Justia Criminal Law Opinion Summaries

In October 2019, Khrysta Turk reported to the Kalispell Police Department that her stepson, L.S., then 13 years old, had inappropriately touched her four-year-old daughter, E.T. L.S. admitted to the inappropriate touching during a police interview. Following the report, L.S.'s mother placed him in various residential treatment facilities for a total of 728 days. The investigation concluded in December 2019, and the matter was referred to the Eleventh Judicial District Court Office of Youth Services in January 2020. The Youth Court decided to monitor L.S.'s treatment informally without initiating formal proceedings.The State filed a formal petition on January 3, 2022, alleging that L.S. committed acts consistent with felony sexual assault. L.S. was appointed counsel, and the District Court set a trial date. L.S. moved for a continuance due to a discovery violation by the State, which delayed the trial. L.S. also filed motions to dismiss for lack of a speedy trial and for the discovery violation. The District Court denied both motions, noting that the case was atypical due to L.S.'s mother's proactive placement in treatment facilities. The trial was rescheduled multiple times, and L.S. eventually admitted to the allegations while reserving the right to appeal the denial of his motions.The Montana Supreme Court reviewed the case and conducted a speedy trial analysis. The Court determined that the delay of 329 days from the filing of the petition to L.S.'s admission was not extraordinary given the serious nature of the allegations. The Court found that the delays were either institutional or due to L.S.'s request for a continuance. L.S. consistently asserted his right to a speedy trial but failed to demonstrate that the delay prejudiced his defense. The Court concluded that no speedy trial violation occurred and affirmed the District Court's denial of L.S.'s motion to dismiss. View "In re L.S." on Justia Law

Calvin Glass, Jr. pled guilty to voluntary manslaughter of Jordan Luis with the personal use of a firearm and the attempted murder of Julius L. He was sentenced to 21 years in state prison. Glass later filed a petition for resentencing under section 1172.6, which was denied by the trial court for failure to state a prima facie case for relief. Glass argued on appeal that his guilty plea could not rule out imputed malice and that the trial court improperly considered matters outside the record of conviction.The Superior Court of San Diego County initially found Glass's petition facially valid, appointed him counsel, and set a hearing. The People argued that Glass was ineligible for relief because his record of conviction showed he was the actual killer and direct perpetrator of the attempted murder. The trial court ruled that Glass was ineligible for resentencing based on his sworn statements in the plea form and at the plea hearing, which indicated he was the killer. The court also referenced a prior opinion affirming Glass's judgment to corroborate its decision.The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case. The court agreed with the People that Glass's record of conviction indicated he was ineligible for relief under section 1172.6. However, following the precedent set by People v. Patton, the court decided to remand the matter to the superior court. Glass was granted 30 days to supplement his petition with additional facts to support his claim. The order denying his resentencing petition was otherwise conditionally affirmed. View "People v. Glass" on Justia Law

Three federal prisoners, Jason Bricker, Ellis McHenry, and Lois Orta, sought compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing a new policy statement by the Sentencing Commission, U.S.S.G. § 1B1.13(b)(6). This policy allows for sentence reductions based on nonretroactive changes in the law if certain conditions are met, including serving at least 10 years of an "unusually long sentence" and a "gross disparity" between the actual and hypothetical sentences under current law.In the Northern District of Ohio, the district court granted Bricker's motion for compassionate release, finding that his sentence would be significantly shorter under current law. The court acknowledged a Sixth Circuit precedent, United States v. McCall, which held that nonretroactive changes in the law are not "extraordinary and compelling reasons" for sentence reduction, but asserted that the Sentencing Commission had overruled this precedent. The government appealed this decision.In McHenry's case, the district court denied his motion for compassionate release, stating that applying the new policy would require disregarding the statutory mandatory minimum and the binding precedent set by McCall. Similarly, in Orta's case, the district court denied the motion, relying on McCall to conclude that nonretroactive changes in sentencing law do not constitute "extraordinary and compelling reasons" for release. Both McHenry and Orta appealed these decisions.The United States Court of Appeals for the Sixth Circuit reviewed the consolidated appeals and held that the Sentencing Commission overstepped its authority with U.S.S.G. § 1B1.13(b)(6). The court concluded that the policy statement was invalid as it conflicted with the statute and the separation of powers. Consequently, the Sixth Circuit reversed the district court's decision in Bricker's case and affirmed the denials in McHenry's and Orta's cases, denying compassionate release for all three prisoners. View "United States v. Bricker" on Justia Law

