Justia Criminal Law Opinion Summaries

On New Year’s Day 2024, a Franklin County sheriff’s lieutenant attempted to stop a speeding Kia driven by Isaac Martinez-Chavez, who was a convicted felon. The vehicle accelerated, turned off its lights, and stopped in a yard. Upon approaching the car, the officer saw Martinez-Chavez reaching into the passenger area. After detaining him, officers found a sawed-off .22 rifle, a .22 revolver, and .22 caliber ammunition inside the vehicle. Martinez-Chavez claimed he was unaware of the firearms, presenting testimony from Olman Vallejos, who said he hid the guns without Martinez-Chavez’s knowledge. However, Vallejos’s credibility was severely undermined at trial.The United States District Court for the Western District of Virginia presided over the trial. Before trial, Martinez-Chavez requested an adverse-inference jury instruction because dispatch recordings of the arrest had been deleted in accordance with a routine records-retention policy. The district court denied this motion, finding no evidence of bad faith or willful conduct by the government and noting comparable evidence remained. During closing arguments, the prosecutor made two improper remarks, one referring to a witness as a “liar” and another appealing to the jury to convict for the sake of law enforcement. The court overruled defense objections but instructed the jury that statements by lawyers were not evidence and that law enforcement testimony was not to be given extra weight.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that although the prosecutor’s remarks were improper, they did not prejudice Martinez-Chavez’s right to a fair trial, given the overwhelming evidence against him and the curative jury instructions. The appellate court also found the district court did not abuse its discretion in denying the adverse-inference instruction, as there was no showing of willful destruction or governmental knowledge of the recordings’ relevance before their deletion. The conviction was affirmed. View "US v. Martinez-Chavez" on Justia Law

Police officers in Miami-Dade surveilled a house known for prior drug activity and a recent drive-by shooting. They observed Olson Joseph getting a haircut on the front lawn and later noticed he was carrying a concealed handgun in his sweatshirt pocket. The officers detained Joseph at gunpoint, removed the firearm, and conducted records checks, revealing Joseph was a felon without a concealed-carry permit. About twenty minutes after the stop, Joseph was transported to the station. He was subsequently charged in federal court with possession of a firearm and ammunition by a felon in violation of 18 U.S.C. § 922(g)(1).The United States District Court for the Southern District of Florida denied Joseph’s motion to dismiss the indictment, rejecting his argument that § 922(g)(1) violated the Second Amendment. The court also denied his motion to suppress the gun, finding the encounter was a Terry stop and that the officers had reasonable suspicion based on Joseph’s gun possession, his presence in a high-crime area, and proximity to a house associated with a recent homicide and drug activity. Joseph entered a conditional guilty plea, preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that, under circuit precedent, § 922(g)(1) does not violate the Second Amendment and affirmed denial of the motion to dismiss. However, the court found that the officers lacked reasonable suspicion for the stop, since Florida’s 2015 concealed-carry statute amendment made carrying a concealed weapon presumptively lawful, and Joseph’s conduct did not indicate criminal activity. The court vacated Joseph’s conviction, reversed the partial denial of the suppression motion, and remanded for further proceedings. View "USA v. Olson" on Justia Law

