Justia Criminal Law Opinion Summaries

The appellant was originally charged in the District of Puerto Rico with firearm and drug offenses. He pleaded guilty to possessing a firearm in furtherance of drug trafficking crimes and possessing marijuana with intent to distribute. He was sentenced to 60 months of imprisonment and 60 months of supervised release. After serving his prison term, his supervised release began in July 2022 and was later transferred to the Middle District of Pennsylvania. While on supervised release, he committed several violations, including testing positive for marijuana and leaving the jurisdiction without permission. After being arrested in Oregon for these violations, he was returned to Pennsylvania, admitted to Grade C violations, and was sentenced to four months of imprisonment followed by 24 months of supervised release. The District Court in Pennsylvania later denied his motion for early termination of supervised release.Prior to this appeal, the U.S. District Court for the Middle District of Pennsylvania denied the appellant's motion to terminate his supervised release less than two months after he began serving the new post-revocation term. The court explained that the reasons for denial were previously provided at his supervised release violation sentencing. The appellant then sought review by the United States Court of Appeals for the Third Circuit.The United States Court of Appeals for the Third Circuit held that under 18 U.S.C. § 3583(e)(1), a district court may only terminate a term of supervised release after the individual has served one year of the specific term sought to be terminated. The court concluded that each post-revocation term of supervised release is a new and separate term for purposes of this provision. Because the appellant had not served one year of his current term, the District Court lacked authority to grant his motion. The Third Circuit affirmed the District Court’s denial. View "USA v. Santana-Robles" on Justia Law

Federal agents investigated an individual in Lodi, California, based on information from a confidential source indicating that the person was involved in large-scale methamphetamine trafficking, had previously possessed firearms, and had multiple felony convictions. Surveillance and a search of the individual's trash corroborated drug-related activity. Upon executing a search warrant at the residence, agents found evidence of methamphetamine being disposed of, drug paraphernalia, $5,972 in cash, and a loaded pistol magazine. Text messages on a seized phone further indicated ongoing drug transactions. The defendant admitted he should not have possessed ammunition due to his status as a felon.A grand jury indicted the defendant for possession with intent to distribute methamphetamine and possession of ammunition as a felon. The case went to trial in the United States District Court for the Eastern District of California. The district court admitted text messages as evidence of intent, excluded the defendant’s own recorded exculpatory statements as hearsay, and allowed a case agent to testify in a dual lay and expert capacity with appropriate jury instructions. The jury convicted the defendant on both counts and found the cash to be drug proceeds. The district court overruled most objections to the presentence report, converted the seized cash to its methamphetamine equivalent for sentencing, and applied a premises enhancement for maintaining a residence for drug distribution. The defendant was sentenced to 300 months’ imprisonment.The United States Court of Appeals for the Ninth Circuit reviewed the conviction and sentence. The court held that the district court did not abuse its discretion in converting the cash, applying the premises enhancement, handling evidentiary rulings, or admitting and excluding challenged evidence. The panel also found no error in the district court’s management of dual-role testimony or in addressing objections to the presentence report. The court declined to reach the Second Amendment challenge to the ammunition conviction due to procedural default and affirmed the judgment. View "USA V. RIVERA" on Justia Law

