Justia Criminal Law Opinion Summaries

Defendants Louis Age Jr., Louis Age III, Stanton Guillory, and Ronald Wilson were convicted and sentenced to life imprisonment for their roles in the murder-for-hire of Milton Womack, a federal witness in a healthcare fraud case. The defendants raised ten issues on appeal, including challenges to the sufficiency of the evidence, the admission of certain evidence, and the jury selection process.The United States District Court for the Eastern District of Louisiana convicted the defendants on multiple counts, including conspiracy to commit murder-for-hire, murder-for-hire, conspiracy to tamper with a federal witness, and witness tampering. The district court sentenced each defendant to at least one term of life imprisonment. The defendants appealed their convictions and sentences, arguing that the evidence was insufficient to support their convictions and that the district court made several errors in admitting evidence and instructing the jury.The United States Court of Appeals for the Fifth Circuit reviewed the case and found no error in the district court's rulings. The court held that the evidence presented at trial was sufficient to support the defendants' convictions. The court also found that the district court did not abuse its discretion in admitting evidence related to the defendants' prior criminal activities and in denying the defendants' motions to sever their trials. Additionally, the court held that the district court did not err in its jury instructions or in its handling of the jury selection process.The Fifth Circuit affirmed the district court's judgment, upholding the defendants' convictions and sentences. The court concluded that the defendants' arguments on appeal were unpersuasive and that the district court had acted within its discretion in its rulings. View "United States v. Age" on Justia Law

Jeremy Mooney, a former deputy in the Pike County Sheriff’s Office, was convicted of two counts of depriving an inmate, Thomas Friend, of his civil rights under color of law, in violation of 18 U.S.C. § 242. The incidents occurred on November 17-18, 2019, when Mooney pepper sprayed and punched Friend multiple times while Friend was restrained in a chair. Surveillance footage captured these events. Mooney claimed his actions were in response to Friend spitting on him and that he was instructed by his supervisor to use pepper spray.The United States District Court for the Southern District of Ohio denied Mooney’s motion to dismiss the indictment, which argued that the government destroyed exculpatory video evidence in bad faith. The court found no bad faith or exculpatory value in the lost footage. At trial, the jury found Mooney guilty on both counts. The court also excluded evidence of Friend’s Hepatitis C, ruling it irrelevant and potentially prejudicial. Mooney was sentenced to 100 months in prison, with an enhancement for obstruction of justice based on allegedly false trial testimony.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed Mooney’s conviction, finding sufficient evidence that Mooney acted willfully to deprive Friend of his constitutional rights. The court also upheld the district court’s evidentiary rulings, including the exclusion of the Hepatitis C evidence and the admission of testimony from Deputy Jonathan Chandler about police training.However, the Sixth Circuit vacated Mooney’s sentence and remanded the case for further proceedings regarding the obstruction of justice enhancement. The court found that the district court failed to make specific findings necessary to establish perjury, as required for the enhancement. The case was sent back to the district court to either resentence Mooney or make the required factual findings. View "United States v. Mooney" on Justia Law

In 2019, Irene Pressley, a rural mail carrier, was found dead in her car in Andrews, South Carolina, having been shot multiple times. An assault rifle and 21 bullet casings were found near the scene. A package containing marijuana addressed to Trevor Seward's residence, with Pressley's blood on it, was discovered nearby. Surveillance footage showed Seward leaving his house after Pressley did not deliver the package and later returning with an assault rifle. Seward's fingerprints and palm prints were found on Pressley's car and packages inside it, including a palm print in her blood.The United States District Court for the District of South Carolina convicted Seward of murdering a federal employee, using a firearm during a crime of violence, Hobbs Act robbery, possessing a firearm after a felony conviction, and conspiring to possess marijuana with intent to distribute. Seward appealed, challenging the qualifications of the government's firearms toolmark examiner and the exclusion of evidence that another witness failed a polygraph test. He also argued that the admission of testimony from the government's DNA expert violated the Confrontation Clause.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the district court did not abuse its discretion in allowing the firearms toolmark examiner's testimony or in excluding the polygraph evidence. Regarding the Confrontation Clause, the court acknowledged that the DNA expert's testimony may have violated the clause but concluded that any error was harmless beyond a reasonable doubt due to the overwhelming evidence of Seward's guilt. Consequently, the Fourth Circuit affirmed the district court's judgment. View "United States v. Seward" on Justia Law

