Justia Criminal Law Opinion Summaries

Law enforcement in New Orleans began investigating a suspected methamphetamine dealer in 2020, leading them to Marshall Grace through surveillance methods such as phone records and tracking devices. Officers stopped Grace’s vehicle after observing traffic violations, detected the smell of marijuana, and subsequently searched his vehicle, finding approximately 441 grams of methamphetamine. Grace was arrested and provided a written statement admitting ownership of the drugs and detailing his ongoing involvement in distributing methamphetamine to others, including regular transactions over a two-year period. Electronic evidence from his phones corroborated his admissions and established communication with other dealers.The United States District Court for the Eastern District of Louisiana presided over Grace’s trial. During jury selection, the government used peremptory strikes to exclude two of five black potential jurors, including one named Edward Davis. Grace challenged the exclusion of Davis under Batson v. Kentucky, arguing it was racially motivated. The district court questioned Davis and ultimately found the government’s reason—Davis having seven sons, one of whom had criminal justice involvement—to be race-neutral and denied Grace’s Batson challenge. The trial concluded with the jury finding Grace guilty on all counts, and the court imposed the statutory minimum sentence. Grace appealed, contesting both the sufficiency of the evidence for his conspiracy conviction and the denial of his Batson challenge.The United States Court of Appeals for the Fifth Circuit reviewed the case. It held there was sufficient evidence to support the conspiracy conviction, given Grace’s admissions, corroborating testimony, and the quantity of drugs involved. The appellate court also found no clear error in the district court’s denial of the Batson challenge, ruling that Grace failed to show purposeful discrimination by the prosecution. The Fifth Circuit affirmed the district court’s judgment in full. View "USA v. Grace" on Justia Law

A young adult defendant was charged with vandalism and vehicle theft in Santa Clara County. After the prosecution indicated the defendant met initial eligibility requirements for a young adult deferred entry of judgment program under Penal Code section 1000.7, the trial court referred the defendant to the county probation department for further assessment. The probation department determined the defendant was unsuitable for the program because he resided in Alameda County, which did not operate a corresponding program, and concluded that he could not benefit from Santa Clara County’s services due to his residency.The Superior Court of Santa Clara County accepted the probation department’s determination and continued the criminal cases, effectively denying deferred entry of judgment. The defense argued that section 1000.7 did not prohibit out-of-county residents from participating, that the trial court should have authority to make the final eligibility determination, and that if the statute granted exclusive authority to probation, it would violate the constitutional separation of powers. The trial court found the statute unambiguously vested eligibility determinations with the probation department.The California Court of Appeal, Sixth Appellate District, reviewed the case on a petition for writ of mandate, prohibition, or alternative relief. The court held that section 1000.7 gives the probation department—not the trial court—the authority to decide whether a defendant meets the statutory criteria for participation in the deferred entry of judgment program. The court also held that assigning this responsibility to the probation department does not violate the separation of powers doctrine. Finally, the court determined that the probation department did not abuse its discretion by denying the defendant entry into the program based on his out-of-county residence. The petition was denied. View "Armstrong v. Superior Ct." on Justia Law

The petitioner was charged in Marshall County, West Virginia, with multiple counts of sexual abuse involving two victims, one of whom was a child. Before trial, the circuit court allowed the child victim to testify via live, closed-circuit television, as permitted by state statute. However, the petitioner elected to leave the courtroom during the child’s testimony, after which he was convicted on all counts. Following his conviction, the petitioner sought habeas corpus relief, raising several claims including the constitutionality of the closed-circuit testimony procedure, the validity of his indictments, his absence from certain pretrial hearings, allegations of improper jury communications, and ineffective assistance of counsel.The Circuit Court of Marshall County initially denied habeas relief without a hearing, but the Supreme Court of Appeals of West Virginia remanded for an omnibus evidentiary hearing, particularly on ineffective assistance of counsel and sentencing concerns. On remand, the circuit court granted relief only on the petitioner’s ex post facto sentencing claim, ordering resentencing on certain counts, and denied all other claims, finding that the petitioner either waived them by not raising them on direct appeal or failed to demonstrate ineffective assistance of counsel.The Supreme Court of Appeals of West Virginia reviewed the case and affirmed the circuit court’s rulings. The court held that because the petitioner did not raise his constitutional and procedural claims on direct appeal and failed to rebut the presumption of waiver, those claims could only be considered within the framework of ineffective assistance of counsel. The court concluded the petitioner’s counsel was not deficient under the standards set by Strickland v. Washington and State v. Miller, and that none of the challenged actions or omissions prejudiced the outcome of the trial. The court also held that Crawford v. Washington did not overrule Maryland v. Craig, and the statutory closed-circuit testimony procedure remained constitutional. View "Arthur C. v. Frame" on Justia Law