Federal agents lawfully searched the home of an individual under investigation for drug trafficking and seized $585,000 in cash from a safe. Before the cash could be processed, an FBI agent stole $218,200 from the seizure. The agent was later prosecuted, pleaded guilty, and was ordered to pay a forfeiture money judgment that included funds traceable to the stolen cash. The individual from whom the money was seized later pleaded guilty to drug-trafficking charges and agreed to forfeit only $366,800—the amount remaining after the theft. The government did not seek forfeiture of the additional $218,200, and the final forfeiture order reflected only the lower amount.The individual then moved under Federal Rule of Criminal Procedure 41(g) in the United States District Court for the Central District of California, seeking the return of the $218,200 that was stolen and never forfeited. The district court, treating the Rule 41(g) motion as a civil complaint, granted summary judgment to the government, finding that the individual had agreed to forfeit all cash seized and that his evidence of lawful ownership was insufficient. The court further found that no reasonable jury could conclude that any portion of the seized money was lawfully obtained while the remainder was subject to forfeiture.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that sovereign immunity did not bar the individual's Rule 41(g) claim for the return of cash that was seized, lost, but then recovered by the government in forfeiture proceedings. The court clarified that when the government possesses money traceable to previously seized funds, the claimant may seek its return, and the government bears the burden to justify retention. Finding that the government failed to meet this burden, the Ninth Circuit reversed the district court's judgment and remanded the case for further proceedings. View "CANNON V. USA" on Justia Law

The case involved a shooting during a parade in Dorchester, Boston, in which Dawn Jaffier was killed and Lealah Fulton was injured. The defendant was with two companions, Reed and Joyce, near the scene. No eyewitness identified the defendant as the shooter, but he was seen shortly after the incident disposing of the murder weapon, which was later determined to have fired the fatal bullets. The defendant, Reed, and Joyce were tested for gunshot residue several hours after the shooting, but all tests were officially negative according to the standard requiring three particles for a positive result. However, one gunshot residue particle was found on the defendant’s hand and another on his T-shirt, while none were found on Reed or Joyce.The case was first tried in the Massachusetts Superior Court, where the Commonwealth moved to admit expert testimony about the subthreshold gunshot residue particles. The trial judge allowed this testimony, finding its probative value outweighed its prejudicial effect. The jury convicted the defendant of murder in the first degree, armed assault with intent to murder, assault and battery by means of a dangerous weapon, and carrying a firearm without a license. The defendant’s motion for a new trial, focusing on the admission of the gunshot residue evidence and other grounds, was denied by a different judge in the Superior Court.On appeal, the Supreme Judicial Court of Massachusetts reviewed both the convictions and the denial of the new trial motion. The court held that the Commonwealth failed to establish the reliability of using the detection of a subthreshold number of gunshot residue particles as evidence that the defendant was the shooter. The court found the admission of this evidence was prejudicial and ordered a new trial on the major charges. The firearm conviction was also vacated due to improper jury instructions regarding licensing. All convictions were set aside and the case was remanded for further proceedings. View "Commonwealth v. Williams" on Justia Law

In this case, the individual who alleged she was sexually assaulted by the defendant requested that her identity remain confidential during the criminal proceedings. Before trial, a Superior Court judge granted her request to be referred to as "Jane Doe" pursuant to Connecticut law. At trial, however, a different judge ordered her to state her full name on the record, and she did so, with her name appearing in the official trial transcripts. The defendant was found not guilty by a jury, and judgment of acquittal was entered. Several years after the acquittal, the complainant filed a motion seeking to reopen the criminal case to have her name redacted from the transcripts and to prevent their dissemination until that was accomplished.The trial court (Superior Court, Vitale, J.) considered the motion and ultimately dismissed it for lack of subject matter jurisdiction, relying on State v. Butler, in which the Connecticut Supreme Court had previously held that trial courts lose subject matter jurisdiction to reopen a criminal case after final judgment when all charges have been dismissed or the defendant acquitted. The trial court recognized the complainant's statutory interest in confidentiality but concluded it lacked the authority to reconsider the earlier order or to grant the requested relief after the case had ended.Upon review, the Connecticut Supreme Court held that, following a judgment of acquittal, the trial court lacked jurisdiction to address the motion to open, since its authority over the criminal case ended with the acquittal. The Court further explained that a trial judge may not reconsider another judge’s prior, now-appealable order once final judgment has entered, as doing so would improperly grant appellate authority to a coequal court. The appropriate avenue for review would have been to seek leave to file a writ of error in the Appellate Court. Accordingly, the Connecticut Supreme Court dismissed the writ of error. View "State v. Khan" on Justia Law

