Justia Criminal Law Opinion Summaries

The defendant was convicted of arson in January 2022 and sentenced to two years in prison. In February 2025, a petition was filed alleging that the defendant had violated Vehicle Code section 14601.2, subdivision (a), but the petition did not specify what was being revoked. At a hearing, the court described the matter as a parole issue, summarily revoked the defendant’s parole supervision, and declined to release him from custody. The defendant was later allowed to represent himself and denied the parole violation, though he admitted to the underlying misdemeanor. At a subsequent hearing, after the defendant’s conviction for the misdemeanor, the court found him in violation of parole “by operation of law,” revoked and reinstated parole, and imposed a jail sentence.The Superior Court of Sonoma County presided over these proceedings. The defendant appealed, arguing that there was insufficient evidence to support the finding that he was on parole at the time of the alleged violation. The prosecution did not introduce evidence at the hearing to show that the defendant was actually on parole when the alleged violation occurred. The prosecution argued on appeal that references to the proceedings as parole revocation proceedings, and the defendant’s acknowledgment of the hearing, were sufficient.The California Court of Appeal, First Appellate District, Division Five, reviewed the matter. It held that to establish a parole violation, the prosecution must prove, by a preponderance of the evidence, that the defendant was on parole at the time of the alleged violation, even if the defendant does not specifically raise the issue before the hearing. Because the prosecution failed to present any evidence of parole status at the time of the violation, the Court of Appeal reversed the order revoking and reinstating parole and imposing jail time. View "People v. Fuller" on Justia Law

Police observed Gerald Cook commit multiple drug transactions outside his residence after receiving information from an informant who had previously purchased heroin from him. Officers corroborated the informant’s account by seeing Cook’s vehicle at his home and conducting two controlled buys, during which officers observed Cook exit his house, complete drug sales, and return inside. After obtaining a warrant, a search of Cook’s home uncovered drugs, firearms, and evidence of drug trafficking. Cook was indicted on drug and gun charges. He later sought to suppress the evidence, alleging that the warrant affidavit was based on false statements, but withdrew his initial motion. Subsequent motions based on similar grounds were denied.The United States District Court for the Northern District of Ohio considered and denied Cook’s motion to suppress evidence from his home, finding the warrant affidavit provided probable cause and that Cook’s Franks v. Delaware claim was untimely and unsupported. The court also denied a later Franks motion, finding no substantial preliminary showing of intentional or reckless falsehoods in the affidavit, and determined the motion was an unjustified attempt to reopen the suppression hearing. After his motions failed, Cook pleaded guilty and received a sentence of 248 months, which was significantly below the applicable Guidelines range. He appealed, challenging the suppression rulings and his sentence.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s decisions. It held Cook did not meet the high threshold for a Franks hearing because the record did not show intentional or reckless falsehoods in the warrant affidavit. The court also rejected Cook’s procedural and substantive challenges to his sentence, concluding the district court did not err in its Guidelines calculations or in declining a further reduction for acceptance of responsibility, and that the sentence was reasonable given the § 3553(a) factors. View "United States v. Cook" on Justia Law

A former member of the Los Angeles County Board of Supervisors was convicted for conspiracy, federal program bribery, and honest services mail and wire fraud. The case centered on a scheme where the then-Dean of the University of Southern California’s School of Social Work helped channel a $100,000 donation of university funds to a nonprofit employing the supervisor’s son. In exchange, the supervisor voted in favor of a county contract for telehealth services with USC. The evidence showed the supervisor valued the indirect transfer of funds for his son’s benefit, especially after previous attempts to provide direct funding raised concerns about nepotism.The United States District Court for the Central District of California presided over a sixteen-day trial. The jury convicted the supervisor on counts specifically related to the funneling of the $100,000 payment, while acquitting him on other counts tied to his son’s admission, scholarship, or professorship at USC. Following conviction, the supervisor appealed, challenging the Government’s theory of fraud and bribery, the legal validity of the “thing of value,” and the sufficiency of evidence for materiality and intent. He also contested the jury instructions and raised Batson challenges regarding the exclusion of Black female jurors.The United States Court of Appeals for the Ninth Circuit reviewed the appeal. The court held that the funneling of $100,000 through USC for the son’s benefit was a “thing of value” sufficient to support convictions for honest services fraud and federal program bribery. The court found the evidence of intent and materiality sufficient, determined there was no error in the jury instructions, and rejected the extension of Batson to intersectional challenges. The convictions for conspiracy, federal program bribery, and honest services fraud were affirmed. View "USA V. RIDLEY-THOMAS" on Justia Law

