Justia Criminal Law Opinion Summaries

Police in Gautier, Mississippi, used an automatic license plate reader (LPR) system to identify a vehicle associated with Elijah Porter, who was wanted on an outstanding warrant for aggravated assault. Officer Hoggard received an LPR alert, confirmed the vehicle’s connection to Porter through a computer check, and conducted a traffic stop. During the stop, Hoggard detained Porter and, while interacting with him, observed the barrel and slide of a firearm, as well as a silver automatic conversion switch, protruding from under the driver’s seat. The officer later retrieved the firearm—a Glock pistol equipped with a machinegun conversion switch—during an inventory search of the vehicle.The United States District Court for the Southern District of Mississippi denied Porter’s motions to suppress both the LPR-derived vehicle location data and the firearm, ruling that use of the LPR data did not constitute a search under the Fourth Amendment, that the stop was supported by reasonable suspicion, and that the plain view and inevitable discovery doctrines applied to the firearm. The court also rejected Porter’s argument that 18 U.S.C. § 922(o), which prohibits possession of a machinegun, was unconstitutional under the Second Amendment. Porter waived a jury trial and was found guilty in a bench trial.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s rulings. It held that use of the LPR system to identify Porter’s vehicle did not violate the Fourth Amendment because there was no reasonable expectation of privacy in movements on public roads or in license plate information, and the LPR data was not as comprehensive as cell-site location data. The court further held that the traffic stop was supported by reasonable suspicion, the firearm was lawfully seized under the plain view doctrine, and Fifth Circuit precedent foreclosed Porter’s Second Amendment challenge to § 922(o). The conviction was affirmed. View "United States v. Porter" on Justia Law

The defendant, employed as a daycare worker, took and distributed a sexually explicit photograph of an infant in her care. She pleaded guilty to one count of production and attempted production of child pornography under a plea agreement that included a waiver of her right to appeal, except in certain circumstances. At sentencing, the government advocated for the statutory maximum sentence and, in doing so, referenced the defendant’s sex as making her conduct more shocking and suggested that a lengthy sentence would prevent her from having children in the future. The district court ultimately imposed the statutory maximum sentence but did not mention the defendant’s sex as a reason for the sentence.The United States District Court for the Northern District of Texas accepted the guilty plea and sentenced the defendant to 360 months in prison, 10 years of supervised release, and restitution. The defendant did not object to the prosecutor’s comments regarding her sex at the sentencing hearing. She appealed, arguing that the government’s statements violated her Fifth Amendment right to equal protection and that the appeal waiver in her plea agreement did not bar her appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case and applied the plain-error standard, as the defendant had not objected to the statements in the district court. The appellate court concluded that the district court did not rely on the prosecutor’s references to the defendant’s sex when imposing sentence. Because the defendant could not show that the government’s statements affected her substantial rights or that a structural error had occurred, the Fifth Circuit held that there was no reversible error. The judgment of the district court was affirmed. View "United States v. Hamilton" on Justia Law

The case arose after the defendant was charged in July 2020 with felony driving under the influence (DUI) in Missoula County, Montana. He entered a plea agreement with the State, pleading guilty to the DUI charge in exchange for dismissal of another case. The parties jointly recommended a 13-month commitment to the Department of Corrections with specific placement and a subsequent suspended sentence. Although they agreed the court could impose the mandatory minimum $5,000 fine, the defendant’s financial circumstances showed he could not pay most of it, as he subsisted primarily on Social Security and had very limited resources.The Fourth Judicial District Court, Missoula County, presided over sentencing. The defendant’s counsel requested the fine be stricken due to the defendant’s inability to pay. The court conducted an inquiry into his financial circumstances, then imposed the $5,000 fine but credited $100 for jail time and suspended the remaining $4,900, contingent on the defendant’s compliance with probation. The court’s judgment reflected an order for the defendant to pay $0 of the fine.On appeal, the Supreme Court of the State of Montana considered whether the District Court legally imposed the mandatory minimum fine by suspending the portion the defendant could not pay. The Supreme Court overruled its prior holding in State v. Gibbons, which had found such mandatory minimum fines facially unconstitutional. The Court held that sentencing courts must impose the statutory minimum fine but are required, under the ability-to-pay statute, to suspend any portion the defendant is unable to pay. The Court concluded that, when the fine is imposed and suspended consistent with the defendant’s ability to pay, the statutory scheme is constitutional, and the sentence is legal. The Supreme Court of Montana affirmed the District Court’s judgment. View "State v. Cole" on Justia Law

