Justia Criminal Law Opinion Summaries

After receiving a citizen’s tip that Black males in a Mercedes were “acting shady,” four San Diego Police Department (SDPD) officers drove to the scene in two marked vehicles, activating emergency lights in one. Parking behind the Mercedes, the officers positioned themselves beside each of its four doors and asked the three teenagers inside for their names and identification. A records check later indicated that the driver was on probation subject to a Fourth Amendment waiver. The officers searched the vehicle and recovered a loaded firearm and sneakers linking the minors to a recent robbery. The minors moved to suppress the evidence found in the car, claiming their initial detention was not supported by reasonable suspicion. Finding the encounter was consensual rather than a detention, the juvenile court denied the motions. Two of the minors pleaded guilty to a subset of the charges originally filed. In a consolidated appeal, two of the minors, Edgerrin J. and Jamar D. challenged the denial of their motions to suppress, arguing the juvenile court erred in finding the encounter consensual, and claimed the citizen’s tip did not establish reasonable suspicion to detain them. To this, the Court of Appeal agreed on both points. However, the Court found conflicting evidence as to whether officers knew other facts that might furnish reasonable suspicion for the stop, or justify the detention and search pursuant to Edgerrin’s active Fourth Amendment waiver. Because the rationale for its ruling made it unnecessary for the juvenile court to address these other issues, judgment was reversed and remanded for a new hearing to permit it to assess witness credibility and reach factual findings in the first instance. View "In re Edgerrin J." on Justia Law

Fields filed claims under 42 U.S.C. 1983 and state law against Chicago, Chicago police officers, and former Cook County prosecutors. Fields alleged that the defendants violated his constitutional rights and state law by fabricating evidence and withholding exculpatory evidence in a criminal investigation that resulted in Fields’s conviction for a 1984 murder. A retrial resulted in an acquittal, 12 years after the original trial. The individual who had implicated Fields in the crimes eventually confessed to committing the murder. Fields sought a certificate of innocence, which was denied.After a third trial, the jury found in favor of Fields against Detectives O’Callaghan and Murphy on one of his section 1983 claims, against Chicago on Fields’s Monell liability claim, and against O’Callaghan on a claim for intentional infliction of emotional distress, and found for the defendants on the remaining claims. The jury awarded Fields $22 million in compensatory damages and punitive damages of $30,000 against O’Callaghan and $10,000 against Murphy. The Seventh Circuit affirmed, rejecting the detectives’ challenges to evidentiary rulings concerning wiretaps, character evidence, evidence of Fields’s 1972 murder conviction, and evidence concerning prison incidents. The evidence allowed a jury to conclude that the city had failed to take the necessary steps to address an unconstitutional practice of using street files and that there was a “systemic underproduction of exculpatory materials to prosecutors and defense counsel.” View "Fields v. City of Chicago" on Justia Law

In 2015, a jury convicted Daniel of second-degree murder in the death of his girlfriend. He was sentenced to 15 years to life in prison. In 2018, Senate Bill 1437 altered liability for murder under the theories of felony murder and natural and probable consequences and established a procedure, Penal Code section 1170.95, for eligible defendants to seek resentencing. Daniel filed a petition for relief, alleging that he was convicted of murder under the natural and probable consequences doctrine or the felony murder doctrine and could no longer be convicted of murder because of Senate Bill 1437’s changes to the law.The trial court summarily denied the petition, reasoning that the jury was not instructed on either theory of liability and the record showed Daniel was the actual killer. The court of appeal affirmed. Although the judge who ruled on the petition failed to appoint counsel and was not the sentencing judge, both violations of section 1170.95, the errors were harmless. A court’s failure to appoint counsel after a petitioner files a facially sufficient petition for relief is not prejudicial error when records in the court’s own file—here, the jury instructions— demonstrate that the petitioner is ineligible for relief as a matter of law. View "People v. Daniel" on Justia Law

