Justia Criminal Law Opinion Summaries

A lawyer who served as a legal advisor to a Puerto Rican municipality and its mayor became involved in a scheme related to funds awarded to the municipality for trauma center renovations. The municipal legislature had created a for-profit corporation to promote economic development. Following the deposit of $9 million—traceable to the trauma center renovation funds—financial consultants persuaded the mayor to invest the money, promising it would benefit the municipality and be returned after generating interest. However, the consultants and associates, including the defendant, orchestrated a fraudulent transfer of the funds through multiple accounts and corporate entities. The defendant’s company received significant payments from these transactions, for which he fabricated invoices and provided no actual services. He used some of the money for personal expenses. When auditors later questioned the $9 million transfer, the defendant and others falsely asserted that the transaction was lawful and the funds were appropriately invested.A federal grand jury in Puerto Rico indicted the defendant and several others on charges including wire fraud conspiracy, substantive wire fraud, and money laundering. At trial in the United States District Court for the District of Puerto Rico, the defendant moved for judgment of acquittal based on insufficient evidence, but the court denied the motions. The jury found him guilty on all counts. The district court sentenced him to thirty-seven months’ imprisonment and denied his subsequent pro se motion for a sentence reduction.The United States Court of Appeals for the First Circuit reviewed the case. The court held that sufficient evidence supported the defendant’s convictions, as a reasonable jury could find he knowingly participated in a single overarching conspiracy to defraud the municipality. The court also held it lacked jurisdiction to review the denial of his sentence reduction motion because no notice of appeal was filed for that order. The court affirmed the convictions and dismissed the sentencing challenge. View "US v. Irizarry-Irizarry" on Justia Law

A licensed podiatrist in Illinois, holding a DEA registration, was investigated for his opioid prescription practices. After an undercover operation involving agents posing as patients, he was indicted on 74 counts for unlawfully prescribing controlled substances. The indictment included prescriptions written for undercover agents and several patients, with each count corresponding to a specific prescription. At trial, the evidence focused on a single undercover visit where the agent explicitly stated she was not in pain but only had discomfort from work. Despite this, the doctor prescribed her 90 hydrocodone pills without any medical examination, diagnosis, or documentation.A jury in the United States District Court for the Northern District of Illinois, Eastern Division, found the doctor not guilty on 73 counts but convicted him on the count related to prescribing opioids to the undercover agent who reported only discomfort. The district court sentenced him to six months’ incarceration, three years of supervised release, and imposed a $50,000 fine. The defendant challenged the sufficiency of the evidence, certain evidentiary rulings, the denial of his motion for a mistrial, and the imposition of the fine.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court did not abuse its discretion in admitting lay testimony from a pharmacist, as it was limited to personal observations and did not constitute expert opinion. The court also held there was no error in denying a mistrial based on a stray witness remark, as it was isolated and unrelated to the count of conviction. The Seventh Circuit found the evidence sufficient to support the conviction and concluded that the district court properly considered the relevant factors in imposing the fine. The conviction and sentence were affirmed. View "USA v Fung" on Justia Law

Nearly forty years ago, the defendant was convicted of the sexual battery and first-degree murder of an eleven-year-old child. After the Governor signed a warrant for execution in February 2026, the defendant filed several postconviction motions. These included a motion for DNA testing of a sample from the victim's underwear and a fifth successive motion for postconviction relief. The circuit court granted the DNA testing request but denied the postconviction relief motion. DNA testing did not exonerate the defendant, and the stay of execution was lifted.Following those events, the defendant filed a second post-warrant motion for DNA testing, seeking analysis of additional items, as well as a sixth successive motion for postconviction relief. The Circuit Court for Lake County summarily denied both motions, finding the DNA testing request was procedurally barred because the defendant could have sought testing of those items earlier. The court also determined there was no testable genetic material on the items requested for testing. Regarding the postconviction motion, the court rejected the defendant’s claim that the State violated due process by not sending a sample to a Texas laboratory for a different DNA testing method, finding no evidence of bad faith by the State in consuming the sample during testing.On appeal, the Supreme Court of Florida affirmed the circuit court’s summary denial of both motions. The Court held that the DNA testing motion was procedurally barred and meritless, as no DNA existed on the items sought to be tested. The Court also held that the defendant failed to demonstrate bad faith by the State under Arizona v. Youngblood in the destruction of evidence during DNA testing. The Court denied the motion for stay of execution and stated that no motion for rehearing would be considered. View "Duckett v. State" on Justia Law

