Justia Criminal Law Opinion Summaries

During a contentious divorce and custody dispute, Amanda Hovanec, who had returned to Ohio from South Africa with her children, conspired with Anthony Theodorou, her romantic partner, to kill her husband, T.H. After failed attempts to hire hitmen in South Africa, Theodorou, at Hovanec’s direction, obtained and shipped etorphine, a dangerous animal tranquilizer, to the United States. Hovanec ultimately used the drug to fatally inject T.H. at her mother Anita Green’s home. Green assisted after the murder by helping to select a burial site, driving the others to dig a grave, and later transporting them and the body for burial. The group also undertook efforts to conceal the crime, including disposing of T.H.’s belongings and misleading authorities. All three were arrested after an investigation revealed dashcam footage of the crime.In the United States District Court for the Northern District of Ohio, Hovanec pleaded guilty to multiple controlled-substance offenses resulting in death, and Green pleaded guilty to being an accessory after the fact. Hovanec received a 480-month sentence; Green received 121 months and was ordered to pay restitution for psychological care for T.H.’s and Hovanec’s children. Both defendants appealed their sentences and, in Green’s case, the restitution order.The United States Court of Appeals for the Sixth Circuit affirmed the sentences for both Hovanec and Green. The appellate court upheld the denial of a sentencing reduction for Green based on her lack of candor regarding knowledge of the murder plan. The court also affirmed the sentencing enhancements for Hovanec’s leadership role and obstruction of justice. However, the court reversed the restitution order against Green, holding that under federal law, restitution for psychological care requires evidence of bodily injury, defined as physical harm or physical manifestations of psychological harm, and remanded for further factual findings on this issue. View "United States v. Green" on Justia Law

After a fatal shooting in Topeka, Wesley Rayton was arrested and charged with several crimes, including first-degree felony murder, after admitting to firing a gun during an altercation that resulted in Michael Comp’s death. Surveillance footage and witness statements corroborated Rayton’s actions. As part of a plea agreement, Rayton pled guilty to first-degree felony murder in exchange for dismissal of all other charges in this case and in a separate pending case. He was thoroughly advised by the court and his attorney about the sentencing consequences, including a mandatory life sentence with parole eligibility after 25 years.Following his plea but before sentencing, Rayton wrote to the Shawnee District Court seeking to withdraw his guilty plea. He alleged he did not fully understand the plea, felt pressured, was under the influence of medication, and had only 24 hours to consider the agreement. The district court held an evidentiary hearing, heard testimony from Rayton and his counsel, and reviewed the plea proceedings. The court found that Rayton had ample time to consider the plea, was not misled or coerced, received competent representation, and entered the plea understandingly and voluntarily. The motion to withdraw the plea was denied.The Supreme Court of the State of Kansas reviewed Rayton’s direct appeal of the denial. Applying the abuse of discretion standard, the court considered the factors established in State v. Edgar: counsel’s competence, absence of coercion or misleading information, and whether the plea was understandingly made. The court held that the district court did not abuse its discretion in denying Rayton’s motion, as substantial evidence supported the findings that Rayton was competently advised and understood the plea’s consequences. The Supreme Court affirmed the district court’s decision. View "State v. Rayton " on Justia Law

In this case, the defendant was convicted by a jury of first-degree felony murder, aggravated kidnapping, criminal use of weapons, and driving a vehicle without the assigned tag. The victim was found shot multiple times, with his hands bound by rope. The evidence against the defendant was largely circumstantial, relying on testimony from various witnesses, many of whom had credibility issues due to their involvement with drugs and deals with law enforcement. No one testified to witnessing the defendant inflict harm on the victim, and the murder weapon was never recovered. However, forensic evidence and the sequence of events, including video surveillance and statements from associates, connected the defendant to the kidnapping and eventual death of the victim.The case was tried in the Sedgwick District Court, where the defendant did not testify or present any witnesses. During trial, the defense requested jury instructions on lesser included offenses—simple kidnapping and criminal restraint—which the district court denied. The jury found the defendant guilty on all charges and he was sentenced accordingly. On appeal, the defendant argued that prosecutorial error had occurred during closing arguments and that the failure to instruct the jury on lesser included offenses was reversible error.The Supreme Court of the State of Kansas reviewed the appeal. The court held that the prosecutor’s challenged remark during rebuttal argument was not error when viewed in context, as it was a permissible response to the defense’s arguments and did not comment on the defendant’s failure to testify or shift the burden of proof. Regarding the lesser included offense instructions, the court found that although the district court erred in failing to provide the requested instructions, the error was harmless given the strength of the evidence supporting the convictions. The Supreme Court affirmed the defendant’s convictions and sentence. View "State v. Arroyo " on Justia Law

