Justia Criminal Law Opinion Summaries

The defendant was convicted by a jury in 2002 on multiple federal drug and firearm charges, receiving a lengthy sentence. He unsuccessfully challenged his convictions and sentence through direct appeals and several motions for habeas relief under 28 U.S.C. § 2255, including claims of ineffective assistance, vindictive prosecution, and arguments based on later Supreme Court rulings. After a First Step Act sentence reduction in 2019, which resulted in an amended judgment and a reduced sentence, the defendant filed another pro se § 2255 motion in 2022, arguing that he was actually innocent of one of his firearm convictions because both firearm offenses occurred as part of the same drug conspiracy.The United States District Court for the District of South Carolina dismissed the defendant’s 2022 habeas motion on two alternative grounds: first, that it was an unauthorized “second or successive” motion because a First Step Act sentence reduction does not create a “new judgment” for purposes of AEDPA; and second, that it was untimely under the one-year limitations period, with no basis for equitable tolling. The district court found that even if the motion was not successive, it was still time-barred, and the merits of his claim did not justify tolling.The United States Court of Appeals for the Fourth Circuit reviewed only the question of whether a First Step Act sentence reduction results in a “new judgment” under AEDPA, having denied the defendant’s request to expand the appeal to include the timeliness issue. The Fourth Circuit held that, because the district court’s alternative ruling of untimeliness was not appealable and would remain unaffected regardless of the outcome on the “new judgment” issue, the court had no ability to redress the defendant’s injury. As a result, the appeal was dismissed as moot. View "United States v. Robinson" on Justia Law

The case concerns an individual who, after viewing pornographic videos online, believed that two people had violated federal obscenity laws. Despite reporting these suspicions to law enforcement without result, he decided to attempt a citizen’s arrest himself. He visited the couple’s home multiple times: the first time, disguised as a pizza delivery worker and equipped with restraints and weapons, he tried to detain one of them but was stopped and warned by police. On a later visit, he left documents at the door. On his final visit, after the couple had separated, he forcibly entered the home, leading to a physical altercation with one resident involving a firearm. Ultimately, he was arrested by police.In the Eighth Judicial District Court, Clark County, the defendant was charged with multiple offenses, including attempted second-degree kidnapping, second-degree kidnapping with the use of a deadly weapon, residential burglary while in the possession of a firearm, assault with a deadly weapon, battery with substantial bodily harm, and stalking. At trial, the district court excluded most evidence related to the alleged federal crimes of the victims, ruling that a citizen’s arrest defense was not available for federal felonies and that the evidence did not support such a defense. The court also declined to give a jury instruction on citizen’s arrest and did not sua sponte instruct the jury on lesser-included offenses.The Supreme Court of Nevada reviewed the appeal. It held that Nevada’s citizen’s arrest statute does not authorize private persons to arrest for federal felonies committed outside their presence; thus, the district court correctly excluded the evidence and denied the defense. The court also held that district courts are not required to give lesser-included-offense instructions sua sponte and overruled prior precedent requiring such instructions without a request. The remaining arguments were found meritless, and the convictions were affirmed. View "Ser v. State" on Justia Law

The defendant, Marcos Hernandez, has a documented history of violence against the mother of his child, Jessica Murillo, including multiple arrests and convictions for assault. His conduct escalated over several years, resulting in convictions for misdemeanor and felony assault of a family member under Texas law. In May 2023, Hernandez was found in possession of a short-barreled, unregistered 12-gauge shotgun while walking along a railroad track in El Paso, Texas. Subsequent investigation confirmed he had no firearms registered to his name. Hernandez was indicted for possession of a firearm by a convicted felon and possession of an unregistered firearm.The United States District Court for the Western District of Texas denied Hernandez’s motion to dismiss the indictment, in which he argued that both statutes violated the Second Amendment and, for one count, the Commerce Clause. Hernandez then pled guilty to both charges, admitting to his prior felony convictions and the facts surrounding the firearm. The district court sentenced him to concurrent terms of imprisonment and supervised release. Hernandez timely appealed.The United States Court of Appeals for the Fifth Circuit reviewed Hernandez’s constitutional challenges de novo. The court concluded that his facial Second Amendment and Commerce Clause challenges to 18 U.S.C. § 922(g)(1) are foreclosed by precedent. Regarding his as-applied Second Amendment challenges to both statutes, the Fifth Circuit held they fail because the Second Amendment does not protect possession of short-barreled shotguns and because Hernandez’s predicate offenses are crimes of violence. Under Fifth Circuit precedent, such convictions permit categorical disarmament. The court affirmed the district court’s judgment, upholding Hernandez’s convictions. View "United States v. Hernandez" on Justia Law

