Justia Criminal Law Opinion Summaries

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In the case before the Court of Appeal, Fourth Appellate District Division One State of California, the defendant, Devin Gaillard, appealed from a lower court decision denying his petition for resentencing on a 2014 voluntary manslaughter conviction under Penal Code section 1170.95 (now § 1172.6). Gaillard argued that he had established a prima facie case because the record of conviction did not conclusively establish his ineligibility for relief. The People, represented by the Attorney General, conceded this error and agreed that the order must be reversed.Gaillard had initially pled guilty to counts of voluntary manslaughter and transportation of marijuana, admitting that he "aided [and] abetted the voluntary manslaughter of Dillon Davis [and] transported marijuana." The trial court sentenced him to a 25-year prison term.In 2022, Gaillard filed a petition for resentencing under section 1172.6. However, the trial court denied the petition, concluding that Gaillard was a direct aider and abettor and therefore ineligible for relief under the law. Gaillard then filed a timely appeal.The appellate court concluded that the trial court erred in its decision. It found that Gaillard’s guilty plea did not conclusively establish his ineligibility for relief under section 1172.6. The court ruled that Gaillard’s admission that he aided and abetted in the crime did not definitively establish that he could still be convicted of murder under current law, which requires the defendant to personally harbor malice aforethought. The appellate court reversed the trial court’s order and remanded the matter for further proceedings, directing the trial court to issue an order to show cause and hold an evidentiary hearing on the petition. View "People v. Gaillard" on Justia Law

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The California Fifth Appellate District Court examined a case where the defendant, Brandon Michael Patterson, petitioned for resentencing under Penal Code section 1172.6. Patterson was initially convicted for first-degree murder and sentenced to 25 years to life. He later petitioned for resentencing, claiming that he did not meet the criteria for murder under changes made to sections 188 and 189. The lower court agreed and redesignated his murder conviction as attempted robbery and first-degree residential burglary.However, the appellate court found that the murder conviction could not be redesignated as a first-degree residential burglary because it was not the "underlying felony" of Patterson's felony-murder conviction. Based on the instructions given to the jury during the original trial, the only "underlying felony" was attempted robbery. The court ruled that the term "underlying felony" refers to the specific crime that underlies a felony-murder conviction, which, in this case, was attempted robbery. Consequently, the court reversed the lower court's decision to redesignate the murder conviction as a first-degree residential burglary, and remanded the case for Patterson to be sentenced on the redesignated attempted robbery conviction. View "People v. Patterson" on Justia Law

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The case concerns an appeal by Andrew Ocanas Garza against his conviction and a 235-month sentence for drug trafficking and firearm possession. Garza argued that the court incorrectly used his 2016 felony drug offenses for sentencing enhancement, contending that the 2018 amendment to the Agricultural Improvement Act altered marijuana’s definition, potentially excluding the substance he was previously convicted for trafficking. He also claimed that the court erred by not suppressing an unMirandized statement he made about having a gun in his bedroom during the execution of a search warrant.The United States Court of Appeals for the Fifth Circuit affirmed the District Court's ruling. The Appeals Court held that Garza waived his right to challenge the admission of the Bedroom Gun statement by bringing it up during the trial. The Court also rejected Garza's argument concerning the sentencing enhancement based on his 2016 drug convictions. The Court applied the "backward-looking" test, which determines whether the prior convictions were felonies at the time of conviction and were final at the time of sentencing for the current crimes. The Court found that Garza's 2016 convictions met these criteria, making them applicable for sentencing enhancement. The Court also noted that even if the District Court had erred in applying the sentencing enhancement, the error was harmless, as the same sentence would have been imposed. View "United States v. Garza" on Justia Law

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This case relates to the admission of an investigator's testimony from a preliminary hearing in a subsequent trial. The appellant, Maurice Kent, was a member of a violent gang and was charged with RICO conspiracy and five other substantive crimes, including the attempted murder of Shadeed Muhammad. The government alleged that the gang murdered a former member, Qualeef Rhode, for cooperating with the police’s investigation into the attempted murder. The government introduced an investigator’s testimony from a preliminary hearing in a related case, which identified Rhode as cooperating with law enforcement to implicate Kent in the attempted murder. Kent argued that this testimony was hearsay and its admission violated his Confrontation Clause rights.The United States Court of Appeals for the Eleventh Circuit rejected Kent's arguments and affirmed the decision of the district court. The court held that the investigator's testimony was not hearsay because it was offered for the effect it had on the listeners (other gang members) and not for the truth of the matter asserted. It was relevant because it influenced Kent and the other gang members who heard the testimony at the preliminary hearing, providing them with a motive to murder Rhode. The court also determined that the district court had sufficiently reduced the risk that the jury would improperly consider the out-of-court statement for the truth of the matter asserted by redacting the most prejudicial portions of the testimony and instructing the jury to consider the testimony only for its effect on the listeners. Therefore, the admission of the testimony did not violate Kent's rights under the Confrontation Clause. View "United States v. Kent" on Justia Law