George Smith was convicted of first-degree murder and causing the death of another during the commission of a firearm offense. On April 8, 2021, Smith spent the day with his great-uncle, Jimmy Arthur, and later that evening, Arthur was fatally shot in the back of his head and neck while seated at his dining table. Smith claimed masked intruders were responsible, but evidence suggested otherwise. Smith was found with Arthur's body and had moved it, tampering with the crime scene. Blood consistent with Arthur's was found on Smith's sweatpants, and Smith had attempted to pawn a .25 caliber pistol earlier that day, which matched the caliber of the shell casing found at the scene.The United States District Court for the Eastern District of Oklahoma tried Smith, and a jury convicted him on both counts. Smith was sentenced to life in prison. He appealed, arguing insufficient evidence, juror misconduct, and prosecutorial misconduct.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court found that sufficient evidence supported the jury's verdict, including Smith's presence at the scene, his inconsistent statements, and the forensic evidence. The court also determined that the district court did not abuse its discretion in handling the juror misconduct incident, as the court conducted a thorough investigation and found no prejudice to Smith. Lastly, the court found no prosecutorial misconduct, as the statements made by the prosecutor were not improper, and any errors in testimony were corrected during the trial.The Tenth Circuit affirmed Smith's convictions, concluding that the evidence was sufficient, the juror misconduct was properly addressed, and there was no prosecutorial misconduct affecting the trial's fairness. View "United States v. Smith" on Justia Law

Bruce Holder was accused of running a fentanyl distribution ring in western Colorado, distributing thousands of counterfeit pills resembling oxycodone. He was convicted of four federal drug crimes, including charges related to the death and serious injury of buyers of his product. Holder challenged the constitutionality of his trial, arguing that the district court’s COVID-19 protocols violated his right to a public trial, that the jury pool unreasonably underrepresented certain racial groups, that several counts were constructively amended at trial, and that the evidence was insufficient to support the jury’s finding that his fentanyl distribution resulted in a victim’s death.The United States District Court for the District of Colorado imposed COVID-19 protocols, including social distancing, mask-wearing, and limited public access to the courtroom. Holder objected to these protocols, particularly the lack of video access and the limited public attendance. The jury convicted Holder on all four counts.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court found that the district court’s COVID-19 protocols did not violate Holder’s public trial rights, as the partial closure of the courtroom was justified by the substantial interest in protecting public health. The court also found no unreasonable racial disparity in the jury pool, as the absolute and comparative disparities were within acceptable limits. Additionally, the court determined that the indictment was not constructively amended, as the jury instructions did not alter the essential elements of the charges. Finally, the court held that there was sufficient evidence to support the jury’s finding that Holder’s fentanyl distribution resulted in a victim’s death.The Tenth Circuit affirmed Holder’s conviction. View "United States v. Holder" on Justia Law

Randal Wise was convicted of possessing child pornography, attempting to entice a minor, and attempting to transfer obscene matter to a minor. Wise used the Grindr app to contact undercover police officers posing as minors, sending explicit photos and attempting to arrange meetings for sexual activities. He was arrested while holding an iPhone that contained sexual chats and child pornography.The United States District Court for the District of New Jersey denied Wise's motion to sever the charges, and the jury convicted him on all counts. The judge sentenced him to 288 months in prison. Wise appealed, arguing that the charges should not have been joined and that the District Court should have severed them. He also raised several sentencing claims.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the charges were properly joined as they involved the sexual exploitation of minors. The court found no abuse of discretion in the District Court's decision to deny severance, as there was little risk of spillover prejudice, and the jury was instructed to consider each charge separately.The Third Circuit also upheld Wise's sentence. The court found that the District Court properly applied a five-level enhancement for a pattern of sexual abuse or exploitation of a minor and another five-level enhancement for repeated sex crimes against minors. The court also held that an iPhone qualifies as a computer under U.S.S.G. § 2G2.2(b)(6), thus justifying the two-level enhancement for using a computer in the crime.Finally, the court declined to address Wise's ineffective assistance of counsel claim, suggesting it be raised in a collateral review. The Third Circuit affirmed the District Court's judgment. View "USA v. Wise" on Justia Law

Christopher Couch was stopped by an Oklahoma Highway Patrol trooper for a tag light violation. The trooper observed signs of intoxication, including bloodshot eyes and the smell of alcohol, and administered field sobriety tests, which Couch failed. Couch agreed to a breath test, but due to errors, the test results were invalid. Despite the invalid test, Service Oklahoma revoked Couch's driver's license.The district court upheld the revocation, and the Court of Civil Appeals, Division III, affirmed this decision. However, Division IV of the Court of Civil Appeals had previously ruled in a separate case that revocation could not stand without a valid test result. Couch appealed, arguing that his revocation should be reversed based on Division IV's ruling and the relevant statutes requiring a valid test for revocation.The Supreme Court of the State of Oklahoma reviewed the case to resolve the conflict between the appellate divisions. The court held that a driver's license could be revoked based on an officer's sworn report establishing reasonable grounds for believing the driver was under the influence, even if the chemical test results were invalid. The court found that the officer's observations and Couch's performance on the field sobriety tests provided sufficient evidence to support the revocation. The court vacated the Court of Civil Appeals' opinion and affirmed the district court's order, upholding the revocation of Couch's driver's license. View "COUCH v STATEOF OKLAHOMA ex rel. DEPT. OF PUBLIC SAFETY" on Justia Law

