Justia Criminal Law Opinion Summaries

Law enforcement attempted to stop a vehicle driven by Jeremy Martin for speeding. Martin fled both in his vehicle and on foot before being apprehended. Upon his arrest, officers discovered a pistol, ammunition, and methamphetamine in his possession. Martin, a convicted felon, was charged with being a felon in possession of a firearm under federal law and pleaded guilty to that offense. His criminal record included several recent state convictions, among them multiple drug offenses and a conviction for unlawful betting, where he had used someone else’s identification at a casino, allegedly to avoid paying a $44,000 debt to the State of Iowa. He also owed over $60,000 in child support.The United States District Court for the Northern District of Iowa calculated Martin’s advisory sentencing range at 110-137 months and imposed a sentence of 126 months, to be served consecutively to his outstanding state sentences. The court considered Martin’s criminal history, including the unlawful betting conviction, as aggravating factors. It also discussed his significant child support arrears and inferred that his attempt to use a fake name at the casino was motivated by a desire to avoid paying child support. Martin did not object to these factual statements at sentencing.On appeal, Martin argued to the United States Court of Appeals for the Eighth Circuit that the district court’s inference about his motivation for the unlawful betting offense was based on clearly erroneous facts, specifically conflating his child support debt with his other obligations to the state. The Eighth Circuit reviewed for plain error and held that the district court’s inference was a reasonable one based on undisputed facts in the presentence report. Even if the inference was mistaken, the court found that it was not a principal basis for the sentence and did not affect Martin’s substantial rights. The appellate court affirmed the sentence. View "United States v. Martin" on Justia Law

The State charged Karen Peterson in 2015 with felony possession of a controlled substance. To avoid conviction, Peterson entered the Snohomish County Adult Drug Treatment Court program, agreeing to pay a nonrefundable $900 participation fee and waiving her rights to a speedy trial and a jury. Upon her successful completion of the program, the trial court dismissed the charges with prejudice in 2017. Four years later, the Washington Supreme Court, in State v. Blake, ruled the simple drug possession statute unconstitutional. Peterson, who was never convicted, sought relief under CrR 7.8, requesting a refund of her drug court fee and vacatur of the dismissed charge.The Snohomish County Superior Court granted Peterson’s request, vacating the charge and ordering the State to refund the $900 fee. The Washington Court of Appeals reversed, concluding that CrR 7.8 did not authorize vacatur because Peterson was not convicted, and the fee was not a legal financial obligation (LFO) imposed as part of a criminal sentence. The appellate court also ruled that the trial court had abused its discretion by exceeding its authority under the rule, Blake, and the relevant statute.The Washington Supreme Court reviewed the case de novo. It held that Peterson could use CrR 7.8(b)(5) to seek relief from the order requiring her to pay the drug court fee, as the rule applies to orders as well as judgments. However, the Court found that federal due process protections do not require refund of the fee because it was paid voluntarily as part of an agreement to avoid conviction, not as a consequence of an unconstitutional conviction. The Supreme Court reversed the appellate court in part, affirming that Peterson could seek relief under CrR 7.8(b)(5), but denied her claim for a refund on the merits. View "State v. Peterson" on Justia Law