On February 26, 2022, the appellant and another individual arrived at a Conway, Arkansas house where several people had gathered. After an argument broke out between the appellant and a partygoer, the appellant made threats and left. He later returned with his accomplice, both armed, and a gunfight ensued outside the house. One person was fatally wounded after being shot multiple times. During the incident, a third party arrived with his child, and their vehicle was struck by gunfire, with evidence suggesting the child was endangered. Police recovered numerous shell casings at the scene matching the weapons used by both the appellant and his accomplice. The appellant was charged with capital murder, two counts of aggravated assault, and a firearm enhancement.The case was tried before the Faulkner County Circuit Court. A jury convicted the appellant on all counts, and the court imposed a life sentence without parole for capital murder, concurrent five-year sentences for aggravated assault, and a consecutive ten-year sentence for the firearm enhancement. The enhancement for committing the crimes in the presence of a child was dropped by the State. The appellant timely filed a notice of appeal, challenging six evidentiary rulings made during the trial.The Supreme Court of Arkansas reviewed the case. Applying an abuse-of-discretion standard, the court addressed each evidentiary challenge, including hearsay objections, expert testimony, and use of documents by a witness. The court found no reversible error, determining either that the disputed evidence was admissible under exceptions to hearsay or that the appellant failed to demonstrate prejudice. The court also concluded that the cumulative-error argument was not preserved for review. After conducting its required review for additional prejudicial error, the Supreme Court of Arkansas affirmed the convictions and sentences imposed by the circuit court. View "TATE v. STATE OF ARKANSAS" on Justia Law

James Ray Davis pleaded guilty in 2017 to several charges, including commercial and residential burglary. Later, while incarcerated, Davis filed a pro se petition for writ of habeas corpus in the county of his incarceration. In his petition, Davis asserted that his guilty plea was induced by prosecutor deception, ineffective assistance of counsel, and trial court misconduct. He also alleged constitutional and due process violations. The petition included affidavits that were difficult to interpret, and although Davis used a form referencing Arkansas Code Annotated section 16-112-201, he did not claim actual innocence or request scientific testing.The Jackson County Circuit Court treated Davis’s petition as seeking habeas relief under sections 16-112-101 to -123, since he neither stated a claim under section 16-112-201 nor filed the petition in the county of conviction as required for claims based on new scientific evidence. The circuit court denied Davis’s petition, concluding that he failed to state a cognizable action for the writ to issue. Specifically, the court found that Davis did not provide a sentencing order showing the alleged illegality of his sentence and did not demonstrate either facial invalidity of the judgment or lack of circuit court jurisdiction.The Supreme Court of Arkansas reviewed the case and applied the clearly erroneous standard to the circuit court’s ruling. The court held that Davis failed to establish a basis for habeas relief because he did not show that the judgment was invalid on its face or that the circuit court lacked jurisdiction. Without the sentencing order or proof of illegality, the Supreme Court of Arkansas affirmed the circuit court’s denial of Davis’s petition. View "DAVIS v. STATE OF ARKANSAS" on Justia Law

The defendant was charged with multiple counts of predatory criminal sexual assault, aggravated criminal sexual assault, and aggravated criminal sexual abuse involving his younger half-sister, K.P., who was under the age of thirteen at the time of the alleged offenses. The key evidence presented was a video-recorded, victim-sensitive interview conducted with K.P. when she was nine years old, in which she described repeated sexual abuse by the defendant. Prior to trial, the State sought to admit this interview under section 115-10 of the Illinois Code of Criminal Procedure, and the Cook County circuit court held a reliability hearing, ultimately finding the statement sufficiently reliable for admission if K.P. testified.At trial, K.P. showed reluctance and limited recall when testifying, acknowledging her participation in the interview and identifying the defendant, but consistently stating she did not remember the events described or her prior statements. The defense emphasized that her statements were made following a brutal beating by another household member. Despite K.P.’s minimal substantive testimony regarding the abuse, the jury found the defendant guilty on several counts. The circuit court sentenced him to consecutive prison terms totaling 21 years and denied his motion for a new trial.The Appellate Court of Illinois, First District, affirmed the convictions, holding that K.P.’s in-court testimony satisfied the statutory and constitutional requirements for admitting her out-of-court statements. On further appeal, the Supreme Court of Illinois held that section 115-10(b)(2)(A) and the confrontation clauses of both the state and federal constitutions do not require a child witness to recall or accuse the defendant at trial for such statements to be admissible. The Court found that K.P. was available for cross-examination, and the admission of her prior statements did not violate the defendant’s confrontation rights. The judgments of the circuit and appellate courts were affirmed. View "People v. Butler" on Justia Law

A Kendall County sheriff’s deputy responded to a domestic battery call at the home of Isaiah Williams and his girlfriend. During the deputy’s investigation and Williams’s subsequent arrest and transport, Williams made several threatening statements toward the deputy, some of which included specific threats to harm and kill the officer. These statements were captured on video and were later admitted as evidence at trial. Williams was charged with aggravated domestic battery and threatening a public official under Illinois law, which requires that threats to a sworn law enforcement officer contain specific facts indicative of a unique threat, not just a generalized threat of harm.The case was first tried in the Circuit Court of Kendall County, where Williams’s counsel did not object to the jury instructions provided, which included Illinois Pattern Jury Instructions, Criminal Nos. 11.49 and 11.50. The jury found Williams not guilty of aggravated domestic battery but guilty of threatening a public official, and he was sentenced to probation. On appeal to the Appellate Court of Illinois, Second District, Williams argued that the jury instructions were conflicting and potentially misleading regarding the “unique threat” element. The appellate court rejected this argument, finding the instructions complementary—one providing a general definition, and the other specifying the required propositions for conviction, including the unique threat requirement—and affirmed Williams’s conviction.The Supreme Court of the State of Illinois reviewed the case. It held that the trial court did not err in providing both instructions, as they were not inconsistent and, when read together, accurately conveyed the law and required elements to the jury. The court further held there was no plain error nor ineffective assistance of counsel related to the instructions. The Supreme Court affirmed the judgments of both the appellate and circuit courts. View "People v. Williams" on Justia Law

