Justia Criminal Law Opinion Summaries

The defendant was convicted and sentenced in several related criminal cases involving offenses such as vehicle theft, drug possession for sale, and inflicting corporal injury on a spouse. He had a substantial criminal history and had previously served time in prison. After being released, he reoffended multiple times, leading to new charges and alleged violations of both probation and post-release community supervision. As part of a global negotiated disposition, he pleaded no contest to several charges and admitted aggravating factors. Prior to sentencing, the defendant submitted evidence of severe childhood trauma and substance abuse, linking his criminal behavior to those experiences.The Superior Court of Mendocino County, acting as the trial court, sentenced the defendant to the upper term of four years on the principal offense and imposed concurrent sentences on the other cases. The court also terminated his probation and post-release supervision as unsuccessful. The defendant timely appealed, arguing that the trial court failed to apply the presumption in favor of the lower term sentence under Penal Code section 1170, subdivision (b)(6), given his history of childhood trauma. He also argued that the court erred by not properly stating his custody credits in one case.The California Court of Appeal, First Appellate District, Division Four, held that while the defendant made a sufficient initial showing that his childhood trauma contributed to his offenses, the record did not affirmatively show that the trial court misunderstood or failed to apply the section 1170(b)(6) presumption. The appellate court presumed the trial court knew and applied the law, given the circumstances. Additionally, the court found that the custody credit issue was moot because the sentence in question had already been served. The judgment was affirmed. View "People v. Nielsen" on Justia Law

Federal agents began investigating after tracing firearms used in crimes in Massachusetts to purchases made by a South Carolina resident, Brunson. During interviews in 2021, Brunson told agents he had purchased twenty-four firearms for someone known as “Boston,” later identifying Roache as that individual. Brunson described a process in which Roache would select, pay for, and then receive firearms from him. Additional investigation revealed more firearms linked to Brunson’s purchases had been recovered in Massachusetts, and records showed similar transactions between Brunson and Roache continued into early 2023. In total, agents traced at least forty-six firearms purchased by Brunson, with evidence directly connecting Roache to six purchases in 2023.Roache and Brunson were indicted and pled guilty in the United States District Court for the District of Massachusetts to conspiring to traffic firearms. The Presentence Investigation Report (PSR) recommended a six-level sentencing enhancement based on the number of firearms Brunson stated he had purchased for Roache, as well as those confirmed in 2023. Roache objected, arguing that Brunson’s statements about the earlier purchases were uncorroborated and unreliable. The district court overruled Roache’s objection, finding that Brunson’s statements were sufficiently reliable, given corroborative evidence and the consistency of the described transactions with later confirmed acts. Roache was sentenced to fifty-seven months’ imprisonment, with three years of supervised release.The United States Court of Appeals for the First Circuit reviewed the district court’s application of the six-level enhancement for procedural error. The appellate court held that the district court did not abuse its discretion in crediting Brunson’s statements about the number of firearms trafficked, as those statements were supported by adequate indicia of reliability, and affirmed the sentence. View "United States v. Roache" on Justia Law

Three individuals entered an apartment in Plover, Wisconsin, and committed an armed robbery, physically assaulting the two residents and stealing electronics and guitars. Two of the robbers, Lyndell Dale and Archie Biddell, were apprehended shortly after and implicated Maurice Holt as the third participant. Initially, the victims identified Gosha, Holt’s nephew, as the third assailant, but later expressed uncertainty. Two days after the robbery, Holt sold some of the stolen guitars, using his real name. A search of Holt’s residence, which Gosha frequented, yielded additional stolen property. Holt denied involvement and claimed he was elsewhere during the crime.Holt was tried in Wisconsin state court on charges including armed robbery. The prosecution relied on the sale of stolen items, pretrial identifications by Dale and Biddell, and circumstantial evidence. Neither victim could positively identify Holt at trial. Holt’s defense was twofold: that Gosha was the third robber, and that Holt had an alibi. Holt’s counsel attempted to introduce photographs to support the defense theory, but the trial court excluded them as irrelevant and cumulative. Holt was convicted on all counts and sentenced to twelve years. He pursued post-conviction relief, arguing the exclusion of evidence and ineffective assistance of counsel. The state post-conviction court and the Wisconsin Court of Appeals denied his claims, and the Wisconsin Supreme Court declined review.Holt sought habeas relief in the United States District Court for the Western District of Wisconsin, which granted his petition. On appeal, the United States Court of Appeals for the Seventh Circuit reversed. The Seventh Circuit held that the Wisconsin Court of Appeals reasonably applied Supreme Court precedent in rejecting Holt’s constitutional claims regarding exclusion of evidence and ineffective assistance of counsel. The court concluded that any errors did not have a substantial and injurious effect on the verdict and did not warrant habeas relief. View "Holt v. Boughton" on Justia Law

