Justia Criminal Law Opinion Summaries

Walker was involved in a scheme with two others to distribute cocaine. He arranged for cocaine to be mailed from a supplier near the U.S.-Mexico border, using one co-conspirator to send the packages and a postal worker whom he paid to deliver them along his mail routes. Law enforcement intercepted two cocaine packages, observed Walker conducting drug sales from his girlfriend’s home, and later searched that residence, finding drugs, paraphernalia, and Walker’s phone. Walker confessed to drug activities after the search.The United States District Court for the Western District of Michigan denied Walker’s motion to suppress evidence from the residence, finding probable cause for the search warrant and, alternatively, that the good-faith exception applied. At trial, the jury convicted Walker on all counts related to the drug conspiracy, and he was sentenced to 360 months’ imprisonment.Walker appealed to the United States Court of Appeals for the Sixth Circuit, raising three main issues. First, he argued that the evidence from the search should have been suppressed. The Sixth Circuit found the warrant affidavit was sufficient to establish probable cause and, even if not, that the officers' reliance on the warrant was objectively reasonable under the good-faith exception. Second, Walker challenged the admission of statements he made during a proffer session, asserting protection under Federal Rule of Evidence 410. The appellate court held that Walker, through counsel, had waived this argument by conceding that certain statements were admissible due to their inconsistency with his trial defense. Third, Walker argued a violation of his Confrontation Clause rights regarding a co-defendant’s testimony. The court found this right was also waived when Walker and his counsel agreed to a curative instruction for the jury to disregard the testimony. The Sixth Circuit affirmed the convictions. View "United States v. Walker" on Justia Law

A man who served as a confidential informant for the Department of Homeland Security became involved in criminal activity by continuing to deal drugs while cooperating with law enforcement. He developed a corrupt relationship with his handler, a special agent, who was later convicted of federal corruption charges. The informant’s unauthorized criminal conduct was uncovered when he became the target of two separate narcotics sting operations. Following his arrest, law enforcement searched his home and cell phone, and he was charged with multiple drug-related crimes.In proceedings before the United States District Court for the Northern District of Illinois, the defendant moved to suppress his post-arrest statements and evidence obtained from the warrantless searches of his home and cell phone. The district court suppressed his post-arrest statements as involuntary but denied suppression of the physical evidence, holding it admissible under the inevitable discovery doctrine. The court also denied his motions to dismiss for vindictive prosecution, sever various counts for trial, and quash a subpoena to his former handler, who invoked his Fifth Amendment right against self-incrimination. The case proceeded to a jury trial, where the defendant was convicted on three drug counts but acquitted on one. His post-trial motions for acquittal or a new trial were denied, and he was sentenced to 156 months in prison.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The appellate court held that the district court did not abuse its discretion in quashing the subpoena, that the inevitable discovery doctrine applied to the search evidence, and that the evidence was sufficient to support the convictions. The court also determined that the defendant’s other claims were either waived or without merit, and it found no abuse of discretion in the sentence imposed. View "USA v Howard" on Justia Law

After a physical altercation between a man and his former girlfriend, the man was charged with attempted strangulation, a felony under Idaho law. The incident involved conflicting accounts: the alleged victim reported that the defendant choked her after an argument, while the defendant claimed she was the aggressor and he did not harm her. Police observed some injuries but did not initially see marks on her neck; however, follow-up photos taken more than a day later showed signs consistent with strangulation. The defendant was also charged with violating a no-contact order, and the State alleged he was a persistent violator due to prior felony convictions.The case proceeded to a jury trial in the District Court of the Sixth Judicial District, Bannock County. During the trial, the court, over the defendant's objections, instructed the jury on domestic battery with traumatic injury as a lesser included offense of attempted strangulation. The jury acquitted the defendant of attempted strangulation and violation of the no-contact order, but convicted him of domestic battery with traumatic injury and found him to be a persistent violator. The district court imposed a ten-year sentence. The Idaho Court of Appeals affirmed the conviction, reasoning that the defendant had not preserved his objection regarding the lesser included offense and found no reversible or fundamental error.Upon review, the Supreme Court of the State of Idaho determined that the district court erred by instructing the jury on domestic battery with traumatic injury as a lesser included offense of attempted strangulation. The Supreme Court held that this error was not harmless, as it directly affected the deliberative process and outcome. The Court vacated the conviction for domestic battery with traumatic injury and the persistent violator finding, remanding the case for entry of a judgment of acquittal on the attempted strangulation charge. View "State v. Crombie" on Justia Law

