Justia Criminal Law Opinion Summaries

After receiving an anonymous tip, law enforcement in Mercer County, Kentucky, stopped Steven Fellmy, who was driving a silver Ford Mustang matching the tip’s description. The stop was based on observed traffic violations, including a non-illuminated license plate and failure to signal a turn. After backup arrived, Fellmy was asked to exit the vehicle. He declined consent for a search, so a trained drug dog was led around the car. The dog briefly jumped up onto the car door and partially sniffed through the open window, ultimately alerting officers to drugs. A subsequent search revealed methamphetamine and heroin, leading to Fellmy’s arrest and charge for possession of methamphetamine with intent to distribute.The United States District Court for the Eastern District of Kentucky reviewed and denied Fellmy’s pretrial motion to suppress the drugs. The court found that officers lawfully ordered Fellmy out of the vehicle after a valid traffic stop and that the dog’s actions did not constitute an unlawful search because the officers did not encourage the dog to intrude into the car’s interior. The court also denied Fellmy’s motion in limine to exclude the drug evidence, ruling that concerns about authentication and chain of custody went to the weight of the evidence, not its admissibility, and could be addressed during cross-examination. The drugs were admitted, and Fellmy was convicted by jury and sentenced to 300 months’ imprisonment.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings. The Sixth Circuit held that ordering Fellmy out of the car after a valid stop was lawful and that the dog’s brief contact with the car did not amount to a Fourth Amendment search under prevailing legal standards. The court also held that the district court did not abuse its discretion in admitting the drug evidence or in denying an evidentiary hearing regarding the chain of custody. The conviction and sentence were affirmed. View "United States v. Fellmy" on Justia Law

Christopher Singer, a previously convicted felon, was investigated in connection with a drive-by shooting in Oklahoma City. Police found spent and live ammunition in his possession, leading to federal charges for being a felon in possession of ammunition. Singer pleaded guilty to this charge. At sentencing, the United States Probation Office presented a report noting Singer’s three prior Oklahoma state convictions: two for assault and battery with a dangerous weapon under Okla. Stat. tit. 21, § 645, and one for robbery with a firearm.The United States District Court for the Western District of Oklahoma reviewed Singer’s objections to the presentence investigation report. Singer argued that his prior convictions under § 645 should not be classified as categorical crimes of violence for purposes of the United States Sentencing Guidelines or as violent felonies under the Armed Career Criminal Act (ACCA), because the statute could apply to assaults against unborn victims, which federal law does not include in its definitions of “crime of violence.” The district court, relying on prior Tenth Circuit precedent in United States v. Taylor, overruled Singer’s objection, determined the convictions qualified under both the Guidelines and ACCA, and sentenced Singer to 180 months, the mandatory minimum under ACCA.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the sentencing determination de novo. The court concluded that Oklahoma’s § 645 does criminalize assault and battery with a dangerous weapon against unborn persons. Guided by its own precedent, notably United States v. Adams, the Tenth Circuit held that because federal law excludes crimes against unborn persons from its definition of “crime of violence,” Singer’s prior convictions under § 645 do not categorically qualify as such under the Guidelines or ACCA. The Tenth Circuit reversed the district court’s sentencing decision and remanded for resentencing consistent with this ruling. View "United States v. Singer" on Justia Law

A defendant was charged with multiple counts of child molestation sexual assault involving his biological daughter, referred to as Maria, who was fourteen years old at trial. The alleged incidents took place when Maria was around eleven and occurred during visits with her father, including one on a bus and another at her paternal grandmother’s residence. Maria did not immediately report the assaults due to fear and concern for her father but eventually disclosed them to a friend, a program instructor, and ultimately to medical professionals. At Hasbro Children’s Hospital and its Aubin Child Protection Center, Maria was evaluated physically and mentally, and she recounted the assaults to Dr. Barron, a specialist in child-abuse pediatrics.In the Providence County Superior Court, two counts were dismissed—one by the prosecution and one by the trial justice following a motion for acquittal. The jury found the defendant not guilty on one count and guilty on another, resulting in a life sentence. The defense’s pretrial motions sought to exclude Dr. Barron’s testimony, arguing that Maria’s statements to her were not made for medical diagnosis or treatment but for evidence collection. The trial justice allowed the testimony, finding it related to Maria’s diagnosis and treatment, especially given her mental health concerns and risk of self-harm.On appeal, the Supreme Court of Rhode Island reviewed whether challenged hearsay statements made by Maria to Dr. Barron were properly admitted under Rule 803(4) of the Rhode Island Rules of Evidence. The Court held that, except for one preserved objection, the defendant had waived the hearsay objections by failing to renew them at trial. The Court further concluded that the admitted statement was pertinent to medical diagnosis and treatment and, even if it were not, its admission was harmless as it was cumulative of other properly admitted evidence. The judgment of conviction was affirmed. View "State v. Cable" on Justia Law

