Justia Criminal Law Opinion Summaries

Derek Muñoz-Gonzalez was indicted on multiple charges related to child pornography, including production, possession, and distribution. He agreed to plead guilty to two counts of producing child pornography. The plea agreement included a waiver-of-appeal clause, which stated that Muñoz waived his right to appeal if sentenced to 327 months or less. The district court sentenced him to 327 months. Muñoz appealed, claiming the prosecutor breached the plea agreement by advocating for two enhancements not included in the agreement's sentencing guidelines calculation and argued that the waiver-of-appeal clause did not preclude him from raising this breach claim.The United States District Court for the District of Puerto Rico initially reviewed the case. Muñoz was charged by a federal grand jury and subsequently pleaded guilty to two counts of producing child pornography. The plea agreement stipulated an advisory guideline range of 262 to 327 months' imprisonment, and the government agreed to dismiss the other counts. At sentencing, the district court considered the stipulated facts and sentenced Muñoz to 327 months, within the waiver-of-appeal limit.The United States Court of Appeals for the First Circuit reviewed the case. Muñoz argued that the prosecutor breached the plea agreement by highlighting facts not included in the guidelines calculation. The court held that the prosecutor did not breach the plea agreement, as the comments made were consistent with the stipulated facts and were in response to the defense's arguments for a lesser sentence. The court also noted that Muñoz failed to address the plain-error standard in his opening brief, resulting in a waiver of his breach-of-plea-agreement claim. Consequently, the court affirmed the district court's decision. View "United States v. Munoz-Gonzalez" on Justia Law

Dr. Ron Elfenbein, who runs an urgent-care clinic in Maryland, was charged with healthcare fraud for allegedly overbilling insurers by using high-level codes for simple COVID-19 tests and submitting false medical records. The clinic, which shifted to primarily COVID-19 testing during the pandemic, billed five patient visits at level four, which is typically reserved for more complex medical decision-making.In the United States District Court for the District of Maryland, a jury found Elfenbein guilty on all charges after an 11-day trial. However, the district court acquitted him, reasoning that the evidence was insufficient to support the jury's verdict. The court also conditionally granted a new trial, citing the close nature of the case and the significant evidence that came from Elfenbein's own witnesses.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the jury had enough evidence to convict Elfenbein, as the government presented sufficient testimony and documentation to support the charges of overbilling and submitting false records. The court noted that the jury could reasonably conclude that the level-four codes were inappropriate for the simple COVID-19 tests and that the medical records were materially false.However, the Fourth Circuit also affirmed the district court's decision to grant a new trial. The appellate court acknowledged that the district court did not abuse its discretion in ordering a new trial, given the weaknesses in the government's case-in-chief and the significant evidence that came from the defense. The case was remanded for a new trial. View "United States v. Elfenbein" on Justia Law

In the early morning of January 8, 2021, two individuals dressed in black entered Samuel Johns' residence. Patrycia Labombard, a visitor, witnessed one of the assailants armed with a handgun and described one as a young woman. Labombard was restrained with zip ties but managed to hide in the bathroom. She heard a fight, gunshots, and then the assailants leaving. Johns was found with gunshot wounds and later died. Police interviews with witnesses and family members pointed to Clyde Ewing and his son Demetri as suspects, motivated by a dispute over a stolen pistol and backpack. Evidence collected included surveillance footage, physical evidence from the crime scene, and items found in the suspects' motel room.The District Court of the Second Judicial District of Idaho charged Clyde with first-degree felony murder. Clyde filed motions to dismiss based on his right to a speedy trial, which were denied by the district court, citing COVID-19 related delays as good cause. The court also admitted a video interview of a deceased witness and a compilation video prepared by a police officer, despite Clyde's objections. Clyde was found guilty by a jury and sentenced to life in prison without parole.The Supreme Court of Idaho reviewed the case and affirmed the district court's judgment. The court held that the COVID-19 pandemic constituted good cause for trial delays, thus not violating Clyde's right to a speedy trial. The court also found that while the admission of the deceased witness's video interview violated the Confrontation Clause, the error was harmless given the overwhelming evidence against Clyde. Additionally, the court ruled that the compilation video was properly admitted as it summarized voluminous recordings that could not be conveniently examined in court. The cumulative error doctrine did not apply as only one error was identified, which was deemed harmless. View "State v. Ewing" on Justia Law