A man became the primary caregiver for his two-month-old daughter after his partner returned to work. Within a few days, the child was found to have severe and unexplained injuries, including multiple broken bones, bruises, and scratches. The child’s mother noticed initial injuries but delayed seeking medical attention until a scheduled check-up, at which point a pediatrician directed them to the hospital and notified authorities. Medical examination suggested the injuries were caused by forceful, non-accidental actions over a period of days. The accused gave varying explanations for the injuries, none of which were found consistent with the medical evidence.The United States District Court for the Eastern District of Oklahoma conducted a two-day jury trial. The prosecution presented expert and lay witnesses, including a specialist in child abuse who diagnosed the child as having suffered abuse and neglect. The defense challenged the admissibility and scope of the expert’s testimony, as well as certain statements by lay witnesses, arguing they improperly commented on the defendant’s credibility and offered expert opinions. The jury found the defendant guilty on both charges of child abuse and child neglect. The district court denied the defendant’s motion for a new trial and imposed a ten-year sentence.The United States Court of Appeals for the Tenth Circuit reviewed the case. The appellate court held that the district court did not abuse its discretion in permitting the expert’s medical diagnoses, as these did not address the defendant’s mental state—a necessary element for conviction—leaving that determination to the jury. The court also found that any improper lay witness testimony was harmless given its similarity to uncontested expert testimony. Arguments regarding prosecutorial misconduct and cumulative error were rejected. Consequently, the Tenth Circuit affirmed the convictions. View "United States v. Wilson" on Justia Law

Rodney Brown was charged with Hobbs Act robbery and brandishing a firearm during a crime of violence after he robbed a convenience store, threatening a cashier and her son, and stealing money and personal items. The robber left a soda bottle at the scene, which, along with a mask found nearby, was tested for DNA. Law enforcement obtained Brown’s DNA and had it analyzed by a private lab. At trial, a DNA analyst from the lab testified that Brown’s DNA matched the evidence, but the analyst had not personally performed the hands-on lab work generating the DNA profiles.In the United States District Court for the Southern District of Florida, a jury found Brown guilty on both counts. At sentencing, the court classified Brown as a career offender under the United States Sentencing Guidelines, using the 2023 version of the Guidelines, which treated Hobbs Act robbery as a crime of violence. This resulted in an increased sentencing range, and Brown was sentenced to 324 months in prison.On appeal to the United States Court of Appeals for the Eleventh Circuit, Brown argued for the first time that his Confrontation Clause rights were violated by the DNA analyst’s testimony, and that the Ex Post Facto Clause was violated when the district court used a later version of the Guidelines Manual. The Eleventh Circuit held that the district court did not plainly err in permitting the DNA analyst’s testimony, since the analyst independently reviewed and analyzed the DNA profiles and did not merely act as a surrogate for other lab personnel. However, the court found plain error in sentencing Brown under the 2023 Guidelines Manual, as the offense occurred before the relevant amendment. The court affirmed Brown’s convictions, vacated his sentence, and remanded for resentencing under the correct Guidelines version. View "USA v. Brown" on Justia Law

The case concerns the fatal shooting of Samantha Bozeman by Maxwell Lartery on February 5, 2024, at Bozeman’s home in Fulton County, Georgia. Lartery, Bozeman’s boyfriend, was involved in a heated argument with her, which was partially captured on video by Bozeman’s Ring surveillance camera. After Bozeman threw water at Lartery and locked him out, Lartery retrieved a handgun from his fanny pack and fired four shots through the front door, subsequently exclaiming, “That’s what! You’re dead.” Bozeman was later found dead from gunshot wounds. Witnesses and video evidence identified Lartery as the shooter. Lartery denied responsibility, claimed he was being framed, and offered alternative theories, but ultimately admitted to firing his gun after being confronted with video evidence.The Superior Court of Fulton County presided over the trial, where a jury found Lartery guilty of malice murder and related charges. The court sentenced him to life imprisonment with the possibility of parole and imposed additional consecutive sentences. Lartery’s motions for a new trial were denied without a hearing, and he appealed his conviction.The Supreme Court of Georgia reviewed the case, considering Lartery’s claims that the trial court erred by refusing to instruct the jury on voluntary manslaughter and by admitting expert testimony on domestic violence. The court held that there was insufficient evidence of serious provocation to warrant a voluntary manslaughter charge, as the facts did not meet the objective standard required by Georgia law. Regarding the expert testimony, the court found that even if its admission was erroneous, any error was harmless given the overwhelming evidence of Lartery’s guilt. Accordingly, the Supreme Court of Georgia affirmed the judgment of conviction. View "LARTERY v. THE STATE" on Justia Law

