Justia Criminal Law Opinion Summaries

A criminal complaint was filed against an individual in July 2024, alleging multiple counts of lewd acts, forcible lewd acts, and continuous sexual abuse of four minors, all of whom are his grandchildren. The prosecution also alleged a multiple victim enhancement. At an initial arraignment, the magistrate court set bail and imposed protective orders. Later, the prosecution moved to have the defendant held without bail, citing the danger he posed to the community. At a Humphrey hearing, the prosecution presented testimony and evidence suggesting repeated sexual abuse over many years, including admissions by the defendant. The magistrate court found this evidence reliable and determined that nonfinancial conditions of release would not protect the public or victims, ordering the defendant held without bail.The defendant challenged the no-bail order in the Superior Court of Fresno County through a petition for writ of habeas corpus. He argued the magistrate court abused its discretion, particularly in considering the prosecution’s request for remand without bail absent a change in circumstances, and asserted there was insufficient evidence to support a finding of substantial likelihood of great bodily harm. The superior court issued an order to show cause on these specific issues but ultimately denied the petition after considering the parties’ responses.Upon further review, the California Court of Appeal, Fifth Appellate District, was directed by the California Supreme Court to address whether Penal Code section 292 constitutes an impermissible legislative extension of the constitutional terms “acts of violence” and “great bodily harm,” and whether, absent section 292, clear and convincing evidence supported denial of bail. The appellate court held that section 292 is a valid legislative implementation, not an invalid extension, of the bail exception in article I, section 12 of the California Constitution. The court further found that substantial evidence supported the finding that the defendant’s release would pose a substantial likelihood of great bodily harm, and denied the petition for writ of habeas corpus. View "In re Bergstrom" on Justia Law

Four women incarcerated at the Huron Valley Correctional Facility in Michigan suffered from persistent, painful rashes between 2016 and 2019. Despite repeated complaints, medical staff—contracted through Corizon Health—failed to diagnose scabies, instead providing ineffective treatments and attributing the condition to environmental factors like improper laundering. It was only after an outside dermatologist intervened that scabies was correctly identified, prompting prison-wide treatment efforts. However, these efforts were delayed and, in some cases, inadequate, resulting in prolonged suffering for the affected inmates.After their experiences, the four women filed suit in the United States District Court for the Eastern District of Michigan against multiple defendants, including high-level Michigan Department of Corrections officials and Wayne State University medical officers, alleging Eighth Amendment violations and state-law negligence. The district court found that the women’s complaint plausibly alleged “clearly established” Eighth Amendment violations by all defendants and denied the officials’ request for qualified immunity. The court also rejected a claim of state-law immunity, finding that the officials could be the proximate cause of the inmates’ injuries under Michigan law.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denials. The Sixth Circuit held that existing precedent did not “clearly establish” that the non-treating prison officials’ reliance on contracted medical providers was so unreasonable as to violate the Eighth Amendment. Thus, it reversed the district court’s denial of qualified immunity on the federal damages claims. However, the appellate court affirmed the denial of state-law immunity, finding the plaintiffs adequately pleaded proximate cause under Michigan law. The case was remanded for further proceedings consistent with these holdings. View "Machelle Pearson v. MDOC" on Justia Law

