Justia Criminal Law Opinion Summaries

David Stanley was convicted in the Montana Eighteenth Judicial District Court, Gallatin County, for felony criminal possession of methamphetamine. Stanley appealed, arguing that the District Court erred in denying his motion to suppress drug evidence found during a post-arrest jail intake search. The key issue was whether the police had the requisite particularized suspicion to justify the investigative stop that led to Stanley's arrest and the subsequent discovery of the drugs.In the lower court, the District Court found that the police lacked particularized suspicion to justify the stop. However, it ruled that the "attenuation doctrine" exception to the exclusionary rule applied, meaning the drug evidence did not need to be suppressed despite the initial unlawful stop. Stanley then pled guilty under a plea agreement that reserved his right to appeal the suppression ruling.The Montana Supreme Court reviewed the case and held that the police had a reasonable particularized suspicion to stop Stanley. The court noted that the police received an anonymous tip about a fugitive, Daniel Sobrepena, who was reportedly wearing a distinctive red curly wig to avoid arrest. When Officer Ahmann saw Stanley wearing a similar wig in the area described, it was reasonable to suspect he might be Sobrepena or have information about him. The court found that the initial stop and subsequent questioning were justified and conducted within a reasonable scope and duration.The Montana Supreme Court concluded that the District Court reached the correct result in denying the motion to suppress, albeit for different reasons. The court affirmed Stanley's conviction, holding that the investigative stop was lawful and the resulting drug evidence was admissible. View "State v. Stanley" on Justia Law

Mica Martinez was convicted by an Oklahoma jury of two counts of first-degree murder and sentenced to death. Martinez sought federal habeas relief, arguing that his appellate counsel was ineffective for not raising a claim about his trial counsel’s inadequate investigation and presentation of testimony from his grandfather, mother, and uncle. He also claimed that his sentencing was fundamentally unfair due to witness testimony about his use of a racial slur and argued for reversible cumulative error.The Oklahoma Court of Criminal Appeals (OCCA) affirmed Martinez’s conviction and sentence, finding sufficient evidence of malice aforethought and holding that trial counsel did not perform deficiently. The OCCA also rejected Martinez’s claim that the introduction of a racial slur during sentencing denied him a fair proceeding, concluding that any error was cured by the trial court’s instruction to the jury to disregard the comment. The OCCA denied Martinez’s applications for postconviction relief, including his claim that appellate counsel was ineffective for not raising the issue of trial counsel’s investigation.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the denial of habeas relief. The court held that the OCCA did not unreasonably apply clearly established federal law or rely on an unreasonable factual finding in rejecting Martinez’s ineffective assistance of counsel claim. The court also found that Martinez failed to point to any clearly established federal law regarding the introduction of inflammatory evidence, and the OCCA did not base its decision on an unreasonable factual finding. Consequently, the court affirmed the denial of relief on the cumulative error claim as well. View "Martinez v. Quick" on Justia Law

In the early hours of November 13, 2021, DeAnna Suazo was found dead outside her home on the Taos Pueblo, New Mexico, under her running vehicle, showing signs of being run over. Her boyfriend, Santiago Martinez, after a failed polygraph test, admitted to pushing Suazo to the ground and running her over. Martinez was indicted for second-degree murder in Indian Country. Several pretrial motions were adjudicated, leading to three separate appeals.The United States District Court for the District of New Mexico granted Martinez's motion to suppress his post-polygraph statements to the FBI, ruling that he should have been re-Mirandized before the post-polygraph interview. The court also ruled inadmissible certain text messages between Suazo and Martinez, which the Government argued were not hearsay but showed their effect on Martinez. Additionally, the court excluded witness testimony of a prior incident where Martinez allegedly assaulted Suazo, ruling it inadmissible under Rule 404(b).The United States Court of Appeals for the Tenth Circuit reviewed the case. The court reversed the district court's suppression of Martinez's post-polygraph statements, holding that the initial Miranda waiver was valid and did not require re-advisement before the post-polygraph interview. The court also reversed the exclusion of the text messages, agreeing with the Government that they were not offered for the truth of the matter asserted but to show their effect on Martinez. Lastly, the court reversed and remanded the exclusion of the prior assault testimony for reconsideration, given the changed evidentiary landscape with the admissibility of Martinez's statements. The case was remanded for further proceedings consistent with the appellate court's opinion. View "United States v. Martinez" on Justia Law

