Justia Criminal Law Opinion Summaries

In 1993, Joseph Cornette was involved in a drunk driving incident that resulted in a serious car accident and injury to another driver. He pleaded guilty to Assault Second Degree and Driving Under the Influence (DUI), with other charges being dismissed as part of a plea agreement. After serving his sentence and remaining crime-free for decades, Cornette received an unconditional pardon for his assault conviction from the Governor of Delaware. He then petitioned for discretionary expungement of the pardoned assault conviction, without seeking expungement for the DUI conviction.The Superior Court of the State of Delaware denied Cornette’s petition. Initially, a court commissioner found that DUI offenses are not eligible for expungement and denied relief. On appeal, a Superior Court judge denied Cornette’s petition on the grounds that Delaware law requires all charges in a case to be eligible for expungement before any charge in that case may be expunged. The court reasoned that because Cornette’s DUI conviction was not eligible for expungement, the pardoned assault conviction could not be expunged either. A motion for reargument was also denied.The Supreme Court of the State of Delaware reviewed the case and reversed the judgment of the Superior Court. The Supreme Court held that under 11 Del. C. § 4375, an individual with a pardoned conviction may seek discretionary expungement of that specific conviction, even if other charges in the case are not eligible for expungement. The Court concluded that the statute permits partial expungement and does not require all charges in a case to be eligible. The case was remanded to the Superior Court for further proceedings consistent with this interpretation. View "Cornette v. State" on Justia Law

The case centers on a defendant who was indicted on two counts: unlawful possession of a firearm by a drug user and making a false statement during the purchase of a firearm. The indictment alleged that, on specific dates in 2022, the defendant, as an unlawful user of marijuana and cocaine, possessed multiple firearms and falsely represented on a federal form that he was not an unlawful user or addict of a controlled substance. The evidence included the defendant’s admissions of regular drug use, his possession of firearms during the same period, and his acknowledgment that he was not prescribed any controlled substances. Additional evidence established that, at the time of a firearm purchase, he smelled of marijuana, and a subsequent search uncovered both a loaded pistol and marijuana in his vehicle. Drug tests confirmed recent use of marijuana and cocaine.The United States District Court for the Northern District of Iowa denied the defendant’s motion to dismiss, rejected his claims that the statutes were unconstitutionally vague, and found him guilty on both counts in a bench trial based on stipulated facts. The court concluded that the statutory terms were not vague as applied to the defendant, given his admissions and the explicit warning on the federal form. The court also held that the statute prohibiting firearm possession by drug users was consistent with historical tradition and deferred ruling on the as-applied Second Amendment challenge until trial evidence was complete. The defendant was sentenced to concurrent terms of imprisonment.On appeal, the United States Court of Appeals for the Eighth Circuit vacated the conviction for unlawful possession of a firearm by a drug user under 18 U.S.C. § 922(g)(3) and remanded for the district court to reassess the defendant’s as-applied Second Amendment challenge in light of intervening circuit precedent. The appellate court affirmed the district court’s decision on all other issues, including the conviction for making a false statement under 18 U.S.C. § 924(a)(1)(A). View "United States v. Ledvina" on Justia Law

Antonio Carrazco-Martinez was investigated by federal authorities for his alleged involvement in a drug trafficking operation with ties to Chicago and Mexico. Law enforcement, after obtaining judicial warrants, used a cell-site simulator to locate his new phone and a closed-circuit television (CCTV) camera to monitor activity in the garage of a stash house. The investigation led to his indictment for conspiracy to distribute narcotics and possession with intent to distribute cocaine and heroin. Carrazco-Martinez sought to suppress evidence obtained from both the cell-site simulator and the CCTV camera, arguing that their use was unlawful, but these motions were denied.The United States District Court for the Northern District of Illinois denied Carrazco-Martinez’s motions to suppress, applying the good faith exception to the exclusionary rule for both the cell-site simulator and the CCTV camera warrants. The court found that the government’s warrant applications were not misleading and that the warrants were neither so lacking in probable cause nor so deficient in scope as to invalidate reliance on them. At trial, the court also overruled Carrazco-Martinez’s objection to a jury instruction (Instruction 28), which stated that the government did not have to prove the specific quantity of drugs alleged, only a measurable quantity, to establish guilt. The jury convicted him on both counts, and his post-trial motions for acquittal and a new trial were denied.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s factual findings for clear error and its legal conclusions de novo. The appellate court held that Carrazco-Martinez failed to rebut the presumption of good faith regarding both warrants. It further held that the challenged jury instruction, when read with the accompanying instruction, correctly stated the law, as drug quantity is a sentencing factor rather than an element of the charged offenses. The Seventh Circuit affirmed the district court’s judgment. View "United States v. Carrazco-Martinez" on Justia Law