A man with two prior felony convictions crashed his car late at night in 2023. When law enforcement arrived, he admitted to drinking. Officers found a vodka bottle and a loaded handgun with a magazine on the ground near the vehicle, as well as a second magazine in the car’s front seat. Both magazines matched the firearm, which had been reported stolen. The man’s criminal record included a violent robbery and a prior conviction for possession of a firearm by a felon, among other offenses. Based on these events, he was charged in the Middle District of North Carolina with being a felon in possession of a firearm and ammunition under 18 U.S.C. § 922(g)(1).In the United States District Court for the Middle District of North Carolina, the defendant moved to dismiss the indictment, claiming that § 922(g)(1) violated the Second Amendment. The district court rejected this argument. The defendant then pleaded guilty while reserving his right to appeal the constitutional issue. At sentencing, the Presentence Report determined that the offense involved a semiautomatic firearm capable of accepting a large capacity magazine, setting his base offense level accordingly. The defendant did not object to the report and confirmed his agreement in open court. The district court adopted the report and sentenced him to 66 months in prison.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed his constitutional and sentencing challenges. The court held that circuit precedent foreclosed both his facial and as-applied Second Amendment challenges to § 922(g)(1). The court also held there was no error in applying the “large capacity magazine” sentencing enhancement, and that the sentence was both procedurally and substantively reasonable. The Fourth Circuit affirmed the judgment of the district court. View "US v. Holman" on Justia Law

In 2005, John Lozano pleaded guilty to four federal felony charges, including conspiracy to distribute methamphetamine and firearm offenses. Due to prior felony convictions, including a Missouri marijuana conviction, Lozano was classified as a career offender under the federal sentencing guidelines, resulting in an enhanced sentence of 322 months. In 2022, Missouri adopted a constitutional amendment legalizing certain marijuana offenses and requiring the expungement of related nonviolent convictions. In 2023, Lozano’s prior marijuana conviction was vacated by a Missouri court under this amendment.After the expungement, Lozano filed a motion under 28 U.S.C. § 2255 in the United States District Court for the Western District of Missouri, seeking to vacate his federal sentence. He argued that the vacated marijuana conviction should not have counted toward his career offender status. The government moved to dismiss, contending that Lozano’s motion was “second or successive” because he had previously filed § 2255 motions in 2009 and 2016, and that the expungement did not affect his guidelines calculation because it was not based on legal error or innocence. The district court granted the motion to dismiss on both grounds.Reviewing the case, the United States Court of Appeals for the Eighth Circuit held that Lozano’s motion was not “second or successive” under § 2255 because his claim was newly ripe, arising only after his conviction was expunged in 2023. Nonetheless, the court concluded that the Missouri expungement order did not warrant resentencing. Under the federal guidelines, only convictions vacated due to innocence or legal error are excluded from career offender calculations; Lozano’s expungement was not based on such grounds. Accordingly, the Eighth Circuit affirmed the dismissal of Lozano’s § 2255 motion. View "Lozano v. United States" on Justia Law

The case concerns a defendant who, during the early months of the COVID-19 pandemic, submitted multiple fraudulent applications for Paycheck Protection Program (PPP) and Economic Injury Disaster Loans (EIDL) using false information and forged documents. The defendant, with family members, obtained over $650,000 in loan proceeds by falsely representing the status and finances of various companies. The fraudulent scheme was uncovered when a lender alerted authorities to suspicious details in one application. Law enforcement executed a search warrant at the defendant’s home, conducted an interview, and discovered evidence of fraud. After initial plea negotiations failed, the defendant traveled to Colombia and did not return voluntarily, prompting an international effort that resulted in his apprehension and extradition to the United States.The United States District Court for the District of Minnesota presided over pretrial matters, including the defendant’s motions to suppress statements made during the home search, requests for new counsel, and pretrial detention issues. The court denied motions to suppress, finding the defendant was not in custody during the interview, and conducted extensive Faretta hearings to confirm the defendant’s voluntary waiver of counsel and decision to proceed pro se. The defendant’s requests for continuances and additional trial accommodations were denied, and the trial proceeded with standby counsel reappointed partway through. The jury convicted the defendant on all counts, and the court applied a sentencing enhancement for obstruction of justice based on the defendant’s actions in fleeing to Colombia.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings. The appellate court held that the defendant was not in custody during the initial interview, his waiver of counsel was knowing and voluntary, the denial of continuances and trial accommodations did not deprive him of a fair trial, and the obstruction-of-justice sentencing enhancement was properly applied. The district court’s judgment was affirmed. View "United States v. Kaeding" on Justia Law

The defendant lived with his parents in Fargo, North Dakota. One evening, after his mother found him inhaling compressed air, an argument ensued. During the dispute, the defendant left the room and returned with a gun, firing it into the ceiling. He refused to relinquish the firearm, pointed it at himself, and then at his father. Law enforcement, including SWAT negotiators, were called and, after several hours, the defendant surrendered. A search of the home revealed several firearms, including a Polymer80 pistol with an attached Glock switch (a machinegun conversion device), a silencer, and various firearm parts and ammunition in the basement, which was the defendant's bedroom.The United States District Court for the District of North Dakota reviewed the case. The defendant was charged with possession of a machinegun and possession of a firearm silencer. He moved to dismiss the indictment, arguing it failed to state the essential elements of the offenses, specifically the knowledge requirement. The district court denied the motion. At trial, a jury convicted the defendant on both counts, finding sufficient evidence of his knowledge regarding the characteristics of the firearms.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether the indictment was legally sufficient and whether the evidence supported the convictions. The court held that the indictment sufficiently alleged the required knowledge element by tracking the statutory language and including phrases such as “knowingly possess.” The court also found that circumstantial evidence and the defendant’s statements supported the jury’s finding that he knew the pistol was capable of automatic fire and that he knowingly possessed the silencer. The Eighth Circuit affirmed the district court’s judgment, upholding both convictions. View "United States v. Opdahl" on Justia Law