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In the case before the United States Court of Appeals for the Seventh Circuit, the petitioner, Monta Anderson, sought to vacate his guilty plea for conspiring to distribute heroin, claiming that his plea was not knowing and voluntary due to his counsel's alleged ineffective assistance. Anderson argued that his counsel advised him to plead guilty without first consulting a toxicology expert on whether the heroin he distributed was a but-for cause of a user's death. Previously, the court had remanded the case for an evidentiary hearing, concluding that Anderson had articulated a viable claim of attorney ineffectiveness.On remand, Anderson presented evidence that consultation with a toxicology expert would have revealed the government's inability to prove beyond a reasonable doubt that the heroin he supplied was a but-for cause of the user's death. However, the government argued that even without the death-results enhancement, Anderson would have faced a mandatory life term due to his prior felony drug convictions and the fact that two individuals suffered serious bodily injuries from overdosing on heroin supplied by Anderson.Having considered the evidence and arguments, the court concluded that Anderson was not prejudiced by any alleged ineffectiveness of his counsel. Even if the death-results enhancement were discounted, Anderson still faced a mandatory life term due to his prior felony drug conviction and the serious bodily injuries caused by his heroin distribution. As such, his decision to plead guilty and accept a 20-year sentence was reasonable. Therefore, the court affirmed the district court's judgment denying Anderson's motion to vacate his guilty plea. View "Anderson v. United States" on Justia Law

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In this case, the United States Court of Appeals for the Seventh Circuit considered an appeal by Linnel Blount, Jr., who was convicted on drug and gun charges in 2019 and sentenced to 63 months in prison. Blount's jury trial was initially set for February 2020 but was postponed to March 2020 at his request. However, due to the COVID-19 pandemic, a series of court orders suspended criminal jury trials from March 2020 through April 2021. The district judge deferred Blount's trial further during this period, citing health and safety considerations. Blount eventually waived his jury trial and agreed to a bench trial, which commenced in July 2021.On appeal, Blount argued that his indictment should have been dismissed under the Speedy Trial Act because the delay of his trial was based on the general pandemic-related court orders rather than individualized, case-specific circumstances. However, the court of appeals found that Blount's lawyer did not make a formal motion to dismiss the indictment, which is necessary under the Speedy Trial Act. Moreover, the court determined that the district judge was not required to interpret Blount's pro se filings as implicit motions to dismiss.More broadly, the court held that the Speedy Trial Act does not require judges to reiterate considerations that have already been established by the court as an institution. It concluded that the delay of criminal jury trials during the COVID-19 pandemic was justified by societal, not personal, considerations, and that such delays were permissible under the Speedy Trial Act. The court affirmed Blount's conviction and sentence. View "United States v. Blount" on Justia Law

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The case concerns an appeal by Brandon Cade against a ruling by the United States District Court for the Northern District of Illinois, Eastern Division, before the United States Court of Appeals For the Seventh Circuit. Cade was arrested by Chicago police officers who noticed an open bottle of alcohol in a sedan next to which Cade and another individual were standing. During a search of the car, officers found an unlicensed firearm and Cade admitted it was his. He was charged with possession of a firearm by a felon. Cade argued to suppress evidence of the gun and his incriminating statements, but the district court denied his motion. Cade pleaded guilty but reserved his right to appeal the suppression ruling. He argued that his initial encounter with the officers was an unlawful seizure and that his incriminating statements should be suppressed because the officers did not have reasonable suspicion to seize him.The Court of Appeals affirmed the lower court's ruling. The court found that the initial encounter with the officers was consensual and did not constitute a seizure. The court also ruled that even if there was an unlawful seizure, Cade's incriminating statements were sufficiently attenuated from any allegedly unlawful conduct. The presence of the open alcohol bottle provided probable cause for the search, which led to the discovery of the firearm, and Cade's admission to owning the firearm occurred after he was read his Miranda rights. The court concluded that there was no evidence of bad faith by the officers, and that an evidentiary hearing was not needed as there were no material factual disputes. View "United States v. Cade" on Justia Law

