Justia Criminal Law Opinion Summaries

The defendant was convicted in Texas state court in 2004 for assault causing bodily injury to a family member, which qualifies as a misdemeanor crime of domestic violence under Texas law. The incident involved the defendant pushing his wife during an argument and, when she attempted to call 911, striking her in the face while trying to knock the phone from her hand. Based on this conviction, he was later indicted under 18 U.S.C. § 922(g)(9) for possessing a firearm after being convicted of a misdemeanor crime of domestic violence.Before the United States District Court for the Western District of Texas, the defendant moved to dismiss the indictment, raising two constitutional challenges: that the statute exceeds Congress’s power under the Commerce Clause, and that, as applied to him, it violates the Second Amendment. The district court denied the motion. The defendant then entered a conditional guilty plea, reserving the right to appeal the denial of his motion to dismiss, and was sentenced to imprisonment and supervised release.The United States Court of Appeals for the Fifth Circuit reviewed the case. It rejected the Commerce Clause challenge, extending the reasoning from United States v. Alcantar to § 922(g)(9). The court then addressed the as-applied Second Amendment challenge, applying the historical tradition test articulated in New York State Rifle & Pistol Ass’n v. Bruen and clarified in United States v. Rahimi. The Fifth Circuit concluded that § 922(g)(9), as applied to the defendant, is consistent with the nation’s historical tradition of disarming individuals found to threaten the physical safety of others. The court found that the statute’s rationale and burden are supported by historical analogues and that the defendant’s conduct was sufficiently dangerous to warrant disarmament. The judgment of the district court was affirmed. View "USA v. Allred" on Justia Law

The case concerns a man accused of kidnapping and sexually assaulting a woman in Maui in 1989. The prosecution’s case relied heavily on circumstantial evidence and expert testimony from an FBI agent, who analyzed hair and fiber samples. The expert testified that hair found in the defendant’s car was “consistent with” originating from the complainant, and that fibers found on her clothing were “consistent with” coming from the car’s seat cover and carpet. The defense challenged the complainant’s credibility but did not contest the expert testimony. The jury convicted the defendant, and he was sentenced to forty years. Nearly thirty years later, a letter from the Department of Justice revealed that the expert’s testimony about hair analysis overstated the science and was invalid. The defense then argued that both the hair and fiber testimony should be deemed unreliable based on scientific developments.The Circuit Court of the Second Circuit held a hearing and found that the hair analysis testimony exceeded the bounds of science but ruled the error harmless beyond a reasonable doubt due to other corroborative evidence. The court did not rule on fiber analysis. The Intermediate Court of Appeals (ICA) affirmed the denial of post-conviction relief, applying the State v. McNulty “newly discovered evidence” test. The ICA found that the fiber testimony was not impeached by the DOJ letter and considered the hair evidence cumulative, so it declined to address whether the new evidence would probably change the result at retrial.The Supreme Court of Hawai‘i reviewed the case and held that when scientific advances later invalidate expert testimony presented at trial, the “false evidence” standard applies, not the “newly discovered evidence” standard. The court found both the hair and fiber testimony materially false, took judicial notice of landmark scientific reports, and concluded there was a reasonable possibility the false evidence contributed to the conviction. The defendant’s due process rights were violated, and the court vacated the lower courts’ decisions, remanding for a new trial. View "Granillo v. State" on Justia Law