The case involves a man who was convicted of first-degree murder in Broward County, Florida, after a fatal shooting during a domestic dispute with his girlfriend. The key evidence during trial was a confession obtained by police after the man initially invoked his right to counsel but later agreed to speak with detectives. This confession was not admitted as direct evidence at his second trial but was used extensively to impeach his testimony when he took the stand in his own defense. The prosecution also presented substantial physical and eyewitness evidence, including the testimony of two individuals present at the scene and expert forensic analysis.After his conviction, the defendant challenged the use of his statement in postconviction proceedings. The Florida trial court denied his motion for a new trial, and the Florida Fourth District Court of Appeal affirmed. The defendant later argued in a state postconviction proceeding that his trial counsel was ineffective for failing to challenge the statement on the grounds that it was coerced, in violation of the Due Process Clause. The state postconviction court, adopting the State’s response, found that the defendant was not prejudiced by any alleged error of his counsel, as the other evidence against him was overwhelming. The Fourth DCA affirmed without opinion.The United States Court of Appeals for the Eleventh Circuit reviewed the denial of federal habeas corpus relief. The court held that the state court had adjudicated the prejudice prong of the ineffective assistance claim on the merits, entitling its decision to deference under the Antiterrorism and Effective Death Penalty Act. The Eleventh Circuit found that the state court’s determination—that the outcome would not have been different even if the statement had been excluded—was neither contrary to nor an unreasonable application of federal law. Accordingly, the denial of habeas relief was affirmed. View "Calder v. Secretary, Florida Department of Corrections" on Justia Law

The case centers on a defendant who, while driving a semi-truck with a trailer, failed to stop at a stop sign and caused a fatal collision. He was initially charged with felony vehicular manslaughter but was acquitted of that charge by a jury and convicted instead of misdemeanor vehicular manslaughter. After the conviction, the defendant was granted a new trial due to an error in the jury instructions. Prior to the retrial, the presiding magistrate judge informed the parties off the record that he would not impose jail time if the defendant was convicted of the misdemeanor, consistent with typical sentencing practices for such offenses.Upon conviction at the second trial, the magistrate judge nonetheless sentenced the defendant to jail. The defendant filed a motion to reduce the sentence, arguing that the sentence was excessive and inconsistent with the judge’s prior assurances. The magistrate court reduced the jail time by one day but denied further relief. On appeal, the district court found that the magistrate’s assurances had tainted the judicial process and vacated the sentence, remanding the case to a different magistrate for resentencing. The new magistrate sentenced the defendant to 90 days in jail. The defendant again appealed, arguing that the new magistrate was bound by the prior assurance of no jail time, but the district court affirmed the sentence.The Supreme Court of the State of Idaho reviewed the case and held that the new magistrate was not bound by the prior judge’s assurances regarding sentencing. The Court found that the law of the case doctrine did not require the resentencing judge to follow the prior judge’s off-the-record statement and that the district court properly affirmed the new sentence. The district court’s decision was affirmed. View "State v. Salazar-Cabrera" on Justia Law

The case concerns a defendant who pleaded no contest in 2009 to second degree murder, shooting at an occupied vehicle, and participating in a criminal street gang, following an amended indictment stemming from a 2006 shooting. The plea was supported by a stipulation that police reports and grand jury testimony provided a factual basis for the charges. The defendant was sentenced to a total of 25 years to life. After a direct appeal resulted in a minor modification to presentence custody credits, the conviction stood.Years later, the defendant filed a petition for resentencing under Penal Code section 1172.6. The Kern County Superior Court initially denied the petition at the prima facie stage, but the California Court of Appeal, Fifth Appellate District, reversed and remanded for further proceedings. Upon remand, the trial court conducted an evidentiary hearing. The People introduced, and the court admitted, transcripts from the grand jury proceedings, police reports, witness statements, and related law enforcement documents, over the defendant’s objections. The trial court denied the resentencing petition, finding the defendant was a major participant in the murder who acted with reckless indifference to human life, relying on the challenged evidence.On appeal, the California Court of Appeal, Fifth Appellate District, found that the trial court erred in admitting the grand jury transcript and police reports at the evidentiary hearing, as these did not fall within the exceptions for admissible evidence under section 1172.6(d)(3). The appellate court held that neither the stipulation to the factual basis for the plea nor any other exception permitted their admission. The court vacated the denial of the resentencing petition and remanded for a new evidentiary hearing, explicitly directing that only admissible evidence consistent with section 1172.6 may be considered. The holding does not bar the prosecution from presenting admissible evidence on remand. View "P. v. Dixon" on Justia Law

A man required to register as a sex offender in Iowa was charged with violating a statutory provision that requires notification to the county sheriff if a registered sex offender stays away from his principal residence for more than five days. The issue arose after local authorities were unable to find him at his registered address in Pilot Mound, and after his eviction from that residence, he registered a new address in Boone. The prosecution alleged that he failed to properly notify the sheriff of his change in location within the statutory timeframe, basing its case on the assertion that he failed to register his change of residence.The Iowa District Court for Boone County denied the defendant’s motions for acquittal and accepted the jury’s guilty verdict under Iowa Code section 692A.105, which concerns temporary lodging away from a principal residence. The court imposed a suspended sentence with probation. On appeal, the Iowa Court of Appeals affirmed the conviction, holding that the defendant’s eviction constituted a change requiring notification under section 692A.105, and that he failed to comply with the five-day reporting requirement.The Supreme Court of Iowa reviewed the sufficiency of the evidence and the proper interpretation of the statute. The court held that section 692A.105 applies only when a sex offender stays away from his principal residence for more than five days, not merely upon a change in residence. The State had not presented evidence that the defendant was away from his principal residence for more than five days to trigger the statutory requirement. Consequently, the Supreme Court vacated the decision of the court of appeals, reversed the district court’s judgment, and remanded for entry of a judgment of acquittal. View "State of Iowa v. Uranga" on Justia Law