In 2019, Jones pleaded guilty to possession with intent to distribute and distribution of cocaine base and was sentenced to the mandatory minimum of 10 years’ imprisonment. Jones filed a pro se emergency motion, seeking compassionate release because of the pandemic. Jones may have respiratory issues, is over 40 years old, and is obese. One out of every four prisoners has tested positive for COVID-19 in the prison where Jones is incarcerated.District courts may reduce the sentences of incarcerated persons in “extraordinary and compelling” circumstances, 18 U.S.C. 3582(c)(1)(A). Previously, only the Bureau of Prisons could file motions for compassionate release. The Bureau rarely did so. The 2018 First Step Act allows incarcerated persons to file their own motions.The Sixth Circuit affirmed the denial of Jones’s motion. In making sentence-modification decisions under section 3582(c)(1)(A), district courts must find both that “extraordinary and compelling reasons" warrant the reduction and that the "reduction is consistent with applicable policy statements issued by the Sentencing Commission” before considering relevant 18 U.S.C. 3553(a)sentencing factors. Sentencing Guideline 1B1.13, which has not been amended to reflect the First Step Act, is not an “applicable” policy statement in cases where prisoners file their own motions. District courts must supply specific factual reasons for their decisions. Here, the court found for the sake of argument that an extraordinary and compelling circumstance existed but that section 3553(a)'s factors counseled against granting release. View "United States v. Jones" on Justia Law

The Ninth Circuit reversed the district court's denial of defendant's motion to suppress a firearm found in a search of his car, vacated his conviction for being a felon in possession of a firearm, and remanded for further proceedings.The panel held that police officers who have reasonable suspicion sufficient to justify a traffic stop—but who lack probable cause or any other particularized justification, such as a reasonable belief that the driver poses a danger—may not open the door to a vehicle and lean inside. In this case, the officer conducted an unlawful search in violation of the Fourth Amendment when he opened the car door and leaned into it to ask defendant for his driver's license and vehicle registration. The panel concluded that nothing about this case calls for a remedy other than the typical remedy for Fourth Amendment violation, which is the exclusion of evidence discovered as a result of that violation from criminal proceedings against defendant. Therefore, the firearm must be suppressed under the exclusionary rule. View "United States v. Ngumezi" on Justia Law

The Ninth Circuit reversed and remanded the district court's denial of qualified immunity to Pelican Bay State Prison officials in a civil rights action brought by plaintiff, an inmate at Pelican Bay, alleging claims over prison noise stemming from the orders of a federal district court adopting recommendations of its Special Master to implement round-the-clock welfare checks to prevent inmate suicides in California's prison system.The panel held that, on the specific facts presented here, no reasonable officer would have understood that these court-ordered actions were violating the constitutional rights of the inmates. The panel explained that, even if the Pelican Bay officials haphazardly implemented the Guard One system, no reasonable official in these circumstances would believe that creating additional noise while carrying out mandatory suicide checks for prisoner safety clearly violated plaintiff's constitutional rights. In this case, where defendants were following court-ordered procedures to enhance inmate safety that are inherently loud, all Pelican Bay officials are entitled to qualified immunity. View "Rico v. Ducart" on Justia Law

In January 2019, 15-year old Heather Juliano was a passenger in a sport-utility vehicle driven by Shakyla Soto in the vicinity of the Capital Green development in Dover, Delaware. Corporal Robert Barrett of the Dover Police Department was patrolling the area, accompanied by Probation Officer Rick Porter, as part of the Department’s Safe Streets program. Corporal Barrett spotted Soto’s SUV exiting Capital Green and noticed that the occupant of the front passenger seat was not wearing a seat belt. Corporal Barrett decided to pull the vehicle over. Almost immediately after Barrett initiated contact with the driver, he heard Porter say “1015 which means take . . . everybody into custody.” Three other Dover Police Department officers arrived on the scene in very short order. All four occupants of the SUV were removed from the vehicle and handcuffed in response to Porter’s order. The SUV was then searched, but no contraband was found. One officer searched backseat passenger Keenan Teat and found a knotted bag containing crack cocaine in one of his pants pockets. Another officer searched passenger Zion Saunders and found both marijuana and heroin in his jacket pockets. But when Officer Johnson searched Juliano, he found no contraband, but $245.00 in cash. Juliano was later taken to the police station, and strip-searched. Officers found marijuana and a bag of cocaine in her pants. Juliano was charged with Tier 1 possession of narcotics plus an aggravating factor (aggravated possession of cocaine), drug dealing, and possession of marijuana. The Delaware Supreme Court determined there was nothing unreasonable in a motor vehicle stop based on an officer's reasonable suspicion the operator or occupant of the vehicle committed a violation of the law - here, traffic laws. "Equally so, we are not prepared to say that, once a vehicle is lawfully stopped, the police must ignore evidence of other criminal activity when that evidence itself is lawfully uncovered." Rejecting Juliano's appellate claims with regard to the initial traffic stop and the suppression od evidence, the Supreme Court felt compelled to address "certain conspicuous irregularities" in the trial court's order denying Juliano's motion to suppress: (1) the trial court did not articulate a basis for finding a reasonable suspicion sufficient to justify the extension of the traffic stop to investigate the vehicle's occupants; and (2) the court's order did not explain the basis upon which the custodial arrest and threatened strip search were justified. The matter was remanded to the trial court for more complete statements of the factual and legal bases with respect to Juliano's search and subsequent arrest. View "Juliano v. Delaware" on Justia Law