In March 2011, Prentice Robinson was indicted on multiple felony charges, including attempted murder, for crimes committed between January and February 2011. Robinson pleaded no contest to several charges, including attempted murder, and admitted to using a firearm during the crime. He was sentenced to 22 years in prison. In January 2022, Robinson filed a petition for resentencing, which was denied by the trial court. Robinson appealed, arguing that the trial court erred by considering grand jury testimony, which he claimed was inadmissible hearsay.The Superior Court of San Joaquin County initially handled the case, where Robinson pleaded no contest and was sentenced. In 2022, Robinson sought resentencing, but the trial court denied his petition after considering grand jury transcripts. Robinson contended that the grand jury testimony should not have been considered, as it constituted inadmissible hearsay and violated his Sixth Amendment rights.The Court of Appeal of the State of California, Third Appellate District, reviewed the case. The court held that the grand jury testimony was admissible under section 1172.6, subdivision (d)(3), which allows for the consideration of evidence previously admitted at any prior hearing or trial if it remains admissible under current law. The court found that the grand jury proceedings were analogous to preliminary hearings and thus fell within the scope of "any prior hearing." The court also determined that Robinson's Sixth Amendment rights were not violated, as the section 1172.6 hearing is a postconviction collateral proceeding, not a new criminal prosecution, and thus does not afford the same constitutional protections.The Court of Appeal affirmed the trial court's decision, concluding that the grand jury testimony was properly considered and that Robinson's due process rights were not violated. View "P. v. Robinson" on Justia Law

Robert Lee Baker, III, was charged with second-degree intentional murder after he shot and killed Maurice Anderson. The incident occurred after Anderson and an accomplice robbed Baker and his girlfriend at gunpoint while they were in a car. As the robbers were leaving with Baker's property, Baker exited the car with a firearm and demanded the return of his belongings. Anderson raised his gun in response, and Baker shot him multiple times, resulting in Anderson's death.At trial, Baker claimed self-defense and defense of others, but the district court refused to instruct the jury on these defenses. The court concluded that Baker was not entitled to the instructions because he failed to establish that he was not the initial aggressor and that he did not have a reasonable means to retreat. The jury found Baker guilty of second-degree intentional murder, and he was sentenced to 438 months in prison. The court of appeals affirmed the conviction, but on different grounds, concluding that Baker's use of deadly force was unreasonable as a matter of law.The Minnesota Supreme Court reviewed the case to determine whether the district court abused its discretion by refusing to instruct the jury on self-defense and defense of others. The court held that the proper standard for determining whether a defendant is entitled to a jury instruction on self-defense or defense of others is whether the defendant produced reasonable evidence to support their claim. The court concluded that Baker presented sufficient evidence to support his claims of self-defense and defense of others, and that the district court's failure to give these instructions was not harmless. Therefore, the Minnesota Supreme Court reversed the decision of the court of appeals and remanded the case for a new trial. View "State of Minnesota vs. Baker" on Justia Law

Almanzo Cotton was found guilty by a jury of second-degree intentional murder and second-degree unintentional murder for beating his girlfriend, Kim Laen Theng, to death. The district court sentenced Cotton to 306 months imprisonment and ordered him to pay $2,362 in restitution to the Minnesota Crime Victims Reparations Board (the Board) to cover the cremation expenses paid by Theng’s daughter, S.T. S.T. had paid for the cremation using her personal credit card and later received funds from a GoFundMe campaign. She also submitted a claim to the Board, which awarded her the full amount of $2,362.Cotton challenged the restitution order, arguing that the GoFundMe proceeds should be considered a collateral source that offset the economic loss. The district court, however, concluded that the GoFundMe funds did not constitute recoupment of the cremation expenses from a collateral source and affirmed the restitution order. The court of appeals upheld the district court’s decision but remanded for the inclusion of a payment schedule.The Minnesota Supreme Court reviewed the case and held that the district court may not consider collateral sources when awarding restitution to the Board under Minn. Stat. § 611A.045, subd. 1(a). The court concluded that the exclusive factors for determining restitution are the amount of economic loss sustained by the victim and the income, resources, and obligations of the defendant. The collateral-source provision of the Minnesota Crime Victims Reparations Act does not apply in this context. The Supreme Court affirmed the decision of the court of appeals. View "State of Minnesota vs. Cotton" on Justia Law

Dontae White was convicted of second-degree intentional murder for the shooting death of Kevin Beasley. Beasley's mother, H.T., requested restitution for funeral expenses totaling $15,778.68. White argued that the life-insurance proceeds H.T. received should be subtracted from the restitution amount. The district court disagreed and ordered White to pay the full amount requested, reasoning that life insurance is intended to provide financial security and not just cover funeral expenses.The district court's decision was appealed, and the Minnesota Court of Appeals affirmed the restitution order. The court of appeals found that life insurance proceeds should not be considered when determining the amount of economic loss sustained by a family member of a deceased person for restitution purposes. The court distinguished life insurance from other types of insurance, noting that life insurance provides financial assistance beyond specific expenses like funeral costs.The Minnesota Supreme Court reviewed the case to determine whether life-insurance proceeds should be considered in calculating economic loss for restitution under Minn. Stat. § 611A.045, subd. 1(a)(1). The court held that life-insurance proceeds paid to a family member of the deceased should not be considered in determining the amount of economic loss sustained by the family member as a result of the murder. The court reasoned that life insurance is an investment contract intended to provide financial security, not merely to cover specific expenses. Therefore, the court affirmed the decision of the court of appeals, upholding the full restitution order. View "State of Minnesota vs. White" on Justia Law