A dual Swedish-Russian national was accused of creating and operating a bitcoin “mixer” service called Bitcoin Fog, which the government alleged was designed to facilitate money laundering and conceal illegal activity. The platform enabled users to deposit and withdraw bitcoin anonymously, making it difficult to trace transactions. Evidence presented at trial included IP address analyses allegedly connecting the defendant to Bitcoin Fog, records of his interest in similar services, and his promotion of illicit darknet marketplaces. Undercover law enforcement also conducted sting operations, sending and withdrawing funds through Bitcoin Fog and communicating intentions to launder proceeds from illegal drug sales. The defendant was arrested in 2021, after which Bitcoin Fog ceased operations.The United States District Court for the District of Columbia conducted a jury trial at which the defendant was convicted of conspiracy to commit money laundering, substantive money laundering, operating an unlicensed money transmitting business, and conducting a money transmission business without a license. The District Court sentenced him to 150 months in prison and rejected his pre-trial and post-trial motions, including challenges to venue, expert testimony admissibility, evidence sufficiency, and access to proprietary software used in the investigation.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. It held that venue was proper in the District of Columbia for all counts, based largely on evidence that Bitcoin Fog served customers there, including undercover agents. The court found no errors in the District Court’s evidentiary rulings, including the admission of expert testimony and “Welcome to Video” evidence, and rejected arguments regarding statute of limitations, due process, and Confrontation Clause violations. The appellate court affirmed all convictions and the sentence, finding no merit in any of the defendant’s arguments. View "USA v. Sterlingov" on Justia Law

The case involves a defendant who, after pleading guilty to conspiring to provide material support to ISIS, was released on bail but later violated release conditions, including absconding from supervision and failing to appear at a court-ordered status conference. Her conduct included removing an electronic monitoring device and attempting to flee, resulting in her rearrest. She later entered into a plea agreement, waiving indictment and pleading guilty to failure to appear under 18 U.S.C. § 3146, as well as agreeing to an enhancement under 18 U.S.C. § 3147 for committing the offense while on release. In exchange for her plea, the government agreed not to pursue additional charges carrying potentially higher penalties.After her guilty plea but before sentencing, the defendant moved to withdraw her plea, arguing her conduct did not fall within the scope of § 3146 because she was not released under the Bail Reform Act. The United States District Court for the Eastern District of New York denied her motion, finding a factual basis for her plea, rejecting her arguments, and sentencing her to 230 months’ imprisonment, including consecutive sentences for failure to appear and the § 3147 enhancement.On appeal to the United States Court of Appeals for the Second Circuit, the defendant argued the district court erred in denying her plea withdrawal and that applying the § 3147 enhancement violated the Double Jeopardy Clause. The Second Circuit held that the defendant’s appellate waiver, which expressly foreclosed challenges that her conduct was outside the statute’s scope, barred her first claim. The court further held that applying the § 3147 enhancement to a § 3146 conviction does not violate the Double Jeopardy Clause, as Congress clearly intended cumulative punishments. The Second Circuit therefore dismissed the appeal in part and otherwise affirmed the district court’s judgment. View "United States v. Ceasar" on Justia Law

The case involves a man who shot and killed his wife during an argument at her home, where he had gone to retrieve his belongings. The incident occurred after a struggle over a handgun, witnessed by the wife’s sister, resulting in the wife’s death from a gunshot wound to the chest. The defendant fled the scene and was apprehended following a high-speed police chase. He was charged with multiple offenses, including manslaughter and use of a deadly weapon to commit a felony.The District Court for Sarpy County conducted a jury trial. Before trial, the State successfully moved to exclude the defendant’s proposed expert witness, a crime scene reconstructionist, finding that his methodology was unreliable and would improperly invade the jury’s role. The jury convicted the defendant of manslaughter, both counts of use of a deadly weapon to commit a felony, and other charges. The court sentenced him to consecutive terms for each conviction. The defendant’s motion for a new trial was denied.On appeal, the Nebraska Court of Appeals upheld the exclusion of the expert witness, concluding the defense failed to prove the reliability of the expert’s methodology under the Daubert and Schafersman standards. However, the appellate court reversed the conviction for use of a deadly weapon to commit a felony as it related to the manslaughter count, vacated the sentence for that conviction, and remanded for a new trial on that charge. The court found that reckless assault, an unintentional act, could not serve as a predicate felony for the weapon charge. The manslaughter conviction itself was affirmed.The Nebraska Supreme Court affirmed the judgment of the Court of Appeals. It held that the trial court properly excluded the defense expert under Daubert/Schafersman and correctly remanded only the use of a deadly weapon charge for retrial, not the manslaughter conviction. View "State v. Alexander" on Justia Law

The defendant was convicted after jury trials in 2011 and 2012 of attempted murder, evading an officer, unlawfully taking a vehicle, and shooting at an inhabited dwelling. Each count included enhancements for gang involvement and firearm use, and he was sentenced to a total of 46 years and eight months to life in prison. Following direct appeal, the judgment was modified to reflect life with the possibility of parole on two counts, with a minimum parole eligibility of 15 years, and otherwise affirmed.Years later, the defendant filed a petition for recall and resentencing under California Penal Code section 1170, subdivision (d)(1), arguing that as a juvenile at the time of the offense and having served over 15 years, his lengthy sentence was effectively a life without parole (LWOP) term. He relied on appellate decisions holding that juvenile offenders sentenced to de facto LWOP terms should be eligible for relief under section 1170, subdivision (d)(1), on equal protection grounds. The Los Angeles County Superior Court reviewed the petition, considered recent appellate decisions and parties’ arguments, and denied the petition.The California Court of Appeal, Second Appellate District, Division Two, reviewed the case. Applying de novo review, it held that the defendant’s sentence did not constitute the functional equivalent of LWOP, as he was eligible for youthful offender parole under section 3051 at age 41. The court determined that section 1170, subdivision (d)(1) only applies to explicit LWOP sentences for juveniles and does not violate equal protection by excluding those sentenced to lengthy indeterminate terms. It affirmed the trial court’s denial of the petition. View "People v. Cortez" on Justia Law