The case concerns a defendant who was arrested on March 18, 2022, after leading police on a high-speed chase in a stolen vehicle while intoxicated. He was charged with several felonies, including felony driving under the influence, criminal endangerment, and theft. At the time of the incident, he was already subject to release conditions in other pending cases. Following his arrest, he was unable to post a substantial bond and was detained until he became a Department of Corrections inmate in November 2022 for an unrelated case. Over the following months, the scheduling of his trial was affected by continuances, plea negotiations, overlapping trial dates with his other pending cases, and court docket priorities.The Twenty-First Judicial District Court denied the defendant’s motion to dismiss for lack of a speedy trial after approximately 476 days elapsed between his arrest and his no-contest plea. The District Court attributed a significant portion of the delay to institutional reasons but also found that the defendant was responsible for numerous delays, including his requests for continuances, his actions during plea negotiations, and his acquiescence in having multiple cases scheduled for trial on the same dates. The District Court concluded that the defendant’s right to a speedy trial had not been violated.On appeal, the Supreme Court of the State of Montana reviewed the District Court’s decision de novo, applying the four-factor test set out in State v. Ariegwe. The Supreme Court held that although the delay was lengthy and primarily institutional, the defendant was responsible for significant portions of it, and his conduct did not display a genuine desire for a speedy trial. The Court further found that the defendant suffered no actual prejudice from the delay. The Supreme Court affirmed the District Court’s denial of the motion to dismiss for lack of a speedy trial. View "State v. Larson" on Justia Law

A vehicle reported stolen was located by police, who discovered Alejandro Flores-Reyes had been driving it and was in possession of its keys. Flores-Reyes stated he had purchased the car and that the items inside belonged to him. Police contacted the registered owner, who consented to a search of the vehicle. The officers, without Flores-Reyes’ consent, conducted a search, manipulated a concealed panel, and found a closed zippered pouch in a hidden compartment. Upon opening the pouch, they found pills suspected to contain fentanyl. The officers then obtained warrants based on this discovery and, during subsequent searches, seized additional narcotics from the vehicle and from Flores-Reyes’ motel room.After initial charges were filed in the District Court of the Fourth Judicial District, Missoula County, the case was dismissed to allow for federal prosecution, but was later reinstated at the State’s request when the federal case was abandoned. Flores-Reyes moved to suppress the evidence, arguing that the search violated his constitutional rights and that the subsequent warrants were tainted by the prior unlawful search. The District Court denied the motion, ruling that Flores-Reyes had no reasonable expectation of privacy in the vehicle as he lacked a legitimate possessory interest, and convicted him of three counts of criminal possession with intent to distribute.On appeal, the Supreme Court of the State of Montana found that the warrantless search of the closed pouch in the concealed compartment exceeded the scope of the owner’s consent because there was no mutual use or joint access to the pouch. The court held that the search violated both the Montana and United States Constitutions. As such, the court reversed the District Court’s order, vacated Flores-Reyes’ convictions, and remanded for suppression of all evidence obtained from the unlawful search and its fruits. View "State v. Flores-Reyes" on Justia Law

Andrew Emmings was subject to a permanent order of protection after repeated contact with a protected party. He was later charged with multiple violations of this order and pled guilty to several counts. While his case was pending, his release was revoked twice for new offenses, and he left Montana without completing required procedures. Emmings subsequently harassed other individuals, including a journalist and a lender, through threatening communications. He was sentenced to a net twelve-year term with ten years suspended, subject to various probation conditions, including restrictions on social media use.After serving his custodial sentence, Emmings was released on probation and later granted conditional discharge from supervision, with the court clarifying the discharge was subject to possible reimposition. Emmings moved to California, and after sending further threats, his conditional discharge was revoked, placing him back on probation. He did not appeal this order. Later, after failing to comply with supervision and communicate with his probation officer, the State petitioned to revoke his suspended sentence. A different district judge dismissed the petition, reasoning that Emmings’ move to California terminated his sentence and that the previous judge’s probation conditions were illegal and amounted to banishment from Montana.The Supreme Court of the State of Montana reviewed the case. It held that Judge Halligan’s order reimposing probation became the law of the case when it was not appealed, and Judge Larson abused his discretion in striking it. The court also held that moving out of state under conditional discharge does not terminate the sentence; the sentence remains subject to revocation, and the statutory procedures for termination were not followed. The court further found that Emmings was not banished from Montana and had not shown that probation conditions were impossible to comply with. The Supreme Court reversed the District Court’s order and reinstated the prior revocation, remanding for further proceedings. View "State v. Emmings" on Justia Law

The case concerns a defendant who entered a no contest plea to felony corporal injury to a spouse or cohabitant and a violation of a court order. As part of a negotiated plea agreement, the trial court offered probation, contingent on the defendant’s appearance at a future sentencing hearing. The plea agreement also included a “Cruz waiver,” which permitted the court to impose a four-year prison sentence if the defendant failed to appear for sentencing. The defendant did not attend the sentencing hearing because he was incarcerated in another county’s jail at that time.After the missed sentencing, the Superior Court of San Luis Obispo County held a hearing to determine whether the defendant had willfully violated the terms of the Cruz waiver by not appearing. The prosecution did not present any witnesses and relied solely on a CLETS report and uncertified court documents from Fresno County to support its claim that the defendant had committed a new offense and willfully failed to appear. The defense objected to the admissibility and sufficiency of this evidence. Despite these objections, the superior court found a violation, determined the failure to appear was willful, and imposed the four-year prison sentence.On appeal, the California Court of Appeal, Second Appellate District, Division Six, reviewed the case. The appellate court held that a defendant who is confined in jail in another county cannot willfully fail to appear in a different county’s court as ordered, since physical custody makes appearance impossible. Further, the court found that the prosecution did not present sufficient admissible evidence to establish willfulness, as the documents used were inadmissible and no witnesses were produced. The appellate court reversed the judgment and remanded the matter for further proceedings consistent with its opinion. View "People v. Jones" on Justia Law