The case concerns a defendant who was arrested after his girlfriend reported to police that he had struck her, taken her handgun, chambered a round, and threatened her with it. Forensic evidence later confirmed his DNA on the weapon. The defendant gave conflicting accounts, initially denying knowledge of the gun, then claiming he took it from his girlfriend to protect himself. Officers arrested him, and he was charged in state court with domestic violence and illegal firearm possession. While out on bond, federal prosecutors indicted him for being a felon in possession of a firearm after an earlier felony conviction. During execution of a federal arrest warrant, officers found a stolen rifle in the home. The government offered a plea deal involving a single count, which the defendant declined, resulting in a superseding indictment on two counts.The United States District Court for the Northern District of Ohio denied the defendant’s motion to suppress the rifle and his motion to dismiss on Second Amendment grounds. The defendant ultimately pleaded guilty to both counts without a written plea agreement. At sentencing, the district court applied an enhancement for possessing a firearm in connection with a felony offense, based on evidence that he had threatened his girlfriend with the handgun, and imposed a 100-month prison sentence. The defendant appealed, raising constitutional arguments and challenging the sentencing enhancement.The United States Court of Appeals for the Sixth Circuit held that, because the defendant pleaded guilty unconditionally and did not comply with Federal Rule of Criminal Procedure 11(a)(2), he waived his right to appeal pre-plea constitutional issues. The court declined to address his ineffective assistance of counsel claim on direct appeal, finding the record undeveloped. Reviewing the sentencing enhancement for clear error, the court found ample evidence to support the district court’s application of the enhancement and affirmed the sentence. View "United States v. Williams" on Justia Law

Christopher Hemwall was convicted by a jury in Michigan of multiple counts of criminal sexual conduct involving his twin half-sisters, with the incidents occurring when the victims were between four and six years old. The offenses took place from 2005 to 2008 and were reported to authorities roughly a decade later. Following his conviction, Hemwall received a lengthy prison sentence. He exhausted his appellate rights, with the Michigan Court of Appeals affirming his conviction and the Michigan Supreme Court denying leave to appeal. Hemwall did not pursue review by the U.S. Supreme Court, and his convictions became final in August 2021.Hemwall sought post-conviction relief in Michigan courts, alleging ineffective assistance of counsel. The Monroe County Circuit Court denied his motion, the Michigan Court of Appeals declined leave to appeal, and the Michigan Supreme Court denied leave in January 2024. Hemwall then filed a federal habeas petition under 28 U.S.C. § 2254 in the United States District Court for the Eastern District of Michigan, but it was filed nearly three months after the statutory deadline. Hemwall requested equitable tolling of the one-year statute of limitations, citing his attorney’s health issues and those of the attorney’s child, as well as COVID-19-related disruptions. The district court dismissed the petition, finding Hemwall failed to establish that these circumstances caused the late filing, but granted a certificate of appealability due to unsettled precedent.The United States Court of Appeals for the Sixth Circuit reviewed the case. It assumed for argument’s sake that the attorney’s health difficulties could qualify as extraordinary circumstances but held that Hemwall did not prove these difficulties caused the late filing. The Sixth Circuit found no clear error in the district court’s factual finding that the attorney’s personal issues did not prevent timely filing, especially given evidence that the attorney was able to continue practicing law and that the federal petition was largely copied from prior state filings. The court affirmed the district court’s dismissal of Hemwall’s habeas petition. View "Hemwall v. Douglas" on Justia Law