A state trooper investigating a stolen motorcycle observed two individuals, including the defendant, standing near two motorcycles without license plates in a hotel parking lot. One motorcycle, recently spray-painted, matched the description of a vehicle reported stolen. The trooper encountered the individuals inside a nearby convenience store, ordered them to the ground, and placed both in handcuffs. After identifying them, the trooper learned that the defendant was on felony probation and had previously signed a waiver allowing warrantless searches. Following authorization from the defendant’s probation officer, the trooper searched the defendant’s backpack, discovering illegal drugs and paraphernalia. The defendant was subsequently charged with multiple drug offenses.The defendant moved to suppress the evidence, arguing that the initial handcuffing amounted to an unlawful de facto arrest in violation of the Fourth Amendment. The District Court for the Fourth Judicial District, Ada County, agreed that the detention was an illegal arrest and rejected the State’s assertion that handcuffing was justified by officer safety. However, the district court denied suppression, holding that the evidence was admissible under the attenuation doctrine, which allows admission if intervening circumstances sufficiently separate the evidence from the illegality. The defendant entered a conditional guilty plea, preserving his right to appeal.On appeal, the Supreme Court of the State of Idaho first affirmed the district court’s ruling based on the inevitable discovery doctrine but granted rehearing. In its subsequent opinion, the Idaho Supreme Court clarified that, although the initial seizure was unreasonable and the attenuation doctrine did not apply, the evidence would have been inevitably discovered through lawful investigative steps absent the unlawful arrest. Thus, the court affirmed the district court’s denial of the suppression motion and upheld the defendant’s conviction, holding that the inevitable discovery doctrine was dispositive. View "State v. Campbell" on Justia Law

A man on probation was investigated for allegedly diverting customer payments from his employer to himself. Law enforcement learned that, as a condition of his probation, he had agreed to allow searches of his person, residence, and electronic devices, but his probation terms specifically excluded “financial accounts or transactions” from warrantless searches. During the investigation, officers arrested him, seized his phone, and searched several banking applications, including Apple Pay. Information from Apple Pay revealed the existence of certain bank accounts, which led officers to obtain a warrant to search those accounts and gather further evidence.In the Superior Court of Orange County, the defendant moved to suppress the evidence obtained from the bank accounts and to quash the warrant, arguing that the Apple Pay search exceeded the scope of his probation terms and that the subsequent warrant was based on unlawfully obtained information. The prosecution argued the motion was more properly a motion to traverse the warrant, contending that Apple Pay was not a “financial account” and that the warrant was supported by probable cause. The trial court denied the suppression and quash motions.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. It held that the defendant’s motion should be treated as a motion to traverse the warrant, as the warrant affidavit omitted material information about the probation search limitations. The court found that Apple Pay is a “financial account” under the plain meaning of the probation terms. Because the information about the bank accounts was obtained through an unlawful search of a financial account, it was improperly included in the warrant application. The appellate court ordered the trial court to vacate its earlier order and grant the motion to suppress the evidence obtained from the bank accounts. View "Meiner v. Superior Court" on Justia Law

Law enforcement officers executed a search warrant at a residence where a firearm was discovered in a bag containing the defendant’s identification and two loaded magazines. The defendant was present in the bedroom with the bag and was on parole for a prior state offense. DNA swabs taken from the firearm, along with a sample from the defendant, were analyzed by the Pennsylvania State Police Crime Laboratory, which identified multiple DNA contributors but could not conclusively match the DNA to the defendant. The DNA evidence was then submitted to a private company using TrueAllele probabilistic genotyping software, which calculated an extremely high likelihood ratio indicating the DNA was much more likely to include the defendant as a contributor.The defendant moved to exclude the TrueAllele evidence in the United States District Court for the Middle District of Pennsylvania, arguing it was unreliable under Daubert v. Merrell Dow Pharmaceuticals, Inc. and Rule 702 of the Federal Rules of Evidence. After a two-day Daubert hearing featuring expert testimony from both sides, the District Court found that the government met its burden to demonstrate the reliability of TrueAllele and denied the motion to exclude. The District Court also rejected the defendant’s motion to dismiss the indictment on Second Amendment grounds. The defendant ultimately pleaded guilty, preserving his right to appeal these rulings, and was sentenced to 78 months of imprisonment, consecutive to an anticipated state sentence.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s Daubert ruling for abuse of discretion and its Second Amendment analysis de novo. The Third Circuit held that TrueAllele’s methodology was sufficiently reliable for admissibility, finding that it satisfied factors such as testability, low error rates, presence of governing standards, peer review, and general acceptance in the relevant scientific community. The Court also affirmed the District Court’s rejection of the defendant’s constitutional and sentencing challenges, and the judgment was affirmed. View "USA v. Anderson" on Justia Law

