Property Act. At the pre-trial immunity hearing, witnesses gave conflicting accounts about whether the victim or others had unlawfully and forcefully entered Dennis’s vehicle before the stabbing. The circuit court found that Dennis failed to prove by a preponderance of the evidence that he was entitled to immunity and denied his request, allowing the prosecution to proceed.Dennis was tried for murder, but the jury could not reach a unanimous verdict, resulting in a mistrial. When the State sought to retry him, Dennis requested a second immunity hearing, arguing that the mistrial entitled him to a new hearing or, alternatively, to introduce new evidence discovered since the first hearing. The circuit court allowed him to present new evidence but ultimately denied a second immunity hearing and again denied immunity. Dennis was convicted at the second trial. He appealed, arguing he was entitled to another immunity hearing after the mistrial. The South Carolina Court of Appeals agreed and reversed his conviction, holding that the mistrial required a new immunity hearing.The Supreme Court of South Carolina reviewed the case and held that a mistrial does not entitle a defendant to a second immunity hearing under the Act. The court reasoned that an immunity hearing is an independent proceeding and its result remains binding after a mistrial. The court also found no abuse of discretion in the original denial of immunity. The decision of the court of appeals was reversed and the case remanded for consideration of the remaining appellate issues. View "The State v. Dennis" on Justia Law

Charles Hembree was previously convicted in Mississippi state court in 2018 for simple possession of methamphetamine, a felony offense. In 2022, he was indicted under federal law for being a felon in possession of a firearm, in violation of 18 U.S.C. § 922(g)(1). Hembree moved to dismiss the indictment, arguing that applying § 922(g)(1) to him violated the Second Amendment, particularly in light of the U.S. Supreme Court’s ruling in New York State Rifle & Pistol Association v. Bruen. The district court denied his motion, after which Hembree entered a guilty plea under an agreement that reserved his right to challenge the denial of his motion to dismiss on Second Amendment grounds. He was sentenced to six months in prison and three years of supervised release.After sentencing, Hembree appealed to the United States Court of Appeals for the Fifth Circuit, preserving only his as-applied Second Amendment challenge to § 922(g)(1). He argued that there was no historical tradition justifying the disarmament of individuals based solely on a conviction for simple drug possession. The government contended that historical analogues, such as laws disarming dangerous persons or severely punishing possession of contraband, supported the statute’s application to Hembree’s circumstances.The Fifth Circuit held that the government failed to meet its burden of demonstrating a historical tradition supporting the permanent disarmament of individuals convicted only of simple drug possession. The court concluded that neither the tradition of punishing possession of contraband nor the disarmament of “dangerous persons” provided a sufficient analogue for Hembree’s predicate offense. Therefore, the Fifth Circuit found § 922(g)(1) unconstitutional as applied to Hembree and reversed his conviction. The court did not address Hembree’s additional constitutional claims, as resolution of the as-applied challenge was dispositive. The court also granted Hembree’s motion to supplement the record. View "United States v. Hembree" on Justia Law

The respondent was charged with aggravated robbery, menacing, and criminal mischief after engaging in erratic and violent behavior in Denver. According to his own testimony, earlier that evening he had consumed beer and accepted a marijuana joint from an acquaintance whose name he did not know. After smoking the joint, he began feeling paranoid and eventually blacked out, recalling nothing until after the events in question. During the trial, the respondent claimed that the joint contained an unknown substance, such as a stimulant, which caused his behavior, and he requested a jury instruction on the affirmative defense of involuntary intoxication.The Denver District Court denied the request for an involuntary intoxication instruction, finding the claim speculative, and a jury convicted the respondent on all counts. On appeal, a division of the Colorado Court of Appeals reversed, holding that the statutory defense of involuntary intoxication is legally available when a defendant knowingly ingests what he believes to be a particular intoxicant, but unknowingly ingests a different intoxicant, and it is the unknown substance that deprives him of the capacity to conform his conduct to the law. The appellate court concluded that this was the essence of the respondent’s claim and that he was entitled to the jury instruction.The Supreme Court of Colorado reviewed the case and reversed the court of appeals. The Court held that, under Colorado law, when a defendant ingests a product containing multiple intoxicants, the relevant “substance” for purposes of the involuntary intoxication defense is the entire product—not each particular component. Because the respondent knowingly smoked a joint he knew or should have known was intoxicating, his intoxication was deemed self-induced, barring the involuntary intoxication defense. The case was remanded for further proceedings consistent with this opinion. View "People v. Mion" on Justia Law

The case concerns a defendant who was serving a term of supervised release following a federal conviction for fentanyl-related offenses. During his supervision, police responded to a domestic disturbance at his apartment, where his wife reported that, after an argument, the defendant struck her and was told to leave. When she locked him out, she stated that he kicked the apartment door, damaging it, re-entered, and took her cell phone. Police and a responding officer documented the damage to the door. The defendant was subsequently charged in state court with vandalism, among other offenses, and federal probation officers sought revocation of his supervised release based on these new alleged criminal acts.The United States District Court for the District of Massachusetts held revocation hearings, during which both documentary evidence, such as police reports and affidavits, and live testimony from the responding officer were presented. The defendant objected to the admission of hearsay statements from his wife, arguing he was entitled to confront her and that the statements were unreliable. The district court found that the interest of justice did not require her appearance, determined her statements were sufficiently reliable, and credited the corroborating testimony of the police officer. The court concluded that the defendant had, by a preponderance of the evidence, committed vandalism under Massachusetts law and revoked his supervised release.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s legal conclusions de novo and factual findings for clear error. The appellate court held that the district court properly admitted the hearsay evidence, conducted the required balancing under Rule 32.1(b)(2)(C), and made supported findings regarding the elements of vandalism. The appellate court concluded there was neither legal error nor clear error and affirmed the revocation of supervised release. View "United States v. Camillo" on Justia Law