In this case, the petitioner was convicted of capital murder and sentenced to death following a 2003 armed robbery in Houston, Texas, during which a restaurant employee was killed. Key evidence included eyewitness testimony, statements from co-defendants and jailhouse informants, and information about the petitioner’s criminal history and conduct in prison. The prosecution’s case centered on the petitioner being the sole gunman, though there was conflicting testimony about whether a second person entered the restaurant.The Texas Court of Criminal Appeals affirmed the conviction and sentence on direct appeal and denied state habeas relief, finding the petitioner’s subsequent and additional habeas claims to be procedurally barred as an abuse of the writ. The petitioner then sought federal habeas relief in the United States District Court for the Southern District of Texas, raising thirteen claims, including allegations of false evidence, inconsistent prosecutorial theories, Brady violations, ineffective assistance of counsel, and racial bias. The district court denied relief on the merits where permitted and found the remaining claims procedurally barred due to default under Texas law, ruling that the petitioner had not shown cause, actual prejudice, or a fundamental miscarriage of justice to excuse the default.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether a certificate of appealability (COA) should issue for the claims dismissed as procedurally barred. The court held that the petitioner failed to show that jurists of reason could debate the district court’s procedural rulings. The court concluded that the claims were subject to an adequate and independent state procedural bar, and the petitioner had not demonstrated cause and prejudice or actual innocence to overcome that bar. The Fifth Circuit therefore denied the application for a certificate of appealability. View "Marshall v. Guerrero" on Justia Law

The case concerns Del Orrin Crawford, who was involved in a deadly altercation outside the South Fork Saloon in Martin City, Montana, on August 26, 2022. After a dispute regarding a golf cart escalated, Crawford fired a handgun, resulting in the death of Whisper Sellers and serious injury to Douglass Crosswhite. Crawford fled the scene, called 911 multiple times claiming self-defense, and was later apprehended by law enforcement. Upon arrest, Crawford surrendered unarmed, and the firearm he used was not immediately recovered. Law enforcement questioned Crawford about the firearm’s location and conducted further interrogation after transporting him to the sheriff’s office.The Eleventh Judicial District Court in Flathead County presided over Crawford’s jury trial. Crawford moved to suppress two sets of statements made to law enforcement after he invoked his right to counsel. The court denied most of his motion, suppressing only statements related to his alcohol consumption before his second Miranda advisement. Crawford was subsequently convicted by the jury of Deliberate Homicide, Attempted Deliberate Homicide, Assault with a Weapon, and Tampering with Physical Evidence, and sentenced to 100 years in prison.On appeal, the Supreme Court of the State of Montana reviewed whether the district court erred in admitting Crawford’s statements regarding the firearm’s location after he requested counsel and whether it was correct in finding that Crawford reinitiated conversation and knowingly waived his right to counsel before making further statements. The Supreme Court held that even if admitting the statements about the firearm’s location was erroneous, any error was harmless beyond a reasonable doubt due to cumulative admissible evidence. The Court further held that Crawford voluntarily reinitiated conversation and validly waived his right to counsel before providing additional statements. The judgment of conviction was affirmed. View "State v. Crawford" on Justia Law