The appellant was convicted of felony murder and other offenses after leading law enforcement officers on a high-speed chase that resulted in a fatal collision. On April 5, 2024, police attempted to stop the appellant’s vehicle for a broken brake light, but he fled, leading officers onto Interstate 285. The pursuit ended when the appellant exited the highway, ran a red light at high speed, and crashed into another vehicle, killing the driver, Tamara Taylor. Evidence showed the appellant was driving recklessly and accelerating as he entered the intersection. He was on felony probation at the time, and over an ounce of marijuana was found in his vehicle.The case was tried in the Superior Court of Fulton County. At trial in April 2025, the jury acquitted the appellant of charges related to a prior pursuit on April 3, 2024, but convicted him of the remaining counts. The trial court sentenced him to life for felony murder and ten years for possession of marijuana, with several counts merged for sentencing. The appellant filed a motion for new trial, which was denied, and subsequently appealed.The Supreme Court of Georgia reviewed the case. The Court held that excluding the Georgia State Patrol’s written pursuit policy from evidence did not constitute plain error, as the appellant did not demonstrate that its admission would have affected the trial’s outcome; the appellant was permitted to question the officer in detail about the policy. The Court also found no plain error in the jury instructions regarding causation and intervening cause, as the appellant had agreed to the instructions at trial. The admission of evidence regarding felony probation was upheld as probative of motive and not unduly prejudicial. Sentencing and merger issues were found either proper or beneficial to the appellant. The Court concluded no cumulative error deprived the appellant of a fair trial and affirmed the judgment. View "HICKS v. THE STATE" on Justia Law

A man was shot and killed outside his home in Fulton County, Georgia. The victim, Sutton Tennyson, was conversing with a carpenter, Carl Price, when Michael Shareef Williams arrived in a dark-colored BMW. After a heated exchange about money, Williams followed Tennyson to his garage and shot him multiple times. Price witnessed the shooting and later described the attacker to police, though he was unable to identify Williams from photos immediately after the incident. Another neighbor, Frank Pickens, identified Williams as the man fleeing the scene. Evidence included surveillance footage, license plate reader data linking the BMW to Williams, and text messages between Williams and Tennyson discussing money.Williams was indicted in the Superior Court of Fulton County for murder and several related charges. In March 2022, a jury found him guilty on all counts. The trial court sentenced Williams to life with the possibility of parole on the malice murder count and imposed additional consecutive sentences for other firearm-related offenses. Several counts were merged or vacated by operation of law. Williams filed a timely motion for new trial, which was denied after a hearing. The trial court later vacated its previous denial and entered a new order, again denying the motion. Williams appealed, and the case was transmitted to the Supreme Court of Georgia.The Supreme Court of Georgia affirmed Williams’s convictions. The Court held that the trial court did not plainly err by failing to give a limiting instruction when evidence of Williams’s prior convictions was admitted, as Williams did not request one at the time. It also found no constitutional ineffectiveness by Williams’s trial counsel, whether for failing to stipulate to Williams’s felon status, failing to seek a limiting instruction, or failing to object to hearsay testimony. Claims of cumulative error were rejected, as only one instance of deficient performance was assumed without deciding. Judgment was affirmed. View "WILLIAMS v. THE STATE" on Justia Law