In 2009, the appellant was convicted of violating California Penal Code section 288.4, subdivision (b), for arranging and attending a meeting with a minor with the intent to commit a sexual offense. The sentencing court imposed felony probation, jail time, and required him to register as a sex offender. In 2024, the appellant sought removal from the sex offender registry, arguing that the statutory scheme’s classification—placing his offense in tier three, which requires lifetime registration—violated his constitutional rights to equal protection. He contended there was no rational basis for imposing lifetime registration for his offense when other, allegedly more serious offenses, such as lewd acts under section 288, subdivision (a), did not require lifetime registration.The Superior Court of Los Angeles County reviewed the writ petition and denied relief. The court found that the Legislature could rationally distinguish between the appellant’s offense, characterized as a predatory “child luring” crime involving planning and a demonstrated unnatural interest in children, and the offenses he cited for comparison. The court explained that the statutory scheme was motivated by a legitimate governmental purpose: managing the risk of recidivism among offenders deemed most likely to reoffend and protecting public safety.The California Court of Appeal, Second Appellate District, Division Three, affirmed the lower court’s order. The appellate court held that under rational basis review, the Legislature had a conceivable and legitimate reason for classifying section 288.4, subdivision (b), offenses as warranting lifetime registration. The court emphasized that equal protection is not violated when the Legislature draws distinctions based on plausible risk assessments and societal interests, even if some other offenses are not treated identically. The appellate court concluded that the statutory classification survived constitutional scrutiny and awarded costs on appeal to the respondent. View "Muradyan v. Bonta" on Justia Law

Two brothers residing in Massachusetts used fake passports to open numerous bank accounts between 2019 and 2020, including accounts in their own names, names of fabricated individuals, and a fictitious company. These accounts were used to deposit funds acquired from romance scams targeting vulnerable victims and unemployment scams involving stolen identities. The brothers exchanged account information with each other and with overseas collaborators, and withdrew funds using debit cards linked to the fraudulent accounts. The FBI investigated after being alerted by victims, ultimately searching the brothers’ residences and storage facilities, where they found fake identification documents and related materials.A grand jury indicted the brothers in 2021 on charges of bank fraud, conspiracy to commit bank fraud, and conspiracy to commit money laundering. After an eight-day jury trial in the United States District Court for the District of Massachusetts, both were convicted on all counts. The district court sentenced Henry to seventy-eight months and Osaretin to seventy-two months of imprisonment, both with two years of supervised release. Restitution was deferred pending a hearing, after which the district court ordered both defendants to pay $615,805.65 in restitution, jointly and severally. The brothers appealed both their convictions and the restitution order.The United States Court of Appeals for the First Circuit reviewed the consolidated appeals, addressing challenges to the sufficiency of the evidence, jury instructions, sentencing enhancements, and restitution orders. The court held that the evidence was sufficient to support the convictions for bank fraud and conspiracy, that the jury instructions were not plainly erroneous or misleading, and that the sentencing enhancement for possession or use of authentication features was appropriate. The court also concluded that the district court had jurisdiction to issue the restitution order and did not err in making the defendants jointly and severally liable. Accordingly, the First Circuit affirmed the convictions and restitution orders. View "US v. Omoruyi" on Justia Law

A company operating as a mortgage lender applied for and received a Paycheck Protection Program (PPP) loan during the COVID-19 pandemic. The company’s PPP loan was later forgiven. A private party, acting as a qui tam relator under the False Claims Act (FCA), alleged that the company and its chief executive officer made several false statements in their loan application and forgiveness process. The key allegations were that the company was ineligible for PPP funds as a financial business primarily engaged in lending, that it misrepresented its use and need for the loan, and that it falsified the number of employees to increase the loan amount. The relator argued that these misrepresentations led the government to approve and forgive the loan improperly.Previously, the United States District Court for the Southern District of California dismissed the relator’s amended complaint. The district court found that the FCA’s public disclosure bar applied, reasoning that the necessary information supporting the ineligibility allegation was already publicly available on a government website, specifically concerning the company’s business classification. The district court also concluded that the relator’s allegations regarding the inflated employee count were speculative. The relator was denied leave to further amend the complaint, on the basis that amendment would be futile.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the public disclosure bar did not apply because the information on the government website was not “substantially the same” as the relator’s allegations, and the company’s own website did not qualify as “news media” under the statute. The appellate court agreed that the relator’s claim regarding the number of employees was not sufficiently pleaded but found the district court abused its discretion by denying leave to amend. The Ninth Circuit reversed the dismissal and remanded for further proceedings. View "RELATOR, LLC V. ERSKINE" on Justia Law

