Justia Criminal Law Opinion Summaries

A federal law enforcement officer was charged following two separate incidents that took place at a U.S. border crossing. In the first, the officer confronted an individual, Espinosa, who had been involved in a verbal disagreement with another officer. The officer intervened, physically redirected Espinosa, and both collided with a door, resulting in Espinosa experiencing physical injuries such as dizziness and confusion. Testimony from a supervisor and an expert witness indicated the force used was excessive and not justified by Espinosa’s behavior at the time. In the second incident, the officer engaged with Estrada, a returning traveler, following a verbal exchange. The officer brought Estrada into a secure area, used force to restrain him, and pressed his face into chairs, causing a nose injury. Witnesses and expert testimony again described the officer’s actions as excessive and unnecessary, and video evidence did not show Estrada acting aggressively or resisting.After these events, the officer filed a report about the Estrada incident, which contained statements that were contradicted by video evidence and expert analysis. The officer also made verbal statements to a supervisor that were later found to be false.The United States District Court for the Western District of Texas conducted a bench trial, found the officer guilty of two counts of deprivation of rights under color of law (18 U.S.C. § 242) and one count of falsifying a record in a federal investigation (18 U.S.C. § 1519), and imposed concurrent sentences below the guidelines. The officer appealed, challenging the sufficiency of the evidence.The United States Court of Appeals for the Fifth Circuit reviewed the case, applying a highly deferential standard to the verdict. The court held that a rational factfinder could find all elements of the crimes proven beyond a reasonable doubt and affirmed the convictions. View "United States v. Delgado" on Justia Law

Police discovered illegal drugs and drug paraphernalia at Felicia Marie Hinkle’s residence, resulting in charges against her for criminal possession of dangerous drugs and drug paraphernalia. Her initial trial in Cascade County was scheduled for August 2023, but procedural errors in juror notification and empanelment led the Eighth Judicial District Court to vacate the trial. The court issued detailed instructions to correct the juror selection process and rescheduled the trial for November 2023. Before the new trial, Hinkle moved to discharge the jury panel, arguing two individuals on the panel had moved out of the county, and requested a hearing supported by her attorney’s affidavit.The Eighth Judicial District Court reviewed Hinkle’s motion and noted that the revised jury selection procedures had been implemented, referencing findings from a hearing held before Judge Kutzman in State v. Burden, where substantial compliance with statutory requirements was found. The court took judicial notice of the Burden proceedings and concluded that the inclusion of nonresident names in the jury pool was a predictable but non-prejudicial outcome of the process, and that the panel for Hinkle’s case was drawn in accordance with statutory requirements. The court denied Hinkle’s motion and did not conduct a hearing.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court erred by denying Hinkle’s motion without a hearing. Applying the substantial compliance standard from State v. Hillious, the Supreme Court held that technical deviations in jury selection statutes that do not affect the randomness or objectivity of the pool, nor a defendant’s right to a fair and impartial jury, do not warrant reversal or a hearing. The court affirmed the District Court’s decision, finding no substantial failure or prejudicial error in the jury selection process. View "State v. Hinkle" on Justia Law

Police stopped the defendant’s vehicle after connecting it to a recent trespass and burglary. The investigation led to charges of felony criminal possession of dangerous drugs and misdemeanor possession of drug paraphernalia. The case proceeded to a jury trial. During jury selection, defense counsel questioned potential jurors about the presumption of innocence and the defendant’s right not to testify. Prospective juror M.W. expressed that, while he would prefer the defendant to rebut the State's evidence, he could acquit if the State’s case was weak and acknowledged the presumption of innocence. Defense counsel moved to strike M.W. for cause, arguing his statements raised concerns about his impartiality.The Twenty-First Judicial District Court, Ravalli County, denied the motion to strike M.W. for cause, finding M.W. had not expressed a fixed bias and could be fair. Haacke used a peremptory challenge to remove M.W. The jury ultimately found Haacke guilty, and the District Court imposed concurrent suspended sentences. Haacke appealed, arguing the court erred by not removing M.W. for cause, relying on Montana law that a juror should be excused if their state of mind raises serious doubts about impartiality.The Supreme Court of the State of Montana reviewed whether the District Court abused its discretion in denying the challenge for cause. The Court held that, under the totality of the circumstances, M.W.’s statements did not amount to a fixed bias or raise a serious question about his ability to be impartial. The Court found no abuse of discretion by the District Court and affirmed Haacke’s conviction. The main holding is that the District Court did not err in refusing to strike M.W. for cause, as the record did not compel a finding of serious doubt about his impartiality. View "State v. Haacke" on Justia Law