Davion Rivers was convicted of possessing a firearm as a convicted felon and sentenced to 188 months in prison. Rivers appealed, arguing that the district court erred in denying his motions to suppress evidence and in sentencing him under the Armed Career Criminal Act (ACCA) without a jury determining whether his prior offenses occurred on different occasions.The district court denied Rivers's motions to suppress the firearm found on his person and a spent shotgun shell from his residence. The court found that the officers' approach to Rivers's residence was lawful under the knock-and-talk exception and that the search warrant for the residence was supported by probable cause. Rivers was convicted by a jury, and the district court applied the ACCA enhancement based on Rivers's prior drug offenses, finding that they occurred on different occasions.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed Rivers's conviction, finding no error in the denial of the suppression motions. The court held that the officers' approach to the residence was lawful and that the search warrant was supported by probable cause.However, the court vacated Rivers's sentence under the ACCA, citing the Supreme Court's decision in Erlinger v. United States, which requires that a jury, not a judge, must determine whether prior offenses occurred on different occasions. The court found that the district court's judicial fact-finding violated Rivers's constitutional rights and that the error was not harmless beyond a reasonable doubt. The case was remanded for resentencing consistent with the Supreme Court's ruling in Erlinger. View "United States v. Rivers" on Justia Law

Carlos Estrada, an Indiana resident, was arrested on February 2, 2023, after arranging the sale of 2,579 grams of heroin to an undercover officer in New Jersey. A search of his Indianapolis residence revealed an additional 371 grams of heroin, a digital scale, and a box containing six pounds of lactose, a cutting agent. Estrada committed this offense six months after being released from prison and starting supervised release for a 2019 heroin-distribution conspiracy conviction in the Southern District of New York.The United States District Court for the Southern District of Indiana accepted Estrada's guilty plea to one count of possessing with intent to distribute at least 100 grams of heroin. The court sentenced him to 87 months in prison, at the low end of the advisory Sentencing Guidelines range. Estrada appealed, arguing that the district court erred procedurally by not varying downward his criminal history category, which included points from a 2018 misdemeanor marijuana possession conviction.The United States Court of Appeals for the Seventh Circuit reviewed the case. Estrada contended that the district court did not adequately explain its decision and misapprehended its authority to depart downward. The appellate court found that the district court's explanation was sufficient, considering Estrada's extensive criminal history, including serious juvenile offenses and the fact that he committed the current offense while on supervised release. The court also determined that the district court did not err in its understanding of its authority to vary downward. Consequently, the Seventh Circuit affirmed the district court's sentence of 87 months in prison. View "United States v Estrada" on Justia Law

Marquise Johnson was injured when his friend, André Lewis, accidentally shot him while attempting to disassemble a handgun in a car. Lewis believed the gun could not fire without the magazine, but it discharged, hitting Johnson in the legs. Johnson sued the gun's manufacturer, importer, and seller, alleging the gun was defective for lacking certain safety features.The Lyon District Court granted summary judgment to the defendants, citing the Protection of Lawful Commerce in Arms Act (PLCAA), which provides immunity to firearm manufacturers and sellers from lawsuits when their products are misused criminally. The court found that Lewis' act of pulling the trigger was volitional and constituted a criminal offense under Kansas law, specifically the strict-liability crime of discharging a firearm on a public road.The Kansas Court of Appeals reversed the district court's decision, interpreting the PLCAA to require an intentional discharge for immunity to apply. The majority held that because Lewis did not intend to fire the gun, the PLCAA did not bar Johnson's lawsuit. A dissenting judge argued that the PLCAA should apply because Lewis' act of pulling the trigger was volitional.The Kansas Supreme Court reviewed the case and reversed the Court of Appeals. The Supreme Court held that the PLCAA bars product-liability actions if a volitional act causes the gun to discharge and the shooting constitutes a criminal offense. The court found that Lewis' deliberate trigger pull was a volitional act and that discharging a firearm on a public road is a strict-liability crime under Kansas law. Therefore, the PLCAA provided immunity to the defendants, and the district court's summary judgment was affirmed. The case was remanded to the district court. View "Johnson v. Bass Pro Outdoor World " on Justia Law

Jeffrey G. Hutchinson was convicted of murdering his girlfriend Renee Flaherty and her three children in 1998. After an argument with Renee, Hutchinson drank heavily, returned to her home with a shotgun, and killed Renee and two of her children with single shots to the head. He then shot the third child, Geoffrey, twice, killing him. Hutchinson called 911, admitting to the shootings, and was found by police with gunshot residue on his hands and body tissue from Geoffrey on his leg. He was charged with four counts of first-degree murder and sentenced to death for the murders of the three children.Hutchinson's convictions and death sentences were affirmed on direct appeal by the Florida Supreme Court. He filed multiple postconviction motions, all of which were denied. His initial state postconviction motion and successive motions were also denied, as were his federal habeas petitions. His fourth successive postconviction motion, filed after the Governor signed a death warrant, was denied by the circuit court without an evidentiary hearing.The Supreme Court of Florida reviewed Hutchinson's appeal of the denial of his fourth successive postconviction motion and his habeas corpus petition. The court affirmed the circuit court's denial, rejecting Hutchinson's claims that the warrant period violated his constitutional rights, that the warrant selection process was arbitrary, and that his execution would be cruel and unusual punishment. The court also denied his habeas claims, including his argument that Atkins v. Virginia should extend to individuals with neurocognitive disorders and his challenge to the heinous, atrocious, or cruel (HAC) aggravator. The court denied Hutchinson's requests for a stay and oral argument, and ordered the mandate to issue immediately. View "Hutchinson v. State" on Justia Law