A man was convicted in California of first-degree murder and sentenced to death for the killing of a homeowner during a burglary in 1985. The prosecution established that the defendant entered the victim’s home, stole property, and shot the victim in the back as he was fleeing. The case against the defendant was supported by fingerprint evidence, eyewitnesses, and testimony about his actions and statements before and after the crime. At trial, the defense argued alternative theories, including that another individual was the actual killer and that the shooting lacked intent. During the penalty phase, the prosecution presented evidence of the defendant’s prior felonies, while the defense offered extensive mitigating evidence regarding his abusive childhood and mental health issues.On direct appeal, the Supreme Court of California affirmed the conviction and death sentence. The defendant subsequently filed state and federal habeas petitions, raising claims about his competency to stand trial, the effectiveness of his counsel, and alleged jury coercion. The California Supreme Court summarily denied these claims, and the United States District Court for the Central District of California denied his federal habeas petition.The United States Court of Appeals for the Ninth Circuit reviewed the appeal. Applying the deferential standard required by the Anti-Terrorism and Effective Death Penalty Act (AEDPA), the court held that the California Supreme Court could have reasonably concluded the evidence did not sufficiently support the defendant’s claims of incompetence or ineffective assistance of counsel. The Ninth Circuit also found no basis to conclude the trial court coerced the jury’s verdict or that California’s death penalty statute was unconstitutional. The Ninth Circuit affirmed the district court’s denial of habeas relief. View "Beeler v. Broomfield" on Justia Law

A man engaged in sexually explicit exchanges with a 13-to-14-year-old girl, during which he solicited and received images and videos depicting the minor’s genitalia and acts of self-penetration with a sex toy. His communications included explicit language suggesting rough and anal sex and requesting increasingly graphic content. After he received sexually explicit media from the minor, he was arrested and charged with several offenses, including sexual exploitation of a minor, receipt and possession of child pornography, and transfer of obscene material to a minor. He ultimately pled guilty to the receipt of child pornography.The United States District Court for the Southern District of Iowa applied a four-level sentence enhancement under U.S.S.G. § 2G2.1(b)(4)(A), reasoning that the material he received depicted sadistic or masochistic conduct or other depictions of violence, specifically the minor’s self-penetration with a foreign object. The court sentenced him to 240 months in prison. The defendant appealed, contending that the enhancement did not apply because the victim was not prepubescent, used a sex toy rather than another object, and appeared to experience sexual pleasure rather than pain.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s factual findings for clear error and its application of the Sentencing Guidelines de novo. The appellate court held that, under its precedent including United States v. Starr, acts of self-penetration by a minor with a foreign object constitute "violence" under the guideline, regardless of the minor’s age, the type of object, or whether the minor experienced pain. The appellate court affirmed the district court’s judgment, upholding the four-level enhancement. View "United States v. Vannausdle" on Justia Law

Police investigating a sexual assault executed a search warrant at a mobile home occupied by three individuals, including the appellant. During the search of one resident’s bedroom, officers found a glass pipe believed to contain methamphetamine residue. The appellant and his mother, who also lived in the home, denied the presence of drugs when questioned. Based on the discovery, law enforcement obtained a second warrant to search the entire residence for controlled substances. This second search led to the discovery of methamphetamine and drug paraphernalia in a bench located in the appellant’s bedroom, resulting in his arrest and charge for felony possession.The District Court of Campbell County presided over the criminal case. The appellant filed a motion to suppress the evidence, arguing that the officer’s affidavit for the second search warrant omitted material facts, such as the pipe being found in a locked bedroom accessible only to one resident, and that these omissions undermined probable cause. After a hearing, the district court denied the motion, finding that the omitted facts would not have defeated probable cause, as the resident in whose room the pipe was found could access the entirety of the home, including the appellant’s bedroom. The appellant then entered a conditional guilty plea, reserving the right to appeal the suppression ruling.Reviewing the appeal, the Supreme Court of Wyoming affirmed the district court’s decision. It held that even if the omitted facts had been included in the affidavit, probable cause existed to search the entire mobile home because the resident implicated by the initial pipe discovery had access throughout the home. The Court concluded that the district court did not err in denying the motion to suppress, and the conviction was affirmed. View "Urrutia v. State" on Justia Law

Gregory Dobbins was wrongfully convicted of possession of a controlled substance in Cook County, Illinois, based on fabricated evidence supplied by a corrupt police sergeant and his team. After serving prison time, Dobbins filed for post-conviction relief, and in April 2022, the circuit court vacated his conviction and the State dismissed the charges against him. Shortly after, Dobbins submitted a petition for a certificate of innocence (COI), which would allow him to seek compensation for his wrongful conviction. However, Dobbins passed away before the scheduled hearing on his COI petition.Following his death, his life partner and estate administrator, Katrina Crawford, moved to substitute herself as petitioner to continue the COI action on behalf of Dobbins’s estate. The circuit court denied this motion and dismissed the COI petition, ruling that the right to a COI is a personal statutory right that does not survive the petitioner’s death. The Appellate Court of Illinois, First District, affirmed the circuit court’s decision, reasoning that the COI statute did not permit estates to seek a COI and that a COI action is not a claim for damages that survives under the Survival Act.The Supreme Court of the State of Illinois reviewed the case and affirmed the lower courts’ judgments. The court held that a petition for a COI is not an action to recover damages but rather a condition precedent to seeking compensation in the Court of Claims. Because the COI itself does not confer damages, the cause of action does not survive the petitioner’s death under the Survival Act. Therefore, the Supreme Court affirmed the dismissal of the petition and denied substitution by the estate. View "People v. Dobbins" on Justia Law

