Justia Criminal Law Opinion Summaries

In the summer of 2019, a series of violent crimes occurred in Woodbridge, Virginia, involving multiple murders linked to members of the Sitios Locos Salvatrucha (STLS) clique of MS-13. After investigations, a group of defendants was indicted on charges including racketeering, violent crimes in aid of racketeering (VICAR), murder, witness tampering, and drug-related offenses. Several defendants pled guilty and cooperated with authorities, while others, including three individuals central to this appeal, proceeded to trial. The prosecution relied heavily on testimony from a cooperating witness who described the structure of the gang and detailed the defendants’ involvement in four murders.The United States District Court for the Eastern District of Virginia severed the trial due to complexity, ultimately trying three defendants together. After closing arguments, the district court found one defendant’s closing argument improper and instructed the jury to disregard it entirely. The jury returned guilty verdicts on all counts for two defendants and on most counts for the third. The convicted defendants raised various challenges, including claims of improper jury instructions, limitations on cross-examination, alleged due process violations related to evidence preservation and witness deportation, and the propriety of certain special jury findings.On appeal, the United States Court of Appeals for the Fourth Circuit held that the district court’s instruction to the jury to disregard the entire closing argument of one defendant was a prejudicial abuse of discretion, vacated the conviction as to that defendant, and remanded for further proceedings. However, the Fourth Circuit affirmed the convictions of the other two defendants, finding that the curative instruction was sufficient to cure any possible prejudice and rejecting the remaining challenges to the trial court’s rulings. View "US v. Arevalo Arias" on Justia Law

A juvenile was charged with two counts of possession or transfer of machinegun conversion devices, known as Glock switches, which enable semiautomatic pistols to fire automatically. The charges were brought under federal statutes, 18 U.S.C. §§ 922(o) and 924(a)(2), after the government certified that the State of Mississippi lacked jurisdiction over the alleged conduct because, at the time, Mississippi did not have a law regulating possession or transfer of machineguns. The juvenile moved to dismiss the charges, arguing that the certification was inadequate and that the statute violated the Second Amendment, but both motions were denied.The United States District Court for the Southern District of Mississippi reviewed the case. After the motions were denied, the juvenile admitted to the charges, waiving appeal rights for all non-jurisdictional issues except his Second Amendment challenge. The district court adjudicated him delinquent and imposed a 19-month term of detention followed by supervised release until age 21.On appeal, the United States Court of Appeals for the Fifth Circuit considered whether the district court had jurisdiction, whether the statute violated the Second Amendment, and whether the Bureau of Alcohol, Tobacco, and Firearms exceeded its authority in classifying Glock switches as machineguns. The Fifth Circuit held that the district court had jurisdiction because Mississippi lacked applicable law at the relevant time, the Second Amendment challenge was foreclosed by United States v. Wilson, 164 F.4th 380 (5th Cir. 2026), which upheld § 922(o) as constitutional, and the statutory challenge regarding ATF’s authority was waived under the terms of the appeal waiver. The Fifth Circuit affirmed the judgment of the district court. View "Sealed Appellee v. Sealed Juvenile" on Justia Law

During a robbery at La Milpa Market in Yakima, Washington, two masked individuals stole approximately $16,000. In the course of the crime, one robber dropped an envelope and the other lost his left glove. Both items were later linked to Eduardo Valencia: the envelope was addressed to his parents’ home and the glove produced a DNA match. Valencia, who has tattoos on the backs of his hands, was arrested months later while driving a car matching the one seen near the crime scene. At trial, Valencia’s defense centered on surveillance footage that did not clearly show tattoos on the left hand of the robber who lost his glove.The United States District Court for the Eastern District of Washington presided over Valencia’s trial. Valencia’s attorney sought to have him display his hands to the jury without testifying, arguing that this act was not testimonial and would not subject him to cross-examination. The district court rejected this, ruling that displaying his hands on the stand constituted testimony and required him to be subjected to cross-examination. Valencia took the stand, testified about his tattoos, and was cross-examined by the government, which then introduced additional evidence—a Facebook photo allegedly contradicting his testimony about the timing of his tattoos. The jury convicted Valencia of Hobbs Act robbery and brandishing a firearm.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that requiring Valencia to take the stand to display his tattoos violated his Fifth Amendment right not to testify, because displaying identifying physical characteristics is not testimonial evidence. This constitutional error was not harmless, as the government emphasized Valencia’s testimony and the jury focused on his hand tattoos. The court reversed the convictions and remanded for a new trial. View "USA V. VALENCIA" on Justia Law