In the early morning of January 8, 2021, two individuals dressed in black entered Samuel Johns' residence. Patrycia Labombard, a visitor, saw the intruders, one of whom was armed with a handgun. She described one as a teenaged girl or young woman. Labombard was restrained with a zip tie but managed to escape and hide. She heard a fight, yelling, and gunshots. After the intruders left, she found Johns with gunshot wounds. Johns died from his injuries. Police interviewed witnesses, including Johns' mother, Debra Moffat, and family members who suspected Clyde Ewing and his son, Demetri Ewing, due to an ongoing dispute over a stolen pistol and backpack. Surveillance footage showed two individuals on bikes near Johns' house. Clyde and Demetri were arrested, and a search of their motel room revealed incriminating evidence.The District Court of the Second Judicial District of Idaho denied Demetri's motion to suppress evidence obtained from the search and arrest warrants, finding probable cause. The court also admitted statements from Moffat, who had died before trial, over Demetri's hearsay objections. Demetri was found guilty of first-degree felony murder and sentenced to life in prison with 25 years fixed.The Supreme Court of Idaho reviewed the case. The court affirmed the district court's denial of Demetri's motion to suppress, finding sufficient probable cause for the search and arrest warrants. The court also found that Demetri was not entitled to a Franks hearing, as he failed to show that any omissions or misstatements in the warrant affidavits were made intentionally or recklessly. However, the court agreed that admitting Moffat's statements violated the Confrontation Clause but concluded that this error did not affect the trial's outcome due to the substantial evidence against Demetri. The Supreme Court of Idaho affirmed the district court's judgment of conviction. View "State v. Ewing" on Justia Law

The case involves a defendant who was convicted of five counts of first-degree murder, 20 counts of arson, and 17 counts of possession of an incendiary device. The charges stemmed from a series of wildland fires in Southern California, culminating in the Esperanza Fire, which resulted in the deaths of five firefighters. The prosecution's case was built on evidence including DNA, eyewitness testimony, and expert analysis of the incendiary devices used to start the fires. The defense argued that the evidence was insufficient to prove the defendant's guilt and challenged the credibility of the prosecution's witnesses.In the lower court, the Riverside County Superior Court, the jury found the defendant guilty on all counts and made true findings on the special-circumstance allegations. The jury returned a verdict of death in the penalty phase, and the trial court denied the defendant's motion to reduce the death verdict, sentencing him to death on the murder convictions and to 28 years on the remaining convictions. The defendant's appeal was automatic.The Supreme Court of California reviewed the case and addressed several issues raised by the defendant, including the sufficiency of the evidence, the admission of certain evidence, and alleged instructional errors. The court found that substantial evidence supported the jury's findings and that any assumed instructional errors were harmless beyond a reasonable doubt. The court also rejected the defendant's challenges to the admission of evidence and the handling of jury selection.The Supreme Court of California affirmed the judgment in its entirety, upholding the defendant's convictions and death sentence. The court concluded that the cumulative effect of any assumed errors did not warrant reversal and rejected the defendant's challenges to California's death penalty statute. View "People v. Oyler" on Justia Law

Richard Walker was arrested at his girlfriend Ramona Paulette's residence, where he was staying overnight. Officers conducted a protective sweep of the residence and found a loaded firearm under the mattress in Walker Jr.'s bedroom. Later, with consent from Paulette's mother, Laverne Shipp, officers conducted a second search and found drugs in Paulette's bedroom. Walker was indicted for being a felon in possession of a firearm and possession with intent to distribute fentanyl. He moved to suppress the evidence, arguing the searches violated the Fourth Amendment.The United States District Court for the Southern District of Illinois denied Walker's motion to suppress, finding the protective sweep and subsequent search justified. Walker entered a conditional guilty plea, reserving the right to appeal the denial of his suppression motion. He was sentenced to 51 months' imprisonment and three years of supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case. Walker argued that the firearm and drugs were discovered through an unconstitutional search. The court found that Walker had standing to challenge the search and that the protective sweep was unlawful in scope when officers lifted the mattress in Walker Jr.'s bedroom. The court also determined that the district court erred in applying the attenuation exception to the exclusionary rule and did not address the inevitable discovery exception.The Seventh Circuit reversed the district court's denial of Walker's suppression motion and remanded the case for further proceedings to determine if the inevitable discovery exception applied and to reassess whether Shipp's consent justified the second search. View "United States v. Walker" on Justia Law

In this case, the father and mother of B.W. had a contentious relationship, and the father was involved in a criminal incident where he shot and killed a man. Following this incident, the father was advised by his criminal defense attorney not to contact the mother or B.W. to avoid jeopardizing his defense. The father was later charged with first-degree murder and conspiracy but was acquitted in December 2021. In March 2022, the father sought to establish his parental rights, and the mother filed for termination of his parental rights based on abandonment.The Superior Court in Maricopa County found that the father had abandoned B.W. by failing to maintain a normal parental relationship for over six months without just cause. The court rejected the father's argument that he had just cause for his inaction, noting that he did not take any legal steps to assert his parental rights. The court concluded that termination of the father's parental rights was in B.W.'s best interest. The father appealed.The Court of Appeals affirmed the juvenile court's decision, agreeing that the father did not demonstrate just cause for his failure to maintain a relationship with B.W. The court held that the father's reliance on his criminal defense attorney's advice did not excuse his inaction.The Supreme Court of the State of Arizona reviewed the case to clarify the meaning of "just cause" under A.R.S. § 8-531(1). The court held that "just cause" refers to a reasonable and justifiable reason for a parent's failure to maintain a normal parental relationship, based on good faith. The court reversed the juvenile court's termination order and remanded the case for reconsideration, instructing the lower court to apply the clarified definition of "just cause" in determining whether the father's actions were justified. The Court of Appeals' decision was vacated. View "In re Termination Parental Rights as to B.W." on Justia Law

