Justia Criminal Law Opinion Summaries

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The Supreme Court of Montana overturned the conviction of Daniel Christopher Rowe for sexual assault, a felony. Rowe was initially charged with the offense for multiple instances of abuse that allegedly took place over several years against H.B., who was under sixteen years of age at the time of the offenses. The case was remanded for a new trial due to two significant issues.First, the court found the lower court erred in admitting a subsequent uncharged act of sexual assault as proof of motive or plan to commit the earlier sexual assaults charged under a "common scheme." The court reasoned that the State had charged Rowe with a non-existent offense not recognized under Montana law, which led to the improper admission of other bad acts evidence.Second, the court found that the lower court erred in giving the jury both conduct-based and result-based definitions of "knowingly" for the sexual assault charge without specifying to the jury which definition applied to which elements of the offense. The court determined that this lowered the State's burden of proof, which violated Rowe's right to due process. The Supreme Court of Montana reversed Rowe's sexual assault conviction and remanded the case for further proceedings. View "State v. Rowe" on Justia Law

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This case involves an appeal from the defendant, Royce Lanele Robinson, who was convicted of domestic violence with great bodily injury and spousal battery. The charges were based on three separate incidents involving his girlfriend, referred to as Jane Doe. Robinson contended on appeal that the trial court erred in allowing the prosecution to introduce evidence of his prior domestic violence conviction without a description of the underlying facts.The Court of Appeal of the State of California Fourth Appellate District Division Three upheld the trial court's decision. The court concluded that Robinson's claim had been forfeited on appeal because he did not raise this argument in the trial court. The court also found that the trial court did not abuse its discretion by admitting the evidence of the prior conviction under Evidence Code section 1109. Even if there was an error, the court stated it would not have been prejudicial, and thus, the judgment was affirmed.The key facts of the case include a series of incidents where Robinson allegedly inflicted bodily harm on Doe. The first incident involved Robinson pushing Doe out of his moving car. In the second incident, Doe reported that Robinson had pushed down on her chest, causing a fracture. In the third incident, Doe reported a prolonged assault by Robinson. Throughout the trial, Doe provided inconsistent testimonies, and Robinson's mother testified that her son attempted to aid Doe during a choking incident. The jury found Robinson guilty of spousal battery for the first incident and guilty of inflicting Doe's chest injury for the second incident. However, Robinson was found not guilty for the charges related to the third incident. View "People v. Robinson" on Justia Law

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In the case before the United States Court of Appeals for the Sixth Circuit, the defendant, Bryce Axline, appealed the 65-month sentence imposed by the district court following his guilty plea to charges of vehicular homicide and vehicular assault on federal lands. Axline argued that the district court imposed a substantively unreasonable sentence by failing to provide sufficiently compelling reasons for varying upward from the Sentencing Guidelines advisory range by approximately 40 percent. The Court of Appeals affirmed the district court's decision, concluding that the sentence was substantively reasonable. The court found that the district court thoroughly assessed the seriousness of Axline's offense, his history with underage substance abuse, and the importance of specific and general deterrence. The court also found that the circumstances of this case fell outside the heartland of similar cases. The court noted that the Guidelines did not necessarily account for the confluence of his underage drinking and extremely reckless driving, nor did they necessarily adequately account for the effect of Axline's actions on multiple victims. Thus, the district court acted within its discretion in varying Axline's sentence above the Guidelines range. View "United States v. Axline" on Justia Law

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In 1995, Armondo Lopez was convicted of first-degree murder and attempted murder for his role in an incident where his co-defendant, intending to kill a rival, accidentally shot and killed an unintended victim. Lopez had assisted his co-defendant, knowing that the co-defendant intended to kill the rival. Although Lopez was not the shooter, he was deemed liable for the unintended victim's death under the doctrine of transferred intent. This doctrine holds that if a person intends to harm one individual but unintentionally harms another instead, the intent to harm is transferred to the actual victim, making the person liable for that harm.In 2021, Lopez filed a petition for resentencing, arguing that changes in the law under Senate Bill 1437 meant he could no longer be convicted of murder. Senate Bill 1437, effective January 1, 2019, amended California's murder law to limit murder liability for accomplices who did not act with intent to kill and were not major participants in the crime. Lopez argued that the doctrine of transferred intent, which had been used to establish his liability for murder, was a form of imputed liability and therefore incompatible with the revised law.The Court of Appeal of the State of California disagreed, holding that Senate Bill 1437 did not abrogate the doctrine of transferred intent. The court reasoned that the bill's language did not suggest any intent to abolish this long-established doctrine. Furthermore, the court found that the doctrine of transferred intent requires an intent to kill, which Lopez had demonstrated through his actions and admissions. Therefore, the court affirmed the trial court's decision denying Lopez's petition for resentencing. View "People v. Lopez" on Justia Law

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This case involves an appeal from a postconviction order for restitution in the amount of $6,700. The defendant, Joshua Jereco Pittman, was ordered to pay this amount for jewelry stolen from the home of victims Michael F. and Betty F. The Court of Appeal of the State of California First Appellate District Division Four affirmed the trial court's restitution order. The court noted that a victim's estimate of the value of stolen items is sufficient to make a prima facie showing of loss, subject to rebuttal by the defendant. In this case, the victims' estimates were contained in a police report and in restitution forms, and the trial court did not abuse its discretion by relying on these estimates. The appellate court also found that evidence of replacement value for the stolen property was sufficient to support the restitution order. View "People v. Pittman" on Justia Law

