Justia Criminal Law Opinion Summaries

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In the United States Court of Appeals for the Fifth Circuit, the case involved Marco Antonio Abundiz, the defendant-appellant, who was convicted and sentenced to life imprisonment for sexually abusing his six-year-old niece, K.Z. Abundiz appealed his conviction arguing that the district court erred in several areas including: allowing the victim to testify via closed-circuit television (CCTV) which he claimed violated his Sixth Amendment right to confrontation; failing to make the necessary findings before permitting the victim to testify via CCTV; admitting evidence of a previous sexual assault; admitting evidence that he possessed child pornography; and the instructions given to the jury regarding evidence admitted under the Federal Rules of Evidence 413 and 414.After reviewing the case, the Court of Appeals affirmed the decision of the district court. The Court held that the district court did not err in allowing the victim to testify via CCTV. The Court determined that the district court made the necessary findings showing that the child would be unable to testify in open court due to fear and a substantial likelihood she would suffer emotional trauma.The Court also found no error in the district court's admission of evidence regarding prior sexual assaults and child pornography possession. The Court observed that the district court had appropriately exercised its discretion to admit this evidence under the Federal Rules of Evidence 413 and 414, providing that such evidence can be considered in sexual assault and child molestation cases, respectively.Lastly, the Court concluded that the district court's jury instructions regarding the use of evidence admitted under Rules 413 and 414 were not erroneous. The Court noted that the instructions appropriately informed the jury that such evidence could be used for any relevant purpose only if it was proven by a preponderance of the evidence. The instructions did not allow the jury to convict using a lower standard of proof or confuse the preponderance and beyond a reasonable doubt standards. View "USA v. Abundiz" on Justia Law

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In this case, the defendant, June Wolverine, was charged with six misdemeanor traffic violations, including a third offense of Driving Under the Influence of Alcohol (DUI). Wolverine was unable to attend her trial due to being in federal custody. The State of Montana moved to continue the trial, but did not provide information on when Wolverine would be released from federal custody. Wolverine subsequently filed a motion to dismiss the charges due to a lack of a speedy trial, as required by Montana law. The Justice Court denied Wolverine's motion, and she pleaded guilty to the DUI charge while reserving her right to appeal the speedy trial issue. The District Court affirmed the Justice Court's denial of the motion to dismiss, ruling that Wolverine's federal incarceration had a clear causal impact on the trial delay.The Supreme Court of the State of Montana reversed the decision of the District Court. The Supreme Court held that the State had failed to demonstrate good cause for the delay in Wolverine's trial. The State knew Wolverine was in federal custody and had ample time to ask for Wolverine’s temporary release for trial or to notify the Justice Court about the looming deadline for a speedy trial. Yet, the State did nothing as the deadline passed. The Supreme Court concluded that the State did not fulfill its obligation to try the defendant in a timely manner, thus violating Wolverine's right to a speedy trial. The court reversed the District Court's decision and ruled in favor of Wolverine. View "State v. Wolverine" on Justia Law

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In this case, defendant Bradley Alan Stokes appealed his convictions from the Fourteenth Judicial District Court, Musselshell County, for both burglary and assault with a weapon. Stokes was charged with these crimes following an altercation at the home of Michael Benson, in which he used a crowbar to break into the residence and assaulted Benson with the crowbar. He was convicted of burglary and assault with a weapon, both felonies. There was agreement that Stokes could not be convicted of both charges, as the assault with a weapon charge was the predicate offense for the burglary conviction. The dispute concerned which of the convictions should be vacated and whether the case should be remanded for resentencing.The Supreme Court of the State of Montana reversed Stokes's conviction for assault with a weapon, as it was determined to be the predicate offense that merged into the principal offense of burglary. The court held that the assault with a weapon conviction should be vacated, following the precedent that when a criminal defendant is improperly convicted of two offenses arising from the same transaction, the remedy is to reverse the conviction for the lesser-included offense only and remand for resentencing. Therefore, the court remanded the case to the District Court to vacate the assault with a weapon conviction and for resentencing on the remaining burglary conviction. View "State v. Stokes" on Justia Law