The case concerns a defendant who was charged with abusing his elderly stepfather, resulting in both mental injury and physical harm. The elderly victim, who had declining health and required assistance, was subjected to several years of verbal threats, intimidation, and, on at least one occasion, physical assault when the defendant struck him in the face. The victim’s daughter and other family members observed concerning behavior, including an incident where the defendant shook the victim in a manner described as threatening. The victim, before passing away, gave a recorded deposition detailing the abuse, his fear, and its emotional toll. The charges included abuse of an elderly person and first-offense partner or family member assault.Prior to trial, the defendant sought to enforce an alleged plea agreement, but the District Court found no such agreement had been accepted, following a hearing. Although a jury trial was scheduled, the defendant requested a bench trial, and the Tenth Judicial District Court, Fergus County, confirmed that he knowingly and voluntarily waived his right to a jury trial, albeit orally rather than in writing. After a two-day bench trial, the court found the defendant guilty on both counts and imposed a prison sentence. The defendant appealed, arguing insufficient evidence due to a lack of expert testimony on mental injury, an improper waiver of jury trial, and that the elder abuse statute was unconstitutionally vague and overbroad.The Supreme Court of the State of Montana held that expert testimony is not required to establish “mental injury” under the relevant statute, as a reasonable person standard applies and lay testimony was sufficient. The court found no manifest miscarriage of justice in accepting the oral waiver of a jury trial. The court also rejected the facial constitutional challenges, as the defendant’s conduct was clearly proscribed by statute. The judgment of the District Court was affirmed. View "State v. Pein" on Justia Law

On March 16, 2017, outside a bar in Helena, Montana, Andrew Lake stabbed Ryan Zitnik following an altercation. Both men were regulars at the bar and had known each other for years. The events leading to the stabbing were disputed, with each party claiming the other was the aggressor. Lake asserted the affirmative defense of justifiable use of force. Witnesses observed the initial confrontation inside the bar but did not witness the stabbing itself. After the incident, Lake was arrested and interrogated, where he discussed contentious remarks he had made about child sex abuse, which had strained his relationship with Zitnik and other patrons.Lake was initially convicted of attempted deliberate homicide in the First Judicial District Court, Lewis and Clark County. He appealed, and the Montana Supreme Court reversed the conviction, holding that the District Court had improperly allowed explicit and repetitive testimony about Lake’s child sex abuse comments, which was unfairly prejudicial under Rule 403 (State v. Lake, 2022 MT 28). The case was remanded for a new trial.Following retrial, Lake was again convicted and appealed to the Supreme Court of the State of Montana. On appeal, Lake argued that the District Court erred by admitting testimony about his child sex abuse comments, claiming its prejudicial effect outweighed its probative value under Rule 403. The Supreme Court reviewed only those instances where Lake made timely objections, finding that the District Court had carefully balanced probative value and prejudice, admitted only limited references, and did not abuse its discretion. The Supreme Court held that the danger of unfair prejudice from the admitted evidence did not substantially outweigh its probative value and affirmed the conviction. View "State v. Lake" on Justia Law

The appellant was convicted of first-degree murder, robbery, and grand theft after brutally beating and killing a woman with whom he was temporarily staying. Evidence at trial established the appellant stole cash and the victim’s car, fled the state, and used an alias before being apprehended in Alabama and returned to Florida for prosecution. The jury convicted him and recommended the death penalty by a 10-2 vote. The trial court found aggravating factors including murder during a robbery and that the crime was especially heinous, atrocious, or cruel, outweighing mitigating circumstances, and imposed a sentence of death.The Supreme Court of Florida previously affirmed the convictions and sentence on direct appeal. The appellant later filed multiple unsuccessful postconviction motions in state and federal courts, including a motion based on the Florida Supreme Court’s decision in Hurst v. State, which was denied due to lack of retroactivity. After the Governor signed a death warrant, the appellant filed a successive motion for postconviction relief and a stay of execution in the Circuit Court for Polk County, raising claims regarding his age and cognitive decline, warrant timing, the warrant process, and the nonunanimous jury recommendation.The Supreme Court of Florida reviewed the circuit court’s summary denial of postconviction relief de novo. The Court affirmed the summary denial, holding the appellant’s claims were either procedurally barred or meritless. Specifically, it ruled there is no constitutional prohibition against executing elderly prisoners experiencing cognitive decline, the expedited warrant period does not violate due process or equal protection, the Governor’s discretion in signing death warrants is not unconstitutional, and a nonunanimous jury recommendation of death does not violate the Fifth, Sixth, or Eighth Amendments. The Court also denied the appellant’s request for a stay of execution. View "Beasley v. State" on Justia Law