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This case revolves around the dismissal of a case due to the plaintiff's counsel's unexcused absence from the final pretrial conference. The United States Court of Appeals for the First Circuit raised the question of whether a district court may dismiss a case for such a reason, especially when it's the first and only instance of non-compliance and the court did not consider a lesser sanction. In this case, the plaintiff had filed a complaint alleging RICO violations and related state-law claims. However, the plaintiff's counsel failed to appear at the final pretrial conference, leading to the dismissal of the case by the district court.Upon review, the Court of Appeals held that while a district court has inherent power to manage its docket and may dismiss a case sua sponte for reasons prescribed in Rule 41(b), such dismissal should only occur when a plaintiff's misconduct has been extreme or contumacious. The dismissal should not be viewed as a sanction of first resort or an automatic penalty for every failure to abide by a court order. Thus, the Court of Appeals found that the district court had erred in dismissing the case without first considering a lesser sanction or warning the disruptive party. The court vacated the district court's dismissal order and remanded the case for further proceedings. View "Vivaldi Servicios de Seguridad, Inc. v. Maiso Group, Corp." on Justia Law

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In this case, Grace Katana appealed his conviction for conspiracy to interfere with interstate commerce by robbery in violation of the Hobbs Act. He argued that the indictment accused him of conspiring to rob Joseph Wilson, while the government only proved at trial that he had planned a break-in at Wilson's home. Katana claimed that this constituted a constructive amendment to the indictment in violation of his constitutional rights, that there was a prejudicial variance from the charge in the indictment, and that there was insufficient evidence to support his conviction.The United States Court of Appeals for the First Circuit rejected Katana's arguments and affirmed his conviction. The court found that the offense charged in the indictment was the same offense on which the court instructed the jury and on which the government presented evidence. The court also held that the identity of the robbery target was not an element of a robbery or conspiracy to commit robbery under the Hobbs Act, so focusing on Wilson's home business as the target at trial did not amount to a constructive amendment. The court further concluded that Katana failed to demonstrate that any variance from the indictment was prejudicial, as the record showed he had sufficient notice of, and was able to defend himself against, the government's theory at trial. Finally, the court ruled that a rational jury could have concluded that Katana and his co-conspirators planned to rob Wilson's home business, so there was sufficient evidence to support his conviction. View "US v. Katana" on Justia Law

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In the case before the United States Court of Appeals for the First Circuit, the defendant, Randall Crater, was convicted of wire fraud, unlawful monetary transactions, and operating an unlicensed money transmitting business based on his involvement in a cryptocurrency scheme. The trial lasted eight days and was based on Crater's management of My Big Coin (MBC), a cryptocurrency company that allegedly misrepresented itself as a gold-backed digital currency and claimed a partnership with MasterCard. The defendant appealed two of the district court's rulings.Firstly, Crater argued that the district court violated his Sixth Amendment right to compulsory process by refusing to enforce subpoenas against three federal agency witnesses due to Crater's non-compliance with the agencies' Touhy regulations. Secondly, Crater contended that the district court did not perform its gatekeeping duty by admitting testimony from the government's cryptocurrency expert without holding a Daubert hearing.However, the Court of Appeals affirmed the district court's decision, stating that Crater's arguments could not be reconciled with controlling precedent or the record in the case. The court found that Crater's failure to show how the excluded testimony of the federal agents would have been both material and favorable to his defense invalidated his Sixth Amendment claim. Furthermore, the court held that Crater's objections to the expert witness's qualifications and methodology were insufficient to necessitate a Daubert hearing. View "US v. Crater" on Justia Law

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The defendant, Michael Rand, was indicted and pleaded guilty to one count of distributing a controlled substance. His sentence was time served followed by 36 months of supervised release. Shortly thereafter, Rand violated his supervised release multiple times, leading to a revocation hearing. At the hearing, Rand was sentenced to 24 months of imprisonment followed by 24 months of supervised release. Rand appealed his sentence on the grounds that it was procedurally and substantively unreasonable. The United States Court of Appeals for the First Circuit affirmed the sentence. The court found that the district court had adequately explained its rationale for the sentence, which was based on a combination of Rand's lying and absconding shortly after his original sentence, his drug relapse, and his failure to comply with the terms of his supervised release. Lastly, the court found that the sentence fell within the broad range of reasonableness considering the totality of the circumstances. View "US v. Rand" on Justia Law

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Juan Sierra-Jiménez was a felon who pled guilty to possessing a firearm. While on supervised release for a prior federal firearm offense, Sierra was arrested and found with a Glock 22 pistol, which had been modified to function as a machine gun. He was also in possession of extra ammunition and approximately five grams of a substance suspected to be heroin. Sierra was sentenced to fifty-eight months in prison and an additional consecutive eighteen-month supervised release violation sentence. Sierra appealed, arguing that the fifty-eight-month sentence was procedurally unreasonable and that the government breached the plea agreement regarding his eighteen-month sentence. The United States Court of Appeals for the First Circuit rejected Sierra's arguments and affirmed the lower court's decision. The court ruled that the district court did not clearly err in its factual findings and did not rely on the suspected heroin possession in determining Sierra's sentence. The court also found that Sierra failed to show that the government's lack of an oral recommendation for a concurrent sentence prejudiced him. View "US v. Sierra-Jimenez" on Justia Law