Justia Criminal Law Opinion Summaries

In June 2023, the defendant was arrested for selling a substantial quantity of methamphetamine to a government informant in two separate transactions, leading to a two-count federal indictment for drug trafficking offenses. Before pleading guilty to one count (with the other dismissed as part of a plea agreement), the defendant successfully petitioned a Mississippi state court to expunge a 2006 felony marijuana conviction. The expungement order, granted without a hearing or any findings of rehabilitation, restored the defendant to his pre-arrest legal status but preserved certain nonpublic records and did not address potential use in later proceedings.During sentencing in the United States District Court for the Northern District of Mississippi, the presentence report included the expunged marijuana conviction in the defendant’s criminal history, resulting in a higher offense level and a calculated guideline range of 262 to 327 months. The defendant objected, arguing the expunged conviction should not count. The district court overruled this objection, finding the expungement did not meet federal Sentencing Guidelines criteria, particularly as it was not based on innocence or legal error, and was instead a mechanism to restore civil rights. The court also questioned the circumstances of the expungement but ultimately imposed a below-guidelines sentence of 180 months, stating it would have imposed the same sentence even if the prior conviction had not been counted.On appeal, the United States Court of Appeals for the Fifth Circuit held that the district court properly included the expunged conviction in the criminal history calculation. The Fifth Circuit clarified that, under the Sentencing Guidelines, only convictions expunged due to innocence or legal error are excluded; expungements granted for other reasons, such as restoring civil rights, must be counted. The court affirmed the sentence. View "United States v. Payne" on Justia Law

The defendant was charged with multiple offenses after causing a fatal collision while driving at over 100 miles per hour, resulting in the deaths of two victims. The defendant’s blood alcohol content was 0.17, and he also tested positive for cannabis. He was charged with gross vehicular manslaughter while intoxicated, several counts of driving under the influence causing injury, and other traffic violations. The factual basis for the plea was agreed upon by both the prosecution and defense, confirming the defendant’s responsibility for the collision.The Kings County Superior Court accepted the defendant’s no contest plea to the charges and enhancements. The court sentenced him to a total of nine years in prison, including terms for gross vehicular manslaughter and the multiple victim enhancement. Sentences for other counts and enhancements were imposed and stayed under Penal Code section 654, and several lesser charges were dismissed pursuant to a plea agreement.On appeal, the California Court of Appeal, Fifth Appellate District, reviewed the defendant’s argument that convictions for driving under the influence causing injury should be reversed because that offense is a lesser included offense of gross vehicular manslaughter while intoxicated. The court applied the legal standard that a lesser included offense must be necessarily committed as part of the greater offense, focusing on the abstract elements rather than the specific facts of the case. The court held that driving under the influence causing injury is not a necessarily included offense of gross vehicular manslaughter while intoxicated, as the latter can be committed in ways that do not require the commission of the former. Accordingly, the court affirmed the judgment of the Superior Court of Kings County. View "People v. Yanez" on Justia Law

Law enforcement officers seized $379,744 in U.S. currency during a search of a Stockton residence linked to Christian Valle and Yessina Vaca. Both were criminally charged with possession of controlled substances for sale. Concurrently, civil forfeiture proceedings were initiated against the seized currency, alleging it was connected to narcotics trafficking. Valle, Yessina, and Jesus Vaca (Yessina’s father) each claimed lawful ownership of portions of the money, with Jesus asserting that a substantial amount belonged to him, earned through legitimate means such as agave farming and construction work. The evidence at trial included large sums of cash found in various containers, drug paraphernalia, and firearms located at a separate residence belonging to Jesus.After the related criminal proceedings concluded, the civil forfeiture case proceeded to a jury trial in the Superior Court of San Joaquin County. The jury found that Jesus had an ownership interest in the seized funds and that some portion was either innocent or he did not know of or consent to its illegal use. However, the jury ultimately awarded Jesus none of the seized money. Yessina was awarded $829, while Valle was found not entitled to any funds. The trial court entered judgment forfeiting all but $829 of the currency and denied posttrial motions challenging the verdicts as inconsistent.The California Court of Appeal, Third Appellate District, reviewed the case and concluded that the jury’s special verdicts as to Jesus were irreconcilably inconsistent. The court held that, under the governing statutes, once the jury found Jesus had an ownership interest and that some portion of his funds were innocent or not knowingly or consensually used for illegal purposes, it was legally required to return an amount greater than zero to him. As a result, the judgment as to Jesus was reversed and remanded for a new trial, while the judgments as to Valle and Yessina were affirmed. View "People v. $379,744 U.S. Currency" on Justia Law

