Justia Criminal Law Opinion Summaries

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The case involves two defendants, Christopher Yates and Shawn Connelly, who were convicted for conspiring to distribute methamphetamine. The conspiracy operated out of Macomb, Illinois, and lasted thirteen months, from January 2019 to February 2020. Yates supplied the drugs, initially from an unknown source in Joliet, Illinois, with alleged Mexican cartel connections. After the arrest of that supplier, Yates sought a new source. Connelly was among the distributors. The government conducted one seizure and nine controlled buys from members of the conspiracy during its investigation.In the United States District Court for the Central District of Illinois, both defendants pleaded guilty without a plea agreement. The main dispute at Yates’s sentencing was the classification of the methamphetamine attributable to him as “ice” or “actual” (i.e., pure) methamphetamine, as opposed to its generic variant. The district court found that all 737.1 grams of methamphetamine for which the conspiracy was accountable was “ice” methamphetamine. Connelly raised two objections to the PSR at his sentencing hearing. He argued that the court could not rely on the statements of his coconspirators, Amber Phelps and Jeanna Rechkemmer, for purposes of determining the amount of methamphetamine handled by the conspiracy. He also contended that the full drug weight attributed to the conspiracy was not reasonably foreseeable to him. The district court denied both objections.In the United States Court of Appeals For the Seventh Circuit, Yates challenged the district court’s finding that the methamphetamine attributable to the conspiracy was “ice” methamphetamine. Connelly once more attacked the district court’s calculation of the total drug weight attributable to him. The court vacated Yates’s sentence and remanded. The court found that the government must supply reliable evidence making that approximation reasonable. Because such evidence was lacking, Yates is entitled to resentencing. The court affirmed Connelly’s sentence. View "United States v. Yates" on Justia Law

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The case involves two defendants, Christopher Yates and Shawn Connelly, who were convicted for conspiring to distribute methamphetamine. The conspiracy operated out of Macomb, Illinois, and lasted thirteen months, from January 2019 to February 2020. Yates supplied the methamphetamine, initially purchasing the drugs from an unknown source in Joliet, Illinois, with alleged Mexican cartel connections. After the arrest of that supplier, Yates sought out a new source. Connelly was among the distributors.The United States District Court for the Central District of Illinois sentenced both defendants. Yates argued that the government failed to prove the purity of all the methamphetamine involved in the conspiracy, having only tested a small, unrepresentative amount. Connelly argued that the court should not have relied on his coconspirators’ statements to calculate the total drug weight, and that the full weight was not reasonably foreseeable to him. The district court rejected both arguments and sentenced Yates to 168 months in prison and Connelly to 188 months’ imprisonment.On appeal, the United States Court of Appeals for the Seventh Circuit vacated Yates’s sentence and remanded the case. The court found that the government did not provide reliable evidence to support the district court's finding that the conspiracy involved at least 737.1 grams of “ice” methamphetamine. Therefore, Yates was entitled to resentencing. However, the court affirmed Connelly’s sentence, finding that the district court did not err in its calculation of the total drug weight attributable to him. View "United States v. Connelly" on Justia Law

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The case revolves around Tamira Durand, who was indicted for several fraud-related offenses, including illegally obtaining a credit card in the name of Scott Blum, a prosecutor with the Maricopa County Attorney’s Office (MCAO), the agency responsible for prosecuting Durand. Durand argued that her due process rights would be violated if she was prosecuted by an agency with a conflict of interest, given that Blum, one of the victims in her case, was a prosecutor with MCAO. The trial court granted Durand’s motion, disqualifying MCAO from the case. The State appealed this decision.The trial court's decision to disqualify MCAO was appealed to the Court of Appeals, which accepted jurisdiction but denied relief. The State then petitioned for review by the Supreme Court of the State of Arizona.The Supreme Court of the State of Arizona reversed the trial court's decision, stating that the trial court had erred by not considering the Gomez factors, a set of considerations established in a previous case, Gomez v. Superior Court, when deciding whether to disqualify MCAO. The court held that the trial court should have considered these factors, which include whether the motion is being made for the purposes of harassing the defendant, whether the party bringing the motion will be damaged in some way if the motion is not granted, whether there are any alternative solutions, and whether the possibility of public suspicion will outweigh any benefits that might accrue due to continued representation. The case was remanded back to the trial court for further proceedings, with instructions to apply the Gomez factors and consider Durand’s due process rights. View "State ex rel Mitchell v. Palmer" on Justia Law

