Justia Criminal Law Opinion Summaries

A federal agent stationed in Dubai, Leatrice De Bruhl-Daniels, developed a romantic relationship with a Syrian national, Nadal Diya, who was under investigation for suspected ties to terrorism. Despite warnings from her colleagues, De Bruhl-Daniels disclosed confidential information to Diya, including details about an ongoing counterterrorism investigation. She later lied to federal investigators about these disclosures.Following a jury trial in the United States District Court for the Southern District of Texas, De Bruhl-Daniels was convicted on twelve counts related to her conduct and sentenced to 108 months in prison. She appealed four of her convictions and her overall sentence, arguing that her false statements did not involve international terrorism under 18 U.S.C. § 1001(a), that the statute’s sentencing enhancement was unconstitutionally vague, and that her conduct did not fall under the scope of 18 U.S.C. § 1512(c)(2).The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed De Bruhl-Daniels' conviction on Count 24, finding sufficient evidence that her false statements involved international terrorism, thus justifying the enhanced sentence under § 1001(a). The court also held that the statute was not unconstitutionally vague. However, the court vacated her convictions on Counts 15, 36, and 37, which were based on obstructing an official proceeding, citing the Supreme Court’s recent decision in Fischer v. United States. The court determined that her conduct did not fall within the scope of § 1512(c)(2) as it did not involve tampering with evidence.As a result, the Fifth Circuit vacated De Bruhl-Daniels' sentence and remanded the case for resentencing based on the remaining convictions. View "United States v. De Bruhl-Daniels" on Justia Law

Julian Valdez was convicted of second-degree unintentional felony murder for fatally shooting Pablo Gutierrez, who was allegedly attacking Valdez's stepbrother. The incident occurred after Gutierrez, who appeared agitated and unarmed, entered Valdez's garage and later got into a physical altercation with Valdez's stepbrother. Valdez retrieved a gun and, during the altercation, shot Gutierrez once, resulting in his death. Valdez claimed he acted in defense of his stepbrother, who was being choked by Gutierrez.The district court instructed the jury that Valdez had a duty to retreat before using force in defense of his stepbrother. Valdez was found guilty of second-degree unintentional felony murder. He appealed, arguing that the district court's instruction was erroneous. The Minnesota Court of Appeals agreed, concluding that the district court abused its discretion by instructing the jury that Valdez had a duty to retreat. The court of appeals reversed Valdez's conviction and remanded for a new trial, finding that the erroneous instruction was not harmless beyond a reasonable doubt.The Minnesota Supreme Court reviewed the case and affirmed the court of appeals' decision. The Supreme Court held that the district court abused its discretion by instructing the jury that Valdez had a duty to retreat before acting in defense of his stepbrother. The court clarified that, to justifiably use force in defense of another, a defendant must subjectively believe that the person in peril has no reasonable possibility of safe retreat, and that belief must be objectively reasonable based on the information available at the time. The court also concluded that the erroneous instruction was not harmless, as it could not be said beyond a reasonable doubt that the error had no significant impact on the verdict. Therefore, Valdez's conviction was reversed, and the case was remanded for a new trial. View "State vs. Valdez" on Justia Law

In April 2018, Justin Little was investigated and arrested by state police in Oklahoma after his wife’s boyfriend was shot and killed on the Muscogee Creek Reservation. Following the Supreme Court’s 2020 decision in McGirt v. Oklahoma, it was established that the Creek Reservation had not been disestablished, meaning state police lacked jurisdiction over Little’s offense. Little was later convicted of first-degree murder in federal court.The United States District Court for the Northern District of Oklahoma denied Little’s motion to suppress evidence collected by state officers, ruling that the officers reasonably believed they had jurisdiction at the time of the investigation. Little was subsequently convicted by a jury and sentenced to life imprisonment.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that the evidence collected by state officers was admissible under the good faith exception to the Fourth Amendment’s exclusionary rule. The court reasoned that, given the historical belief that Oklahoma had jurisdiction over offenses on Creek land and the stay of the mandate in Murphy v. Royal pending Supreme Court review, state officers could reasonably believe they had jurisdiction. The court concluded that excluding the evidence would not have a significant deterrent effect and would impose substantial social costs.The Tenth Circuit affirmed Little’s conviction and sentence, rejecting his other arguments for reversal, including challenges to the admission of evidence, jury instructions, and prosecutorial statements. The court found that none of these issues warranted relief, either individually or cumulatively. View "United States v. Little" on Justia Law

