Justia Criminal Law Opinion Summaries

The appellant was charged with two counts of child molestation involving her two young daughters, following disclosures made by one of them to a teacher. Subsequent investigations included forensic interviews with both children and multiple psychological evaluations of the appellant, which diagnosed her with various mental health disorders, including schizophrenia and stimulant use disorder. At different points, experts disagreed about her competency, but she was eventually found competent to stand trial. The appellant’s counsel filed for permission to assert an insanity defense nearly two years after the statutory deadline and only twelve days before trial, citing late-arriving psychological evaluations and ongoing difficulties communicating with the appellant.The Floyd Circuit Court denied the belated insanity defense motion, finding no good cause for the extensive delay, and subsequently a jury found the appellant guilty on both charges. The court sentenced her to two consecutive forty-year terms, for a total of eighty years. On appeal, the Indiana Court of Appeals, in a divided decision, reversed and remanded, holding that the trial court abused its discretion by denying the belated insanity defense notice. The State then petitioned for transfer to the Indiana Supreme Court, which vacated the Court of Appeals’ decision.The Indiana Supreme Court held that the trial court did not abuse its discretion in denying the belated insanity defense motion, as the appellant failed to show good cause for the lengthy delay after receiving relevant psychological evaluations. The Court further held that the children’s out-of-court statements were properly admitted under the Protected Person Statute, as the trial court’s reliability determination was not an abuse of discretion. Finally, the Court found that the eighty-year sentence was not inappropriate given the nature of the offenses and the appellant’s character, and affirmed the trial court’s judgment. View "Tillett v. State of Indiana" on Justia Law

The case involves a defendant who was charged with felony grand theft and, as part of a plea agreement, admitted to additional probation violations and a misdemeanor. He agreed to serve jail time contingent on possible release to a treatment program, subject to assessment. The trial court subsequently placed him on probation with several conditions, including one that permitted the probation department to transfer him to jail for up to 120 days—without court involvement—if he failed to successfully complete a treatment program. This condition further stated that he would not receive credit for time spent in treatment unless he completed the program.After the trial court imposed these conditions, including the challenged provision, the defendant’s probation was revoked due to his absconding from treatment, and a warrant was issued for his arrest. He was later apprehended and appealed the probation condition, arguing that it unlawfully delegated judicial authority to the probation department and was unconstitutionally vague regarding custody credits. Although the trial court later terminated his probation and credited him for all time spent in custody and treatment, the appeal continued based on the public interest and recurring nature of the legal questions presented.The California Court of Appeal, First Appellate District, Division Three, held that the trial court’s probation condition unconstitutionally delegated excessive judicial authority to the probation department by allowing it to determine and impose significant sanctions without court oversight. The court further concluded that, in the absence of a knowing and intelligent waiver, the defendant could not be denied custody credits for time spent in residential treatment, even if he did not successfully complete the program. Because these issues are likely to recur, the appellate court reached the merits but ultimately dismissed the appeal as moot, since the defendant had already received the credits in question. View "P. v. Emrick" on Justia Law

The case involves a Massachusetts psychiatrist who owned and operated a clinic providing treatment for addiction with imported drugs. The drugs included naltrexone and disulfiram in forms not approved by the FDA for use in the United States. The shipments were brought in from Hong Kong and falsely described on import documents as “plastic beads in plastic tubes,” with their value understated. The government charged the defendant with several crimes, including international money laundering, unlawful importation of merchandise, and receipt and delivery of misbranded drugs. The jury found the defendant guilty on some counts but acquitted him on others, including all counts against his wife.The United States District Court for the District of Massachusetts conducted the trial. After the jury’s verdict, the court sentenced the defendant to 36 months’ imprisonment on each count, to be served concurrently, and calculated the sentence using the fraud guideline in the United States Sentencing Guidelines. The defendant appealed, arguing that the district court erred in its evidentiary rulings, in admitting or excluding certain testimony, and in its application of the Sentencing Guidelines.The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the defendant’s convictions, finding no reversible error in the district court’s evidentiary decisions or in its exclusion of expert testimony. The appellate court vacated the sentence for the misdemeanor misbranding conviction because it exceeded the statutory maximum. The court retained jurisdiction over the appeal and remanded to the district court for clarification regarding the application of the fraud guideline, specifically instructing the lower court to explain the basis for its use of that guideline and to address the impact of recent amendments related to acquitted conduct. View "US v. Shafa" on Justia Law