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In this case, Tony Doolin was sentenced to 60 months of imprisonment and four years of supervised release for distribution of crack cocaine. After his release, Doolin lived in Iowa and possessed a medical-marijuana card, which permitted him to obtain medical marijuana under Iowa law. However, his supervised release was revoked due to his ongoing marijuana use and his distribution of medical marijuana to his girlfriend. Doolin appealed this decision, arguing that it violated the Appropriations Clause of the United States Constitution, due to the Consolidated Appropriations Act (CAA) of 2023. This act prohibits the Department of Justice (DOJ) from using funds to prevent states from implementing their own medical marijuana laws.The United States Court of Appeals for the Eighth Circuit affirmed the decision of the District Court for the Northern District of Iowa, holding that the revocation of Doolin's supervised release did not violate the Appropriations Clause or the CAA of 2023. The court noted that marijuana possession remains illegal under federal law, regardless of any state laws or limits on prosecutorial funding. Federal courts are required to impose a prohibition on a defendant’s unlawful possession or use of all controlled substances, including marijuana, as a condition of any term of supervised release. Even if section 531 of the CAA prohibits the DOJ from funding marijuana-related prosecutions or revocations, where doing so prevents a state from implementing its medical marijuana laws, the district court did not abuse its discretion in revoking Doolin’s supervised release. Doolin engaged in unlawful conduct, even under Iowa’s medical-marijuana regime, as private distribution of marijuana is illegal under Iowa law, as is smoking marijuana, even for medical purposes. Therefore, the court found that the revocation of Doolin's supervised release was not prohibited by the CAA, and the district court did not abuse its discretion in revoking Doolin's supervised release. View "United States v. Doolin" on Justia Law

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In the case before the United States Court of Appeals for the Eighth Circuit, the defendant Mary Linnell appealed her conviction for possession with intent to distribute a controlled substance. The case arose after a traffic stop during which law enforcement officers found methamphetamine, cocaine, and drug paraphernalia in the vehicle in which she was a passenger. Linnell moved to suppress the evidence, arguing that the patrol officer lacked probable cause or reasonable suspicion to conduct the traffic stop. The district court denied the motion, and Linnell entered a conditional guilty plea, preserving her right to appeal the suppression ruling. She was sentenced to 92 months’ imprisonment with 5 years of supervised release to follow.On appeal, Linnell contended that the district court erred in denying her motion to suppress, asserting that the officer lacked probable cause or reasonable suspicion to conduct the traffic stop. The appellate court disagreed, ruling that the district court did not clearly err in finding that the officer observed three traffic violations (running a stop sign, following another vehicle too closely, and speeding), and therefore had probable cause to conduct the traffic stop. The court gave deference to the lower court's credibility determination of the officer's testimony, noting that the officer had several years of experience and had been involved in hundreds of traffic stops. The judgment of the district court was affirmed. View "United States v. Linnell" on Justia Law

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In this case, Chad Michael Rider was convicted of three counts of producing or attempting to produce child pornography in violation of 18 U.S.C. § 2251(a) and was sentenced to 720 months’ imprisonment. The evidence presented included numerous videos that Rider had taken of minors, in various stages of undress, in places where they expected privacy such as bathrooms. Rider appealed his conviction and sentence on several bases, including arguing that his conversation with police officers, where he admitted to setting up cameras, should have been suppressed, that expert testimony about his lack of pedophilic tendencies should have been admitted, that there was insufficient evidence to support his convictions, that the jury instructions constructively amended the indictment, and that his sentence was unreasonable.The United States Court of Appeals for the Fifth Circuit rejected all of Rider's arguments and affirmed his conviction and sentence. The court found that Rider was not in custody when he spoke to the officers, and so his statements were not involuntary. The court also found that there was no error in excluding the expert testimony, as it was not relevant to any element of the charges that the government had to prove. The court also found that there was sufficient evidence to support the convictions, as there was ample evidence that Rider had the intent and took the necessary steps to produce child pornography. The court also ruled that the jury instructions did not constructively amend the indictment. Finally, the court found that the sentence was not unreasonable, given the uniquely disturbing facts of the case and Rider's lack of remorse. View "United States v. Rider" on Justia Law