The defendant was charged with numerous offenses stemming from a series of violent incidents against a single victim, with whom he had a romantic relationship. Over several months, the defendant repeatedly assaulted the victim, causing severe injuries including facial fractures, organ damage, and psychological trauma. The assaults occurred at different locations and were witnessed or reported to various individuals, including family members and law enforcement. The victim sometimes gave inconsistent explanations for her injuries, initially attributing them to accidents or assaults by others, but later testified that the defendant was the perpetrator.The charges were brought in Androscoggin and Franklin Counties and included kidnapping, domestic violence elevated aggravated assault, aggravated assault, stalking, criminal threatening, and violations of conditions of release. After joinder, the case was tried to a jury in Androscoggin County. The defendant denied the assaults and presented an alibi, supported by family testimony. The jury found him guilty of most charges, acquitting him of kidnapping and one count of elevated aggravated assault, but convicting on a lesser-included offense and other counts. The trial court merged certain convictions as required by double jeopardy principles and imposed a primary sentence of twenty-eight years, with concurrent sentences on the remaining counts.On appeal to the Maine Supreme Judicial Court, the defendant challenged the exclusion of impeachment evidence regarding the victim’s prior inconsistent statements, the admission of evidence of earlier assaults, and the sentencing process. The court held that although the impeachment evidence should have been admitted, the exclusion was ultimately harmless given the substantial corroboration of the victim’s account and her impeachment by other means. The court found no error in admitting evidence of prior assaults or in the sentencing analysis. All convictions and the sentence were affirmed. View "State of Maine v. Hanson" on Justia Law

Police officers in Washington, D.C. arrested three men in December 2019 after observing their vehicle parked illegally. One occupant, Antonio Smith, acted erratically and fled from police, carrying suspected narcotics. The officers found a black jacket behind the front passenger seat containing a firearm, drugs, and drug paraphernalia. The jacket belonged to Demann Shelton, who was seated in the back of the car and was cooperative during the encounter. Officers also found Shelton’s identification and mail in the jacket, as well as a significant amount of cash on his person.Shelton was charged in the Superior Court of the District of Columbia with several drug and gun offenses. During the jury trial, the government argued Shelton was the sole possessor of the items found in his jacket. Shelton’s defense theory was that Smith placed the gun and drugs in the jacket before fleeing. After closing arguments, the trial court instructed the jury on actual and constructive possession. During deliberations, the jury asked whether two or more people could have joint possession of an item. The trial court, after conferring with the parties, gave a supplemental instruction explaining joint constructive possession and emphasizing that the jury must find Shelton independently met all elements of constructive possession.On appeal, Shelton argued that the trial court erred by instructing the jury on joint constructive possession without sufficient evidence of concerted action. The District of Columbia Court of Appeals reviewed the trial court’s response for abuse of discretion and the legal accuracy of the instruction de novo. The court held that joint constructive possession does not require proof of concerted action and that the instruction correctly stated the law. The court found the evidence sufficient to support constructive possession and affirmed Shelton’s convictions. View "Shelton v. United States" on Justia Law

The defendant was charged with murder after causing the death of another individual. During the trial, the State amended the charge to manslaughter, alleging he acted with extreme indifference to human life. The defendant argued he acted in self-defense. Evidence was presented concerning a prior assault by the defendant against the victim, including testimony from the victim’s sister and a law enforcement officer recounting admissions made by the defendant. The State also attempted to introduce evidence under North Dakota Rule of Evidence 404(b), but experienced a procedural delay in filing the required notice.The District Court of Grand Forks County, Northeast Central Judicial District, presided over a five-day jury trial. During the proceedings, the court addressed several evidentiary issues. It denied the defendant’s motion for mistrial after certain testimony was objected to and struck from the record, offering a curative instruction that was not requested. The court ultimately admitted the prior-assault evidence, finding good cause for the late notice, identifying non-character purposes for admission, and determining the evidence was reliable and supported by independent proof of guilt. However, the court did not explicitly conduct the required Rule 403 balancing to assess prejudice.Upon appeal, the Supreme Court of North Dakota reviewed the District Court’s rulings. The Supreme Court held that the remedies for the challenged testimony were sufficient and that denying the mistrial was not an abuse of discretion. Although the District Court erred by failing to make a Rule 403 determination on the record when admitting the prior-assault evidence, the Supreme Court found this error harmless due to the limited prejudice and substantial independent evidence supporting the conviction. The Supreme Court affirmed the criminal judgment. View "State v. Bartlette" on Justia Law