An elderly man, Harold Anderson, was removed from his home in Glenrock, Converse County, Wyoming, and hospitalized in Casper, Natrona County, due to mental health issues. While hospitalized and unable to make decisions for himself, Mr. Anderson transferred title of his vehicle and mobile home to Goldie Beedy, who took possession of both items. The transfer documents reflected values significantly below the property’s actual worth. Around the same time, local law enforcement found Ms. Beedy at Mr. Anderson’s Glenrock home, where she claimed she would become his guardian, presenting incomplete guardianship paperwork. Shortly thereafter, the Wyoming Guardianship Corporation was appointed as Mr. Anderson’s guardian.The State charged Ms. Beedy in Converse County with exploitation of a vulnerable adult. She moved to dismiss the charge, contending that the alleged conduct occurred in Natrona County, as Mr. Anderson was hospitalized there during the relevant period. The District Court of Converse County denied the motion, and a jury convicted her. The district court sentenced Ms. Beedy to a suspended prison term with supervised probation and ordered restitution for the mobile home, vehicle, and clothing purchased for Mr. Anderson by his guardian, finding Ms. Beedy’s control of the mobile home prevented access to his clothing. Restitution for other items was denied.On appeal, the Supreme Court of the State of Wyoming held that sufficient evidence supported the jury’s finding that the exploitation occurred in Converse County, as Ms. Beedy’s acts to complete the crime—including taking possession of the property and filing title documents—occurred there. The court also found no abuse of discretion in the restitution order for clothing, as Ms. Beedy’s conduct necessitated the purchases. The Supreme Court affirmed the district court’s judgment in all respects. View "Beedy v. The State of Wyoming" on Justia Law

A police sergeant stopped an individual riding a bicycle at night because he believed the bicycle did not have a light on the front, as required by Wyoming law. Upon approaching, the officer discovered the bicycle had a light, but it was very dim. The officer explained the stop, stating the light did not appear to meet statutory requirements. The individual was arrested on an outstanding warrant, and during a search, drug paraphernalia with methamphetamine residue was found. The defendant moved to suppress the evidence, arguing the stop was invalid because the officer misinterpreted the statutory requirement and made a mistake regarding the presence of a light.The District Court of Natrona County held a hearing, at which only the initial justification for the stop was contested. The court found the officer’s mistake of fact—believing there was no light—was reasonable under the circumstances, even though the statute required the light to be visible from a certain distance, not to project light. The court denied the suppression motion. The defendant entered a conditional guilty plea, reserving the right to appeal the denial of the suppression motion. He was sentenced to probation. On appeal, the defendant raised issues about the extension of the stop and ineffective assistance of counsel.The Supreme Court of Wyoming reviewed the case, adopting the district court’s factual findings unless clearly erroneous and reviewing legal questions de novo. The Court held that the officer’s initial stop was supported by reasonable suspicion based on an objectively reasonable mistake of fact. The Court further held the defendant waived issues relating to the extension of the stop and ineffective assistance of counsel because they were not reserved in his conditional plea agreement and were not tied to the voluntariness of his plea. The judgment was affirmed. View "Glenn v. The State of Wyoming" on Justia Law