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This case involves a federal habeas corpus petition by Darnell Dixon, who was convicted of home invasion and murder by an Illinois state court and sentenced to life imprisonment. Dixon's habeas petition primarily focused on claims of actual innocence and prosecutorial misconduct. The United States Court of Appeals for the Seventh Circuit affirmed the denial of his habeas petition by the United States District Court for the Northern District of Illinois.The case involved a series of events including a drug-related robbery and subsequent murders. Dixon and Eugene Langston were implicated in the murders, with Langston identified in a police lineup by a witness, Horace Chandler. However, Chandler later recanted this identification. The state's case against Dixon relied heavily on a confession that Dixon later claimed was false. Dixon's confession and Chandler's identification of Langston were central to the state's theory of accomplice liability, arguing that Dixon was accountable for Langston's acts.In his habeas petition, Dixon argued that he was denied due process when the trial court excluded evidence that charges against his alleged accomplice, Langston, were dismissed. He also asserted that his trial counsel was ineffective for failing to object to the exclusion of that evidence. Furthermore, Dixon claimed that the state committed prosecutorial misconduct by presenting conflicting positions regarding Langston's involvement in the murders at trial and during post-conviction proceedings.However, the Seventh Circuit found that Dixon's claim of actual innocence, based on the state's post-conviction contention that Langston's involvement was irrelevant and evidence of abusive and perjurious conduct by the case's police detective, did not meet the high standard required to conclusively prove his innocence. The Seventh Circuit also rejected Dixon's arguments of prosecutorial misconduct and ineffective assistance of counsel, finding no clear error in the district court's factual findings on these issues. View "Darnell Dixon v. Tarry Williams" on Justia Law

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In an appeal from the United States District Court for the Northern District of Indiana, the United States Court of Appeals for the Seventh Circuit reviewed a case concerning Adam Tyrale Williams Jr.'s ongoing effort to reduce his sentences for crack-cocaine offenses. Williams was convicted in 2001 of various drug-related offenses, and over the years, he sought sentence reductions based on retroactive amendments to the guidelines and, most recently, the First Step Act of 2018. The district court denied Williams's most recent application for sentence reduction, but the appellate court vacated the decision because the district court failed to calculate the amended statutory sentencing ranges applicable to Williams's convictions. Upon remand, Williams further emphasized changes to his record and conditions of confinement that occurred after the order was vacated. However, the district court again denied Williams's request shortly after receiving the updated motion. The appellate court found that the district court's reliance on its previous reasoning and failure to adequately explain its decision was an abuse of discretion. Thus, the appellate court vacated the judgment and remanded for further proceedings, indicating that a more complete explanation from the district court was necessary given the changes in law and facts relevant to the case. View "USA v. Williams" on Justia Law

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In 2024, the United States Court of Appeals for the Sixth Circuit examined whether a conviction for aggravated robbery with a deadly weapon under Ohio law could be considered a "crime of violence" under the federal Sentencing Guidelines, which would lead to an enhanced sentencing range. The defendant, Alexander Ivy, had pleaded guilty to possession of methamphetamine with intent to distribute and being a felon in possession of a firearm. At sentencing, the district court found that Ivy's prior conviction for aggravated robbery was a "crime of violence," resulting in an increased Guidelines range of 92 to 115 months' imprisonment instead of the likely 46 to 57 months' imprisonment without such a finding. Ivy appealed this decision.The Court of Appeals held that a conviction for aggravated robbery with a deadly weapon under Ohio law without further information that the aggravated-robbery conviction is predicated on a particular underlying theft offense is not a "crime of violence" under the Guidelines. The court found that the Ohio aggravated-robbery statute criminalizes a broader range of conduct than both robbery and extortion, making it not a crime of violence under the Guidelines. Moreover, the court found that Ohio aggravated robbery doesn't require an offender to obtain something of value from another person, making it broader than the definition of extortion under the Guidelines.Therefore, the court vacated Ivy's sentence and remanded the case back to the district court for resentencing, consistent with its opinion. View "United States v. Ivy" on Justia Law