In 2016, Louis Scherzer was fatally shot outside a bar in Kansas City, Kansas. Filiberto B. Espinoza Jr. was linked to the shooting and charged with first-degree premeditated murder, first-degree felony murder, conspiracy to commit aggravated robbery, and attempted aggravated robbery. Espinoza admitted to the shooting but claimed self-defense, stating he shot Scherzer when he saw him pulling a firearm. In September 2017, Espinoza pleaded guilty to first-degree felony murder and received a mandatory minimum sentence of life without parole for 25 years. His sentence was affirmed on appeal in April 2020.Espinoza filed a motion to withdraw his plea on January 5, 2021, which the district court did not rule on before he filed a second motion on November 21, 2023. The district court summarily dismissed both motions on December 20, 2023, noting the 2021 motion was timely but failed to establish manifest injustice, and the 2023 motion was untimely and lacked excusable neglect. Espinoza appealed the denial of both motions.The Kansas Supreme Court reviewed the case de novo. The court affirmed the district court's decision, holding that Espinoza's 2023 motion was untimely and did not demonstrate excusable neglect. The court noted that Espinoza was aware of the video footage and toxicology report during the trial, and his claims of ignorance did not constitute excusable neglect. Additionally, the court found no error in the district court's summary denial of the 2021 motion, as the record showed Espinoza was fully informed of his plea's consequences, and his allegations were conclusory without raising substantial issues of fact.The Kansas Supreme Court affirmed the district court's summary denial of both motions to withdraw Espinoza's plea. View "State v. Espinoza" on Justia Law

A sixteen-year-old defendant, concerned that a poor Spanish grade might hinder his plans to study abroad, conspired with a friend to murder his Spanish teacher. They meticulously planned and executed the murder, later bragging about it to classmates. The defendant initially lied to the police but eventually pleaded guilty to first-degree murder, agreeing to challenge only his sentence. At sentencing, the State recommended life imprisonment with parole eligibility after thirty years, while the defendant argued against any minimum term. The district court sentenced him to life with parole eligibility after thirty-five years.The Iowa District Court for Jefferson County rejected the defendant's argument that a minimum sentence required expert testimony. The court considered various factors, including the impact on the victim's family and community, the defendant's role in the crime, and his potential for rehabilitation. The court found that the severity and premeditation of the crime warranted a minimum term of thirty-five years before parole eligibility.The Iowa Supreme Court reviewed the case, focusing on whether sentencing juvenile offenders to a minimum term before parole eligibility violates the Iowa Constitution and whether expert testimony is required to impose such a sentence. The court upheld the district court's decision, ruling that the Iowa Constitution does not categorically ban minimum sentences for juveniles and that expert testimony is not mandatory. The court found that the district court properly considered the relevant factors and did not abuse its discretion in sentencing the defendant to life with the possibility of parole after thirty-five years. The sentence was affirmed. View "State of Iowa v. Miller" on Justia Law

In the early morning of September 12, 2020, Brookline Police Officer Torrisi encountered a vehicle stopped in the roadway. Upon approaching, he noticed signs of intoxication in the driver, Roy Rogers, whose license was suspended. After administering field sobriety tests, Torrisi determined Rogers was impaired and attempted to arrest him. Rogers resisted, leading to a prolonged encounter involving another officer and a friend of Rogers who arrived at the scene. Despite resistance, Rogers was eventually handcuffed and taken to the police station, where he agreed to a breathalyzer test, which showed a result of .07. Rogers was initially given a hand summons for operating after suspension and allowed to leave.The Circuit Court (Derby, J.) found Rogers guilty of driving under the influence and five counts of resisting arrest but not guilty of negligent driving. Rogers moved to dismiss all charges, arguing that the officers had promised not to prosecute if his breathalyzer result was under .08. The court denied the motion, stating there was no enforceable agreement and that enforcing such an agreement would be against public policy. Rogers was convicted on the remaining charges, leading to this appeal.The Supreme Court of New Hampshire reviewed the case. The court held that there was no enforceable agreement not to prosecute, as there was no meeting of the minds between Rogers and the officers. Additionally, the court addressed Rogers' double jeopardy claim, concluding that the unit of prosecution for resisting arrest is each discrete volitional act of resistance. The court affirmed Rogers' conviction for driving under the influence and two counts of resisting arrest but vacated three of the resisting arrest convictions, determining they constituted a single continuous course of conduct. The case was remanded for further proceedings consistent with this opinion. View "State v. Rogers" on Justia Law

The case involves Denys Korotkiy, the Chief Engineer of a foreign-flagged ship, who was charged with violating U.S. regulations by failing to maintain accurate records of bilge-water operations in the ship's Oil Record Book. The ship, MV Donald, dumped oily bilge water on the high seas and made misleading entries in the Oil Record Book to cover it up. Upon arriving in the U.S., the Coast Guard inspected the ship and found the records to be inaccurate and incomplete.The United States District Court for the Southern District of California denied Korotkiy's motion to dismiss the indictment. Korotkiy argued that the regulation did not require accurate records, that Congress and the international community did not intend for such prosecutions, and that only shipmasters, not chief engineers, should be charged. The district court, relying on precedents from other circuits, found that Korotkiy could be charged for failing to maintain an accurate Oil Record Book while in U.S. waters.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The Ninth Circuit held that 33 C.F.R. § 151.25 requires ships to maintain accurate records in their Oil Record Books while in U.S. waters. The court joined other circuits in interpreting the regulation to impose a duty on foreign-flagged vessels to ensure the accuracy of their records upon entering U.S. territorial waters. The court also rejected Korotkiy's argument that only shipmasters could be charged, noting that chief engineers can be prosecuted for aiding and abetting the failure to maintain accurate records. The court concluded that the regulation's plain language and the legislative purpose of preventing oceanic pollution supported the prosecution. View "USA V. KOROTKIY" on Justia Law

