Justia Criminal Law Opinion Summaries

In August 2020, Armani Miller pled no contest to voluntary manslaughter with a firearm use enhancement and was sentenced to 16 years in state prison. In May 2023, Miller filed a petition for resentencing under Penal Code section 1172.6, arguing that he could not be convicted of murder based on changes to the felony-murder rule effective January 1, 2019. Miller contended that subsequent cases recognizing youth as a factor in determining reckless indifference to human life should apply to his case.The Superior Court of Alameda County denied Miller's petition, finding that he failed to make a prima facie case for relief. The court reasoned that Miller's plea and conviction occurred after the changes to the felony-murder rule, and thus, he could not benefit from the amendments. The court also noted that Miller's argument based on subsequent case law was not sufficient to meet the statutory requirements for relief.The California Court of Appeal, First Appellate District, reviewed the case and affirmed the lower court's decision. The appellate court held that Miller was ineligible for relief under section 1172.6 because the amended information filed against him in January 2020 did not allow the prosecution to proceed under the old, now-invalid theory of felony murder. The court emphasized that the charging document required Miller to be a major participant in the kidnapping and to act with reckless indifference to human life, aligning with the amended felony-murder rule. Therefore, Miller could not establish a prima facie case for relief as he was not charged under a theory that imputed malice solely based on his participation in the crime. The court affirmed the denial of Miller's petition for resentencing. View "People v. Miller" on Justia Law

The case involves Justin Michael Wolfe, who was convicted of hiring Owen Barber to murder Daniel Petrole in 2001. Barber, the key witness, initially testified against Wolfe, implicating him in the murder-for-hire scheme. Wolfe was sentenced to death, but Barber later recanted his testimony, claiming he was coerced by the Commonwealth of Virginia with threats of the death penalty. Wolfe's conviction was vacated by the district court due to Brady violations and other prosecutorial misconduct, and the Commonwealth was ordered to retry Wolfe or release him.The United States District Court for the Eastern District of Virginia granted Wolfe habeas relief, finding that the Commonwealth had withheld exculpatory evidence and engaged in misconduct. The Fourth Circuit Court of Appeals affirmed this decision, but the Commonwealth continued to pursue charges against Wolfe. In a subsequent interview, Commonwealth officials again coerced Barber, leading him to invoke his Fifth Amendment rights, making him unavailable as a witness for Wolfe's retrial. Wolfe ultimately pled guilty to avoid the death penalty, receiving a 41-year sentence.Wolfe filed a new habeas petition in the Eastern District of Virginia, asserting claims of vindictive prosecution and due process violations based on the Commonwealth's intimidation of Barber. The district court dismissed the petition as untimely and found that Wolfe failed to present new, reliable evidence of actual innocence under the Schlup standard. Wolfe appealed to the Fourth Circuit Court of Appeals.The Fourth Circuit held that Barber's new declaration, which exculpated Wolfe and explained his previous invocation of the Fifth Amendment due to Commonwealth threats, constituted new, reliable evidence. The court found that Barber's declaration was credible and that no reasonable juror would have convicted Wolfe if they had heard Barber's recantation. The court vacated the district court's judgment and remanded for adjudication of Wolfe's substantive claims. View "Wolfe v. Dotson" on Justia Law

Geovanni Quijadas Silva was charged with committing a lewd act on a child, and his bail was set at $100,000. The North River Insurance Company posted the bail bond. Silva failed to appear for a plea hearing, leading the trial court to declare the bond forfeited. North River was notified and given 180 days to either produce Silva or demonstrate reasons to set aside the forfeiture. North River requested and received an additional 180-day extension. Near the end of this period, North River located Silva in Mexico and filed a motion to vacate the forfeiture, arguing that the bond should be exonerated if the prosecution chose not to seek extradition.The trial court denied North River’s motion, stating that the prosecution had not made an extradition decision within the appearance period and no statutory provisions required them to do so. The court also denied the request to toll the appearance period or continue the matter, as the prosecution had not agreed to a continuance. Summary judgment was entered against North River for $100,000.North River appealed, and the Court of Appeal initially affirmed the trial court’s decision but later reversed it upon rehearing. The appellate court held that the trial court should either compel the prosecution to make an extradition decision or continue the hearing to allow time for such a decision.The California Supreme Court reviewed the case and concluded that section 1305 does not authorize the trial court to compel the prosecution to make an extradition decision or require the court to continue the hearing on the motion to vacate until the prosecution makes such a decision. The court emphasized that the statutory language and legislative history indicate that prosecuting agencies have exclusive control over extradition decisions. The judgment of the Court of Appeal was reversed. View "P. v. The North River Ins. Co." on Justia Law

