Justia Criminal Law Opinion Summaries

In 2001, after a failed business partnership, an individual kidnapped and killed his former partner. The police investigation began when the victim’s family reported him missing and started receiving ransom calls, which were traced to the accused. Upon arrest, the accused gave a false account, alleging he had been kidnapped, but evidence contradicted his story. Surveillance footage, ballistic evidence, and the eventual discovery of the victim’s body all implicated the accused. At trial, the jury convicted him on multiple charges, including kidnapping and first-degree manslaughter, and recommended a life sentence, which the court imposed.Following his conviction, the accused pursued various appeals and collateral challenges. On direct appeal, he explicitly waived his right to counsel and chose to proceed pro se, despite warnings from the Kentucky Supreme Court and the Department of Public Advocacy. The Kentucky Supreme Court ultimately affirmed his conviction and sentence. Subsequent collateral attacks under Kentucky Rule of Criminal Procedure 11.42 were largely unsuccessful, though he did secure a resentencing on one count, which resulted in the same effective sentence. Further attempts to challenge his conviction, including a second belated appeal and additional Rule 11.42 motions, were denied as untimely or successive, with these decisions upheld on appeal.The United States Court of Appeals for the Sixth Circuit reviewed two claims from his federal habeas petition: whether he was improperly allowed to proceed pro se on direct appeal, and whether trial counsel was constitutionally ineffective during closing arguments. The court held that the accused knowingly and intelligently waived his right to appellate counsel. On the ineffective assistance claim, the court found it procedurally defaulted and not subject to any exception, as the claim lacked merit and he had not shown prejudice. The court affirmed the district court’s dismissal of the habeas petition. View "Gaither v. Lane" on Justia Law

A group of individuals, including the petitioner, became involved in a series of drug-related activities centered around a home in Parkersburg, West Virginia. After the petitioner purchased drugs from Tiffany McCune, he became dissatisfied with their quality, leading to several confrontations and exchanges between the parties. The situation escalated when the petitioner returned to the McCune home, forcibly entered, and assaulted Tiffany with a pistol. During the ensuing chaos, Darren Salaam Sr., who was present in the house, was shot in the back and later died from his wounds. The petitioner fled the scene but was later apprehended. Upon arrest, he made racially charged statements, and photographs taken at booking displayed his swastika and Aryan Brotherhood tattoos.The Circuit Court of Wood County presided over the petitioner’s jury trial. The jury convicted him of felony murder, finding that the underlying felony was burglary. The petitioner was sentenced to life without the possibility of parole. During the trial, the court admitted evidence of the petitioner’s tattoos and statements, as well as Tiffany McCune’s statements to police and a 9-1-1 call, over the petitioner’s objections on various evidentiary and constitutional grounds. The petitioner’s post-trial motions for acquittal and a new trial—primarily challenging the sufficiency of the evidence on the burglary element—were denied.On appeal, the Supreme Court of Appeals of West Virginia reviewed the evidentiary rulings for abuse of discretion and the constitutional claims de novo. The court held that the tattoo evidence was relevant to motive and not unfairly prejudicial, Tiffany’s statements were admissible as excited utterances and not testimonial under the Confrontation Clause, and the evidence was sufficient to support the felony murder conviction. The court affirmed the circuit court’s judgment. View "State v. Thompson" on Justia Law

