Justia Criminal Law Opinion Summaries

During the early morning of February 11, 2018, a shooting occurred at Rehm’s Bar in Huntington, West Virginia, resulting in the death of Brent Jackson from multiple gunshot wounds. Law enforcement responded to the scene and observed two men fleeing: the petitioner, who exchanged gunfire with the bar’s bouncer, and Jordan Jeter, who was seen discarding a firearm and was apprehended. Although Mr. Jeter tested positive for gunshot residue, the police determined that his firearm could not have been the murder weapon and eliminated him as a suspect, focusing their investigation on the petitioner.The petitioner was tried for first-degree murder in the Circuit Court of Cabell County. The State introduced surveillance footage, eyewitness testimony, and statements allegedly made by the petitioner while incarcerated. The defense argued that Mr. Jeter was the shooter, highlighting flaws in the investigation and witness reliability. During trial, a dispute arose regarding whether Mr. Jeter’s plea agreement in federal court would have provided him immunity if he confessed to the murder. The trial judge made a brief comment during this exchange, which the petitioner argues implied judicial endorsement of Mr. Jeter’s innocence. The jury convicted the petitioner of first-degree murder and did not recommend mercy.The Supreme Court of Appeals of West Virginia reviewed the case under the plain error doctrine, given the petitioner’s failure to object contemporaneously or request a mistrial. The Court assumed arguendo that the judge’s comment constituted error but found it was not prejudicial. The Court determined the fleeting comment did not affect the outcome, especially in light of the overwhelming evidence and the judge’s instruction that he had no opinion about the facts. The Court affirmed the conviction and sentence. View "State v. Battle" on Justia Law

The defendant was indicted in Jackson County, West Virginia, for multiple offenses, including grand larceny, alleged to have occurred in January 2020. In June 2021, a jury convicted him on all counts. Shortly after conviction, the State filed a recidivist information, asserting that the defendant had prior felony convictions qualifying him for enhanced sentencing under West Virginia’s habitual criminal statutes. The defendant was arraigned on the recidivist information on June 22, 2021, which was the first day of a new term of court, not during the same term in which he was convicted.The Circuit Court of Jackson County denied the defendant’s motion to dismiss the recidivist information, reasoning that the term of court had not officially ended until the grand jury was impaneled later on June 22. After a jury determined that the defendant was the person previously convicted of felonies, the court imposed consecutive sentences for the underlying offenses and a life sentence enhancement for grand larceny pursuant to the recidivist statute. The defendant was resentenced for purposes of appeal, and he challenged the timeliness of his arraignment on appeal.The Supreme Court of Appeals of West Virginia reviewed the circuit court’s denial de novo and found that, under West Virginia law and court rules, the new term of court began on the fourth Tuesday in June—June 22, 2021—and not when the grand jury was impaneled. The Court held that the statutory requirement for arraignment on a recidivist information during the same term of conviction is mandatory and jurisdictional. Because the defendant was arraigned in the next term, the recidivist enhancement was void. The Court reversed the circuit court’s order imposing a recidivist life sentence and remanded for resentencing without the enhancement. View "State v. Swindler" on Justia Law

The defendant was involved in a fatal altercation at Terry’s Café, where surveillance footage showed he shot and killed an acquaintance, Jeremy Peters, after Peters retrieved and concealed a knife. The defendant was indicted for first-degree murder and three counts of wanton endangerment with a firearm. During his January 2023 trial, several key participants, including the defendant, counsel for both sides, court staff, and at least one juror, contracted COVID-19, leading the Circuit Court of Boone County to declare a mistrial due to health concerns and potential prejudice to both parties.Following the mistrial, the defendant moved to dismiss the charges on double jeopardy grounds, arguing that the retrial was barred because the court failed to consider a brief continuance, which both parties had suggested as an alternative. The Circuit Court denied the motion, finding that the COVID-19 outbreak constituted a manifest necessity for the mistrial and was outside the State’s control. The defendant was retried, found guilty of voluntary manslaughter, acquitted of the wanton endangerment charges, and sentenced to fifteen years of incarceration. He appealed the sentencing order, challenging the mistrial ruling.The Supreme Court of Appeals of West Virginia reviewed the case and held that the circuit court acted within its discretion in determining that a manifest necessity existed for declaring a mistrial due to the widespread COVID-19 outbreak among trial participants. The court concluded that the retrial was not barred by double jeopardy because the mistrial was justified by manifest necessity, even though the procedure for considering alternatives was imperfect. The court affirmed the circuit court’s sentencing order. View "State v. Dickens" on Justia Law