The defendant was convicted after he broke into a high school barn at night and killed a goat and a pig owned by students participating in an agricultural program. Surveillance footage showed someone entering the barn, carrying an axe, and later leaving with a wheelbarrow containing the dead pig. The next day, the deceased goat was found in the barn and the pig’s carcass was discovered hanging from a tree near the defendant’s living area at a nearby homeless encampment. The students who owned the animals testified to their emotional attachments and the distress caused by the incident.The Superior Court of San Benito County found the defendant guilty of two counts of animal cruelty, vandalism, burglary, unlawful possession of ammunition, possession of methamphetamine and drug paraphernalia, and two counts of misdemeanor child abuse for causing emotional harm to the student animal owners. The defendant was sentenced to an aggregate term of 11 years and six months in prison. On appeal, he argued that the trial court erred by not instructing the jury on the statutory exception permitting the killing of animals used for food, that his counsel was ineffective for not requesting such an instruction, and that the evidence was insufficient to support his convictions for animal cruelty related to the pig and for child abuse.The Court of Appeal of the State of California, Sixth Appellate District, affirmed the judgment. The court held that the Penal Code section allowing the “right to kill all animals used for food” does not apply to killing another person’s animal without the owner’s consent. The defendant’s conduct fell outside the statutory exception, and the evidence was sufficient to support all convictions. The court also found no instructional error or ineffective assistance of counsel. The judgment of the Superior Court was affirmed. View "People v. Madruga" on Justia Law

A licensed bail bondsman posted two bonds for an individual, who subsequently failed to appear in court multiple times, resulting in the issuance of several warrants. The bondsman located the individual at a residence owned by a third party and, after unsuccessful attempts to apprehend him alone and with law enforcement assistance, recruited others to help. The group entered the residence, leading to a confrontation during which the bondsman and an associate struggled with the fugitive. During the altercation, the associate obtained the bondsman’s pistol and fatally shot the homeowner. The bondsman called 911, remained at the scene, and cooperated with police.The Montana Second Judicial District Court denied the bondsman’s pretrial motion to dismiss the aggravated burglary charge, rejecting his claim that his status as a bondsman privileged his entry and arrest. The court prohibited him from arguing a legal right to enter the residence based on his bondsman status, though it allowed evidence regarding his authority, the bonds, warrants, and motives. At trial, a jury acquitted him of deliberate homicide under the felony-murder theory but convicted him of deliberate homicide by accountability and aggravated burglary. He was sentenced to concurrent prison terms and appealed.The Supreme Court of the State of Montana reviewed four issues: mental-state instructions, ineffective assistance of counsel, sufficiency of evidence, and the bondsman authority rulings. The court held that although the trial court erred by using a conduct-based definition of “purposely” instead of a result-based definition, the error did not warrant reversal under plain-error review. Counsel’s acceptance of the flawed instruction was deficient but not prejudicial under Strickland. The evidence was sufficient to support the conviction. The court affirmed the trial court’s rulings regarding the bondsman’s asserted authority and refused instructions, concluding that the developed arguments did not establish reversible error. The convictions were affirmed. View "State v. Hubber" on Justia Law

A group of Riverside County residents, having voted in the November 2025 special election on Proposition 50, challenged the actions of the county sheriff’s department. The sheriff, responding to claims by a community group of a significant discrepancy between unofficial poll worker ballot intake logs and the Registrar of Voters’ final certified count, obtained search warrants and seized approximately 650,000 voted ballots. The Registrar of Voters maintained any discrepancy was minimal and within normal bounds, and no party disputed that the alleged discrepancy could not have changed the election outcome.After the sheriff’s department seized and began examining the ballots, the voters filed a petition for a writ of mandate directly in the Supreme Court of California. They argued the sheriff’s actions violated the Elections Code’s strict rules regarding the custody of ballots and requested the court order the immediate return of the ballots to the Registrar. The Registrar did not oppose this relief, and both the Secretary of State and Attorney General supported the petitioners’ position. The sheriff argued his actions were lawful as part of a criminal investigation supported by search warrants.The Supreme Court of California held that the seizure and removal of the ballots from the Registrar’s custody was unlawful under Elections Code section 15551, subdivision (d). The Court explained that the Elections Code specifically requires that voted ballots remain in the custody of the elections official at all times and that this rule applies even during criminal investigations. The Court issued a peremptory writ of mandate directing the sheriff to return all packages containing voted ballots to the Registrar and to refrain from further handling of the ballots, but denied the request for additional relief regarding non-ballot election materials and chain-of-custody reporting. The Court’s order superseded the previously issued superior court search warrants to the extent of any conflict. View "Cervantes v. Bianco" on Justia Law