The defendant, Sylvester Gailes, has a history of domestic violence, including multiple incidents where he physically assaulted his partners. In 2012, he struck his girlfriend in the face, and in 2014, he dragged her by her hair and kicked her in the head. In 2018, he assaulted another ex-girlfriend, choking her and threatening her with a handgun. Gailes was convicted of domestic-violence misdemeanors for each of these incidents. Later, during a traffic accident investigation, police found Gailes in possession of two loaded pistols, leading to his indictment for violating 18 U.S.C. § 922(g)(9), which prohibits individuals convicted of domestic-violence misdemeanors from possessing firearms.The United States District Court for the Western District of Tennessee denied Gailes's motion to dismiss the indictment, in which he argued that 18 U.S.C. § 922(g)(9) is unconstitutional in light of the Supreme Court's decision in New York State Rifle & Pistol Ass’n v. Bruen. Gailes then pleaded guilty to the charges and was sentenced to 50 months in prison. He appealed the district court's decision, challenging the constitutionality of the statute under the Second Amendment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court applied the two-step framework from Bruen, first determining that the Second Amendment's plain text covers Gailes's conduct. The court then examined whether the statute is consistent with the Nation's historical tradition of firearm regulation. The court found that historical analogues, such as surety laws and "going armed" laws, support the constitutionality of disarming individuals who pose a clear threat of physical violence. Consequently, the court held that 18 U.S.C. § 922(g)(9) is facially constitutional and affirmed the district court's judgment. View "United States v. Gailes" on Justia Law

The case involves Constantine Varazo II, who was convicted by a jury for possession with intent to distribute methamphetamine and heroin, and possession of a firearm in furtherance of a drug-trafficking crime. The key facts include a high-speed chase initiated by Deputy Chandler Buchanan after Varazo's vehicle refused to stop. During the chase, items were thrown from the car, which were later identified as drugs. A book bag containing drugs, a firearm, and a cell phone was found by an employee of Miller Supply and eventually handed over to law enforcement.In the lower court, the United States District Court for the Middle District of Georgia admitted Deputy Buchanan’s testimony about statements made by Russell Chapman, a state probation officer, and admitted the book bag over Varazo’s chain-of-custody objection. Varazo did not object at the time to hearsay statements by James Eidson and Cliff Miller regarding the discovery of the bag. The district court denied Varazo’s motion for a new trial and sentenced him to 228 months’ imprisonment.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that any error in admitting Chapman’s out-of-court statements was harmless because Chapman later testified and was subject to cross-examination. The court also held that challenges to the chain of custody go to the weight rather than the admissibility of evidence, and sufficient circumstantial evidence connected the bag to Varazo. Lastly, the court found that any hearsay error regarding the discovery of the bag did not affect Varazo’s substantial rights, as other evidence sufficiently supported the verdict. The Eleventh Circuit affirmed Varazo’s convictions. View "USA v. Varazo" on Justia Law

In May 2020, Daniel Samaniego was charged with gross sexual imposition, a class AA felony. During his trial in May 2021, a detective testified about attempting to interview Samaniego, leading to an objection from Samaniego’s counsel, which was sustained. The jury found Samaniego guilty. Post-trial, a juror indicated that the jury discussed Samaniego’s decision not to testify. Samaniego’s counsel did not move for a new trial based on this potential jury misconduct.Samaniego appealed the criminal judgment in September 2021, arguing insufficient evidence and prosecutorial misconduct. The North Dakota Supreme Court affirmed the conviction, noting the prosecutorial misconduct claim was not preserved for appeal. In May 2023, Samaniego filed for postconviction relief, claiming ineffective assistance of counsel for not preserving the prosecutorial misconduct issue and not moving for a new trial based on jury misconduct. The district court held an evidentiary hearing and denied the application in February 2024.The North Dakota Supreme Court reviewed the case and affirmed the district court’s judgment. The court held that Samaniego did not demonstrate a reasonable probability that the trial outcome would have been different but for his counsel’s alleged errors. The court found no prosecutorial misconduct in the detective’s testimony and noted that the jury’s discussion about Samaniego not testifying did not constitute juror misconduct under the law. The court concluded that Samaniego’s trial counsel’s actions did not fall below an objective standard of reasonableness and that Samaniego was not prejudiced by these actions. View "Samaniego v. State" on Justia Law