Michael Connor was convicted in 2013 after a bench trial in Livingston County, Illinois, of five counts of predatory criminal sexual assault of a child. The offenses involved his daughter and stepdaughter, occurring when they were between five and seven years old. The statutory penalty was six to sixty years per count, to be served consecutively, but if convicted of assaulting multiple victims, the law required a mandatory life sentence. After his conviction, Connor received the mandatory life term.After his direct appeal was unsuccessful, Connor pursued postconviction relief in Illinois state court, arguing that his trial counsel was constitutionally ineffective during plea negotiations by failing to inform him that he faced a mandatory life sentence. He claimed this omission led him to reject an 18-year plea offer. At an evidentiary hearing, Connor testified that he would have accepted the plea had he known about the life sentence. The trial judge, however, found this testimony not credible, noting that Connor had repeatedly asserted his innocence and had unequivocally stated at sentencing that he would not have pleaded guilty even if aware of the outcome. The trial court denied postconviction relief, and the Illinois Appellate Court affirmed, finding no reasonable probability that Connor would have accepted the plea but for counsel’s alleged errors.Connor then sought federal habeas relief in the United States District Court for the Central District of Illinois, which was denied. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the denial. The Seventh Circuit held that federal habeas relief was not warranted because Connor failed to rebut, by clear and convincing evidence, the state court's credibility finding that he would not have accepted the plea. The judgment of the district court was affirmed. View "Connor v. Greene" on Justia Law

In this case, the petitioner was convicted and sentenced to death for the murder and robbery of two men in a Kentucky convenience store in 1987. After being identified as a suspect, he confessed to the crimes but later asserted an insanity defense at trial. His mental health was evaluated by state experts, who found him competent and not suffering from a mental illness that would have excused his conduct. At trial, the defense presented testimony from the petitioner and a psychologist, but the jury found him guilty on all counts and recommended the death penalty. The penalty phase included limited mitigation evidence and testimony.Following his conviction and sentencing, the petitioner pursued direct appeals and post-conviction relief in Kentucky state courts, including before the Kentucky Supreme Court, and sought certiorari from the United States Supreme Court, which was denied multiple times. He then filed a federal habeas corpus petition in the United States District Court for the Eastern District of Kentucky, asserting several constitutional claims, including ineffective assistance of counsel, improper jury instructions on the insanity defense, and cumulative error. The district court denied relief, but granted certificates of appealability on several issues.On appeal, the United States Court of Appeals for the Sixth Circuit first held that the Antiterrorism and Effective Death Penalty Act (AEDPA) is constitutional, rejecting the argument that it unconstitutionally restricts federal habeas review. Applying AEDPA deference, the court found that the Kentucky Supreme Court’s decisions regarding the jury instructions and most of the ineffective assistance of counsel claims were neither contrary to nor unreasonable applications of clearly established federal law. Claims not subject to AEDPA deference failed under de novo review because the petitioner could not show prejudice. The cumulative error claim was found to be procedurally defaulted. Accordingly, the Sixth Circuit affirmed the denial of the habeas petition in full. View "Sanders v. Plappert" on Justia Law

Federal and local law enforcement investigated an individual as part of a drug trafficking organization operating in Tennessee. Over ten months, agents used various investigative techniques, including wiretaps, confidential informants, controlled narcotics buys, and electronic surveillance. Based on the evidence, a grand jury indicted the defendant on multiple counts, including conspiracy to distribute cocaine and heroin, drug distribution, money laundering, and related offenses. The defendant was arrested at his home, questioned by agents, and, after receiving Miranda warnings, confessed to involvement in drug trafficking. Agents also seized and searched his cellphones with his verbal and written consent.Before trial in the United States District Court for the Middle District of Tennessee, the defendant filed motions to suppress his post-arrest statements and evidence from the cellphone searches, arguing violations of his Fifth, Sixth, and Fourth Amendment rights. The district court denied these motions after evidentiary hearings. At trial, a jury convicted the defendant on all counts, and the district court imposed a prison sentence and supervised release.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the denial of the suppression motions. The appellate court held that the defendant’s post-Miranda confession was not coerced, the warnings given reasonably conveyed his rights, and even if there were deficiencies, any error was harmless due to overwhelming other evidence of guilt. The court further found that the defendant voluntarily consented to the cellphone searches, and there was no Fourth Amendment violation. The court noted that no evidence from the cellphones was introduced at trial. Accordingly, the Sixth Circuit affirmed the district court’s denial of the suppression motions and upheld the convictions. View "United States v. Magallon Guerrero" on Justia Law

A physician was charged with unlawfully distributing oxycodone, a controlled substance, after prescribing it to a patient he knew was addicted to opioids, and who subsequently died of a drug overdose. The government alleged that the prescriptions were not issued for legitimate medical purposes and were outside the usual course of professional practice. The physician pled guilty to all charges in 2019. At his plea hearing, the district court explained that the government would have to prove the prescriptions were unauthorized but, following then-binding Fourth Circuit precedent, did not tell him the government also had to prove he knew his conduct was unauthorized.Nearly three years later, the Supreme Court decided Ruan v. United States, holding that, under 21 U.S.C. § 841, the government must prove that a physician “knowingly or intentionally” acted in an unauthorized manner when prescribing controlled substances. The physician filed a motion under 28 U.S.C. § 2255 to vacate his convictions, arguing his guilty plea was invalid because he had not been informed of the scienter requirement articulated in Ruan. The United States District Court for the Middle District of North Carolina denied the motion, finding the claim procedurally defaulted because it was not raised earlier and that Ruan was not so novel as to excuse the default, since similar arguments were available and made by others at the time of the plea.The United States Court of Appeals for the Fourth Circuit affirmed. The court held that the legal basis for the physician’s Ruan-style mens rea claim was reasonably available at the time of his guilty plea, given existing Supreme Court precedent such as Rehaif v. United States. Therefore, the claim was not sufficiently novel to provide cause to overcome procedural default, and collateral relief was precluded. View "United States v. Dimkpa" on Justia Law