The defendant was charged with two counts of aggravated battery of a police officer following an incident at Longview Park in Rock Island, Illinois. The events began after the defendant’s ex-wife contacted police out of concern for their daughter’s welfare, based on alarming statements made by the defendant. Police arrived and, after deciding the child should leave with her mother, the defendant became upset and tried to approach his daughter, prompting police intervention. An altercation ensued: one officer pushed the defendant, who pushed the officer’s arm away, and another officer tackled the defendant, after which the defendant wrapped his arm around the officer’s neck. The defendant was charged based on these physical contacts.The case was tried in the Circuit Court of Rock Island County. During trial, the defendant requested the jury be instructed on self-defense, arguing his actions were a response to excessive force by the officers. The court denied this request, finding the evidence did not support each element required for a self-defense instruction. The jury acquitted the defendant of battery against one officer but convicted him as to the other. The defendant’s posttrial motion challenging the lack of a self-defense instruction was denied.On appeal, the Appellate Court, Fourth District, affirmed the conviction, applying a two-step inquiry: first, whether there was sufficient evidence of excessive force by police, and second, whether all six elements of self-defense were supported. The appellate court found no abuse of discretion in refusing the instruction, focusing on the defendant’s subjective belief element.The Supreme Court of Illinois reviewed the case to resolve a conflict among appellate courts regarding self-defense instructions in cases involving alleged excessive police force. The court held that the long-standing six-element test for self-defense applies, and found there was some evidence for each element in the record. The trial court abused its discretion by refusing the instruction. The Supreme Court reversed the lower courts’ judgments and remanded for further proceedings. View "People v. Vesey" on Justia Law

Two correctional officers witnessed the defendant physically assaulting two women outside a convenience store and intervened to stop the attack. Police arrived shortly thereafter and arrested the defendant. He was charged with three counts of aggravated battery, a felony. From the outset, there were questions about the defendant’s fitness to stand trial, leading to repeated delays as the court attempted, unsuccessfully at first, to obtain a fitness evaluation. Ultimately, the defendant was found fit, his counsel withdrew at his request, and he proceeded to represent himself. The court arraigned him, set bond, and scheduled a jury trial, at which he was convicted of aggravated battery.Prior to trial, the defendant never received a preliminary hearing to determine probable cause, nor was he indicted by a grand jury, as required by the Illinois Constitution for felony charges. The defendant did not object to this omission before or during trial, nor did he raise it in a posttrial motion. On appeal, the Illinois Appellate Court, Fifth District, concluded that the absence of a preliminary hearing or indictment was a structural error reviewable as second-prong plain error, and it reversed the defendant’s convictions outright.The Supreme Court of the State of Illinois reviewed whether the trial court’s failure to provide a prompt preliminary hearing constituted second-prong plain error. The court held that, while the trial court’s failure to provide a preliminary hearing was clear error, it did not amount to a structural error or deprive the defendant of a fair trial, given that his guilt was established beyond a reasonable doubt at trial. Therefore, the error was subject to harmless error analysis and was not reviewable as second-prong plain error. The Supreme Court reversed the appellate court’s judgment and affirmed the convictions and sentence imposed by the circuit court. View "People v. Chambliss" on Justia Law

On September 16, 2022, a police report was filed following the theft of a Glock 42 firearm stamped with the name “Hendricks.” Security footage led authorities to identify Tavion Pegues as the perpetrator, and an arrest warrant was issued. On February 8, 2023, law enforcement arrested Pegues at his sister’s home, where they recovered two firearms from a bedroom that Pegues occasionally used. Pegues’s sister testified that the firearms and associated items found in her son’s bedroom did not belong to her or her family, but belonged to Pegues, who often stayed there. Photographs and videos retrieved from Pegues’s cellphone showed him possessing one of the firearms shortly before the search. Pegues was indicted for armed robbery, possession of a firearm by a convicted felon, and possession of a stolen firearm, but the State proceeded only on the possession charge.The case was tried in the Circuit Court of Oktibbeha County, where a jury found Pegues guilty of possession of a firearm by a convicted felon. Pegues was sentenced as a habitual offender to life without parole. He subsequently moved for a judgment notwithstanding the verdict or for a new trial, but the trial court denied his motion.On appeal, the Supreme Court of Mississippi reviewed Pegues’s claims of prosecutorial misconduct and insufficiency of the evidence regarding constructive possession. The Court held that the State’s comments about Pegues’s failure to call his mother and nephew as witnesses, and its reference to his right to a trial, were not plain error because Pegues’s family members were more available to him than to the State, and the evidence against him was overwhelming. The Court also found the evidence sufficient to prove constructive possession, given Pegues’s connection to the firearms and the items found with them. The conviction and sentence were affirmed. View "Pegues v. State of Mississippi" on Justia Law