Michael Lairy petitioned for a writ of habeas corpus under 28 U.S.C. § 2255, arguing that he did not qualify for the Armed Career Criminal Act’s (ACCA) mandatory 15-year sentence and that his counsel was ineffective for not raising this issue. The government did not address the merits of Lairy’s claims but argued that they were raised after the statute of limitations had expired. The district court denied his petition, rejecting Lairy’s arguments that the government forfeited the statute of limitations defense, that he was actually innocent of ACCA, and that he was entitled to equitable tolling.The United States District Court for the Southern District of Indiana held that Lairy’s petition was untimely and that the government did not forfeit the statute of limitations defense. The court also found that Lairy’s claim of actual innocence did not apply because it was a legal, not factual, argument. Additionally, the court denied Lairy’s request for equitable tolling without conducting an evidentiary hearing.The United States Court of Appeals for the Seventh Circuit reviewed the case and agreed with the district court’s evaluation of forfeiture and actual innocence. However, the appellate court found that the district court abused its discretion by rejecting equitable tolling without first conducting an evidentiary hearing. The Seventh Circuit vacated the denial of the petition and remanded the case to the district court to conduct an evidentiary hearing on equitable tolling. The court affirmed the judgment in all other respects. View "Lairy v. United States" on Justia Law

In October 2018, Veronica Pineda De Aquino used a false identity to apply for a U.S. passport, submitting fraudulent documents. Investigators, with the cooperation of the real identity holder, A.E., determined Pineda was a Mexican citizen who had entered the U.S. in 1999. In June 2023, a grand jury indicted Pineda for making a false statement in a passport application and using another person’s social security number. Pineda initially pled not guilty but later entered a plea agreement, pleading guilty to the first count in exchange for the dismissal of the second count.The United States District Court for the Western District of Arkansas accepted Pineda’s guilty plea but deferred the decision on the plea agreement until reviewing the presentence investigation report (PSR). The PSR detailed Pineda’s difficult background and calculated an advisory Guidelines range of 0 to 6 months of imprisonment. At sentencing, the district court adopted the PSR without objection but varied upward, sentencing Pineda to 32 months of imprisonment, citing the seriousness of her offense and the need for deterrence. The court dismissed the second count as per the plea agreement.The United States Court of Appeals for the Eighth Circuit reviewed the case. Pineda argued that the district court erred by not expressly accepting or rejecting the plea agreement and by imposing a substantively unreasonable sentence. The appellate court found that the district court constructively accepted the plea agreement and that any error was not plain. The court also held that the district court did not abuse its discretion in sentencing Pineda above the Guidelines range, considering the aggravating factors and the need for deterrence. The Eighth Circuit affirmed the district court’s judgment. View "United States v. De Aquino" on Justia Law

Guy Wilson moved into a residence with his girlfriend and her two minor children, including her daughter B.Z. He installed several cameras throughout the home, some of which were hidden in locations such as vents in B.Z.’s bedroom and the bathroom. These hidden cameras recorded B.Z. in various states of undress, including images of her genitals, pubic area, and breasts. Wilson also took and saved screenshots from this footage that focused on B.Z.’s pubic area and genitals.A grand jury in the United States District Court for the Southern District of Iowa indicted Wilson for both production and attempted production of child pornography, but only the attempt charge was submitted to the jury. At trial, Wilson argued he lacked the intent required for the offense and that the images did not meet the statutory definition of child pornography. He moved for judgment of acquittal at the close of the government’s case and again at the close of all evidence, but both motions were denied. The jury found him guilty of attempted production of child pornography. At sentencing, Wilson sought a reduction for acceptance of responsibility under the Sentencing Guidelines, but the district court denied this request and imposed a 240-month sentence.The United States Court of Appeals for the Eighth Circuit reviewed Wilson’s conviction and sentence. The court held that the district court did not abuse its discretion in instructing the jury on the Dost-plus factors for determining whether an image is a “lascivious exhibition,” nor was it required to explicitly state that these factors are non-exhaustive. The court also found sufficient evidence supported the jury’s verdict and concluded that the district court did not clearly err in denying a reduction for acceptance of responsibility. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Wilson" on Justia Law

On September 1, 2016, law enforcement officers conducted narcotics raids at a home and shop in Pulaski County, Arkansas. During the raid, officers found contraband in both locations, and an officer shot and injured Lloyd St. Clair, who was holding a shotgun. Lloyd and other occupants of the home and shop filed a lawsuit under § 1983, alleging violations of their Fourth Amendment rights by the officers and the City of Little Rock.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants. The plaintiffs appealed the decision, arguing that there were genuine disputes of material fact regarding the existence of two separate search warrants and the justification for no-knock entries.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court found that the record included two valid search warrants signed by a state judge, and there was no genuine dispute of material fact regarding their existence. The court also determined that the officers had reasonable suspicion to justify the no-knock entries based on videos of Amy St. Clair shooting firearms, which were seen by Officer Kalmer before the raids.Regarding Lloyd's excessive force claim, the court held that the use of deadly force by Officer Thomas was reasonable, as Lloyd admitted to pointing a gun at Thomas. The court also affirmed the district court's grant of summary judgment on the municipal liability claim, as there was no underlying constitutional violation by the city employees.The Eighth Circuit affirmed the judgment of the district court, upholding the summary judgment in favor of the defendants. View "Davenport v. City of Little Rock" on Justia Law