Nathaniel Taylor was stopped by a police officer for speeding on an interstate in Knoxville, Tennessee. During the stop, the officer requested a K-9 unit based on Taylor’s suspicious activities, including his movements in the car, his criminal history, and the presence of multiple air fresheners. The K-9 unit indicated the presence of drugs, leading to a search of Taylor’s vehicle, which uncovered a firearm. As a felon, Taylor was prohibited from possessing a firearm. Taylor was subsequently indicted for being a felon in possession of a firearm and moved to suppress the evidence, arguing that the officer lacked reasonable suspicion to detain him beyond the time necessary to issue a traffic citation.The United States District Court for the Eastern District of Tennessee denied Taylor’s motion to suppress. Taylor then conditionally pleaded guilty, reserving his right to appeal the district court’s ruling on the motion to suppress.The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that the officer did not have reasonable suspicion to prolong the traffic stop. The court found that the factors cited by the officer, including Taylor’s travel plans, criminal history, air fresheners, and movements, did not collectively amount to reasonable suspicion. The court held that the officer’s extension of the stop to conduct a dog sniff was not justified. Consequently, the Sixth Circuit reversed the district court’s denial of Taylor’s motion to suppress and remanded the case for further proceedings consistent with its opinion. View "United States v. Taylor" on Justia Law

Charles Porter, a Yosemite National Park employee, was charged with various sexual assault offenses after attempting to anally rape T.D., another male park employee, in April 2020. T.D. testified that Porter, heavily intoxicated, forced himself on T.D. in his cabin. Neighbors corroborated T.D.'s account. Porter claimed T.D. was the aggressor. The district court allowed testimony from Porter’s ex-girlfriend, A.H., under Federal Rule of Evidence 413, which permits evidence of prior sexual assaults. A.H. testified that Porter had previously engaged in nonconsensual sex with her.The United States District Court for the Eastern District of California admitted A.H.'s testimony after evaluating its probative value against potential prejudice under Rule 403. The jury found Porter guilty on all counts, and he was sentenced to 148 months in prison. Porter appealed, arguing that Rule 413 violates the Fifth Amendment’s Due Process Clause by allowing propensity evidence.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that Rule 413 is constitutional, referencing its decision in United States v. Lemay, which upheld the analogous Rule 414 for child molestation cases. The court emphasized that Rule 413, like Rule 414, is subject to Rule 403, which allows district courts to exclude unduly prejudicial evidence. The court found that the district court had properly applied Rule 403 and provided appropriate limiting instructions to the jury regarding A.H.'s testimony.The Ninth Circuit affirmed Porter’s conviction, concluding that the admission of A.H.'s testimony under Rule 413 did not violate due process. View "U.S. v. Porter" on Justia Law

Eric Virrueta pleaded guilty to possession with intent to distribute a controlled substance but reserved the right to appeal the denial of his motion to suppress evidence found in a warrantless search of his vehicle after a traffic stop. The evidence included methamphetamine and marijuana. Virrueta challenged the validity of the traffic stop, the extension of the stop, and the search of the vehicle, arguing that the search was not supported by probable cause and that the consent given by his parole agent was invalid.The United States District Court for the District of South Dakota denied Virrueta's motion to suppress. The court found that the initial traffic stop was valid based on reasonable suspicion and probable cause, as Corporal Fischer had identified Virrueta driving without a valid license. The court also concluded that the extension of the stop was justified by the strong odor of raw marijuana emanating from the vehicle, which provided probable cause for the search. Additionally, the court upheld the search based on the consent given by Virrueta's parole agent, who had been informed of multiple parole violations.The United States Court of Appeals for the Eighth Circuit reviewed the district court's factual findings for clear error and its legal conclusions de novo. The appellate court affirmed the district court's rulings, agreeing that the traffic stop was valid, the extension of the stop was justified by reasonable suspicion of additional criminal activity, and the search of the vehicle was supported by probable cause. The court also held that the parole agent's consent provided an independent basis for the search. The judgment of the district court was affirmed. View "United States v. Virrueta" on Justia Law