After an evening involving alcohol, three men—Keith, his brother Dannie, and Bryant—traveled together in Dannie’s truck. The next morning, Bryant was found in the road with a fatal head injury. During the investigation, Dannie provided law enforcement with inconsistent stories but eventually stated that Keith struck Bryant on the head with a club-like object during an argument, after which Bryant did not recover. A search of Dannie’s truck revealed an object matching Dannie’s description. Other witnesses corroborated that the three men left together and that Bryant did not return. The medical examiner concluded that Bryant’s death was a homicide caused by blunt-force trauma.The Copiah County Circuit Court conducted a jury trial. The prosecution introduced autopsy photographs over defense objections, and Dannie testified, admitting his own inconsistent statements. The jury found Keith guilty of second-degree murder but deadlocked on sentencing, resulting in a statutorily mandated thirty-year sentence.On appeal to the Supreme Court of Mississippi, Keith challenged the admission of certain autopsy photographs, the sufficiency of the evidence (arguing that Dannie’s testimony was unreliable), and the propriety of the jury instructions on depraved-heart murder and culpable-negligence manslaughter. The Supreme Court of Mississippi held that the trial court did not abuse its discretion in admitting the photographs, as they supplemented the pathologist’s testimony and were probative given the disputed manner of death. The Court found that the jury was entitled to judge Dannie’s credibility and that the verdict was not against the overwhelming weight of the evidence. The Court also determined that the jury instructions, considered as a whole, properly explained the hierarchy and definitions of the offenses. Any possible error in the manslaughter instructions was deemed harmless, as the jury convicted Keith of murder. The Supreme Court of Mississippi affirmed Keith’s conviction and sentence. View "Goods v. State of Mississippi" on Justia Law

The defendant pleaded guilty to criminal confinement and interfering with reporting a crime, resulting in a five-year sentence: two years served through time already served and work release, followed by three years of probation. The plea agreement specified that violating any court-sponsored program, such as work release, would result in revocation and execution of the sentence. In 2023, the defendant failed to return to the work release facility, prompting his community corrections case manager to file a petition seeking revocation of his work release placement. The petition, however, did not mention probation or request revocation of the suspended portion of his sentence.After the defendant was later arrested and pleaded guilty to failure to return to lawful detention, the trial court addressed both the work release violation and, upon the State’s oral request, the defendant’s probation. Despite the defendant’s counsel objecting that revoking probation without a specific petition violated due process, the trial court revoked both his work release privileges and his probation, ordering the remainder of his sentence executed in the Department of Correction.On appeal, the Indiana Court of Appeals affirmed the trial court, holding that the court had statutory authority to revoke probation and that due process was satisfied through the plea agreement and the notice provided by the work release revocation petition. The defendant sought further review.The Indiana Supreme Court granted transfer, vacated the Court of Appeals opinion, and reversed the probation revocation. The Court held that due process requires that the State may only seek sanctions identified in the revocation petition or for which the defendant has actual notice. Because there was no petition or adequate notice seeking probation revocation, the trial court’s order revoking probation was improper. View "Ewing v. State" on Justia Law

A Texas-based company distributed files online that enabled the 3D printing of functional, untraceable firearms. After New Jersey’s Attorney General issued a cease-and-desist letter and the state legislature enacted a statute prohibiting the distribution of such files to unlicensed individuals, the company and an affiliated nonprofit restricted New Jersey residents from accessing these files. The plaintiffs challenged the actions, alleging violations of the First, Second, and Fourteenth Amendments.Initially, the plaintiffs filed suit in the Western District of Texas, which dismissed the case for lack of personal jurisdiction. Plaintiffs then filed a similar suit in the District of New Jersey, alleging the statute constituted criminal censorship. After complex procedural maneuvers—including appeals and transfers between Texas and New Jersey, and requests for retransfer—the litigation proceeded in the District of New Jersey, which consolidated the relevant cases.The United States Court of Appeals for the Third Circuit reviewed the District of New Jersey’s decision to dismiss the complaint with prejudice. The Third Circuit affirmed the lower court’s rulings. It held that the district court did not abuse its discretion in denying retransfer to Texas. The court further held that the plaintiffs lacked standing to bring a Second Amendment claim, as there were no allegations that any plaintiff or member was prevented from 3D-printing a firearm. The court also found the statute was not void for vagueness under the Due Process Clause, as it provided fair notice of prohibited conduct. Finally, the court held that plaintiffs failed to plead sufficient facts showing that the computer code at issue was expressive and entitled to First Amendment coverage, as the complaint did not detail the nature or expressive use of the files. The dismissal with prejudice was affirmed. View "Defense Distributed v. Attorney General New Jersey" on Justia Law