A noncitizen defendant was charged in 2015 with serious felonies, including assault with intent to commit rape, following a single incident. He faced nearly certain deportation if convicted, as his charges qualified as “aggravated felonies” under federal immigration law. Initially represented by a public defender, the defendant later retained new counsel and proceeded to trial, ultimately being convicted on all counts in 2017. During plea negotiations, the prosecution required any deal to include prison time, sex offender registration, and a “strike,” but no immigration-safe plea was pursued. Notably, after the defendant changed attorneys, a federal appellate decision altered the immigration consequences for certain California offenses, making immigration-neutral pleas possible.After completing his sentence, the defendant filed a motion under California Penal Code section 1473.7 to vacate his conviction, arguing that he did not meaningfully understand the dire immigration consequences of conviction and would have sought an immigration-safe plea had he been properly advised. The Superior Court of Riverside County denied the motion, finding the defendant was ineligible for relief because his conviction was final before the current statutory amendment applied, and concluding he would not have accepted a plea in any event.On appeal, the Court of Appeal of the State of California, Fourth Appellate District, Division Two, reversed. The appellate court held that Penal Code section 1473.7 relief is available for final convictions, including those after trial, and found that the defendant did not meaningfully understand the immigration consequences. The court further held there was a reasonable probability he would have pursued an immigration-safe plea, and that such a plea would likely have been accepted by the prosecution and trial court. The appellate court remanded with instructions to grant the motion and vacate the conviction. View "P. v. Avena" on Justia Law

A defendant accessed the internet using a publicly available Wi-Fi network operated by a local business, A&W, located near his home. Access to the Wi-Fi required users to acknowledge terms of service that, among other things, stated A&W did not actively monitor the network but could cooperate with legal authorities and disclose users’ activities in response to lawful requests. After A&W’s owner and their consultant noticed suspicious activity flagged by their firewall, they informed law enforcement, which then directed A&W to monitor and log the defendant’s internet activity for approximately one year. This surveillance included tracking over 255,000 webpage visits and collecting packet capture data. Information obtained through this monitoring led to the defendant’s identification, arrest, and conviction on charges of encouraging child sexual abuse.The case was first heard in the Lane County Circuit Court, where the defendant moved to suppress evidence obtained from the year-long monitoring. The trial court found A&W’s owner and consultant acted as state agents but ruled that the defendant had no protected privacy interest in his use of the public Wi-Fi network, and denied the suppression motion. After a stipulated facts trial, the court convicted the defendant. On appeal, the Oregon Court of Appeals affirmed, holding that the defendant did not have a constitutionally protected privacy interest in his internet browsing activities on the public network under the circumstances.The Supreme Court of the State of Oregon reversed the decision of the Court of Appeals in part, and reversed the judgment of the circuit court, remanding the case for further proceedings. The Supreme Court held that under Article I, section 9, of the Oregon Constitution, a person retains a right to privacy in their internet browsing activities even when accessing the internet via a public network, and that acknowledging terms of service like those present did not eliminate that privacy right. The year-long warrantless monitoring constituted a “search,” and the State failed to justify the lack of a warrant. View "State v. Simons" on Justia Law