The defendant operated trucking and oil-drilling businesses and hired a hit man to murder two business associates, resulting in their deaths. He also solicited another hit man to kill three additional associates, but those killings did not occur. In 2016, a jury found the defendant guilty of multiple offenses, including four counts of solicitation to commit a crime of violence under 18 U.S.C. §§ 373(a) and 1958(a). Two of these solicitation convictions were based on acts that resulted in death, and two were based on acts that did not.Following the jury verdict, the United States District Court for the Eastern District of Washington sentenced the defendant to life imprisonment and other terms. In 2023, the defendant filed a motion under 28 U.S.C. § 2255 to vacate his four solicitation convictions, arguing that a violation of § 1958(a) is not categorically a crime of violence and thus cannot serve as a predicate offense under § 373(a). The district court vacated the convictions on counts related to solicitations that did not result in death, citing United States v. Linehan, but declined to vacate the convictions related to solicitations that resulted in death, reasoning that those offenses were categorically crimes of violence.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s partial denial and partial grant of the § 2255 motion. The Ninth Circuit held that solicitation of murder-for-hire resulting in death under § 1958(a) is not categorically a crime of violence because the death-results element lacks a mens rea requirement. Therefore, it cannot serve as a predicate offense under § 373(a). The court affirmed the district court’s vacatur of two convictions, reversed its denial regarding the other two, and remanded with instructions to vacate those remaining convictions. View "USA V. HENRIKSON" on Justia Law

Several individuals charged with crimes in Maryland were found by circuit courts to be incompetent to stand trial and dangerous due to mental disorders. Under Maryland law, such defendants must be committed to a designated health care facility for treatment, and the Maryland Department of Health is required to admit them within ten business days of receiving the court’s order. In these cases, the Department failed to meet that deadline, resulting in extended detention for the affected individuals in local facilities rather than treatment centers.After the Department’s delays, the defendants sought relief. The Circuit Court for Kent County and the Circuit Court for Baltimore County held hearings and imposed monetary sanctions on the Department under Maryland Criminal Procedure § 3-106(c)(4), which authorizes courts to impose sanctions to compel compliance with the statutory deadline. In four cases, defendants had not yet been transferred by the time of the hearings; in two cases, the Department had admitted the defendants before the hearings, but the courts still imposed sanctions. The Department argued that it was impossible to comply due to full facilities and long waiting lists, and that sanctions could not reasonably compel compliance. The Department also raised a separation of powers argument at one hearing but did not pursue it on appeal.The Appellate Court of Maryland affirmed the imposition of sanctions, holding that the circuit courts did not abuse their discretion. It ordered recalculation of the sanction amounts in some cases and rejected the argument that the Department’s later compliance prevented sanctions.The Supreme Court of Maryland affirmed the Appellate Court’s judgment. It held that trial courts may impose monetary sanctions reasonably designed to compel the Department to admit defendants as soon as possible after the ten-day deadline, including where waiting lists exist. The Court also held that sanctions can be imposed even after a defendant is belatedly admitted. Finally, the Court found no separation of powers violation in the statutory sanctions mechanism. View "Dept. of Health v. Boulden" on Justia Law