Three men were implicated in the shooting death of an individual inside a ransacked townhome, where stolen items and evidence of forced restraint were discovered. Investigators connected the suspects to the scene through surveillance footage, fraudulent use of a credit card, recovery of stolen items from their residences, and cell phone records indicating communications and location proximity to the crime. A rented maroon vehicle, tied to one defendant, was placed at the scene by GPS data. The suspects’ explanations at trial were contradicted by physical and circumstantial evidence.A Fulton County grand jury indicted all three for malice murder, felony murder, home invasion, burglary, armed robbery, aggravated assault, false imprisonment, firearm offenses, and related fraud crimes. At a joint jury trial in December 2018, two defendants were found guilty on all counts, while the third was acquitted of malice murder but convicted on other charges. The trial court imposed life sentences, some without parole, and additional concurrent and consecutive sentences for other offenses. The defendants filed motions for new trial, which were denied by the trial court in November 2024. They appealed to the Supreme Court of Georgia.The Supreme Court of Georgia affirmed the convictions and sentences. The Court held that the evidence was sufficient to support the convictions, both as a matter of federal constitutional due process and Georgia law, including circumstantial evidence standards. The Court found no prejudicial error regarding the use of leg restraints, missing trial exhibits, or jury instructions, and concluded that related claims were either unpreserved or without merit. Claims of ineffective assistance of counsel and cumulative error were rejected for lack of deficient performance, prejudice, or both. The denial of speedy appeal and other procedural claims was also affirmed. View "Gines v. State" on Justia Law

The defendant entered a bank in Baton Rouge, Louisiana, and gave a cashier a note demanding money and threatening harm to everyone present. Believing he was armed, the cashier complied, handing over approximately $20,000. The defendant was later arrested and pled guilty to bank robbery under federal law. In the presentence report, the probation officer recommended a career-offender sentencing enhancement based on two prior Louisiana convictions: one for armed robbery and another for attempted armed robbery.At sentencing, the United States District Court for the Middle District of Louisiana agreed with the presentence report's assessment and found that the defendant qualified as a career offender under the United States Sentencing Guidelines § 4B1.1(a). As a result, the defendant’s offense level and criminal history category were increased, resulting in a recommended guideline range of 151 to 188 months. The district court sentenced the defendant to 151 months in prison and three years of supervised release. The defendant objected, arguing that Louisiana armed robbery does not categorically qualify as a “crime of violence” for purposes of the Guidelines.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s determination de novo. The appellate court concluded that Louisiana’s armed robbery statute requires the intentional use, attempted use, or threatened use of physical force, and not merely reckless or negligent conduct. The court found that the defendant failed to show any realistic probability that Louisiana would apply its statute to unintentional acts. Therefore, the Fifth Circuit held that Louisiana armed robbery constitutes a “crime of violence” under the force clause of the Sentencing Guidelines and affirmed the district court’s sentence. View "USA v. Lanaute" on Justia Law

Several Iraqi citizens detained at Abu Ghraib prison during the U.S. occupation of Iraq alleged that, between October and December 2003, they were subjected to severe abuse by military police. The plaintiffs claimed that employees of CACI Premier Technology, Inc., a contractor providing interrogation services to the U.S. military, conspired with military personnel to “soften up” detainees for interrogation, resulting in torture and cruel, inhuman, and degrading treatment (CIDT). While CACI’s contract required its personnel to operate under military supervision, evidence suggested inadequate oversight and that CACI employees directed some of the abusive tactics. Plaintiffs did not allege direct physical abuse by CACI interrogators, but asserted conspiracy liability.The case was initially filed in the United States District Court for the Eastern District of Virginia, advancing claims under both the Alien Tort Statute (ATS) and state law. Over time, the plaintiffs narrowed their suit to ATS claims for torture, CIDT, and war crimes, proceeding on conspiracy and aiding-and-abetting theories. The district court dismissed some claims and parties, and after two trials—one ending in mistrial—the jury found CACI liable for conspiracy to commit torture and CIDT, awarding significant compensatory and punitive damages.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed multiple legal challenges by CACI, including justiciability, immunity, preemption, and the state secrets privilege. The court held that application of the ATS was proper because the conduct at issue occurred within U.S.-controlled territory (Abu Ghraib during the CPA regime), was actionable under universal jurisdiction principles, and enough domestic conduct was involved. The court found that conspiracy liability and corporate liability are recognized under the ATS, and rejected CACI’s defenses and challenges regarding sovereign immunity, political question doctrine, preemption, and evidentiary rulings. The Fourth Circuit affirmed the judgment against CACI, vacated the district court’s judgment in favor of the United States on third-party claims due to sovereign immunity, and remanded with instructions to dismiss those claims. View "Al Shimari v. CACI Premier Technology, Inc." on Justia Law