Ronell Moses was driving through his Pittsburgh suburb when Officer Dustin Hess, in a marked police SUV, smelled burnt marijuana and saw that Moses's car windows were tinted very dark, both of which are illegal. The officer followed Moses to his home, where Moses parked in his driveway. The officer walked up the driveway, searched Moses's car, and found a loaded, stolen pistol. Moses, a felon on probation, was arrested and charged with possessing a gun and ammunition as a felon.The United States District Court for the Western District of Pennsylvania denied Moses's motion to dismiss the indictment, which challenged the constitutionality of the law under the Second Amendment. The court also denied his motion to suppress the gun, rejecting his claim that the officer had invaded his home's curtilage without a warrant. Moses then pleaded guilty conditionally, preserving his right to appeal the curtilage issue and the constitutionality of the law.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the officer did not invade Moses's curtilage by walking halfway up the driveway, as the driveway was not an extension of Moses's home. The court applied a de novo standard of review to curtilage decisions, aligning with other circuits. The court also held that the officer's actions were constitutional and that Moses, as a felon on parole, could be prosecuted for possessing a gun. The court affirmed Moses's conviction. View "United States v. Moses" on Justia Law

In early 2021, Jason Turner Johnson was charged with first-degree burglary and fifth-degree assault in Minnesota. Later, an additional charge of second-degree burglary was added. Johnson pleaded guilty to the second-degree burglary charge, and the other charges were dismissed. He was sentenced to 28 months in prison, but the sentence was stayed, and he was placed on probation for five years. In August 2023, Johnson's probation officer reported multiple probation violations, including new criminal charges and failure to contact his probation officer. Johnson requested jail credit for time spent in custody in North Dakota, which the district court partially granted.The district court revoked Johnson's probation, executed his stayed sentence, and awarded him partial jail credit for time spent in custody in North Dakota. The State of Minnesota appealed the jail credit determination. Johnson moved to dismiss the appeal, arguing that the State had no right to appeal the jail credit determination. The Minnesota Court of Appeals denied Johnson's motion, holding that the State's right to appeal a jail credit determination arises by necessary implication from its right to appeal any sentence imposed or stayed by the district court in a felony case.The Minnesota Supreme Court reviewed the case to determine whether the State could appeal the district court's jail credit determination following a probation revocation. The court concluded that the State's right to appeal a jail credit determination arises by necessary implication from its express right to appeal a probation revocation decision under Minnesota Rule of Criminal Procedure 27.04, subdivision 3(4)(a). Therefore, the court affirmed the decision of the court of appeals, allowing the State's appeal to proceed. View "State of Minnesota vs. Johnson" on Justia Law

In 1997, Milton K. Sanders was found guilty by a jury of one count of first-degree murder and two counts of attempted first-degree murder. The district court sentenced him to life in prison for the first-degree murder conviction and to consecutive 180-month prison sentences for the attempted first-degree murder convictions. Sanders's convictions and sentences were affirmed on appeal in 1999.In May 2024, Sanders filed a motion to correct his sentence, arguing that his consecutive sentences were unauthorized by law because they exaggerated the criminality of his conduct and were based on an incorrect criminal history score. The district court denied his motion, concluding that the sentences were authorized by law and that any error related to the criminal history score was harmless.The Minnesota Supreme Court reviewed the case. The court held that Sanders's argument regarding the exaggeration of his criminality was barred by the law of the case doctrine, as it had been previously addressed and denied in his direct appeal. Additionally, the court found that the consecutive sentences did not unfairly exaggerate the criminality of Sanders's conduct, as each offense involved a different victim, consistent with past sentences for similar offenses.Regarding the criminal history score, the court determined that any error in the district court's failure to pronounce Sanders's criminal history score at sentencing was harmless. The life sentence for first-degree murder was mandatory and unaffected by the criminal history score. The consecutive 180-month sentences for attempted first-degree murder were consistent with the presumptive sentence for a criminal history score of zero, as required by the sentencing guidelines.The Minnesota Supreme Court affirmed the district court's decision, concluding that the sentences were authorized by law and that any error related to the criminal history score was harmless. View "Sanders vs. State of Minnesota" on Justia Law