Police investigating suspected drug trafficking received information from a confidential informant about two individuals selling drugs. Surveillance linked the suspects to multiple addresses. The investigation included controlled drug buys and installation of a pole camera outside an apartment building. On April 4, 2023, the informant reported a possible deceased person inside one of the apartments. Surveillance footage showed the suspects and another individual entering and exiting the building. Police detained the suspects at a traffic stop and seized keys. Officers then entered the apartment building without a warrant, finding a deceased person in the second-floor apartment and, upon entering the third-floor apartment, discovering drug paraphernalia and contraband.The Providence County Superior Court held a hearing on the defendant’s motion to suppress evidence obtained during the warrantless search and seizure. The trial justice denied the motion, concluding that the police were responding to a sudden emergency involving a possible death and acted rationally to protect citizens from harm and prevent destruction of property. The defendant was subsequently found guilty on all charges following a bench trial and sentenced to twenty-five years, with twenty years to serve and five years suspended. The defendant appealed.The Supreme Court of Rhode Island reviewed the denial of the motion to suppress under the Fourth Amendment and article 1, section 6 of the Rhode Island Constitution, applying the totality of the circumstances standard and deferring to factual findings unless clearly erroneous. The Court held that police had no constitutionally permissible reason to enter the third-floor apartment after finding the deceased in the second-floor apartment and that the exigency justifying entry had evaporated. The Court concluded that the error was not harmless, vacated the conviction, and remanded for a new trial. View "State v. Moronta" on Justia Law

Corrie Singleton, along with his brother and a minor, committed an armed robbery at a Chase Bank in Lansing, Illinois, using a stolen vehicle. Singleton held a loaded firearm to a Brink’s employee’s head during the robbery, while his accomplices emptied cash from the ATM and the armored truck. After fleeing the scene and crashing the getaway car, Singleton and the minor were apprehended by law enforcement, who recovered over $1 million in cash and firearms. Singleton’s brother escaped arrest. A federal grand jury charged Singleton with conspiracy to commit armed robbery, Hobbs Act robbery, and brandishing a firearm during and in relation to a crime of violence. Singleton pled guilty to the latter two charges.The United States District Court for the Northern District of Illinois, Eastern Division, sentenced Singleton in June 2025. The court reviewed the Presentence Investigation Report, which calculated an advisory guidelines range of 219 to 252 months’ imprisonment. Singleton requested a downward departure in light of his youth, lack of criminal history, and potential for rehabilitation, referencing a recent amendment to the Sentencing Guidelines. The government sought a sentence of 204 months. Ultimately, the district court imposed a below-guidelines sentence of 96 months for robbery, followed by the mandatory consecutive 84 months for the firearm charge, totaling 180 months’ imprisonment and four years of supervised release. The court explained its reasoning, referencing Singleton’s mitigating circumstances.On appeal, before the United States Court of Appeals for the Seventh Circuit, Singleton argued that his sentence was procedurally unreasonable because the district court failed to adequately consider his mitigation arguments and explain its reasoning. The Seventh Circuit held that the district court sufficiently addressed Singleton’s principal mitigation arguments and explained its rationale for the below-guidelines sentence. The court affirmed the district court’s judgment. View "USA v. Singleton" on Justia Law

The appellant was originally convicted of felony destruction of property after damaging storage units. He received a suspended prison sentence and was placed on probation, with conditions requiring him not to consume alcohol, not to violate laws, and to participate in and complete an Adult Community Corrections (ACC) program. While participating in the Casper Re-Entry Center (CRC), the appellant consumed alcohol and failed to return on time from an approved absence, leading to his being reported as an escapee, convicted of escape, and terminated from the program.The District Court of Natrona County held a probation revocation hearing, where the appellant did not dispute the underlying violations but argued his actions were not willful, asserting that medication contributed to his behavior. The court heard testimony from the appellant and his probation agent and determined that the appellant had willfully violated his probation conditions during the adjudicatory phase of the proceeding. The court then revoked his probation and imposed the original prison sentence.On appeal, the Wyoming Supreme Court considered whether it was plain error for the district court to determine willfulness in the adjudicatory phase rather than in the dispositional phase, as Wyoming law requires the willfulness of a probation violation to be considered during the dispositional phase. The Supreme Court found the district court erred by making this determination prematurely but concluded the appellant suffered no material prejudice. The record showed the appellant had the opportunity to present arguments regarding willfulness, and the court fully considered his claims before imposing sentence. Therefore, the Supreme Court affirmed the district court’s decision, holding that the error did not rise to the level of plain error warranting reversal. View "Smith v. The State of Wyoming" on Justia Law