The defendant was charged with aggravated battery in a public place following an incident at a bar. Initially charged with misdemeanor battery, the State later enhanced the charge to two felony counts. The defendant participated in pretrial hearings, often via Zoom, and was twice expressly admonished by the trial court that his failure to appear at future court dates, including trial, could result in trial and sentencing in absentia. Despite these warnings, the defendant did not appear on the scheduled trial date. The trial proceeded in his absence, and a jury found him guilty. He was subsequently sentenced in absentia and later taken into custody.After conviction, the defendant appealed, arguing the trial court had erred by proceeding with the trial in absentia without strictly complying with section 113-4(e) of the Illinois Code of Criminal Procedure. Specifically, he pointed out that the trial court did not inform him that his absence would waive his right to confront witnesses. The Appellate Court of Illinois, Second District, agreed, holding that the admonishments were insufficient because both warnings—the possibility of a trial in absentia and the waiver of the right to confront witnesses—are required. The appellate court reversed the conviction and remanded for a new trial.The Supreme Court of the State of Illinois reviewed the case and addressed whether the trial court’s admonishments substantially complied with section 113-4(e). The court held that substantial compliance does not demand a verbatim recitation of the statute, but rather that the defendant be made aware that the trial could proceed in his absence. The court concluded that advising the defendant of the risk of a trial in absentia was sufficient to meet the statute’s essence, even without explicitly stating the waiver of confrontation rights. The Supreme Court reversed the appellate court’s decision and affirmed the conviction. View "People v. Hietschold" on Justia Law

The defendant was charged with preventing arrest and domestic violence following an incident at his mother’s residence in Minot, North Dakota. The alleged facts included a confrontation between the defendant and his sister, during which she claimed the defendant pushed her, causing her to fall and sustain injuries. Police responded to the scene, and when attempting to arrest the defendant, he physically resisted, repeatedly stating he was “not going to jail.” Officers used force to restrain and handcuff him, and body camera footage was entered into evidence.The case was heard in the District Court of Ward County, North Central Judicial District. At trial, testimony was provided by the victim, two police officers, and the defendant. The court also reviewed photographic and video evidence. The defendant made motions for acquittal at the close of the State’s case and at the end of all evidence, both of which were denied. The District Court found the defendant guilty of both charges, sentencing him to 360 days’ imprisonment with most suspended for supervised probation on the preventing arrest conviction, and a concurrent 30-day sentence on the domestic violence conviction.On appeal to the Supreme Court of North Dakota, the defendant argued that the evidence was insufficient to support his convictions, claiming he was not informed of his arrest before being restrained and that he acted in self-defense with no intent to cause injury. The Supreme Court held that sufficient evidence supported both convictions. The Court found that the officers were justified in not informing the defendant of his arrest prior to his resistance, and that the defendant’s actions toward his sister constituted willful, or at least reckless, conduct resulting in bodily injury. The criminal judgment was affirmed. View "State v. Gores" on Justia Law

On November 4, 2024, an individual went to his stepchild’s elementary school to speak with the principal about the child’s recent suspension from bus privileges. During and after this meeting, his behavior—raising his voice, pushing a garbage can into a door, forcefully exiting the building, yelling obscenities, and making obscene gestures in the presence of children—alarmed the principal, a school counselor, and a paraprofessional. Each testified that his actions caused them alarm. He was later charged with disorderly conduct under North Dakota law.The case proceeded to a bench trial in the District Court of Richland County, Southeast Judicial District. The defendant waived his right to a jury trial. The district court found, based on testimony and the totality of the conduct, that the defendant’s actions—including using obscene language, physical agitation, and reckless driving in the school parking lot—constituted tumultuous behavior that reasonably alarmed those present. The court found the statutory elements of disorderly conduct were proven beyond a reasonable doubt and entered a criminal judgment of conviction. The defendant appealed.The Supreme Court of North Dakota reviewed the conviction. The defendant argued that his conduct was constitutionally protected as an exercise of parental rights and that the evidence was insufficient. The Supreme Court held that because the defendant did not raise constitutional claims at trial or argue obvious error on appeal, those arguments would not be addressed. Applying the standard of viewing evidence in the light most favorable to the verdict, the court found that there was sufficient evidence that the defendant acted with at least reckless disregard as to whether his behavior would alarm others and that his conduct was tumultuous. The Supreme Court of North Dakota affirmed the conviction for disorderly conduct. View "State v. Vetter" on Justia Law