Kelly was suspected of illegal drug activity after Detective Jonathan Smith observed a drug sale involving a black male who left the scene in a red vehicle with a white female passenger. Shortly after, Deputy Cody Jett received an anonymous tip indicating Heather McDonald would arrive in a red Hyundai at a McDonald’s restaurant, accompanied by a black male driver, and that both individuals possessed heroin and were dealing drugs. Deputy Jett verified an arrest warrant for McDonald. At the restaurant, Jett observed a vehicle matching the tip, McDonald, and a black male later identified as Kelly. After Kelly and McDonald responded to Jett’s instructions, McDonald attempted to flee and was apprehended, while Kelly was detained and eventually admitted there were drugs in the vehicle. Officers subsequently obtained a search warrant, found additional evidence, and arrested Kelly for driving with a suspended license and several drug offenses.The United States District Court for the Middle District of Florida initially denied the officers’ motion to dismiss under Heck v. Humphrey, finding it could not conclude at that stage that Kelly’s Fourth Amendment claims were barred. Later, upon motions for summary judgment, the district court granted summary judgment in favor of the officers, holding that Heck barred Kelly’s suit because success would imply the invalidity of his convictions. The district court did not address qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and declined to base its decision on Heck. Instead, the appellate court found that both Deputy Jett and Detective Smith were entitled to qualified immunity because there was probable cause to detain Kelly, given the corroborated anonymous tip and observed circumstances. The Eleventh Circuit affirmed the summary judgment in favor of the officers. View "Kelly v. Jett" on Justia Law

The defendant, a law enforcement officer, was accused of knowingly engaging in sexual contact with his nine-year-old daughter during a family cruise to the Bahamas. The incident occurred in a public dining room on the cruise ship, where witnesses observed the defendant repeatedly reaching under his daughter’s dress and touching her upper and inner thighs, with some testimony indicating attempts to touch her groin area. One witness recorded the incident, and security personnel were alerted. Upon the ship’s return to Miami, law enforcement detained and questioned the defendant, who denied any sexual intent, claiming his actions were innocent.The United States District Court for the Southern District of Florida conducted a jury trial in which the government presented video evidence, eyewitness testimony, and expert opinions. The defense offered character witnesses and expert testimony negating any sexual motivation or psychiatric disorder, and the defendant testified in his own defense. The jury found him guilty of violating 18 U.S.C. § 2244(a)(5). After trial, it was discovered that the jury had access to an unredacted indictment containing forfeiture allegations referencing statutes related to child pornography, though the case did not involve such materials. The defendant filed motions for acquittal and for a new trial, arguing insufficient evidence of intent and prejudice from the jury’s exposure to extrinsic evidence.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the evidence presented at trial was sufficient for a rational jury to find the necessary criminal intent beyond a reasonable doubt, and that the district court did not abuse its discretion in concluding that the government had rebutted the presumption of prejudice arising from the jury’s exposure to the unredacted indictment. The Eleventh Circuit affirmed the conviction and denial of a new trial. View "USA v. Sigmon" on Justia Law

The case concerns a shooting in a Los Angeles park involving rival gangs. Jesus Guzman, associated with Lawndale 13, was accused of killing David Najera, a member of Muertos 13, after an altercation between the gangs the previous night at a hookah bar. The prosecution argued that Guzman and his gang sought revenge for the prior incident, resulting in Najera’s death and the attempted murder of another Muertos member, Portillo. Evidence against Guzman included eyewitness descriptions, video footage, and information from a confidential reliable informant who identified Guzman by his gang moniker and linked his social media account to the crime.The Superior Court of Los Angeles County presided over Guzman’s trial. The jury convicted Guzman of second-degree murder and premeditated attempted murder, finding that a principal—but not Guzman himself—personally and intentionally discharged a firearm causing death. Guzman was sentenced to 22 years to life. The central issue on appeal was Guzman’s challenge to the police search of his social media account, arguing that the affidavit supporting the search warrant lacked sufficient probable cause and did not establish a link between his account and the crime.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. The court held that the evidence obtained from Guzman’s social media account was properly admitted because, at a minimum, the good-faith exception to the exclusionary rule applied. The affidavit supporting the search warrant provided a reasonable basis for police to believe the warrant was valid, and it was reasonable to infer that the social media account would contain relevant evidence. The judgment of the trial court was affirmed. View "People v. Guzman" on Justia Law

Victor Grandy was convicted by a jury in 1993 for distributing at least fifty grams of crack cocaine, violating 21 U.S.C. § 841(a)(1). He was sentenced to life imprisonment and a ten-year term of supervised release, as required by the statute at the time. After serving over twenty-six years in prison, Grandy’s sentence was reduced in 2019 under the First Step Act, and he began his supervised release. During supervised release, Grandy demonstrated successful reintegration, maintaining stable employment, volunteering, and pursuing a flourishing art career. However, the conditions of supervised release limited his ability to travel for art shows. In February 2025, Grandy moved for early termination of supervised release, citing his exemplary conduct and professional burdens.The United States District Court for the Central District of California denied Grandy’s motion. The court reasoned that the mandatory minimum term of supervised release imposed under 21 U.S.C. § 841(b)(1) precluded early termination. It further determined Grandy had not shown extraordinary circumstances warranting early termination, relying on extrarecord sources: a 2022 U.S. Sentencing Commission recidivism study and an outdated Administrative Office of the U.S. Courts’ Guide. The court misinterpreted statistics from the study and applied an obsolete nine-factor test, concluding Grandy’s ongoing success justified continued supervision.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that 21 U.S.C. § 841(b)(1) does not prohibit early termination of supervised release under 18 U.S.C. § 3583(e)(1), as the government conceded. The Ninth Circuit found the district court abused its discretion by misinterpreting extrarecord evidence, relying on outdated guidance, and treating Grandy’s success as a reason for continued supervision. The court reversed the denial of Grandy’s motion and remanded for further proceedings, declining to reassign the case to a different judge. View "USA V. GRANDY" on Justia Law