The defendant was accused of participating in a plan to attack a public event in Garland, Texas, which was targeted for its association with controversial depictions of the Prophet Muhammad. The attack was carried out by two individuals, Simpson and Soofi, who were killed during the incident. Investigators uncovered evidence of the defendant’s close association with the attackers, his consumption of extremist propaganda, and his involvement in firearms training and procurement. The government argued that the defendant, along with Simpson and Soofi, conspired to provide material support to ISIS, specifically as “personnel” or by providing “services” in the form of the attack.After a trial in the United States District Court for the District of Arizona, a jury convicted the defendant on all counts, including conspiracy to provide material support to a foreign terrorist organization in violation of 18 U.S.C. § 2339B (Count 5). The district court sentenced him to 360 months’ imprisonment. Post-trial, the defendant filed motions for acquittal and new trials, including arguments based on Brady violations, but relief was denied for Count 5. The government dismissed another count, and the district court resentenced him to the same term. The defendant timely appealed his conviction on Count 5, arguing insufficient evidence to support the jury’s finding.The United States Court of Appeals for the Ninth Circuit reviewed the sufficiency of the evidence under the Jackson v. Virginia standard, regardless of whether the claim was preserved below. The court held that the government failed to present sufficient evidence that the defendant intended to join a conspiracy in which material support would be provided to ISIS, either as “personnel” acting under ISIS’s direction or as “services” beyond independent advocacy. The court reversed the conviction on Count 5, remanded for entry of acquittal and resentencing, and affirmed the district court’s rulings on all other issues. View "USA V. ABDUL KAREEM" on Justia Law

In December 2024, Colton Kenneth Defoe was stopped by a McKenzie County Sheriff’s officer due to an outstanding warrant. The officer cleared Defoe’s vehicle of other passengers and used a K-9 unit to inspect the car, which resulted in an alert for narcotics. A search revealed a plastic baggie and a bindle, both containing methamphetamine residue, and a plastic tube with burn marks. Although Defoe and his passengers denied possession, lab tests confirmed methamphetamine in both the baggie and the bindle, while the tube yielded inconclusive results. No gabapentin was detected, contrary to initial suspicions.Defoe was charged in the District Court of McKenzie County, Northwest Judicial District, with possession of methamphetamine, possession of drug paraphernalia, and driving under suspension. Two additional charges were dismissed before trial. The jury found Defoe guilty on all counts, and the district court entered judgment. Defoe appealed, arguing improper jury instructions deprived him of due process and that there was insufficient evidence to support his convictions. He did not object to the jury instructions at trial but argued the issue in his Rule 29 motion for acquittal, which was denied.The Supreme Court of North Dakota reviewed the appeal. It held that Defoe had not preserved any challenge to the jury instructions for appellate review, as he failed to object distinctly and specifically as required under N.D.R.Crim.P. 30(c). The Court also found no plain error in the instructions, concluding they accurately stated the law and did not mislead the jury. Additionally, the Court determined that substantial evidence supported the jury’s verdicts. The criminal judgment was affirmed. View "State v. Defoe" on Justia Law

In 1981, a murder occurred in Wichita, Kansas, and physical evidence, including fingernail scrapings and a hair strand, was collected from the victim. The State charged an individual with the murder, largely based on eyewitness testimony. The defendant argued that the physical evidence could exculpate him, but the jury convicted him of first-degree premeditated murder, and he was sentenced to life in prison. His conviction and sentence were affirmed on direct appeal.Years later, the defendant filed successive petitions in Sedgwick District Court—first in 2008, then in 2010, and again in 2025—seeking postconviction DNA testing of the fingernail scrapings and hair strand under K.S.A. 21-2512. In each instance, the district court summarily denied the petitions, finding that the State no longer possessed the items. The court’s denials of the 2008 and 2010 petitions were not appealed.When the third petition was filed in 2025, the Sedgwick District Court again denied relief, this time also ruling that issue preclusion (collateral estoppel) barred the claim because the same issue—the availability of the evidence—had already been decided on the merits in the earlier, unappealed decisions. The defendant appealed this third denial directly to the Supreme Court of the State of Kansas.The Supreme Court of Kansas held that issue preclusion barred the third DNA-testing petition because the requirements for the doctrine were met: the same issue had previously been litigated, was necessary to the prior judgments, and involved the same parties. The court further found no abuse of discretion by the district court in applying issue preclusion, even though the defendant argued he was not advised of his right to appeal earlier denials. The judgment of the district court was affirmed. View "State v. Rhodes " on Justia Law

The defendant was charged with two counts of first-degree premeditated murder and several related offenses. Jury selection began, but before the jury was sworn, the defendant entered into a plea agreement to plead guilty to two counts of first-degree felony murder. At the plea hearing, the district court, prosecutor, defense counsel, and the written plea agreement all stated that the defendant would be eligible for parole after 25 years. However, due to the defendant’s criminal history, the applicable statute required a mandatory minimum sentence based on sentencing guidelines, resulting in a much longer period before parole eligibility. The defendant later learned of this discrepancy and moved to withdraw his pleas, arguing he had been misinformed about the parole eligibility date and would not have pleaded guilty had he known the true consequences.The Wyandotte District Court reviewed the motion to withdraw the guilty pleas before sentencing. The court found that the defendant had been adequately advised and entered his pleas freely, knowingly, and voluntarily. It denied the motion, imposed concurrent life sentences with parole eligibility after 620 months, and did not address the issue of the incorrect parole eligibility information. The defendant timely appealed, raising both the plea withdrawal issue and a challenge to the classification of a prior conviction.The Supreme Court of the State of Kansas held that the district court abused its discretion by denying the motion to withdraw the guilty pleas. The Court concluded that a plea cannot be considered fairly and understandingly made when the plea agreement and colloquy materially misstate parole eligibility, the misinformation is not corrected before the plea, and the record shows this mistake directly influenced the decision to plead guilty. The Court reversed the convictions, vacated the sentences, and remanded the case with directions to allow the defendant to withdraw his pleas. View "State v. Byers " on Justia Law