The case concerns a criminal defendant charged with kidnapping his fiancée, L.S., for ransom or extortion. At the time of the alleged offense, L.S. was under a temporary conservatorship due to a probate court’s finding that she was “gravely disabled” as defined by the Lanterman–Petris–Short Act (LPS Act), and the San Bernardino County Public Guardian was appointed as her conservator. After the defendant subpoenaed L.S. to testify in his defense at the preliminary hearing, the Public Guardian moved to quash the subpoena, arguing that L.S. was incompetent to testify by virtue of the probate court’s grave disability finding.The Superior Court of San Bernardino County granted the motion to quash, ruling that the finding of grave disability was tantamount to a finding of incompetence to testify under Evidence Code section 701, and that the issue did not need to be relitigated. The defendant then petitioned for a writ of mandate, challenging the trial court’s legal conclusion.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The appellate court held that a finding of grave disability under the LPS Act does not by itself establish incompetence to testify under Evidence Code section 701. The standards for grave disability and testimonial competence are distinct, and incompetence to testify may not be presumed from a grave disability finding or an involuntary medication order. The appellate court directed the superior court to vacate its order granting the motion to quash, to enter a new order denying the motion, and to determine L.S.’s competence to testify under the correct legal standard. The previously ordered stay was vacated upon issuance of the remittitur. View "Esparza v. Super Ct." on Justia Law

The case involves a defendant who was convicted by a jury of aiding and abetting kidnapping after an incident in Detroit. The events began when the defendant was shot during a confrontation involving rival gang members, after which the victim was taken by the defendant’s associates for interrogation. The victim was confined, threatened, and beaten at the defendant’s home, with parts of the incident recorded and later shared in an Instagram group chat. After these events, the victim was driven around, further assaulted, and eventually released.Prior to this appeal, the United States District Court for the Eastern District of Michigan oversaw the trial. The court denied the defendant’s motions to suppress evidence obtained from social media accounts, motions to exclude alleged co-conspirator statements, and ruled partially in favor of the government’s effort to limit cross-examination of the victim. After a weeklong trial, the jury acquitted the defendant of conspiracy but found him guilty of aiding and abetting kidnapping. The district court sentenced him to 198 months in prison and imposed several special conditions of supervised release, some of which were only included in the written judgment.The United States Court of Appeals for the Sixth Circuit reviewed the case. It affirmed the district court on four grounds: the denial of suppression motions, the admission of co-conspirator statements, the limitation on cross-examination, and the sufficiency of the evidence for conviction. The appellate court held that the defendant’s constitutional and evidentiary challenges failed. However, it found a discrepancy between the oral pronouncement of sentence and the written judgment regarding two special conditions of supervised release. The court remanded the case to the district court to resolve this discrepancy and, if needed, to consider the constitutional challenges to those conditions. View "United States v. Blake" on Justia Law

Brandie Nicole Appleton, along with an accomplice, burglarized a Tennessee pharmacy, stealing substantial quantities of controlled substances, firearm parts, and ammunition. After fleeing the scene and attempting to evade law enforcement, Appleton was apprehended, and the stolen items were recovered from her vehicle. Appleton subsequently pleaded guilty to possessing controlled substances with intent to distribute and possessing stolen ammunition. As part of her plea agreement, she waived her right to appeal any sentence within or below the Sentencing Guidelines range.The United States District Court for the Middle District of Tennessee determined Appleton’s Guidelines range to be 41 to 51 months of imprisonment but, noting her progress in overcoming addiction and her personal circumstances, sentenced her to five years of probation. The district court warned her of serious consequences if she violated any probation conditions. Approximately six weeks later, Appleton was arrested for possessing an unprescribed controlled substance, which constituted a violation of her probation. After a revocation hearing, the district court sentenced her to 44 months of imprisonment, within the original Guidelines range.The United States Court of Appeals for the Sixth Circuit reviewed Appleton’s appeal, in which she argued that the district court erred in imposing her sentence after revoking her probation. The government contended that her appeal was barred by the waiver in her plea agreement. The Sixth Circuit held that Appleton’s appeal waiver applied to any sentence within the Guidelines range, including one imposed after probation revocation for the same underlying offense. The court concluded that the waiver was knowingly and voluntarily made, encompassed her present claims, and did not fall under any exceptions. Therefore, the court dismissed her appeal. View "United States v. Appleton" on Justia Law

An individual who served as Executive Director of a local economic development authority in Virginia was indicted on thirty-four counts stemming from multiple fraudulent schemes. These included wire fraud, bank fraud, money laundering, and aggravated identity theft. The prosecution presented evidence that the defendant used forged documents and misrepresentations to divert public funds for personal gain. One scheme involved a $2 million wire transfer, where the defendant lied to both her employer and others, using another person’s identity to facilitate the movement of funds. The trial was repeatedly delayed due to health issues experienced by the defendant and her counsel, resulting in significant breaks and several motions for mistrial by the defense.The United States District Court for the Western District of Virginia presided over the trial, ultimately entering judgments of acquittal on four counts of bank fraud but allowing the remaining convictions to stand. The court denied the defendant’s motions for mistrial, a new trial, and to introduce certain grand jury testimony. After the jury returned guilty verdicts on the remaining counts, the defendant was sentenced accordingly. The defendant appealed, challenging the aggravated identity theft conviction, the handling of trial delays, evidentiary rulings, and a supplemental jury instruction given after closing arguments.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that, under Dubin v. United States, the aggravated identity theft conviction could not stand because the use of another’s identity was not at the “crux” of the predicate wire fraud offense. The court vacated the conviction and sentence on that count and remanded for resentencing. However, the Fourth Circuit affirmed the district court’s rulings on all other issues, including denial of a mistrial, exclusion of grand jury testimony, and the propriety of the additional jury instruction. View "United States v. McDonald" on Justia Law

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