A chemical dependency counselor and clinical supervisor, who also served as a treatment team representative for a drug court program, developed a relationship with a drug court coordinator. The coordinator requested drugs from the counselor, who procured them through her boyfriend. After several exchanges, the coordinator died from an overdose. Law enforcement traced the drugs to the counselor and her boyfriend. A grand jury indicted the counselor for conspiracy to distribute a controlled substance, but she ultimately pleaded guilty to an amended charge of conspiracy to possess a controlled substance, specifically methamphetamine, following a plea agreement.The Circuit Court of the Fourth Judicial Circuit, Meade County, accepted the plea and sentenced the counselor to five years in the state penitentiary, suspending one year contingent on compliance with treatment and payment of costs. The court cited several aggravating factors justifying departure from presumptive probation, including the counselor’s failure to cooperate with a presentence investigation, drug use while employed as a counselor, failure to take responsibility, repeated unsuccessful treatment attempts, and connection to the coordinator’s death. The counselor appealed, arguing that the sentence exceeded the statutory maximum for her offense.The Supreme Court of the State of South Dakota reviewed the case under a plain error standard, as the issue was not raised in the lower court. The court found that the circuit court erred by imposing a sentence authorized for a Class 5 felony rather than for a Class 6 felony, which is the appropriate classification for conspiracy to possess a controlled substance under South Dakota law. The Supreme Court vacated the sentence and remanded the case for resentencing within the statutory limits for a Class 6 felony. View "State V. Pray" on Justia Law

Several misdemeanor prosecutions were consolidated in a municipal court after the City Attorney for Henderson argued that Nevada Revised Statute 178.4849(1), which requires pretrial release hearings within 48 hours of arrest, impaired prosecutors’ ability to prepare adequately for those hearings. The City sought a declaration that the statute was unconstitutional under Marsy’s Law and the separation-of-powers doctrine. In each case, defendants were arrested on weekends and brought before the municipal court within 24 hours. The City asserted that the compressed timeline undermined its ability to protect victims’ rights and to present sufficient evidence for bail determinations.The Henderson Municipal Court consolidated the cases and found that the City had both direct standing and third-party standing to challenge the statute on behalf of victims. It declared NRS 178.4849 unconstitutional under Marsy’s Law and separation-of-powers principles, citing conflicts with statewide pretrial risk assessment requirements and judicial precedent. Respondents petitioned the Eighth Judicial District Court for a writ of mandamus or prohibition. The district court concluded the City lacked both direct and third-party standing, as it failed to demonstrate a concrete, traceable injury and victims were not hindered from asserting their own interests. The district court also found the statute constitutional and granted the petition.Reviewing the appeal, the Supreme Court of the State of Nevada determined that the City of Henderson had not established standing. It found no concrete injury to the City’s prosecutorial interests that was traceable to NRS 178.4849 or likely to be redressed by the requested relief. The court held that the City lacked both direct and third-party standing, and the public-importance exception did not apply. Without standing, the court declined to address the constitutional merits and affirmed the district court’s order granting the writ. View "CITY OF HENDERSON VS. ARMENDAREZ" on Justia Law

Law enforcement officers obtained a warrant for Robinson’s arrest on charges of attempted murder and possession of a firearm by a convicted felon. After an arrest at a music festival, Robinson was booked on “local charges” relating to contraband discovered at the scene, while a detainer was placed for the Duval County charges. He was convicted and served a sentence for the local offenses before being transported to Jacksonville, where he was formally charged with the Duval County offenses nearly two years after his initial arrest.Robinson moved for discharge, arguing that the initial arrest triggered the speedy trial period and that the State’s failure to file charges within 175 days entitled him to automatic discharge under State v. Williams. The Circuit Court in Duval County denied the motion. Robinson subsequently entered a plea and was sentenced, but appealed the denial. The Fifth District Court of Appeal reversed the trial court, finding Williams compelled discharge because charges were filed after expiration of the speedy trial period. The judges applied the Melton v. State test to determine the arrest date and agreed that if the arrest occurred on November 2, 2015, the speedy trial period had expired before charges were filed. However, they questioned whether Williams was correctly decided and certified a question of public importance.The Supreme Court of Florida reviewed the certified question de novo. It concluded that rule 3.191 never permitted automatic discharge solely for failure to file charges within the speedy trial period, and that the State is entitled to the recapture period in all situations, even when charges are filed after the speedy trial time has run. The court receded from Williams, quashed the Fifth District’s decision, and remanded with instructions to reinstate Robinson’s convictions and sentences. View "State v. Robinson" on Justia Law