In 1969, then 20-year old Williams and two juveniles committed an attempted robbery of a milkman; the milkman was fatally shot. Williams was convicted of first-degree murder. The court noted that the overwhelming evidence that Williams was present and participated. After serving seven years, Williams was released on parole. In 1979, he committed another murder. Williams was convicted of second-degree murder.In 2019, Williams sought to vacate his 1969 conviction. He cited the sentencing transcript in which the court had stated the crime was “senseless and cruel" but "not deliberate and premeditated,” and the expression of “some doubt" that Williams "did the actual killing’” and a 2014 decision by former Governor Brown reversing a favorable parole recommendation, stating that “Williams’ crime partners shot and killed a milkman.” The court found Williams not eligible for resentencing because he could have been found guilty of first-degree murder under the newly-amended Penal Code 189 as a major participant who acted with reckless indifference to human life in the commission of felony murder.The court of appeal affirmed. The robbery was planned at Williams's home. Williams held the gun, which contained at least three bullets; the court could reasonably infer that Williams had a reasonable expectation that death could result. He had an opportunity to act as a restraining influence on the attempted robbery and the juveniles. After the shooting, the three fled without calling for assistance or attempting to render aid to the victim who did not die at the scene. View "People v. Williams" on Justia Law

Loren Larson, Jr. was convicted in 1998 of two counts of first-degree murder and one count of first-degree burglary, and he was sentenced to two consecutive 99-year terms for the murder counts and a 10-year concurrent term for the burglary count; the court of appeals affirmed Larson’s conviction in 2000. In 2003, the court of appeals affirmed the superior court’s subsequent dismissal of Larson’s post-conviction relief claim. Larson maintained his innocence and has unsuccessfully challenged the convictions in numerous other proceedings. Larson claimed he wanted to apply for clemency from the Alaska Governor on grounds he was innocent and wrongly convicted, But he did not want to execute two required information release forms that were part of the clemency application. Larson was advised by the Board of Parole that under the current administrative framework an incomplete application would be returned to him and not forwarded to the governor. Larson then sued the Board, arguing that its refusal to forward his application without the release forms violated his due process right to submit a clemency application. He further argued that enforcing the information release requirement would violate the unconstitutional conditions doctrine, which in some contexts barred the government from conditioning a benefit on the waiver of a constitutional right. The superior court granted summary judgment to the Board, rejecting the applicant’s constitutional arguments. Because the Board did not violate the applicant’s constitutional rights, the Alaska Supreme Court affirmed the superior court’s dismissal of the lawsuit. View "Larson Jr. v. Alaska, Department of Corrections, Board of Parole" on Justia Law

The Court of Appeal held that custody credits do not accrue with each Post Release Community Supervision (PRCS) flash incarceration or jail sanction, thereby shortening the PRCS three-year supervision period. The court stated that the very thought of custody credits whittling down a PRCS supervision period is counter-intuitive and counterproductive.The court exercised its discretion to resolve the appeal, despite claims of mootness, rejecting defendant's claims that custody credits accrue with each PRCS flash incarceration and jail incarceration, and the custody credits automatically shorten the three-year PRCS supervision period. The court explained that PRCS was enacted to rehabilitate nonviolent felons at the local level, not to reward the felon with custody credits that can theoretically reduce the PRCS supervision period to zero. Furthermore, the word "supervision" in PCRS means just that. Because PRCS supervision is not a sentence, the supervision period is not shortened by custody credits. Finally, the court held that this appeal is consistent with People v. Espinoza (2014) 226 Cal.App.4th 635. The court affirmed the order revoking PRCS and ordering 180 days county jail, and order denying motion to terminate PRCS supervision. View "People v. Shelp" on Justia Law