Justia Criminal Law Opinion Summaries

by
The Eleventh Circuit affirmed the district court's grant of habeas relief to petitioner, who was convicted of felony murder and sentenced to death. The court held that the Georgia state habeas court's fact-finding was not entitled to deference in the pre-Antiterrorism and Effective Death Penalty Act of 1996 regime. In this case, the state habeas court adopted verbatim the state's proposed order; offered no guidance to the Assistant Attorney General drafting the proposed order; did not review the order, other than signing it, dating it, and changing the concluding sentence, notwithstanding the glaring errors it contained; and did so ex parte without so much as affording petitioner a chance to challenge any of it or propose an alternative order. The court also held that the district court correctly determined that petitioner's trial lawyers' conduct fell beneath an objective standard of reasonableness when they failed to adequately investigate whether petitioner suffered from organic brain damage at the time of the killing. In light of the substantial evidence petitioner demonstrated showing that he suffered from organic brain damage, the court held that the district court did not err in finding that petitioner had been prejudiced by his lawyers' deficient performance. View "Jefferson v. GDCP Warden" on Justia Law

by
Marquis Stevenson was convicted of first-degree murder and possession of a firearm by a convicted felon for shooting Marvion Leflore in the chest. On appeal, Stevenson argued his convictions were contrary to the weight of the evidence, and that his trial counsel rendered ineffective assistance of counsel. Because Stevenson’s convictions were not contrary to the weight of the evidence, the Mississippi Supreme Court affirmed. Because the record was insufficient to determine whether ineffective assistance of counsel was rendered, the Supreme Court dismissed his ineffective-assistance-of-counsel claim without prejudice. View "Stevenson v. Mississippi" on Justia Law

by
The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court so that she may file a petition for writ of error coram nobis in her criminal case, holding that Petitioner's claims did not establish a ground for the writ. Petitioner was convicted of aggravated robbery and theft of property and sentenced to an aggregate term of 480 months' imprisonment. The court of appeals affirmed. In her coram nobis petition Petitioner claimed that there was a conflict of interest in her representation, a Brady violation, and misconduct on the part of the prosecutor. The Supreme Court denied the petition, holding that Petitioner failed to state sufficient allegations to satisfy issuance of the writ. View "Joiner v. State" on Justia Law

by
The Supreme Court dismissed Appellant's appeal from the denial of his pro se petition to proceed in forma pauperis in a habeas proceeding, which rendered moot Appellant's motion to supplement the record, holding that the circuit court did not abuse its discretion in denying Appellant's petition. In denying the petition, the circuit court found that the petition for writ of habeas corpus raised a jurisdictional issue that had already been decided. The Supreme Court affirmed, holding that the circuit court properly denied the petition and that this Court already addressed the issue raised by Appellant in a prior appeal. View "Russell v. Kelley" on Justia Law

by
The Supreme Court affirmed the dismissal of Appellant's pro se petition for writ of habeas corpus filed pursuant to Ark. Code Ann. 16-112-101, holding that Appellant did not state a ground for the writ. Appellant, who was convicted of residential burglary and rape, filed his habeas petition in the county where he was currently incarcerated, alleging that he had been denied a speedy trial. The circuit court dismissed the habeas petition on the merits, holding that Appellant had not been denied a speedy trial. The Supreme Court affirmed, holding that the circuit court properly dismissed the petition and did not err in not holding a hearing on the petition. View "Noble v. State" on Justia Law

by
The Supreme Court treated the three pro se motions filed by Petitioner seeking leave to proceed with an appeal of an order that denied his motion for writ of habeas corpus as motions for belated appeal and denied the motions, holding that Petitioner did not meet his burden of establishing good cause for not abiding by the rules that govern the orderly administration of justice. Petitioner filed to file a timely notice of appeal from the order from which he sought to appeal. Petitioner also filed a motion to correct the circuit court's order and other motions. The Supreme Court denied Petitioner's request to proceed with a belated appeal and declared moot the remaining motions, holding that Petitioner failed to show good cause for his failure to file a timely notice of appeal. View "D'Angelo v. State" on Justia Law

by
The Supreme Court reversed the firearm enhancements applied to Defendant's sentence and affirmed Appellant's convictions and sentences in all other respects, holding that because the jury did not find beyond a reasonable doubt that Appellant used a firearm as a means of committing terroristic acts, his twenty-nine one-year sentences imposed as firearm enhancements must be reversed. Defendant was convicted of first-degree murder, a terroristic act causing death, and twenty-eight counts of terroristic acts. Further, Defendant was subject to enhanced penalties pursuant to Ark. Code Ann. 16-90-120, the firearm-enhancement statute. The Supreme Court struck the firearm enhancements but otherwise affirmed, holding that the jury did not clearly find that Defendant employed a firearm as a means of committing the twenty-nine terroristic acts, and therefore, the twenty-nine firearm enhancements imposed by the jury must be reversed. View "Ellis v. State" on Justia Law

by
The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus to compel the court of common pleas judge to resentence him, holding that Appellant had an adequate remedy at law by way of appeal. Appellant was convicted of the rape of and gross sexual imposition on a child less than thirteen years of age. Appellant later filed a complaint for a writ of mandamus arguing that his sentence was void because the trial court failed properly to notify him of his post release control and abused its discretion in sentencing him to a definite term of life imprisonment. The court of appeals dismissed the complaint, concluding that res judicata barred Appellant's arguments. The Supreme Court affirmed, holding (1) the court of appeals erred when it dismissed Appellant's mandamus claim on res judicata grounds; but (2) Appellant had an adequate remedy of law by way of appeal, and therefore, Appellant was not entitled to mandamus relief. View "State ex rel. Green v. Wetzel" on Justia Law

by
The Supreme Judicial Court dismissed the Commonwealth's appeal from the trial court's allowance of Defendant's motion filed under Mass. R. Crim. P. 25(a), holding that the trial judge erred in reserving decision on Defendant's Rule 25(a) motion and that the error violated Defendant's right to due process and permeated the remainder of the trial. Defendant was charged with murder in the first degree. At the close of the Commonwealth's case Defendant moved for a required finding of not guilty pursuant to Rule 25(a). The judge reserved decision and submitted the case to the jury. The jury found Defendant guilty of murder in the second degree. Defendant subsequently renewed his motion under Rule 25(a). The judge allowed the motion, nunc pro tunc, to the close of the Commonwealth's case. The Commonwealth petitioned for relief under Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court denied relief, holding (1) in allowing the motion for a required finding nunc pro tunc after the jury returned their verdict the judge deprived the Commonwealth of its right to appeal from a postverdict acquittal; but (2) because the initial error in reserving decision on the motion implicated Defendant's constitutional rights and infected the remainder of the trial, the Commonwealth could not appeal. View "Commonwealth v. Yasin" on Justia Law

by
Petitioner was granted a certificate of appealability (COA) to address whether the district court abused its discretion in failing to grant relief to petitioner on his claims for denial of the right to a speedy trial, on claims of violation of due process based on the suppression of evidence, and on the claim that he was entitled to substitute counsel. Petitioner had pleaded guilty to the offense of injury to a child and received a twenty-year sentence. The Fifth Circuit held that it had jurisdiction over the appeal but did not reach the merits on the grounds that petitioner, on appeal, has waived any argument related to the issue upon which he was granted appellate review. View "Webb v. Davis" on Justia Law