The defendant was convicted of first-degree murder and sentenced to 25 years to life. During pretrial proceedings, his defense counsel raised doubts about his competency to stand trial, leading the trial court to suspend criminal proceedings and appoint a psychologist for evaluation. The psychologist observed the defendant's extremely low intelligence, confusion during police interviews and the competency evaluation, and scores below the cutoff on a test designed to assess incompetence due to intellectual disability. Despite these observations, the psychologist concluded that the defendant was competent to stand trial. The trial court found the defendant competent based on the psychologist's report, and criminal proceedings resumed.The defendant appealed, arguing that the trial court mishandled the procedures for determining his competency. He contended that there was sufficient evidence of intellectual disability to trigger the trial court's duty to appoint the director of the regional center for the developmentally disabled, or the director’s designee, to examine him. The appellate court agreed, concluding that the trial court was presented with evidence raising sufficient doubt that the defendant was intellectually disabled and was thus obligated to appoint the regional center director or their designee for evaluation. The court's failure to do so was deemed prejudicial error.The California Court of Appeal, Fifth Appellate District, reviewed the case and held that the trial court erred by not appointing the regional center director or their designee to evaluate the defendant for developmental disability. The appellate court found that the psychologist's report, which indicated the defendant's extremely low IQ and confusion, raised sufficient doubt about his intellectual disability. The court concluded that the trial court's failure to appoint the regional center director deprived the defendant of a fair competency trial. Consequently, the appellate court reversed the judgment and remanded the matter for a new trial. View "People v. Lara" on Justia Law

Federal agents conducted a sting operation in which Rami Ghanem attempted to export military equipment from the United States to Libya. Ghanem pleaded guilty to six counts, including violations of the Arms Export Control Act, unlawful smuggling, and money laundering. He proceeded to trial on a charge of conspiring to acquire, transport, and use surface-to-air missiles, for which he was found guilty and initially sentenced to 360 months in prison.The United States Court of Appeals for the Ninth Circuit vacated Ghanem’s conviction on the missile conspiracy charge due to improper jury instructions on venue and remanded the case for resentencing. On remand, the district court recalculated the guidelines range as 78-97 months but imposed the same 360-month sentence, considering the same relevant conduct as before.The Ninth Circuit reviewed Ghanem’s appeal, rejecting his arguments that the district court committed procedural errors at resentencing. The court held that the district court applied the correct legal standards in declining to reduce Ghanem’s offense level for acceptance of responsibility and did not clearly err in finding that Ghanem’s failure to accept responsibility outweighed his guilty plea and truthful admissions. The court also found that the district court adequately explained its sentencing decision, addressed Ghanem’s argument about sentencing disparities, and correctly considered conduct underlying the dismissed charge.The Ninth Circuit affirmed the 360-month sentence, concluding that the district court did not abuse its discretion in determining that the sentence was warranted under the 18 U.S.C. § 3553(a) factors. The court also rejected Ghanem’s constitutional arguments under Apprendi v. New Jersey, holding that the district court’s reliance on conduct underlying the dismissed charge did not violate the Fifth or Sixth Amendments. View "United States v. Ghanem" on Justia Law

A police officer stopped a vehicle driven by the defendant after learning that the vehicle’s registered owner had a suspended license, but before identifying the driver. The defendant moved to suppress the evidence from the stop, arguing that the officer lacked reasonable suspicion because the driver was not identified before the stop. The trial court denied the motion, concluding it was reasonable for the officer to infer that the registered owner was driving. The defendant was convicted of driving with a suspended license.On appeal, the defendant acknowledged that the stop would be lawful under the Court of Appeals case law, State v. Panko, but argued that Panko was wrongly decided and should be overruled. The Court of Appeals disagreed, concluding that Panko was not "plainly wrong" and was binding. The defendant then sought review from the Oregon Supreme Court.The Oregon Supreme Court affirmed the decision of the Court of Appeals. The court held that an officer has reasonable suspicion to make an investigatory stop when the officer believes, based on specific articulable facts, that the person stopped has committed or is about to commit a specific crime, and that belief is objectively reasonable under the circumstances. The court concluded that the officer’s suspicion that the defendant was driving with a suspended license was objectively reasonable because the officer saw a vehicle matching the description and license plate of the defendant’s vehicle, knew the defendant’s license was suspended, and confirmed the defendant was the sole registered owner. The court held that these facts made the officer’s inference objectively reasonable, and the possibility that someone else was driving did not undercut this reasonableness. The decision of the Court of Appeals and the judgment of the circuit court were affirmed. View "State v. Betancourt" on Justia Law