The case concerns a defendant who was charged with unlawfully purchasing a firearm. The district attorney’s office prepared an affidavit and requested that the trial court issue a criminal citation for the defendant to appear in court. The trial court signed the citation, which was then served to the defendant by a sheriff’s deputy. The defendant failed to appear, and a warrant for his arrest was subsequently issued. Later, the state charged him with failure to appear on a criminal citation. The defendant moved to dismiss this charge, arguing the citation was invalid because it was issued by the court rather than a peace officer, as required by statute.The Union County Circuit Court denied the defendant’s motion, concluding the citation was lawful in both form and content. The defendant entered conditional guilty pleas in both the unlawful purchase and failure-to-appear cases, reserving his right to appeal the trial court’s denial of his dismissal motions. On appeal, the Oregon Court of Appeals did not address the merits of the defendant’s argument. Instead, it affirmed on procedural grounds, holding that the defendant’s challenge was not properly made by a pretrial motion to dismiss, as it was essentially a challenge to the sufficiency of the state’s evidence—a matter for trial, not pretrial disposition.The Supreme Court of the State of Oregon reviewed the case to determine whether the Court of Appeals erred by not reaching the merits of the defendant’s challenge. The Supreme Court held that, given the record and the parties’ consent to a conditional plea, the appellate court was required to consider the merits of the legal question reserved. On the merits, the Supreme Court concluded that the criminal citation was not lawfully issued under the relevant statutes because it was issued by the court rather than a peace officer. The Court affirmed in part and reversed in part, upholding the conviction for unlawful purchase but reversing the failure-to-appear conviction and remanding that case. View "State v. Sarria" on Justia Law

After being arrested during a traffic stop in April 2024, the defendant faced multiple criminal charges in Laramie County, Wyoming. At the time, he was already on probation for prior misdemeanor offenses and had an outstanding warrant in a separate felony case. Following the arrest, he was charged with new felonies and misdemeanors, and his probation was eventually revoked, resulting in the imposition of the underlying misdemeanor sentence. Over the subsequent months, he remained in custody at various points for reasons including probation violations and failure to appear, and he ultimately entered guilty pleas to select charges in two felony cases pursuant to a plea agreement.The District Court of Laramie County, after accepting the plea agreement, sentenced the defendant to concurrent terms of imprisonment on the felony charges. At sentencing, the parties disputed the amount of credit for presentence confinement to be applied to his sentences. The State argued that he was entitled only to credit for days spent in custody after completion of his misdemeanor sentence, while the defendant sought credit for nearly all days spent in custody between his arrest and sentencing. The district court initially awarded 56 days of credit, later increasing this to 64 days after further argument, but declined to grant additional credit for periods during which the defendant was serving his misdemeanor sentence.The Supreme Court of Wyoming reviewed the legality of the sentence, specifically the award of credit for presentence confinement. The court held that, under Wyoming precedent, a defendant is only entitled to credit against concurrent sentences in separate cases for time spent in custody if that confinement was due solely to a financial inability to post bond. Because the defendant was in custody for probation revocation and serving a sentence in another case, rather than solely due to an inability to post bond, he was not entitled to additional credit. The Supreme Court of Wyoming affirmed the district court’s judgment. View "Gauna v. State" on Justia Law

A man was convicted and sentenced to death for the murder and kidnapping of another individual, whose body was found in a remote wooded area after he went out to earn money by posing for nude photographs. The victim suffered strangulation and other trauma, and investigators found evidence linking the defendant to the scene, including paint chips matching his father’s car and records of purchases made shortly before the murder. Prior to this incident, the defendant had assaulted another victim in a similar manner. The evidence presented at trial included testimony from medical experts, forensic analysis, and corroboration from law enforcement investigations.After his conviction, the defendant pursued multiple collateral challenges in state and federal courts, including motions for post-conviction relief and DNA testing under Florida Rules of Criminal Procedure 3.851 and 3.853. The Circuit Court in and for Charlotte County summarily denied his third and fourth successive motions for post-conviction relief, as well as his motion for DNA testing. The defendant appealed these denials, requested a stay of execution, and filed a petition for a writ of habeas corpus in the Supreme Court of Florida. The appeals and petition were consolidated for review.The Supreme Court of Florida affirmed the trial court’s summary denials, finding that the defendant’s claims of newly discovered evidence were based on information that could have been obtained earlier through due diligence and did not meet procedural requirements. The Court also held that advances in DNA testing did not create a reasonable probability of a different outcome, and that expedited post-warrant proceedings did not violate due process. The habeas petition was found to be procedurally barred and lacking in merit. Accordingly, the Court denied all relief, including the request for a stay of execution. View "Conahan v. State" on Justia Law

The case arose from a single incident in which the petitioner forcibly took a 2000 BMW from its owner at gunpoint during a high-speed chase through Idaho County. He was charged with multiple offenses, including grand theft of an automobile and armed robbery, both relating to the same act of taking the BMW. The petitioner pleaded guilty to several charges pursuant to a plea agreement, and the district court sentenced him to consecutive terms, including for both grand theft and armed robbery.After his conviction was affirmed by the Idaho Court of Appeals on direct appeal (where he did not raise a double jeopardy argument), the petitioner filed for post-conviction relief in the District Court of the Second Judicial District. He argued that his trial counsel was ineffective for not raising a double jeopardy objection to being convicted and sentenced for both offenses stemming from the same conduct. The district court summarily dismissed his petition, concluding that the double jeopardy claim was both procedurally barred and, on the merits, that grand theft was not a lesser included offense of armed robbery under either the Blockburger test or Idaho’s pleading theory. The Idaho Court of Appeals affirmed.The Supreme Court of the State of Idaho reviewed the case and held that, under the Idaho Constitution’s double jeopardy provision and Idaho’s pleading theory, grand theft as charged was a lesser included offense of the armed robbery charge because both counts were based on the same act of taking the same car from the same victim. The Court clarified that the pleading theory, not the strict elements (Blockburger) test, governs such double jeopardy claims under Idaho law. As a result, the Court vacated the judgment, reversed the district court’s order granting summary disposition, and remanded the case for further proceedings, concluding that the petitioner established a prima facie case of ineffective assistance of counsel. View "Sedillo v. State" on Justia Law