A woman was charged in connection with the death of her eleven-month-old niece, who had been left in her care for several hours. The infant, previously healthy, was found unresponsive, and surveillance footage captured the sounds of crying and a sequence of thuds before the defendant called 911. Medical personnel observed a bruise on the child’s head, and subsequent hospital treatment and autopsy revealed acute subdural hematoma, brain swelling, and multiple bruises. Expert witnesses for the prosecution testified that the injuries were consistent with abusive head trauma, while the defense experts posited that the child suffered from chronic subdural bleeding and that a minor bump could have caused a rebleed.The defendant was indicted for first-degree murder in the Massachusetts Superior Court. Prior to trial, the judge conducted a Daubert-Lanigan hearing on the admissibility of expert testimony regarding abusive head trauma. The judge ruled experts could testify that the injuries were “consistent with” abusive head trauma but could not state that such trauma definitively caused the death. Testimony was also limited regarding the causation of such trauma by short falls. At trial, the jury convicted the defendant of involuntary manslaughter under theories of battery and wanton or reckless conduct. The defendant’s motions for a required finding of not guilty were denied.On appeal, the Supreme Judicial Court of Massachusetts reviewed whether there was sufficient evidence for conviction and if the trial judge abused discretion in admitting expert testimony. The Court held the evidence was sufficient for a rational jury to find the elements of involuntary manslaughter beyond a reasonable doubt. The Court also held that the trial judge did not abuse discretion in admitting expert testimony that the injuries were “consistent with” abusive head trauma, finding the diagnosis generally accepted in the medical community. The judgment of conviction was affirmed. View "Commonwealth v. Hsu" on Justia Law

On New Year’s Day 2024, a Franklin County sheriff’s lieutenant attempted to stop a speeding Kia driven by Isaac Martinez-Chavez, who was a convicted felon. The vehicle accelerated, turned off its lights, and stopped in a yard. Upon approaching the car, the officer saw Martinez-Chavez reaching into the passenger area. After detaining him, officers found a sawed-off .22 rifle, a .22 revolver, and .22 caliber ammunition inside the vehicle. Martinez-Chavez claimed he was unaware of the firearms, presenting testimony from Olman Vallejos, who said he hid the guns without Martinez-Chavez’s knowledge. However, Vallejos’s credibility was severely undermined at trial.The United States District Court for the Western District of Virginia presided over the trial. Before trial, Martinez-Chavez requested an adverse-inference jury instruction because dispatch recordings of the arrest had been deleted in accordance with a routine records-retention policy. The district court denied this motion, finding no evidence of bad faith or willful conduct by the government and noting comparable evidence remained. During closing arguments, the prosecutor made two improper remarks, one referring to a witness as a “liar” and another appealing to the jury to convict for the sake of law enforcement. The court overruled defense objections but instructed the jury that statements by lawyers were not evidence and that law enforcement testimony was not to be given extra weight.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that although the prosecutor’s remarks were improper, they did not prejudice Martinez-Chavez’s right to a fair trial, given the overwhelming evidence against him and the curative jury instructions. The appellate court also found the district court did not abuse its discretion in denying the adverse-inference instruction, as there was no showing of willful destruction or governmental knowledge of the recordings’ relevance before their deletion. The conviction was affirmed. View "US v. Martinez-Chavez" on Justia Law