The case involves a defendant who was convicted of two counts of felony murder after setting fire to his estranged girlfriend’s apartment, resulting in the deaths of her two roommates. The relationship between the defendant and his girlfriend was tumultuous, and on the night of the incident, after a series of arguments and threatening communications, the defendant poured gasoline on the apartment couch and set it ablaze. Surveillance footage placed him at the scene, and an arson investigator determined that accelerant had been used. Following his arrest, the defendant was interrogated by police and ultimately confessed to pouring the gasoline but denied intending to kill anyone.In Multnomah County Circuit Court, the defendant moved to suppress statements made during his police interrogation, arguing they were involuntary, and filed a demurrer contending that Oregon’s felony-murder statute, ORS 163.115(1)(b), violated due process by either creating an impermissible presumption regarding the mental state or by imposing strict liability for murder. The trial court denied both motions, finding the confession was voluntary under the totality of the circumstances and that the statute did not violate due process. The defendant was convicted, and the Oregon Court of Appeals affirmed, agreeing with the trial court’s rulings.The Supreme Court of the State of Oregon reviewed both issues. It held that the trial court did not err in declining to suppress the confession, emphasizing that, under the totality of the circumstances, the statements were voluntary and not the product of coercion or improper inducement. The court further held that Oregon’s felony-murder statute, as previously interpreted in State v. Blair, does not violate the Due Process Clause because it does not create a conclusive presumption regarding mental state or impose unconstitutional strict liability. The Supreme Court of Oregon affirmed the decisions of both the Court of Appeals and the circuit court. View "State v. Monaco" on Justia Law

The case concerns a habeas corpus petition filed by an individual convicted and sentenced to death for the willful, deliberate, and premeditated murder of Janine Lee in California in 1993. The petitioner had worked with the victim and, after planning the crime, killed her for financial gain and subsequently attempted to cash her checks. Forensic evidence and the petitioner’s confession corroborated his involvement, including details about the killing, use of martial arts training, and subsequent events. Expert testimony at trial highlighted the petitioner’s mental health issues, drug use, and troubled social history, but the jury found him guilty and sentenced him to death.Following his conviction and sentencing, the California Supreme Court affirmed the judgment on direct appeal and summarily denied habeas relief. The United States District Court for the Central District of California denied the federal habeas petition under 28 U.S.C. § 2254, but granted a certificate of appealability for claims of ineffective assistance of counsel during the penalty phase. The petitioner sought to expand the certificate to include additional claims related to competency and juror bias.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial of habeas relief. Applying AEDPA deference, the Ninth Circuit held that the California Supreme Court could have reasonably determined that the petitioner failed to make a prima facie case for relief on all penalty-phase ineffective assistance subclaims, including alleged failures to investigate, prepare witnesses, and rebut aggravating evidence. The court also rejected cumulative error and competency claims, and denied a certificate of appealability for juror bias. The panel granted a certificate for one penalty-phase competency subclaim but affirmed its denial. The district court’s denial of habeas corpus relief was affirmed. View "COMBS V. BROOMFIELD" on Justia Law