While serving a term of supervised release for prior, unrelated convictions, an individual was found by probation officers to have acquired several weapons, including a loaded assault-style rifle. During subsequent proceedings, the individual attempted to persuade a young man to falsely claim ownership of the rifle at a revocation hearing, offering payment and making threats against the young man’s mother. The young man later recanted and disclosed the threats and payment. As a result, a jury convicted the individual of unlawful possession of a firearm and of witness tampering.The United States District Court for the Northern District of West Virginia received a presentence investigation report that set the base offense level at twenty-six under the Sentencing Guidelines, citing the type of firearm and the defendant’s two prior controlled substance felony convictions—one federal and one under West Virginia law. The defendant objected pro se to considering the state conviction as a qualifying offense, and also argued for a downward departure based on alleged mistreatment while in pretrial detention. At sentencing, the district court adopted the presentence report in full, imposed enhancements for obstruction, and, after weighing the 18 U.S.C. § 3553(a) factors and considering arguments from both sides, denied a downward departure. The court imposed concurrent sentences of 120 months for the firearm offense and 180 months for witness tampering, citing the seriousness of the conduct and the defendant’s lengthy, violent criminal history.The United States Court of Appeals for the Fourth Circuit reviewed the sentence. It held that the district court did not plainly err in treating the West Virginia conviction as a qualifying controlled substance offense for Guidelines purposes and that the district court did not abuse its discretion in addressing the defendant’s sentencing arguments. The Fourth Circuit affirmed the sentence. View "United States v. Wable" on Justia Law

The defendant was charged with conspiracy to possess with intent to distribute and distribute 500 grams or more of methamphetamine, a violation of federal law. He entered into a written plea agreement, in which he acknowledged understanding the nature and elements of the charge, agreed he was guilty, and specifically waived his right to appeal except for limited circumstances. During the plea colloquy, the district court confirmed the defendant’s understanding of the plea and the appeal waiver, and reviewed the drug quantity at issue. The defendant and his counsel reserved the right to object to specific drug amounts attributable to him, but agreed there was a sufficient factual basis for the essential elements of the crime, including responsibility for at least 500 grams of methamphetamine.After entering his plea, and nearly a year later, the defendant moved to withdraw his guilty plea in the United States District Court for the District of North Dakota. He claimed that the court failed to establish an adequate factual basis for the drug quantity element, that he did not understand the nature of his offense, and that his plea was not voluntary. The district court denied the motion, finding that the record established an adequate factual basis for the drug quantity, that the defendant was aware of the nature of the offense, and that the plea was knowing and voluntary.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether the defendant’s plea and appeal waiver were entered knowingly and voluntarily, and whether enforcing the waiver would result in a miscarriage of justice. The court held that the record showed the defendant understood the charge, including the drug quantity element, and knowingly and voluntarily entered his plea and waiver. The court found no grounds for applying the miscarriage-of-justice exception. As a result, the Eighth Circuit enforced the appeal waiver and dismissed the appeal. View "United States v. Caster" on Justia Law

Two individuals were convicted of armed robberies and related firearms offenses in separate incidents, resulting in lengthy prison sentences due to mandatory minimums under 18 U.S.C. § 924(c). Years after their sentencing, Congress passed the First Step Act of 2018, which reduced mandatory penalties for repeat § 924(c) violations, but did not make these changes retroactive. Both individuals argued that, had they been sentenced under the amended law, their sentences would be significantly shorter. They sought sentence reductions under the compassionate release statute, 18 U.S.C. § 3582(c)(1)(A), asserting that the disparity created by the nonretroactive change constituted “extraordinary and compelling reasons” for release.The United States District Court for the Northern District of Iowa and the United States District Court for the Southern District of Iowa both rejected these arguments, relying on the Eighth Circuit’s prior decision in United States v. Crandall, which held that nonretroactive sentencing changes do not qualify as extraordinary and compelling reasons for compassionate release. Although the United States Sentencing Commission subsequently amended its policy statement to allow consideration of nonretroactive legal changes in some circumstances, the district courts concluded that Crandall remained controlling law in the Eighth Circuit and that the Commission’s policy statement was inconsistent with the statute.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district courts’ decisions. The Eighth Circuit held that, in light of the Supreme Court’s recent decision in Rutherford v. United States, nonretroactive sentencing amendments—standing alone or in combination with other insufficient factors—cannot constitute “extraordinary and compelling reasons” to reduce a sentence under § 3582(c)(1)(A), even if the Sentencing Commission’s policy statement suggests otherwise. The court affirmed the orders denying compassionate release. View "United States v. Loggins" on Justia Law

Josue Arita was charged in 2019 with two counts of aggravated criminal sodomy and two counts of aggravated indecent liberties with a child, specifically under statutory subsections criminalizing causing a child to engage in acts with a third party. At trial, the State presented evidence that Arita himself engaged in the acts, not that he caused the children to engage with others. The jury instructions and evidence focused on Arita as the direct actor rather than as an instigator involving a third party. A jury convicted Arita on all counts, and he was imprisoned.A panel of the Kansas Court of Appeals reviewed the case and reversed Arita’s convictions, vacating his sentences. The panel found that the State had failed to present evidence supporting the charged alternative means—crimes involving a third party—while evidence at trial supported other, uncharged means. Because of this mismatch between the charges and proof, the Court of Appeals determined that double jeopardy barred retrial. The State did not appeal, and the mandate issued.Arita subsequently filed a wrongful conviction claim under K.S.A. 60-5004 in the Wyandotte District Court, arguing he was factually innocent. The district court granted summary judgment to the State, concluding that Arita’s convictions were not reversed due to actual or factual innocence, but because of a legal error regarding the charging document and evidence. On direct appeal, the Supreme Court of the State of Kansas affirmed. The court held that for alternative means crimes, a claimant must show by a preponderance of the evidence that their conviction was reversed because they are factually or actually innocent of the overall crime, not just a specific alternative means. Because Arita failed to show factual innocence of the crimes as a whole, summary judgment for the State was affirmed. View "In re Wrongful Conviction of Arita " on Justia Law