The case centers on a petitioner who was convicted of murder and related crimes following a 2016 jury trial. The conviction stemmed from a shooting incident in New London, Connecticut, in which several eyewitnesses, including Alice Phillips, identified the petitioner as the perpetrator. Phillips’ credibility was challenged at trial, but she remained an important witness for the prosecution. After the trial, it came to light that Phillips had previously provided false testimony regarding expected consideration for her cooperation in a different, unrelated murder trial prosecuted by the same state’s attorney’s office.Following his conviction, the petitioner filed a habeas petition in the Superior Court for the judicial district of Tolland, arguing that his due process rights were violated when the prosecutor failed to disclose Phillips’ prior false testimony. The habeas court denied his petition, and the Appellate Court dismissed his appeal, reasoning that the prosecutor in the petitioner’s trial had no obligation to seek out impeachment material from unrelated cases absent a specific request from the defense.On appeal, the Connecticut Supreme Court held that the state’s attorney’s office is a single entity for Brady v. Maryland purposes. Therefore, the prosecutor was responsible for disclosing exculpatory or impeachment evidence known to other prosecutors in the same office, including the information about Phillips’ false testimony in the unrelated case. However, the Supreme Court concluded that the nondisclosure was immaterial because Phillips was not the only eyewitness, her credibility was effectively challenged at trial, and there was significant additional evidence implicating the petitioner.Accordingly, the Connecticut Supreme Court vacated the Appellate Court’s determination regarding the scope of the prosecutor’s disclosure obligations but affirmed the judgment in all other respects, finding no Brady violation as the suppressed evidence was not material to the outcome. View "Vega v. Commissioner of Correction" on Justia Law

The case concerns a drive-by shooting in Hartford, Connecticut, in which the defendant, accompanied by his younger brother, fired several shots from a vehicle, resulting in the death of the driver of another car and wounding a passenger. The surviving passenger, Ortiz, who was also the victim’s girlfriend, identified the defendant as the shooter both to police at the scene and during trial. The identification was based on Ortiz’s prior familiarity with the defendant and the vehicle used in the shooting, which had distinctive features and had recently belonged to her boyfriend. The defendant was charged with murder, conspiracy to commit murder, assault in the first degree with a firearm, and criminal possession of a firearm.The case was tried jointly with the defendant’s brother in the Superior Court for the judicial district of Hartford. The jury found the defendant guilty on all counts. The trial court rendered judgment in accordance with the verdict and sentenced the defendant to a total effective sentence of fifty years’ imprisonment.On direct appeal to the Connecticut Supreme Court, the defendant argued that the trial court committed plain error by failing to instruct the jury on eyewitness identification in accordance with State v. Ledbetter. He also asked the Court to require such an instruction whenever a good faith misidentification is at issue and to abrogate the excited utterance exception to the hearsay rule. The Supreme Court held that the trial court’s failure to provide a specific eyewitness identification instruction did not constitute plain error because Ortiz’s familiarity with the defendant and corroborating evidence negated a significant risk of misidentification. The Court also declined to mandate an eyewitness identification instruction in all such cases or to abrogate the excited utterance exception. The judgment of the trial court was affirmed. View "State v. Franqui" on Justia Law

A shooting occurred after a series of violent confrontations between a victim and two brothers, one of whom is the defendant. The victim was killed while driving, and his girlfriend, who was a passenger, identified the defendant as the driver of the car from which the fatal shots were fired by his elder brother. She gave this identification at the scene and again in a written statement later that day, but at trial, she was unsure if the defendant was the driver. Other evidence included the elder brother’s admission to another sibling that he had committed the shooting, and the defendant’s prior altercations and threats against the victim.The case was tried in the Superior Court for the judicial district of Hartford, where the defendant was charged with conspiracy to commit murder, accessory to murder, and accessory to assault in the first degree with a firearm. The trial was joined with the elder brother’s case and went before a jury, which convicted the defendant on all counts. The trial court rendered judgment in accordance with the verdict and sentenced the defendant to fifty years in prison. The defendant appealed directly to the Supreme Court of Connecticut, raising constitutional and evidentiary challenges, including the sufficiency of the evidence identifying him as the driver and the use of prior inconsistent statements under the State v. Whelan doctrine.The Supreme Court of Connecticut held that it would not overrule State v. Whelan, reaffirming the substantive admissibility of certain prior inconsistent statements. The court also declined to overrule State v. Newsome, finding that the challenged identification was corroborated by other evidence. The court refused to abrogate the excited utterance exception to hearsay and determined that the evidence was sufficient for the jury to find the defendant guilty. The judgment of conviction was affirmed. View "State v. Franqui" on Justia Law

Law enforcement suspected an individual of drug trafficking activity from his home in Oklahoma. Investigators used a confidential informant and GPS tracking of a known methamphetamine dealer’s vehicle, which led them to the suspect’s residence. A search of trash from the property revealed syringes and baggies that tested positive for methamphetamine, along with mail addressed to the suspect. Agents learned the suspect was a member of the Cherokee Nation and had a significant criminal history involving drugs. Because the house was in Indian Country and the suspect’s co-resident was a non-Indian, officers sought warrants from both a tribal and a state judge. The tribal judge issued a warrant based on the initial affidavit, while the state judge initially denied a similar application but later granted one after additional information was provided. Officers executed the search under the tribal warrant and found drugs, paraphernalia, and firearms.In the United States District Court for the Northern District of Oklahoma, the defendant moved to suppress the evidence found during the search, arguing it was the fruit of an unlawful search, and to compel disclosure of the government’s confidential informant. The district court denied suppression, applying the good-faith exception, and also denied the motion to compel after the government stated it would not use the informant or related evidence at trial.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that the search was supported by probable cause and that the good-faith exception to the exclusionary rule applied even though the state judge initially denied a similar warrant. The court also found no violation of Federal Rule of Criminal Procedure 41, as the search was not federal in character. Regarding the confidential informant, the appellate court held that the defendant waived his argument about disclosure aiding his suppression hearing, as this was not raised below. The conviction was affirmed. View "United States v. Holt" on Justia Law