Dedric Mayfield, a felon, was convicted by a jury of possessing ammunition in violation of 18 U.S.C. § 922(g)(1) after being recorded by a police-operated camera firing a handgun during an altercation. Mayfield had five prior adult felony convictions. Before trial, he did not stipulate to the authenticity or admissibility of any government exhibits. When the camera operator became unavailable for trial, Mayfield volunteered to stipulate to the authenticity and admissibility of the footage, allowing a detective to testify about it. The district court denied the government's motion for a continuance and instructed Mayfield to stipulate to the authenticity and admissibility of exhibits unless he had a good-faith basis not to do so. Mayfield stipulated to some exhibits, and the jury found him guilty. He was sentenced to 120 months in prison.The United States District Court for the District of Colorado handled the initial trial. Mayfield did not object to the district court's instructions regarding stipulations during the trial. He later argued that these instructions violated his Sixth Amendment fair-trial and Fourteenth Amendment due-process rights by coercing his counsel into stipulating to the government's evidence, thus depriving him of a fair trial.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court assumed without deciding that the district court's instructions were erroneous but found that Mayfield failed to demonstrate a reasonable probability that the outcome of the trial would have been different but for the error. The court also rejected Mayfield's argument that 18 U.S.C. § 922(g)(1) is facially unconstitutional under the Second Amendment, citing precedent that upheld the statute's constitutionality. The Tenth Circuit affirmed the district court's decision. View "United States v. Mayfield" on Justia Law

Cedric Ray Jones pleaded guilty to charges including conspiracy to commit Hobbs Act robbery and using and brandishing a firearm during a crime of violence. The conspiracy charge was the predicate for the firearm conviction under the residual clause of 18 U.S.C. § 924(c). Jones waived his rights to challenge his convictions and sentences on direct appeal or through collateral attack as part of his plea agreement. After the Supreme Court struck down the residual clause of § 924(c) in United States v. Davis, Jones sought to vacate his § 924(c) conviction under 28 U.S.C. § 2255, but the district court ruled that his collateral attack was barred by his appeal waiver.The United States District Court for the Northern District of Texas denied Jones's motion to dismiss the firearm counts and later denied his § 2255 motion, concluding that the appeal waiver was enforceable. The court granted a certificate of appealability on whether the waiver barred his Davis claim and whether it was unenforceable under the miscarriage of justice exception. Jones argued that the waiver should not apply because it was too broad, unknowing, and that enforcing it would result in a miscarriage of justice.The United States Court of Appeals for the Fifth Circuit reviewed the case and held that the appeal waiver was enforceable. The court rejected Jones's arguments, stating that the waiver was knowing and voluntary, and that the statutory-maximum exception did not apply. The court also declined to recognize a broad miscarriage-of-justice exception to the waiver. Consequently, the Fifth Circuit affirmed the district court's judgment, upholding the enforcement of the appeal waiver and denying Jones's request for relief based on the Davis decision. View "United States v. Jones" on Justia Law

Twin brothers Elijah and Kareem Muhammad were investigated for sex trafficking by the Fort Worth Police Department (FWPD) starting in 2018. Elijah was arrested in 2019 during a sting operation, and Kareem was arrested in 2023. The investigation revealed sex-trafficking activities dating back to 2011, involving multiple victims across several states. Concurrently, the FWPD and the Drug Enforcement Administration (DEA) were investigating the brothers for fentanyl trafficking. In 2023, Elijah and Kareem were arrested for drug-related offenses, leading to their guilty pleas for possession with intent to distribute fentanyl and unlawful possession of ammunition, respectively.The United States District Court for the Northern District of Texas handled the initial cases. Both brothers signed plea agreements in which the government promised not to bring additional charges based on the conduct underlying their guilty pleas. However, after their guilty pleas, the government charged them with sex trafficking in a separate case. The district court denied their motions to dismiss the sex-trafficking charges, finding that the sex-trafficking conduct was distinct from the drug-related offenses in terms of time, location, and statutory violations.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the sex-trafficking conduct was temporally, geographically, and statutorily distinct from the drug-related conduct. The court found that the sex-trafficking activities spanned over a decade and involved multiple states and victims, whereas the drug-related offenses were confined to a specific period and location. Consequently, the court concluded that the government did not breach the plea agreements by prosecuting the brothers for sex trafficking. The judgment of the district court was affirmed. View "United States v. Muhammad" on Justia Law