The case concerns a defendant convicted by a jury of first-degree premeditated murder and aggravated battery, arising from a shooting incident in which he killed his friend and injured another person. The defendant claimed at trial that he acted in self-defense after an attempted armed robbery by the victims, but the prosecution presented a different narrative, arguing the shooting was deliberate. The jury rejected the self-defense claim, and the court imposed a life sentence. The Kansas Supreme Court previously affirmed these convictions.Subsequently, the defendant filed a pro se motion under Kansas’s postconviction DNA testing statute, seeking forensic testing on various items, including a rifle, clothing, and biological samples. The State responded that few, if any, relevant biological materials were in its possession and argued that even if DNA evidence existed, testing would not yield exculpatory results because the defendant admitted handling the weapon. The Wyandotte District Court appointed counsel and held an evidentiary hearing, at which the defendant focused his request on DNA from the murder weapon. Ultimately, the district court denied the motion, finding that the defendant failed to identify specific biological material in the State’s possession and that, regardless, such testing would not produce exculpatory evidence relevant to his claim of innocence.On appeal, the Supreme Court of the State of Kansas reviewed the district court’s factual findings for substantial competent evidence and its legal conclusions de novo. The Supreme Court held that the district court did not err in denying the postconviction DNA testing request. It concluded that, even if DNA from the rifle or other items were available for testing, the results would not produce exculpatory evidence as required by statute, because such evidence would not prove a disputed material fact relevant to the defendant’s claim of wrongful conviction. The Supreme Court affirmed the district court’s denial of the motion. View "State v. Dotson " on Justia Law

In this case, law enforcement initiated an investigation after receiving a tip about online activity linked to incriminating material involving child sexual exploitation. The investigation led to the arrest and prosecution of the defendant for rape, aggravated criminal sodomy, and sexual exploitation of a child based on alleged conduct years prior, as well as an additional charge of solicitation to commit capital murder after the defendant allegedly attempted to have his accusers killed to prevent their testimony. The alleged offenses involved two victims who were minors at the time.The Leavenworth District Court initially denied the defendant’s pretrial motion to dismiss the sex offense charges as time-barred under the statute of limitations and later permitted consolidation of the solicitation charge. The defendant was convicted by a jury on all counts and received consecutive life sentences for the sex offenses and a separate sentence for the solicitation charge. The defendant renewed his statute of limitations defense post-trial, relying on a different legal theory than had been presented before trial. The district court rejected the post-trial motion. The Kansas Court of Appeals affirmed the convictions, determining that the statute of limitations defense was not preserved for the rape and sodomy charges but was preserved for the sexual exploitation charge, and rejected other claims of trial error.The Supreme Court of the State of Kansas reviewed whether the statute of limitations defense and related sufficiency claims were properly preserved for appeal, as well as challenges to the solicitation conviction and a claim of cumulative error. The court held that preservation requires the same legal theory be presented in the district court and on appeal and that a statute of limitations defense is a waivable affirmative defense, not a jurisdictional issue. Because the defendant’s post-trial theory was not preserved, the court declined to reach the merits and affirmed the lower courts’ rulings, upholding all convictions. View "State v. Manczuk " on Justia Law

A man was involved in two separate incidents in Wichita, Kansas, in early 2021. In March, he was accused of aggravated assault and criminal possession of a weapon after a confrontation with a restaurant owner and his stepson, during which he allegedly displayed a firearm. In May, he was involved in a fatal altercation with a security guard outside a convenience store, resulting in the guard’s death by gunshot. Surveillance footage and eyewitness accounts connected him to both events, and he was identified and arrested. He was charged in a single complaint with six crimes stemming from these incidents.In the Sedgwick District Court, the defendant moved to sever the charges from the two incidents, arguing they should not be tried together. The district court denied this motion, finding the crimes were of the same or similar character and could be joined under Kansas law. At trial, the defendant testified in support of self-defense, but the jury convicted him of first-degree premeditated murder and other related offenses, acquitting him on one aggravated assault charge. He was sentenced to life imprisonment and appealed directly to the Kansas Supreme Court.The Supreme Court of the State of Kansas reviewed several claims: improper joinder of charges, erroneous jury instructions (including those on self-defense and lesser included offenses), exclusion of evidence related to self-defense, and cumulative error. The court held that the charges were properly joined as they were of the same or similar character, the jury instructions given were both legally and factually appropriate, and the exclusion of certain evidence did not violate the defendant’s right to present a defense. Finding no reversible errors, the court affirmed the convictions. View "State v. West " on Justia Law