Police officers in Miami-Dade surveilled a house known for prior drug activity and a recent drive-by shooting. They observed Olson Joseph getting a haircut on the front lawn and later noticed he was carrying a concealed handgun in his sweatshirt pocket. The officers detained Joseph at gunpoint, removed the firearm, and conducted records checks, revealing Joseph was a felon without a concealed-carry permit. About twenty minutes after the stop, Joseph was transported to the station. He was subsequently charged in federal court with possession of a firearm and ammunition by a felon in violation of 18 U.S.C. § 922(g)(1).The United States District Court for the Southern District of Florida denied Joseph’s motion to dismiss the indictment, rejecting his argument that § 922(g)(1) violated the Second Amendment. The court also denied his motion to suppress the gun, finding the encounter was a Terry stop and that the officers had reasonable suspicion based on Joseph’s gun possession, his presence in a high-crime area, and proximity to a house associated with a recent homicide and drug activity. Joseph entered a conditional guilty plea, preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that, under circuit precedent, § 922(g)(1) does not violate the Second Amendment and affirmed denial of the motion to dismiss. However, the court found that the officers lacked reasonable suspicion for the stop, since Florida’s 2015 concealed-carry statute amendment made carrying a concealed weapon presumptively lawful, and Joseph’s conduct did not indicate criminal activity. The court vacated Joseph’s conviction, reversed the partial denial of the suppression motion, and remanded for further proceedings. View "USA v. Olson" on Justia Law

A man became the primary caregiver for his two-month-old daughter after his partner returned to work. Within a few days, the child was found to have severe and unexplained injuries, including multiple broken bones, bruises, and scratches. The child’s mother noticed initial injuries but delayed seeking medical attention until a scheduled check-up, at which point a pediatrician directed them to the hospital and notified authorities. Medical examination suggested the injuries were caused by forceful, non-accidental actions over a period of days. The accused gave varying explanations for the injuries, none of which were found consistent with the medical evidence.The United States District Court for the Eastern District of Oklahoma conducted a two-day jury trial. The prosecution presented expert and lay witnesses, including a specialist in child abuse who diagnosed the child as having suffered abuse and neglect. The defense challenged the admissibility and scope of the expert’s testimony, as well as certain statements by lay witnesses, arguing they improperly commented on the defendant’s credibility and offered expert opinions. The jury found the defendant guilty on both charges of child abuse and child neglect. The district court denied the defendant’s motion for a new trial and imposed a ten-year sentence.The United States Court of Appeals for the Tenth Circuit reviewed the case. The appellate court held that the district court did not abuse its discretion in permitting the expert’s medical diagnoses, as these did not address the defendant’s mental state—a necessary element for conviction—leaving that determination to the jury. The court also found that any improper lay witness testimony was harmless given its similarity to uncontested expert testimony. Arguments regarding prosecutorial misconduct and cumulative error were rejected. Consequently, the Tenth Circuit affirmed the convictions. View "United States v. Wilson" on Justia Law

Rodney Brown was charged with Hobbs Act robbery and brandishing a firearm during a crime of violence after he robbed a convenience store, threatening a cashier and her son, and stealing money and personal items. The robber left a soda bottle at the scene, which, along with a mask found nearby, was tested for DNA. Law enforcement obtained Brown’s DNA and had it analyzed by a private lab. At trial, a DNA analyst from the lab testified that Brown’s DNA matched the evidence, but the analyst had not personally performed the hands-on lab work generating the DNA profiles.In the United States District Court for the Southern District of Florida, a jury found Brown guilty on both counts. At sentencing, the court classified Brown as a career offender under the United States Sentencing Guidelines, using the 2023 version of the Guidelines, which treated Hobbs Act robbery as a crime of violence. This resulted in an increased sentencing range, and Brown was sentenced to 324 months in prison.On appeal to the United States Court of Appeals for the Eleventh Circuit, Brown argued for the first time that his Confrontation Clause rights were violated by the DNA analyst’s testimony, and that the Ex Post Facto Clause was violated when the district court used a later version of the Guidelines Manual. The Eleventh Circuit held that the district court did not plainly err in permitting the DNA analyst’s testimony, since the analyst independently reviewed and analyzed the DNA profiles and did not merely act as a surrogate for other lab personnel. However, the court found plain error in sentencing Brown under the 2023 Guidelines Manual, as the offense occurred before the relevant amendment. The court affirmed Brown’s convictions, vacated his sentence, and remanded for resentencing under the correct Guidelines version. View "USA v. Brown" on Justia Law