Police officers in the District of Columbia stopped a man on the street after receiving a tip from a confidential informant that a man with a gun was in a particular area, wearing specific clothing and carrying a bag. The tip was relayed between officers, and one officer sent another a screenshot taken from a surveillance camera. The officer who received the tip from the informant did not testify at the suppression hearing. The only testifying officer could not provide details about the informant's reliability or how the tip was obtained, and the description from the informant was generic, lacking specifics such as physical attributes.The Superior Court of the District of Columbia denied the defendant’s motion to suppress, reasoning that the officer’s knowledge of the informant’s reliability could be imputed to the officer who made the stop, and that the informant’s tip was corroborated by finding the defendant at the described location wearing the described clothing. The government argued that the police had reasonable articulable suspicion, and the trial court agreed, endorsing the government’s argument and allowing the evidence recovered after the stop to be used at trial. A jury subsequently convicted the defendant of several firearm-related offenses.On appeal, the District of Columbia Court of Appeals reviewed the suppression ruling de novo, finding that the government failed to provide the court with sufficient facts to independently assess the reliability of the informant’s tip. The court held that conclusory assertions about the informant’s reliability were inadequate, that corroboration of innocent details alone was insufficient, and that the government had not established reasonable articulable suspicion for the stop. The court reversed the defendant’s convictions and remanded for further proceedings. View "Johnson v. United States" on Justia Law

The case involves an altercation between Calvon Reginald Brown and Johnny Paul inside a corner store in Southeast D.C. Video footage showed Brown apparently selling pills to another man just before Paul entered. Paul arrived playing music on a speaker, leading to an argument between Brown and Paul. The pair left the store and continued their confrontation in a nearby alley, where Paul testified that Brown fired a gun at him three times, striking his hip. Paul managed to wrestle the gun away, after which Brown fled. Police recovered shell casings and a bullet fragment from the alley but did not find the gun. Brown was arrested and charged with aggravated assault and related offenses.The Superior Court of the District of Columbia presided over Brown's trial. The government moved to admit video evidence showing Brown seemingly dealing drugs before the encounter with Paul. Brown objected, arguing it was inadmissible and unfairly prejudicial. The court admitted the video without directly addressing the prejudice argument. During trial, the government referenced Brown’s “business” in the store, implying drug activity. The jury convicted Brown on all counts. Before sentencing, Brown’s counsel sought to withdraw due to a conflict of interest stemming from Brown's intent to claim ineffective assistance. The court denied her motion, reasoning that such claims could be raised after sentencing. Brown was sentenced to thirteen years’ imprisonment.The District of Columbia Court of Appeals reviewed the case. It held that the trial court abused its discretion by admitting prejudicial video evidence without properly weighing its probative value and by allowing prejudicial references during trial, but found these errors harmless given the strong evidence supporting conviction. The appellate court also held that the trial court erred by denying counsel’s motion to withdraw before sentencing due to an actual conflict of interest, warranting resentencing before a different judge. The convictions were affirmed, but the case was remanded for resentencing. View "Brown v. United States" on Justia Law

Police officers observed an individual walking past their cruiser and believed, based on the shape protruding from his waistband, that he was carrying a handgun. The individual entered a carry-out restaurant, and when he exited, the officers followed him, repeatedly calling out to get his attention. The individual did not respond and eventually fled, at which point the officers chased and tackled him, recovering a handgun from his person. The officers had no prior information about him, were not responding to a reported crime, and did not know if he had a permit or license to carry the firearm.The Superior Court of the District of Columbia denied the individual’s motion to suppress the evidence obtained from the stop, concluding that there was reasonable, articulable suspicion for the officers to believe he was engaged in criminal activity. The court credited the officer’s testimony that he recognized the outline of a firearm and relied on the individual’s flight as suggestive of consciousness of guilt. Following trial, the individual was convicted of multiple weapon offenses.The District of Columbia Court of Appeals reviewed the case and analyzed whether the stop was supported by reasonable, articulable suspicion as required by the Fourth Amendment. The court concluded that, in light of recent constitutional and statutory changes—including Supreme Court decisions affirming a right to carry firearms—the mere possession of a handgun does not, without additional evidence, provide reasonable suspicion for a stop. The court also determined that the circumstances surrounding the individual’s flight reduced its value as an indicator of criminal wrongdoing. The court therefore held that the officers lacked reasonable, articulable suspicion to justify the stop, vacated the convictions, and remanded the case for further proceedings. View "Quarles v. United States" on Justia Law