The defendant was on probation after being convicted of conspiracy to commit murder. His probation was revoked based on allegations that he participated in a home invasion, left the state without permission, and failed to submit to substance abuse evaluations and counseling. The defendant contested the revocation, particularly challenging the admission of an out-of-court identification by a witness, Rainey, who was unavailable for cross-examination.The trial court admitted Rainey’s identification without applying the balancing test required by State v. Crespo, which weighs the defendant’s right to confront witnesses against the state’s reasons for not producing the witness and the reliability of the evidence. The court found the defendant violated his probation and imposed a thirteen-year sentence. The defendant appealed, arguing the trial court erred by not applying the Crespo balancing test.The Appellate Court affirmed the trial court’s decision, concluding that the defendant had abandoned his request for the Crespo balancing test during the probation revocation hearing. The defendant then appealed to the Connecticut Supreme Court.The Connecticut Supreme Court found that the defendant did not abandon his Crespo claim. The court noted that the defendant consistently argued for the application of the Crespo balancing test and that the trial court should have engaged in this balancing before admitting Rainey’s identification. The Supreme Court reversed the Appellate Court’s judgment in part and remanded the case for a new probation revocation hearing limited to determining whether the defendant was involved in the home invasion. The findings that the defendant violated other conditions of his probation were upheld and not to be relitigated. View "State v. Wade" on Justia Law

Briana Marquise Matthews, a former prison guard, was charged with two counts of custodial sexual misconduct for having sexual encounters with an inmate. She pleaded guilty to both counts and was sentenced to 10 years, with 18 months to be served in custody and the remainder on probation. Upon starting her probation, Matthews was informed she had to comply with the Alabama Sex Offender Registration and Community Notification Act (ASORCNA) requirements.Matthews filed a petition in the St. Clair Circuit Court seeking relief from the ASORCNA requirements, arguing that these were not part of her plea agreement. The State responded that her petition was incorrectly filed in the criminal action and should be a new civil action. Matthews withdrew her petition and filed a new one as a civil action, seeking relief from the ASORCNA requirements and restrictions. The circuit court temporarily relieved her from these requirements pending further orders but ultimately denied her petition, stating that her convictions were not among those listed in § 15-20A-24(a) for which relief could be sought.The Supreme Court of Alabama reviewed the case. It dismissed the appeal from the criminal action, stating that the circuit court lacked jurisdiction to consider the petition in the criminal case, making the order void. However, the court affirmed the judgment in the civil action, agreeing that Matthews's convictions for custodial sexual misconduct were not eligible for relief under § 15-20A-24(a). The court also noted that Matthews was not entitled to seek relief while still serving her probationary term. View "Matthews v. State of Alabama" on Justia Law

Damaris Quinn was convicted in the Clay County Circuit Court of attempted murder and possession of a firearm by a convicted felon. The incident occurred on October 18, 2016, when Quinn shot his wife, Basheeba Ward, five times with a .32 caliber revolver. The shooting took place at Quinn's mother's house, where the couple was living. Ward survived the shooting and testified that Quinn shot her after an argument about her not wearing her wedding ring. Quinn's aunt and mother also provided testimony about the events surrounding the shooting.The jury found Quinn guilty of both charges. Quinn appealed his attempted murder conviction, arguing that the trial court erred by denying a jury instruction related to his defense and that there was insufficient evidence to support his conviction. The trial court had denied a motion for a directed verdict on the attempted murder charge, asserting that the State failed to establish the element of intent for attempted murder.The Supreme Court of Mississippi reviewed the case and found no merit in Quinn's claims. The court held that the jury instruction provided by the trial court properly tracked the attempted-murder statute and that the evidence presented at trial was sufficient for a reasonable jury to find Quinn guilty beyond a reasonable doubt. The court noted that intent could be inferred from Quinn's actions, including shooting Ward multiple times and reloading the gun. The court affirmed Quinn's convictions for attempted murder and possession of a firearm by a convicted felon. View "Quinn v. State of Mississippi" on Justia Law