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The case in question originated from the United States Court of Appeals for the Fourth Circuit. The appellant, Carlos Emanuel Kinard, had been convicted on twelve counts related to a drug and racketeering conspiracy in 1994. One of the counts was for the use of a firearm during and in relation to a "crime of violence" under § 924(c), with the predicate offense arising under the violent crimes in aid of racketeering statute (VICAR) for VICAR assault with a dangerous weapon, which incorporated the North Carolina statutory crime of assault with a deadly weapon. In 2016, Kinard moved to vacate his sentence under § 2255, arguing that the VICAR assault offense was not a "crime of violence" as per the definition in Johnson v. United States. The district court rejected this as untimely and meritless.In 2019, Kinard moved for authorization to file a successive habeas petition based on the Supreme Court's decision in United States v. Davis, which held that the residual clause of § 924(c) is unconstitutionally vague. Kinard argued that the VICAR assault offense is not categorically a "crime of violence" as it could be committed without the use, attempted use, or threatened use of physical force against another and could be committed negligently or recklessly. The district court denied this motion, leading to Kinard's appeal.The Fourth Circuit Court of Appeals held that the VICAR assault with a dangerous weapon, incorporating the North Carolina assault offense, qualifies as a § 924(c) "crime of violence". The court relied on its recent decision in United States v. Thomas to conclude that the purposeful or knowing conduct element of the VICAR assault offense satisfies the mens rea requirement for a "crime of violence" under § 924(c). Thus, the court affirmed the district court's judgment. View "US v. Carlos Kinard" on Justia Law

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The Court of Appeal of the State of California, Fourth Appellate District, Division One, reversed and remanded a case involving a defendant, George Thomas Rouston, Jr., convicted of premeditated attempted murder, conspiracy to commit murder, and shooting at an occupied vehicle. The charges stemmed from a gang-related drive-by shooting. On appeal, Rouston argued that the trial court erred by allowing the lead detective in the case to opine on the main disputed issue: whether Rouston fired a gun. The appellate court agreed, stating that the detective's opinion on Rouston's guilt was "too helpful" and supplanted the jury's role. The court found this to be an abuse of discretion by the trial court. The court also found this error to be prejudicial, determining that without the detective's testimony, it was reasonably probable the jury’s verdict would have been different. Thus, the court reversed the judgment of conviction and remanded the case for a new trial. View "People v. Rouston" on Justia Law

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In a case before the Supreme Court of the State of Colorado, the defendant, Sir Mario Owens, appealed his convictions for first-degree murder, witness intimidation, conspiracy to commit first-degree murder, and accessory to a crime. The convictions stemmed from two separate incidents: the Lowry Park shootings, in which Owens was involved, and the subsequent Dayton Street shootings, for which Owens was convicted. The defendant argued that the trial was unfair due to the court's rulings on several issues, including the admission of evidence related to the Lowry Park shootings, the denial of Owens's motions for mistrial, and the limitation on cross-examination and impeachment of the prosecution's key witness. The Supreme Court held that the trial court's rulings were proper and did not constitute reversible error. Consequently, the Supreme Court affirmed the judgment of conviction. View "People v. Owens" on Justia Law

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In November 2018, Joseph Hoskins was stopped by a Utah state trooper, Jared Withers, because his Illinois license plate was partially obscured. The situation escalated when Trooper Withers conducted a dog sniff of the car, which led him to search the car and find a large amount of cash. Mr. Hoskins was arrested, and his DNA was collected. Mr. Hoskins sued Trooper Withers and Jess Anderson, Commissioner of the Utah Department of Public Safety, alleging violations of the First and Fourth Amendments and state law.The United States Court of Appeals for the Tenth Circuit held that Trooper Withers had reasonable suspicion to conduct the traffic stop because Utah law requires license plates to be legible, and this applies to out-of-state plates. The court also found that the dog sniff did not unlawfully prolong the traffic stop, as Mr. Hoskins was searching for his proof of insurance at the time. The court ruled that the trooper's protective measures, including pointing a gun at Mr. Hoskins, handcuffing him, and conducting a patdown, did not elevate the stop into an arrest due to Mr. Hoskins's confrontational behavior.The court further held that the dog's reaction to the car created arguable probable cause to search the car and that the discovery of a large amount of cash provided arguable probable cause to arrest Mr. Hoskins. The court found that Trooper Withers did not violate any clearly established constitutional rights by pointing a gun at Mr. Hoskins in retaliation for protected speech or as excessive force. Lastly, the court found no violation of Mr. Hoskins's due process rights related to the handling of his DNA sample, as neither the Due Process Clause nor state law created a protected interest in a procedure to ensure the destruction of his DNA sample. View "Hoskins v. Withers" on Justia Law