On the afternoon of July 31, 2022, a shooting occurred at a BP gas station in Overland Park, Kansas. Surveillance video captured Zarrell Semaj Finley retrieving an AK-47 from a backpack and shooting Shaquille Jackson multiple times following a brief physical struggle over the backpack. Finley then fled the scene with others, leaving Jackson, who later died from his wounds. During a subsequent police interview, Finley admitted to drinking heavily before the incident and claimed he acted in self-defense, believing Jackson was armed and posed a threat. Finley's sister testified that the firearm belonged to her, and Finley had been drinking on the day of the shooting.In Johnson District Court, Finley was charged with first-degree premeditated murder and criminal possession of a weapon by a convicted felon, to which he pleaded guilty to the weapons charge. The murder charge proceeded to trial, where the jury found Finley guilty, and the court imposed a life sentence. At trial, the court denied Finley’s requests for jury instructions on voluntary intoxication and heat of passion voluntary manslaughter. The court also declined to instruct on voluntary manslaughter based on defense of an occupied vehicle, but did instruct on imperfect self-defense voluntary manslaughter and other lesser included offenses.The Supreme Court of the State of Kansas reviewed Finley’s direct appeal. The court held that the district court properly refused Finley’s requested jury instructions because the evidence did not support a finding of impairment sufficient for voluntary intoxication, nor was there legally sufficient provocation for heat of passion manslaughter or factual basis for a defense of an occupied vehicle instruction. The court found that any prosecutorial errors during closing argument were harmless beyond a reasonable doubt. Finally, it concluded that sufficient evidence supported the jury’s finding of premeditation. The court affirmed Finley’s conviction. View "State v. Finley " on Justia Law

The defendant was convicted by a jury of six child-sex crimes involving two minor victims. At sentencing, the district court imposed life imprisonment without the possibility of parole for 100 years and ordered the defendant to pay a $2,400 Children's Advocacy Center fee, calculating $400 for each conviction as required by the relevant Kansas statute.Following sentencing, the defendant appealed to the Kansas Court of Appeals, arguing that the statute, K.S.A. 20-370(a), only permitted the imposition of a single $400 fee regardless of the number of convictions. The Kansas Court of Appeals disagreed and held that the statute’s plain language required a $400 fee for each conviction where a minor was a victim.The Supreme Court of the State of Kansas granted review to resolve the statutory interpretation question. Upon examining the statutory text, the Supreme Court determined that K.S.A. 20-370(a) is ambiguous because it supports both a per-defendant and a per-conviction reading. Applying ordinary rules of grammar, the Court concluded that the statute imposes a single $400 fee per qualifying defendant, not per conviction. The Court found that other interpretive canons and legislative history did not provide convincing evidence to contradict this grammatical reading.Accordingly, the Supreme Court of the State of Kansas held that K.S.A. 20-370(a) requires courts to order any defendant convicted of a crime involving a minor to pay only one $400 assessment fee, regardless of the number of convictions in that case. The Court reversed the judgment of the Court of Appeals, vacated the district court’s fee order, and remanded the case with directions to impose just a single $400 fee. View "State v. Mildfelt " on Justia Law

The defendant was charged with aggravated assault after an incident in downtown Fargo, where the victim sustained serious injuries, including facial fractures and lacerations. Security footage captured the assault, and the defendant was later found wearing clothing matching the assailant in the video. The victim did not testify, but had signed a medical authorization allowing disclosure of certain health information to the police. At trial, the State called a physician to testify about the victim’s injuries. The defense did not object to the introduction of medical testimony or records, and explicitly agreed that such evidence would be admissible, provided it did not identify the defendant as the assailant. During opening statements, the prosecutor made remarks inviting jurors to imagine themselves in the victim’s position.The District Court of Cass County, East Central Judicial District, admitted the physician’s testimony regarding the victim’s injuries, over no objection from the defense, and allowed the medical authorization into evidence. The jury found the defendant guilty of aggravated assault.On appeal to the Supreme Court of the State of North Dakota, the defendant argued that the district court erred by compelling the physician’s testimony in violation of the physician-patient privilege, and that the State committed prosecutorial misconduct by making a “golden rule” argument during opening statements. The Supreme Court held that the physician-patient privilege belongs exclusively to the patient, not the defendant, so the defendant could not assert it to exclude the physician’s testimony. The court also concluded that, although the prosecutor’s remarks were improper, the lack of a timely objection and the context of the case meant there was no obvious error requiring reversal. The Supreme Court of North Dakota affirmed the conviction. View "State v. Rockefeller" on Justia Law