The appellant was convicted of delivery of methamphetamine, second or subsequent offense, and received a suspended sentence with three years of supervised probation. Conditions of probation included obeying Department of Corrections rules and completing any treatment required by his probation officer. After seven months, the State filed a petition to revoke probation, alleging that the appellant left required inpatient treatment at Southwest Counseling Service without completing it. The probation officer’s affidavit detailed that he left treatment against staff advice, had missed office visits, continued to use methamphetamine, and had fled from the probation office, resulting in new criminal charges.The District Court of Carbon County held a probation revocation hearing. Although the appellant initially admitted violating probation, he later claimed his attendance at inpatient treatment was voluntary. The court proceeded to an evidentiary hearing, where the probation officer testified about the appellant’s ongoing drug use, failure to attend required evaluations, and his departure from treatment. The court found by a preponderance of the evidence that he violated probation by not completing required treatment, revoked his probation, and imposed the underlying six to ten-year prison sentence, citing willful violations and unsuitability for continued probation. The appellant appealed, arguing that his due process rights were violated when the State relied on other uncharged probation violations during the dispositional phase.The Supreme Court of Wyoming reviewed the case under the plain error standard because the due process argument was not raised below. The court held there was no due process violation, explaining that written notice is required only for the specific alleged probation violation that forms the basis for revocation, not for other conduct considered during the dispositional phase. The court affirmed the district court’s order revoking probation and imposing the prison sentence, finding no clear or unequivocal rule of law was violated. View "Bustos v. The State of Wyoming" on Justia Law

The defendant was convicted after a jury trial of aggravated eluding, reckless driving, driving under suspension, and failing to stop at a stop sign, all arising from an incident in Sioux Falls, South Dakota. Law enforcement responded to a call about a family dispute, with the caller reporting that the defendant was driving a red Toyota Camry. Officers observed the vehicle and identified the defendant as the driver, who then fled at high speed through residential neighborhoods. The defendant later testified that he was not involved, did not own or drive the Camry, and denied fleeing from police.The Circuit Court of the Second Judicial Circuit, Minnehaha County, presided over the trial. Prior to trial, the defendant moved to exclude statements related to the BOLO alert and the caller’s association of him with the Camry, arguing hearsay and character evidence grounds. The court denied these motions, reasoning that the BOLO and information about the vehicle were relevant to the officers’ actions and not unduly prejudicial. During trial, officers testified about the BOLO and caller’s statements, and defense counsel made a continuing objection referencing Crawford v. Washington. The jury returned guilty verdicts on all counts, and the defendant was sentenced with all terms suspended.The Supreme Court of the State of South Dakota reviewed the case. The defendant argued that admitting the caller’s statement violated his Sixth Amendment right to confrontation and constituted inadmissible hearsay. The court held that the defendant had not properly preserved the Confrontation Clause issue for appeal, as he failed to provide sufficient facts or request a determination about whether the caller’s statement was testimonial. Regarding hearsay, the court found that, even if error occurred, it was not prejudicial because the officers’ identification testimony and dash camera videos provided strong, independent evidence of the defendant’s identity. The Supreme Court affirmed the conviction. View "State v. Clifford" on Justia Law

The defendant was involved in a series of criminal incidents beginning in late December 2023, including an alleged domestic assault, multiple vehicle thefts, assaulting a law enforcement officer with a vehicle, fleeing police, violating no-contact orders, drug possession, and failing to appear in court. These incidents led to six separate felony cases in Lawrence and Meade Counties. In each case, the defendant entered into plea agreements, resulting in guilty pleas to several counts in exchange for the dismissal of other charges and enhancements. The sentences imposed by the circuit court were largely concurrent, except for a consecutive sentence in the Meade County case.Following his convictions and sentencing, the defendant appealed, asserting that his guilty plea in the primary Lawrence County case was not knowing and voluntary. He claimed that both his counsel and the presentence investigation report (PSI) led him to believe he would be eligible for parole after serving a portion of his sentence, when in fact, state law rendered him ineligible for parole on the aggravated assault against a law enforcement officer charge. He further argued that, if his plea was invalid, the sentences in his other Lawrence County cases should also be vacated under the sentencing package doctrine.The Supreme Court of the State of South Dakota reviewed the totality of the circumstances and found that the plea was knowing and voluntary. The court held that neither the circuit court nor counsel was required to inform the defendant of collateral consequences such as parole eligibility, and inaccuracies or misunderstandings about parole did not render the plea involuntary. Because the defendant did not prevail on his primary claim, his argument regarding the sentencing package doctrine was moot. The Supreme Court affirmed all of the circuit court’s judgments. View "State v. Ware" on Justia Law