Peace officers developed probable cause to believe that controlled substances were being distributed from a house in Des Moines. After conducting multiple controlled buys, officers obtained a premises search warrant for the house. On the morning the warrant was executed, Andrew Porter arrived at the house carrying a backpack. About forty minutes later, officers entered and found Porter in the living room; the backpack was in a corner, not within his immediate reach. During the search, Porter repeatedly denied ownership of or knowledge about the backpack, both when questioned outside and inside the house. Officers searched the backpack and found methamphetamine, marijuana, and drug paraphernalia. Porter was arrested and charged with several drug offenses.Porter filed a motion to suppress the evidence obtained from his backpack, arguing that the search violated his constitutional rights under the Fourth Amendment and the Iowa Constitution. The Iowa District Court for Polk County denied the motion after reviewing evidence, including bodycam footage. Porter sought and was granted discretionary review to challenge this ruling.The Supreme Court of Iowa addressed whether the federal or state constitutional right to be free from unreasonable searches prohibits officers executing a search warrant from searching a container on the premises, such as a backpack, capable of holding evidence described in the warrant, when the container is not in a person’s physical possession. The court held that the search of the backpack was within the scope of the premises warrant because it was not in Porter’s physical possession at the time of the search and was a plausible repository for the evidence sought. The court further found that Porter’s repeated denials of any connection to the backpack constituted abandonment, negating any privacy interest. The court affirmed the district court’s denial of the motion to suppress. View "State v. Porter" on Justia Law

The case concerns the conviction of an individual for first degree murder following the death of his former partner. On June 19, 2023, the defendant and the victim, who shared two sons, spent the day at a YMCA with their children. An argument occurred between the defendant and the victim, leading to further tension. That evening, the victim returned home with her children, and the next morning, the victim’s daughters found her unresponsive in her bed, with evidence of a fatal gunshot wound. The investigation revealed no murder weapon or direct physical evidence linking the defendant to the crime, but circumstantial evidence included text messages suggesting ongoing conflict, the defendant’s suspicious movements according to location data, and a statement reportedly made by the defendant to his brother confessing to the shooting.The Lowndes County Circuit Court held a jury trial where the State presented primarily circumstantial evidence, including testimony about the defendant’s ability to enter locked doors and his proximity to the victim’s home at critical times. After the State rested, the defendant’s motion for a directed verdict was denied. The jury found him guilty of first degree murder, and he was sentenced to life imprisonment. Post-trial motions for a judgment notwithstanding the verdict or a new trial were also denied.On appeal, the Supreme Court of Mississippi reviewed whether the evidence was sufficient to prove deliberate design and whether the verdict was against the overwhelming weight of the evidence. The Supreme Court held that the circumstantial evidence, viewed in the light most favorable to the State, was sufficient for a rational juror to find guilt beyond a reasonable doubt. The Court further concluded that the verdict did not represent an unconscionable injustice. The conviction and sentence were affirmed. View "House v. State" on Justia Law

A man was pursued by police after driving a car rented by his mother in a reckless manner to avoid a checkpoint, ultimately crashing in a residential area and fleeing the scene. His passenger, apprehended and interviewed the same night, identified him as the driver. The car contained cocaine, marijuana, and prescription bottles in his name. The defendant was later arrested after hiding from law enforcement in his home. At trial, the State presented testimony from law enforcement and the passenger identifying him as the driver. The defense called alibi witnesses who claimed he was at home during the incident, and the defendant himself denied involvement.The Circuit Court of Madison County found the evidence sufficient to convict him of cocaine possession and felony evasion. The court admitted his prior felony convictions for impeachment purposes after conducting an analysis under Mississippi Rule of Evidence 609(a)(1)(B) and the Peterson factors, and sentenced him as a nonviolent habitual offender and subsequent drug offender. The defendant appealed, arguing the evidence was insufficient, the prior convictions were improperly admitted, the flight instruction was erroneous, and the habitual offender sentence was incorrect. The Court of Appeals affirmed the sufficiency of the evidence but reversed the convictions, finding the trial court’s Rule 609(a)(1)(B) analysis inadequate and the issue not procedurally barred.On certiorari, the Supreme Court of Mississippi found the challenge to the admission of prior convictions was procedurally barred due to the lack of a specific objection at trial. The court further held that the trial judge properly applied the Rule 609(a)(1)(B) standard and the Peterson factors, and that the flight instruction and habitual offender sentence were not erroneous. The Supreme Court affirmed the Court of Appeals’ finding on sufficiency but reversed its decision to grant a new trial, reinstating and affirming the trial court’s judgment and sentences. View "Gardner v. State" on Justia Law