A woman was found dead in a Seattle park in 1998. The victim, who worked as a sex worker, had been strangled, sexually assaulted, and robbed. DNA evidence from the crime scene went unmatched for several years until, in 2004, it was linked to John Ray Stearns, who was serving time for another offense. Although probable cause existed at that time, charges were not filed until 2016. At trial, the State introduced evidence of two prior sexual assaults committed by Mr. Stearns, arguing these acts were sufficiently similar to show a common scheme or plan and to rebut his claim of consent.Following a first trial that ended in a hung jury, Mr. Stearns was convicted at retrial in King County Superior Court. On appeal, Division One of the Washington Court of Appeals initially reversed the conviction on the grounds of preaccusatorial delay but, after the Washington Supreme Court reversed and remanded, the Court of Appeals addressed remaining issues. The appellate court concluded that the trial court erred by admitting evidence of prior bad acts under the common scheme or plan exception to ER 404(b) and reversed in part.The Supreme Court of the State of Washington reviewed whether the trial court abused its discretion in admitting evidence of prior sexual assaults. The court held that the trial court did not abuse its discretion: the prior acts were markedly similar to the charged crime, and the victims and circumstances were sufficiently similar to support admission under the common scheme or plan exception. The Supreme Court clarified that the test does not require markedly similar victims, only sufficient similarities in acts and circumstances. The court also found no abuse of discretion in the trial court’s prejudice analysis. The Supreme Court reversed the Court of Appeals and reinstated Mr. Stearns’ conviction. View "State v. Stearns" on Justia Law

This case involves a defendant who was charged with four counts of rape involving three victims. Each victim testified that they did not consent to sexual activity with the defendant, and their decisions to report the assaults were interconnected—one victim’s report influenced another’s decision to come forward, and the relationships among the victims were relevant to the timing and manner of their disclosures. The defendant maintained that all sexual encounters were consensual.Before trial, the defendant repeatedly moved to sever the charges into separate trials, arguing that joinder would unfairly prejudice him. The Superior Court for Snohomish County denied these motions, finding that the charges were properly joined because they were of the same or similar character and involved related events and witnesses. The court determined that the evidence on each count was similarly strong, that the defenses were clear and substantially the same, that the jury could be properly instructed to consider each count separately, and that much of the evidence would be cross-admissible due to the interconnectedness of the victims and their reports. The jury convicted the defendant on all counts.The Washington Court of Appeals reversed the convictions, holding that the trial court abused its discretion by not severing the charges. On review, the Supreme Court of the State of Washington applied the abuse of discretion standard and concluded that the trial court had properly weighed the relevant factors. The Supreme Court held that, while not all evidence would have been cross-admissible in separate trials, the prejudice did not outweigh the benefits of joinder given the overlapping witnesses and related circumstances. Therefore, the Supreme Court reversed the Court of Appeals and remanded for further proceedings consistent with its opinion. View "State v. Krause" on Justia Law

Michael Johnson was charged with murder in connection with a death where the cause was disputed and involved conflicting evidence regarding physical injuries and substance use. At trial, Johnson’s counsel requested that the jury receive an instruction on the lesser-included offense of homicide by assault. However, the instruction given, which was drafted and approved by Johnson’s counsel, mischaracterized the required mens rea for homicide by assault. The jury convicted Johnson of intentional murder.On appeal, Johnson did not argue that his counsel was ineffective for proposing the erroneous instruction, nor did he claim the trial court committed plain error. Despite this, the Utah Court of Appeals raised the instructional error sua sponte and, applying the exceptional circumstances exception, found the error prejudicial and reversed the conviction. The Supreme Court of the State of Utah granted certiorari and reversed the Court of Appeals, holding that it was improper to address the instructional error under the exceptional circumstances exception since it had not been preserved or raised by the parties. The case was remanded, and the Court of Appeals summarily affirmed Johnson’s conviction.Johnson then sought postconviction relief, arguing his trial and appellate counsel were ineffective for failing to challenge the jury instruction. The Third District Court found deficient performance but concluded Johnson suffered no prejudice because the instruction’s first element required the jury to rule out murder before considering the lesser offense. Since the jury convicted on murder, the court found no reasonable probability of a different outcome.The Supreme Court of the State of Utah affirmed, holding that its prior decision vacated the Court of Appeals’ prejudice analysis, leaving the district court free to make its own ruling. It further held that Johnson could not establish prejudice, as the unchallenged first part of the instruction precluded conviction on the lesser offense once the jury found murder. View "Johnson v. State" on Justia Law