The case involves a defendant who owned a cell phone store near Chicago and purchased stolen phones from robbery crews based in Grand Rapids, Michigan. These crews conducted armed robberies at retail cell phone stores, sometimes injuring employees and stealing both store and personal property. The defendant was not physically present at the robberies but played an active role by encouraging, directing, and facilitating the thefts, including providing instructions on what to steal and how to avoid law enforcement. He would travel to Michigan to acquire the stolen merchandise, then resell it domestically and internationally, using his technical skills to circumvent security measures on the devices.Following investigation, law enforcement linked the defendant to a series of robberies and recovered evidence from his electronic accounts. A grand jury in the United States District Court for the Western District of Michigan indicted him on conspiracy and interstate transportation of stolen goods. A jury convicted him on all counts. At sentencing, the district court applied multiple enhancements based on the conduct of his coconspirators and for use of sophisticated means, resulting in a sentence of 109 months' imprisonment. The defendant appealed, arguing that the sentencing enhancements were improperly applied to his case.The United States Court of Appeals for the Sixth Circuit reviewed whether the district court properly attributed the coconspirators’ conduct to the defendant and whether the sophisticated-means enhancement was appropriate. The appellate court found that the district court did not err in its determination that the robberies and associated conduct were within the scope of the jointly undertaken criminal activity, and that the defendant’s actions met the requirements for the sophisticated-means enhancement. The Sixth Circuit affirmed the district court’s judgment and sentence. View "United States v. Yousef" on Justia Law

Two physicians who operated a pain management clinic and laboratory were indicted on multiple federal charges, including conspiracy to unlawfully distribute controlled substances, health care fraud, and making false statements relating to health care matters. In exchange for the government dropping the majority of charges, both defendants pled guilty to a single count of making false statements about health care matters. The plea agreements included stipulations that they submitted nearly 3,000 claims to government health benefit programs for unnecessary drug screens, receiving over $166,000 in payments, and contained waivers of their right to appeal the conviction or sentence unless the sentence exceeded the statutory maximum.The United States District Court for the Southern District of Ohio sentenced each defendant to five years of probation, ordered restitution of the full amount defrauded to be paid jointly and severally, and imposed a fine of $125,000 on each. At sentencing, the defendants objected to the fines as procedurally improper, unsupported by the record, and unconstitutional under the Eighth Amendment's Excessive Fines Clause. The district court rejected these arguments.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether the appellate waivers in the plea agreements barred the defendants’ challenges. The court held that the waivers precluded their arguments regarding procedural and substantive unreasonableness of the fines. Regarding the Eighth Amendment claim, the court concluded that, even if not barred, the argument failed because the fines were not grossly disproportional to the stipulated offense conduct, which included the full fraudulent scheme and resulting harm. The court found the fines were well below the statutory maximum and appropriate given the seriousness and scope of the offense. Accordingly, the Sixth Circuit affirmed the district court’s imposition of the fines. View "United States v. Mukhdomi" on Justia Law

Two individuals, Nazaski Carrasco-Smith and Devin Delacruz, were shot while sitting in a vehicle in Providence, Rhode Island, on December 4, 2020. Carrasco-Smith survived; Delacruz did not. The investigation led police to a rented Nissan Altima and uncovered connections between the defendant, his girlfriend, and others through surveillance footage, GPS tracking, and extensive cell phone data analysis. Police also discovered a GPS tracker on Carrasco-Smith’s vehicle and recovered incriminating text messages between the defendant and his girlfriend, some of which contained accusations related to the murder.After a grand jury indictment, the case proceeded to trial in the Providence County Superior Court. The state presented forensic and digital evidence as well as expert testimony on local gang rivalries, suggesting a motive. During the trial, the prosecution introduced text messages from the defendant’s girlfriend accusing him of involvement in the murder. The defendant moved to exclude these messages, arguing they were hearsay and unfairly prejudicial. The trial justice denied the motion, admitted the messages, and issued cautionary instructions to the jury. The jury convicted the defendant on all counts, including first-degree murder and multiple firearm offenses. The defendant moved for a new trial, which was denied, and was sentenced to consecutive life terms and additional concurrent sentences.The Supreme Court of Rhode Island reviewed the case. It held that the trial justice abused her discretion by admitting the girlfriend’s accusatory text messages, finding that their probative value was substantially outweighed by their prejudicial effect under Rule 403 of the Rhode Island Rules of Evidence. The court determined that the cautionary instructions given did not cure the prejudice and that the error was not harmless in light of the prosecution’s emphasis on the messages. The court vacated the conviction and remanded for a new trial. View "State v. Chandler" on Justia Law