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The case involves Harold McGhee, who was convicted and sentenced for drug trafficking. In August 2021, law enforcement received information from a confidential source about a drug dealer distributing large amounts of cocaine in Peoria, Illinois. The dealer was said to drive a Chevy Malibu and supplied cocaine to a house on West Millman Street. With this information, along with details from other informants and a tracking warrant, the police identified McGhee as the suspected dealer. They conducted three controlled buys and a trash pull at McGhee's residence, which led to the discovery of rubber gloves and baggies with a white powdery residue that tested positive for cocaine. This evidence led to a search warrant for McGhee's residence, vehicle, person, and electronic devices, resulting in the discovery of nearly a kilogram of various drugs, a handgun, and other drug trafficking paraphernalia.McGhee sought to suppress the evidence recovered at his residence and moved for a hearing to challenge the validity of the search warrant. He argued that the affidavit's use of "SUBJECT PREMISES," in reference to both his residence and the Millman Street house, was impermissibly ambiguous. The district court denied the motion. McGhee later renewed his motion to suppress, arguing that the trash pull was constitutionally unreasonable because it was executed without a warrant. The court denied this motion as well.On appeal, McGhee raised ten challenges to the criminal proceedings resulting in his convictions and sentence. The court considered some of his arguments on the merits and resolved others on procedural grounds. Ultimately, the court affirmed the judgment of the district court in all respects. View "United States v. McGhee" on Justia Law

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The case involves Mark Cardilli Jr., who was convicted of manslaughter after shooting and killing Isahak Muse, the boyfriend of Cardilli's sister. Cardilli claimed he acted in self-defense, fearing that Muse, who was unarmed but physically aggressive, would take his gun and use it against him and his family. The trial court found that Cardilli's belief that deadly force was necessary was objectively unreasonable, leading to his conviction.Cardilli appealed his conviction, arguing that his trial attorneys failed to adequately argue that he acted in self-defense. The post-conviction court agreed, granting Cardilli's petition for post-conviction relief, vacating his conviction, and ordering a new trial. The court found that Cardilli's attorneys did not have a cohesive trial strategy and did not communicate effectively, which could have affected the trial court's fact-finding.The State of Maine appealed the post-conviction court's decision, arguing that Cardilli did not show prejudice resulting from the ineffective assistance of counsel. The Maine Supreme Judicial Court agreed with the State, finding that the trial court's factual findings left no room for any argument that Cardilli's use of deadly force against Muse was justified. The court concluded that the legal argument Cardilli claimed his counsel should have pursued was incompatible with the court's findings about what occurred. The court vacated the post-conviction court's judgment and remanded for the entry of a judgment denying Cardilli's petition for post-conviction relief. View "Cardilli v. State" on Justia Law

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The case revolves around the conviction of Leashebia Davis for capital murder. The incident occurred on May 4, 2020, when Elvis Kendal was shot and killed. Davis was charged with capital murder on July 1, 2020, and was later convicted by a Jefferson County Circuit Court jury on May 17, 2023. She was sentenced to life imprisonment without the possibility of parole. The case was based on the testimonies of multiple witnesses, including Natasha Gill, a cousin of the victim, who witnessed the shooting, and Roderick Breedlove and Michael Brazell, who were with Davis in the vehicle at the time of the incident. The testimonies varied, with Davis and Breedlove implicating Brazell as the shooter, while Brazell testified that Davis was the shooter.The Jefferson County Circuit Court found Davis guilty of capital murder. Davis appealed the decision, arguing that there was insufficient evidence to support her conviction and that the court erred in denying her motion for a new trial based on juror misconduct. The court denied her motion for a new trial, asserting that Davis failed to demonstrate that the juror in question engaged in misconduct.The Supreme Court of Arkansas affirmed the lower court's decision. The court found substantial evidence to support Davis's capital murder conviction, including the testimonies of witnesses and the video-surveillance footage. The court also held that Davis failed to prove that the juror engaged in misconduct, as there was no evidence that the juror was dishonest during the jury-selection process or had any relationship with Davis's defense attorney. The court concluded that the lower court did not abuse its discretion by denying Davis's motion for a new trial. View "Davis v. State" on Justia Law