Oscar Hudspeth, a member of the Oglala Sioux Tribe, was convicted by a jury of two sex abuse offenses involving his young stepdaughter, D.J., which occurred when she was between five and seven years old and living in his home. The prosecution’s evidence included D.J.’s testimony about the abuse and statements Hudspeth made during a post-polygraph interview with an FBI agent, where he admitted to inappropriate touching. Prior to trial, both parties agreed to exclude any reference to the polygraph test from evidence, and the district court admitted a redacted version of the interview transcript omitting mention of the polygraph.In the United States District Court for the District of South Dakota, Hudspeth moved to either exclude the entire interview or, alternatively, to ensure all polygraph references were redacted. When it became clear that a redacted version would be admitted, Hudspeth changed his position, seeking to admit the entire interview, including polygraph references, to provide context for his admissions. The district court admitted the redacted interview and excluded polygraph references, noting that Hudspeth had earlier agreed to the exclusion. Hudspeth was ultimately found guilty and sentenced to the mandatory minimum term.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether excluding polygraph references violated Hudspeth’s constitutional right to present a complete defense. The court held that the exclusion did not violate his constitutional rights or constitute an abuse of discretion. It found that polygraph evidence is generally unreliable and disfavored, and that the exclusion was neither arbitrary nor disproportionate. The court concluded that even if there was error, it was harmless beyond a reasonable doubt due to the strength of the prosecution’s case. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Hudspeth" on Justia Law

Police in Bloomington, Minnesota, stopped a vehicle after observing a suspended object hanging from the rearview mirror and learning that the vehicle’s registered owner, Damion Kent Hallmon, had a suspended license. Hallmon was driving, accompanied by his fiancée, Ieisha McGrone, and their two children. During the stop, police observed a bag that appeared to contain marijuana, prompting a search of the vehicle. In a handbag on the front passenger seat, officers found a loaded pistol. Both Hallmon and McGrone made statements regarding the gun, with Hallmon ultimately admitting ownership and describing the firearm. Hallmon was arrested and charged with being a felon in possession of ammunition.Before trial in the United States District Court for the District of Minnesota, Hallmon moved to suppress the evidence and statements from the stop, and to dismiss the indictment on Second Amendment grounds. A magistrate judge recommended denial of the suppression motions, and the district court adopted this recommendation and denied the dismissal motion. At trial, the government presented testimony that the ammunition traveled in interstate commerce. Hallmon attempted to introduce recorded jail calls with McGrone, but the district court excluded them as hearsay. The jury found Hallmon guilty, and the district court imposed a two-level sentencing enhancement for obstruction of justice, sentencing him to 74 months’ imprisonment and three years’ supervised release.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that the stop, search, and seizure were constitutional; Hallmon was not in custody for Miranda purposes when making statements; sufficient evidence supported the interstate commerce element; exclusion of the jail calls was proper; the obstruction of justice enhancement was warranted; and existing circuit precedent foreclosed Hallmon’s Second Amendment challenge. View "United States v. Hallmon" on Justia Law

The defendant was convicted by a jury of first-degree felony murder, aggravated burglary, attempted aggravated robbery, two counts of aggravated assault, and criminal possession of a weapon after a 2016 home invasion and homicide. Following a mistrial at his first proceeding, a second trial resulted in convictions on all charges. At his original sentencing, the district court calculated the defendant’s criminal history score as A, in part based on a 2003 criminal-threat conviction, and imposed a life sentence without parole eligibility for 653 months, plus consecutive sentences on the remaining counts.On appeal from the original sentencing, the Supreme Court of Kansas affirmed the convictions but vacated the sentence. The court concluded that the district court erred in including the 2003 conviction in the criminal history score, as the statute under which it was obtained had been found unconstitutional in part by the Supreme Court of Kansas in State v. Boettger, 310 Kan. 800 (2019). The court remanded the case for resentencing with instructions not to include the 2003 conviction. On remand, the district court recalculated the criminal history score as B and resentenced the defendant accordingly, reducing the parole eligibility period and other determinate sentences. The court denied the defense’s renewed motion for a departure sentence.The Supreme Court of Kansas reviewed the appeal from resentencing. The defendant raised, for the first time, constitutional challenges to the Kansas Sentencing Guidelines Act, arguing that it violated his jury trial rights by permitting a judge to determine prior convictions that enhance punishment. The court declined to review these unpreserved claims, finding that settled law foreclosed relief. The defendant’s claim for additional jail credit was rendered moot by a nunc pro tunc order from the district court. The Supreme Court of Kansas affirmed the judgment of the district court. View "State v. Smith " on Justia Law