The defendant was found driving a car in which police discovered an assault rifle with a large-capacity magazine on the front seat. He attempted to evade a traffic stop and subsequently fled the vehicle. The prosecution charged him with felony “receiving” a large-capacity magazine under California Penal Code section 32310, subdivision (a). The only evidence presented was that the defendant possessed the magazine, with no additional evidence about how or when he acquired it.The Contra Costa County Superior Court convicted the defendant of felony receiving a large-capacity magazine. The defendant appealed, contending there was insufficient evidence to support the conviction for receiving, as opposed to mere possession, and that the jury was incorrectly instructed on the distinction between the two offenses. He also argued the statute was unconstitutional. The prosecution argued that the evidence was sufficient to support the felony conviction and that the defendant’s actions supported a finding of receiving rather than just possessing.The Court of Appeal of the State of California, First Appellate District, Division One, reviewed the case. The court concluded that Penal Code section 32310 distinguishes between “receiving” and “possessing” a large-capacity magazine, with “receiving” punishable as a felony or misdemeanor and “possessing” punishable as a misdemeanor or infraction. The appellate court found that mere possession is insufficient to support a conviction for receiving; additional evidence is required to show how or when the defendant acquired the magazine. Because the record contained no such evidence, the court reversed the defendant’s felony conviction for receiving a large-capacity magazine. The rest of the judgment was affirmed. The appellate court did not reach the issues of instructional error or the statute’s constitutionality. View "P. v. Newt" on Justia Law

The case concerns a petitioner who was convicted in West Virginia state court in 2004 of sexually abusing his son. After the trial, it was discovered that, during jury deliberations, one juror told others that he knew the petitioner’s family and feared for his own family’s safety if the petitioner was acquitted. Four jurors later confirmed that the comments had been made, though the juror in question denied them. The petitioner argued this introduced an impermissible external influence into the deliberations, violating his right to an impartial jury.The trial court in West Virginia denied the petitioner’s request for a new trial, finding insufficient evidence of juror impartiality and concluding that the statements related only to the jury’s deliberative process, not to any external influence. The Supreme Court of Appeals of West Virginia affirmed this decision, holding that the comments were intrinsic to the deliberations and thus not grounds to set aside the verdict. The petitioner then sought federal habeas relief under 28 U.S.C. § 2254 in the United States District Court for the Southern District of West Virginia, which denied his petition, concluding the state court had not unreasonably applied Supreme Court precedent.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial of habeas relief de novo but applied the deferential standard required by § 2254. The Fourth Circuit held that the state court did not unreasonably apply clearly established Supreme Court law in finding that the juror’s comments were intrinsic, not external, to the deliberation process. The court concluded that, under existing Supreme Court precedent, the statements did not rise to the level of external influence necessary to violate the petitioner’s Sixth Amendment rights. Accordingly, the Fourth Circuit affirmed the district court’s judgment denying habeas relief. View "Daugherty v. Dingus" on Justia Law

Paul Daugerdas was convicted in federal court for orchestrating a fraudulent tax shelter scheme that defrauded the U.S. Treasury of significant tax revenue. A jury found him guilty of conspiracy to defraud the IRS, mail fraud, client tax evasion, and obstructing the internal revenue laws. The federal district court sentenced him to 15 years in prison, ordered forfeiture of $164.7 million, and imposed $371 million in restitution, to be paid jointly and severally with co-conspirators. The criminal restitution order set a payment schedule of 10% of Daugerdas’s gross monthly income following his release from prison.After the United States Court of Appeals for the Second Circuit affirmed the convictions and sentence, the Internal Revenue Service, relying on 26 U.S.C. § 6201(a)(4)(A), assessed the same $371 million restitution as a civil tax liability, making the entire amount immediately due. The IRS also filed a notice of federal tax lien against Daugerdas’s property in Illinois. Daugerdas challenged the IRS’s authority to impose and collect restitution in this manner, particularly objecting to the acceleration of the payment schedule. The United States Tax Court upheld the IRS’s actions, ruling that the statutory provision authorized the IRS to assess and collect restitution for tax-related offenses, even when the underlying criminal conviction was under Title 18 rather than Title 26.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the Tax Court’s judgment de novo. The court held that 26 U.S.C. § 6201(a)(4)(A) empowers the IRS to assess and collect restitution ordered under 18 U.S.C. § 3556 for tax-related crimes, including those prosecuted under Title 18, and that the IRS is not bound by the payment schedule set by the criminal court. The Seventh Circuit affirmed the Tax Court’s judgment for the Commissioner. View "Daugerdas v CIR" on Justia Law

Richard Sims was charged with several offenses stemming from a conspiracy to distribute methamphetamine. In October 2023, he pleaded guilty to five counts and a forfeiture allegation without a plea agreement. Before sentencing, Sims sought to withdraw his guilty plea, citing confusion about the consequences of the plea, diminished mental capacity due to prior brain surgeries, and health issues including cancer and vision and hearing impairments. He also requested new counsel. The district court held a status conference, denied his motion to withdraw the plea, but granted his request for new counsel.Following this, the United States District Court for the Western District of Missouri sentenced Sims in January 2025. The advisory Sentencing Guidelines range for his offenses was 360 months to life in prison. The government requested a 360-month sentence, while Sims, referencing his acceptance of responsibility and serious health problems, requested the statutory minimum of 120 months. The district court considered Sims’s health issues and age but also noted his significant criminal history and the seriousness of the offense, ultimately imposing a below-guidelines sentence of 240 months.On appeal to the United States Court of Appeals for the Eighth Circuit, Sims challenged the district court’s denial of his motion to withdraw his guilty plea and the substantive reasonableness of his sentence. The appellate court held that Sims’s general claims of ineffective assistance of counsel were not supported by the record and were more appropriate for post-conviction proceedings. It further found that the district court did not err in concluding Sims was competent to plead guilty and was not required to order a competency evaluation. Regarding sentencing, the Eighth Circuit determined that the district court properly considered Sims’s health and other relevant factors, and did not abuse its discretion in imposing a 240-month sentence. The appellate court affirmed the district court’s judgment. View "United States v. Sims" on Justia Law

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