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Jessie Hill, a prisoner serving life imprisonment without parole for capital murder and an additional 720 months for first-degree murder, filed multiple pro se petitions for writ of habeas corpus. He claimed double jeopardy, violations of his right to due process, insufficient evidence supporting his convictions, and other obscure claims. The Jefferson County Circuit Court dismissed his petitions, noting that Hill's pleadings were often illegible and contained profane language. The court concluded that Hill failed to establish that he was being illegally detained.Hill had previously filed multiple petitions for postconviction relief, including four habeas corpus petitions, all of which were denied by the circuit court and affirmed on appeal. In his current appeal, Hill argued that his convictions violated the prohibition against double jeopardy, that the charging informations were defective and violated his right to due process, and that there was insufficient evidence to support his convictions.The Supreme Court of Arkansas affirmed the circuit court's decision, stating that Hill's claims did not challenge the legality of his sentences or the subject-matter jurisdiction of the trial courts that entered the judgments of conviction. The court noted that a habeas proceeding does not afford a petitioner an opportunity to retry his case and is not a substitute for raising an issue either at trial or on direct appeal. The court concluded that Hill's double-jeopardy claim failed to state a basis for habeas relief, and his sufficiency-of-the-evidence claims represented an abuse of the writ as he had raised these claims in his previous habeas petitions. View "Hill v. Payne" on Justia Law

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Eddie Lee Patrick, Jr., a prisoner, appealed the denial of his pro se petition for a writ of habeas corpus by the Jefferson County Circuit Court. Patrick was convicted of rape and terroristic threatening in the first degree by a Jefferson County jury in 2003 and was sentenced to 480 months' imprisonment. His conviction was affirmed by the Arkansas Court of Appeals. Patrick's petition for habeas corpus relief was based on pretrial DNA testing that he claimed proved his innocence.The Jefferson County Circuit Court denied Patrick's petition, and he appealed to the Supreme Court of Arkansas. Patrick argued that the lower court erred in not granting him habeas relief because the DNA evidence established his actual innocence. He also claimed that because the lower court allowed him to proceed in forma pauperis (without payment of a fee), it essentially held that the writ should be issued.The Supreme Court of Arkansas affirmed the lower court's decision. The court found that while the DNA report showed that Patrick's DNA was not present, the jury was aware of this evidence and still found him guilty. The court also noted that Patrick did not meet the requirements to state a prima facie claim under Act 1780, as he did not seek specific scientific testing of evidence that was not available at the time of trial nor allege the existence of new scientific methods to retest evidence that was available at the time of trial. The court concluded that Patrick's claim for habeas relief was merely a challenge to the sufficiency of the evidence supporting his conviction. The court also rejected Patrick's argument about proceeding in forma pauperis, stating that being allowed to file a petition without paying a fee does not equate to the issuance of the writ. View "Patrick v. Payne" on Justia Law

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David Stewart, an inmate, appealed the denial of his pro se petition for a writ of habeas corpus. He argued that his conviction for two counts of sexual assault violated the prohibition against double jeopardy and that a condition of his incarceration, requiring him to complete the Reduction of Sexual Victimization Program (RSVP), made his sentencing order illegal. Stewart also filed a motion for default judgment, claiming that the respondent failed to respond to his petition.The Jefferson County Circuit Court found that the sentencing order was not illegal on its face and that Stewart was not entitled to a default judgment on his petition for the writ. The court noted that Stewart was originally charged with one count of rape and one count of sexual assault, indicating distinct impulses involved in each charge of sexual assault. The court also found that the RSVP requirement was often imposed as a condition of parole or suspended imposition of sentence (SIS), not incarceration.The Supreme Court of Arkansas affirmed the lower court's decision. The court held that Stewart failed to demonstrate that the sentencing order was illegal on its face or that the trial court lacked jurisdiction to convict him of separate counts of second-degree sexual assault. The court also found that Stewart failed to show that the RSVP requirement and the no-contact order were part of his incarceration rather than his suspended sentence. Lastly, the court ruled that the circuit court did not err in denying Stewart's motion for a default judgment, as the Arkansas Rules of Civil Procedure do not apply to a postconviction habeas proceeding. View "Stewart v. Payne" on Justia Law

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Tristen Simonsen was convicted on two counts of solicitation of a minor, one count of sexual contact with a minor under the age of sixteen, and one count of rape in the fourth degree. The court did not specify during sentencing whether it intended to treat each charge as a separate transaction. After sentencing, the court signed four separate judgments of conviction and ordered each conviction to be served consecutively. Later the same day, the court held a hearing to clarify its intent, determining that each charge was the result of a separate transaction. Simonsen appealed, arguing that the court improperly enhanced his sentence after it had already commenced.The Supreme Court of South Dakota disagreed, ruling that the circuit court's post-sentencing declaration to treat each charge as a separate transaction only affected Simonsen's future eligibility for parole, not his sentence. The court also rejected Simonsen's argument that his constitutional rights were violated by his absence from the post-sentencing hearing, noting that the hearing only impacted his parole eligibility. The Supreme Court affirmed the circuit court's decision. View "State V. Simonsen" on Justia Law