The defendant was convicted of malice murder and robbery following the death of a woman with whom he had a deteriorating relationship. Evidence at trial showed that he had threatened her life in the days leading up to the incident, and witnesses testified to his hostile intent. On the day of the crime, the victim left a friend’s house to check her mail and did not return. The defendant’s brother testified that the defendant went to their shared apartment with the intention of confronting the victim, gagged and bound her, and transported her in her vehicle. Physical evidence at the scene, including matching boot prints and DNA, corroborated the brother’s account. The defendant’s girlfriend and other witnesses provided additional evidence regarding his whereabouts. The victim’s body and belongings were found along a highway, and the medical examiner confirmed death by blunt force trauma. The defendant testified in his own defense, providing an alternate account of his movements.The Superior Court of Burke County presided over the trial, during which a jury found the defendant guilty of both charges. After sentencing, the defendant filed several post-trial motions, including motions for new trial. There was an extended delay in post-conviction proceedings, with issues regarding missing transcripts and unavailable evidence. Ultimately, the trial court denied the defendant’s motions for new trial, finding no prejudice from the delay and rejecting claims of ineffective assistance of counsel.The Supreme Court of Georgia reviewed the case on appeal. The court held that the evidence was sufficient to support both convictions under constitutional and statutory standards. The court further held that the defendant’s claims of ineffective assistance of counsel failed because there was no objectively unreasonable performance or resulting prejudice. The court also found no due process violation from the prosecution’s conduct or from the post-conviction delay, as no actual prejudice was demonstrated. The judgment was affirmed. View "JOHNSON v. THE STATE" on Justia Law

In this case, the defendant was charged with malice murder and related offenses following the August 2016 shooting death of a woman who was killed while driving away from a friend’s house in Fulton County, Georgia. The investigation linked the defendant and several others to the crime through a combination of witness testimony, forensic ballistics, and cell phone location data. A key witness, who was an accomplice and had entered a plea to a reduced charge, testified that the group, including the defendant, planned and executed a retaliatory shooting in the area where the victim was killed. The defendant contested his involvement, claiming that he was not present during the shooting and that his cell phone, which was tracked to the scene, was not in his possession at the relevant time.The Superior Court of Fulton County initially conducted a joint trial for the defendant and two co-defendants. The jury convicted the co-defendants but was unable to reach a verdict as to the defendant, resulting in a mistrial. The defendant was retried separately and found guilty on all counts. He subsequently filed a motion for new trial, which was denied after an evidentiary hearing. The defendant then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia affirmed the convictions. It held that the evidence, viewed in the light most favorable to the verdict, was constitutionally sufficient to support the convictions, and that the accomplice’s testimony was adequately corroborated by independent evidence, including physical evidence and cell phone data. The Court also held that the defendant, by remaining silent and failing to object when the trial court declared a mistrial in the first trial, had consented to the mistrial, and thus could not later invoke double jeopardy principles to bar retrial. Accordingly, the judgment was affirmed. View "ASH v. THE STATE" on Justia Law

The case concerns the shooting death of Keenan Leonard on January 1, 2021. Investigators traced a maroon SUV seen fleeing the scene to the mother of Camron Chase Downing. Evidence linked Downing to a .357 Magnum revolver, which was ultimately recovered after police questioned his brother, Cole, who had moved the gun to a friend's property. Downing was indicted for malice murder and related charges. At trial, the prosecution relied on forensic evidence connecting the revolver to the shooting and Downing’s prior possession of the weapon. Downing was convicted on all counts and sentenced to life without parole.After his conviction in the Superior Court of Troup County, Downing, represented by new counsel, filed a motion for a new trial. He argued that the murder weapon should have been suppressed as the "fruit of the poisonous tree," since it was discovered based on his unwarned, custodial statement to police, allegedly obtained in violation of Miranda v. Arizona, 384 U.S. 436 (1966). Downing also claimed his trial counsel was ineffective for failing to introduce key bodycam footage showing how police used his statement to pressure Cole into revealing the gun's location. The trial court agreed, finding the gun inadmissible and that counsel was ineffective.On appeal, the Supreme Court of Georgia examined whether the trial court erred in granting a new trial. The Supreme Court held that physical evidence derived from an unwarned statement is only suppressible if the statement was involuntary, not merely because Miranda warnings were not given. The trial court had not made a finding as to whether Downing’s statement was voluntary. Therefore, the Supreme Court of Georgia vacated the trial court’s order granting a new trial and remanded the case for a determination of voluntariness under the correct legal standards. View "THE STATE v. DOWNING" on Justia Law