A man shot and killed his pregnant girlfriend while she slept on a couch in his mother's apartment, then shot her again minutes later. Both the woman and her unborn child died. The man had a history of substance abuse, mental health issues, and trauma stemming from his father's murder and the surrounding police misconduct. After his arrest, he exhibited erratic behavior, and later pleaded guilty to two counts of premeditated first-degree murder—one for the girlfriend and one for the unborn child.Following the guilty plea, the parties jointly recommended concurrent sentences but disagreed on their length: the prosecution sought concurrent life sentences without parole for 50 years (“hard 50”), while the defendant sought concurrent life sentences with parole eligibility after 25 years (“hard 25”) based on mitigating circumstances. The Johnson District Court held a two-day evidentiary hearing, reviewed thirteen mitigating factors—including trauma, addiction, and mental disturbance—and found several substantial, but not “substantial and compelling” enough to warrant a departure from the hard 50 sentence. The court imposed two concurrent hard 50 sentences.On direct appeal to the Supreme Court of the State of Kansas, the defendant argued that the district court applied incorrect legal standards to statutory mitigating circumstances concerning his mental state, and that the sentence was unreasonable given his background and mental health. The Kansas Supreme Court reviewed the district court’s sentencing decision for abuse of discretion, assessing whether the court applied the correct law or reached an unreasonable result.The Kansas Supreme Court held that the district court correctly applied the legal standards and reasonably considered all mitigating evidence. The court concluded that the unprovoked killings did not warrant a lesser sentence, and affirmed the concurrent hard 50 sentences. View "State v. Sublett " on Justia Law

Police investigating a fatal fentanyl overdose in Leavenworth, Kansas, suspected that a supplier was distributing drugs from a woman’s residence. Over several weeks, law enforcement surveilled the home and a related apartment, observing frequent short visits, repeated appearances by suspected dealers, and traffic consistent with narcotics sales. A trash pull at the residence yielded evidence of drug activity, including baggies with residue testing positive for controlled substances, a handwritten ledger, and mail addressed to the resident. Additional evidence included drug paraphernalia found in the resident’s car and information linking associates to drug distribution and overdoses. Based on these observations, an officer compiled an affidavit and obtained a search warrant, leading to a search that uncovered substantial drug evidence and resulted in criminal charges.In the Leavenworth District Court, the defendant moved to suppress the evidence, arguing that the affidavit failed to show probable cause. The district court agreed, finding the affidavit’s details—especially those about the trash pull and vehicle search—insufficient to connect the alleged criminal activity to the residence. The court also found that much of the supporting information was uncorroborated or indicative of innocent conduct. The State appealed, and the Kansas Court of Appeals agreed the affidavit was deficient, but held that the evidence was admissible under the good-faith exception.The Supreme Court of the State of Kansas reviewed the case and concluded that both the district court and the Court of Appeals used an incorrect legal standard by analyzing the affidavit’s facts in isolation rather than considering the totality of the circumstances. The Supreme Court held that the affidavit provided the issuing judge with a substantial basis for finding probable cause. The court affirmed the reversal of the suppression order but on different grounds, and remanded the case, vacating the Court of Appeals’ discussion of the good-faith exception. View "State v. Gardner " on Justia Law

The defendant was convicted by a jury of first-degree murder for killing his girlfriend, whose body was discovered in her apartment in May 2014. Key evidence at trial included testimony from another girlfriend, placing the defendant at the victim’s apartment in the early morning hours before the victim’s phone activity ceased. The State’s pathologist could not precisely determine the time of death but indicated it was at least several hours before discovery. The defendant was sentenced to life imprisonment.Following the conviction, the defendant, with new appellate counsel, pursued a direct appeal to the Nebraska Supreme Court, raising several claims of ineffective assistance of trial counsel. Some claims were rejected outright, while others were found to lack sufficient record support. The conviction was affirmed. Subsequently, the defendant began postconviction proceedings in the District Court for Douglas County, filing multiple amended motions, some pro se while represented by counsel, which complicated the procedural history. The district court ultimately allowed the defendant, through counsel, to file a third amended verified motion for postconviction relief, which included numerous claims of ineffective assistance by trial and appellate counsel.The Nebraska Supreme Court reviewed the denial of the third amended postconviction motion. The court held that Burries’ claims were either procedurally barred, insufficiently alleged, or affirmatively refuted by the record. Specifically, claims regarding failure to challenge the pathologist’s testimony and failure to call a witness were barred or lacked merit, as evidence of the time of death uncertainty and witness statements were already in the record, and no prejudice could be shown. The court clarified procedural standards for postconviction filings and affirmed the district court’s denial of an evidentiary hearing and postconviction relief. View "State v. Burries" on Justia Law