Two individuals were separately stopped and searched by law enforcement officers in Maryland in January 2023, prior to the effective date of a new statute, Criminal Procedure Article (“CP”) § 1-211. The stops and searches were based solely on the odor of cannabis. Contraband was discovered in both cases, and the individuals were charged with various offenses. Each moved to suppress the evidence, arguing that the newly enacted statute, effective July 1, 2023, rendered evidence obtained solely on the basis of cannabis odor inadmissible, even though their searches had occurred before the law took effect.In both cases, the Circuit Court for St. Mary’s County and the Circuit Court for Worcester County denied the motions to suppress, ruling that the statute did not apply retroactively because it was not in effect at the time of the searches. The Appellate Court of Maryland affirmed both decisions, reasoning that the statute created a new substantive right and remedy that only attached to searches occurring on or after its effective date. The Appellate Court relied on its prior decision in Kelly v. State and distinguished these cases from others involving procedural or remedial statutes.Upon review, the Supreme Court of Maryland affirmed the judgments of the Appellate Court. The Court held that CP § 1-211’s exclusionary remedy applies only to evidence discovered or obtained in violation of the statute, and no violation can occur before the statute’s effective date. The Court found the statute unambiguous, rejected arguments for retroactive application based on procedural or remedial theories, and emphasized the General Assembly’s clear intent for prospective application. Therefore, the exclusionary remedy in CP § 1-211(c) does not apply to pre-enactment cannabis-related stops or searches, and the evidence was properly admitted. View "Cutchember v. State" on Justia Law

The case involved a traffic stop in Salem, New Hampshire, where a police officer, upon detecting a strong odor of alcohol in a vehicle, interacted with its passengers. The defendant, seated in the back, became verbally aggressive toward the officer, yelling and cursing. After being ordered out of the vehicle, the defendant stepped toward the officer, pointed at him, and shoved his finger into the officer’s chest. When the officer attempted to arrest him, the defendant pulled away, struggled, and resisted being handcuffed. A portion of this encounter was captured on video by another passenger.Following these events, the defendant was charged in the Rockingham County Superior Court with misdemeanor counts of simple assault and resisting arrest. At trial, the jury was presented with video evidence and heard testimony from the officers involved. The defendant moved to dismiss the charges for insufficient evidence, but the trial court (St. Hilaire, J.) denied these motions. The jury found the defendant guilty on both counts, leading to the present appeal.The Supreme Court of New Hampshire reviewed the case. The defendant argued that appellate review of video evidence should be de novo, asserting that the court was in as good a position as the jury to interpret such evidence. The court rejected this argument, holding that video evidence must be reviewed under the traditional standard: all evidence, including video and live testimony, is viewed in the light most favorable to the State to determine whether any rational jury could find guilt beyond a reasonable doubt. Applying this standard, the court found sufficient evidence to support both convictions. The court also rejected the defendant’s argument that his conduct was de minimis, noting it was not preserved or plain error. The court affirmed the convictions. View "State v. Wells" on Justia Law

A former ship captain was prosecuted after a fire broke out on his vessel, resulting in the deaths of thirty-four passengers and crew members. The ship, used for recreational diving, had multiple fire safety features and regulatory requirements, including the need for a roving night patrol and crew training in fire response. The captain had extensive maritime experience, but his crew was relatively inexperienced and had not been adequately trained in emergency procedures. On the night of the incident, no one was assigned to patrol for fires, and when the fire was discovered, the crew was unprepared to respond effectively. The captain contacted the Coast Guard but did not use the ship’s public address system to warn those below deck or attempt a rescue, ultimately abandoning ship along with other crew members. All individuals below deck died from smoke inhalation and asphyxiation.The United States District Court for the Central District of California presided over the initial criminal case. The first indictment tracked the language of the seaman’s manslaughter statute but was dismissed by the district court for not alleging gross negligence, which the court believed was required based on prior interpretations of a different manslaughter statute. The government reindicted, alleging gross negligence, and the case proceeded to trial. The jury was instructed that conviction could follow if the captain engaged in “misconduct and/or acted with gross negligence.” The jury found the captain guilty.On appeal, the United States Court of Appeals for the Ninth Circuit held that the seaman’s manslaughter statute, 18 U.S.C. § 1115, requires only ordinary negligence, not gross negligence. The court further concluded that, even if the jury instruction’s use of “misconduct” was erroneous, any such error was harmless because the instructions repeatedly referenced the higher gross negligence standard, the prosecution did not argue for a lower standard, and overwhelming evidence supported the conviction. The judgment was affirmed. View "USA V. BOYLAN" on Justia Law