Justia Criminal Law Opinion Summaries

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The case concerns an appeal by Carl Monroe Gordon against his conviction on the grounds of aggravated sexual abuse of a child, traveling to engage in illicit sexual conduct, and abusive sexual contact with a child. Gordon argued that his statutory and constitutional rights to a speedy trial were violated due to delays in bringing him to trial and the denial of his motion to dismiss the indictment by the district court. The United States Court of Appeals for the Fifth Circuit affirmed the district court's judgment. The Court held that the delay in bringing Gordon to trial did not violate the Speedy Trial Act since the period of delay was attributed to other proceedings related to the defendant and ends-of-justice continuances due to the COVID-19 pandemic. Furthermore, the Court determined that Gordon's Sixth Amendment right to a speedy trial was not violated as he failed to demonstrate actual prejudice resulting from the delay. View "United States v. Gordon" on Justia Law

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In this case, defendant Charles Yeager-Reiman, a veteran, pleaded guilty to misdemeanor grand theft in connection with fraudulent activities related to veterans' benefits from the United States Department of Veterans Affairs (VA). Yeager-Reiman appealed his conviction, arguing that his prosecution was preempted by federal law, as his offenses concerned the theft of benefits from the VA.The Court of Appeal of the State of California Second Appellate District Division Five disagreed with Yeager-Reiman's contention, and affirmed the lower court's judgement. The court ruled that federal preemption did not apply in this case. While federal law establishes the guidelines and regulations for VA benefits, it does not prohibit state-level criminal prosecutions for fraudulent activities related to these benefits.In terms of field preemption, the court determined that the provisions of the federal law did not indicate an intent by Congress to occupy the field of criminal prosecution of veterans in connection with the theft of VA benefits. As for obstacle preemption, the court found that allowing state-level prosecutions for theft of VA benefits actually promotes Congress's purpose of aiding veterans by preserving funds for veterans' benefits through deterrence.Therefore, the court concluded that neither field preemption nor obstacle preemption deprived the trial court of jurisdiction to hear Yeager-Reiman's case. View "People v. Yeager-Reiman" on Justia Law

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The case revolves around the interpretation of the term "resources" as used in the criminal restitution statute, Minnesota Statutes section 611A.045, subdivision 1(a)(2). Specifically, the case examines whether the equity in a defendant's home, which he co-owns with his spouse, can be considered as a "resource" when awarding restitution. The appellant, Joshua Henry Baion Cummings (Baion), was convicted of one count of theft by false representation and was ordered to pay restitution. The district court considered the equity in Baion’s home as one of his resources when determining the amount of restitution. Baion appealed, arguing that the equity in a home owned with a non-defendant spouse cannot be considered a resource under the restitution statute. The Court of Appeals affirmed the district court's decision. The Minnesota Supreme Court also affirmed, holding that the term “resources” in the restitution statute unambiguously means useful and valuable possessions, and that home equity, even when the home is co-owned with a non-defendant spouse, may be such a possession. View "State v. Cummings" on Justia Law

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In this case, the Los Angeles County District Attorney appealed an order denying the prosecution’s attempt to reinstate charges accusing two defendants, Woodrow Kim and Jonathan Miramontes, of filing false peace officer reports. The charges were related to a police incident involving a high-speed chase and subsequent officer-involved shooting. The defendants, both deputies with the Los Angeles County Sheriff’s Department, were accused of falsely reporting that a suspect, Martinez, had walked into their patrol vehicle and remained standing, when in fact, video evidence showed that the patrol car’s door had hit Martinez with enough force to knock him to the ground. The Court of Appeal of the State of California, Second Appellate District, Division Five, reversed the lower court's decision, concluding that there was a rational basis for believing that both deputies had filed false reports in violation of Penal Code section 118.1. The court ordered the lower court to reinstate the complaint and return the matter to the magistrate for further proceedings. View "P. v. Kim" on Justia Law

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In a case before the United States Court of Appeals for the Fourth Circuit, six men affiliated with the transnational criminal organization MS-13 were convicted of sex trafficking a thirteen-year-old girl by force, fraud, or coercion, and conspiracy to do the same. The accused appealed the district court’s denial of their motions to suppress evidence obtained from Facebook warrants, arguing the warrants failed the probable cause and particularity requirements of the Fourth Amendment. One of the accused also appealed the district court’s denial of his motion for acquittal, contending that the evidence presented at trial was insufficient to sustain his conviction.The court held that the Facebook warrants were supported by probable cause, as they were based on substantial evidence linking the accused’s use of Facebook to their criminal activities. The court also held that the warrants were sufficiently particular as they identified the items to be seized by reference to the suspected criminal offenses and confined the officers’ discretion by restricting them from rummaging through the accused’s social media data in search of unrelated criminal activities. However, the court noted that future warrants enhance their claims to particularity by requesting data only from the period of time during which the defendant was suspected of taking part in the criminal conspiracy.The court rejected one appellant's sufficiency challenge to his conviction and affirmed his convictions, finding that substantial evidence supported the jury’s conclusion that he was guilty of conspiracy to engage in sex trafficking of a minor under fourteen or of a minor by force, fraud, or coercion, and of conspiracy to transport a minor in interstate commerce with intent for the minor to engage in prostitution or illegal sexual activity.Therefore, the court affirmed the judgment of the district court in all respects. View "United States v. Zelaya-Veliz" on Justia Law

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In the case before the United States Court of Appeals for the Tenth Circuit, the defendant, Jody Rufino Martinez, a member of the Syndicato de Nuevo México (“SNM”), a violent New Mexico-based prison gang, was convicted of murder under the Violent Crimes in Aid of Racketeering (“VICAR”) Act, racketeering conspiracy, and unlawful possession of a firearm. The convictions were related to the 2008 murder of David Romero and the 2018 shooting of Donald Salazar. On appeal, Mr. Martinez argued that the district court erred in three ways: (1) denying his motion to dismiss under the Speedy Trial Act, (2) admitting unduly prejudicial evidence during trial, and (3) denying his motion for a new trial after evidence emerged that he was involved in threats to kill the presiding district court judge. The Tenth Circuit affirmed the district court's decisions. The court held that the district court did not abuse its discretion in denying Mr. Martinez's motion to dismiss under the Speedy Trial Act, as the court's finding that Mr. Martinez did not oppose a motion to continue the trial was plausible given the record as a whole. The court also held that the district court did not abuse its discretion in admitting evidence of SNM's violent acts, as that evidence was probative of SNM's use of violence to maintain and augment organizational respect and played a critical role in the government's case. Lastly, the court held that the district court did not err in failing to recuse itself, as the judge had no knowledge during the trial that Mr. Martinez was connected to threats against him. View "United States v. Martinez" on Justia Law

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In Vermont, the defendant, Denzel Lafayette, was charged with sexual assault, sexual exploitation by luring a child, and carrying a weapon while committing a felony. The case revolved around an incident in which Lafayette had sexual intercourse with a 15-year old girl, whom he had been communicating with on Facebook. Lafayette had also allegedly shown her a firearm during their encounter.The jury found Lafayette guilty of sexual assault and carrying a weapon while committing a felony. On appeal, Lafayette argued that the evidence was insufficient to support the convictions and that the trial court committed an error by not instructing the jury that it had to find that the carrying of the gun was related to the sexual assault.The Vermont Supreme Court disagreed with Lafayette's claims. The court found that the victim's testimony provided sufficient evidence for the jury to find Lafayette guilty beyond a reasonable doubt of sexual assault. It further held that the evidence was sufficient to support the conviction for carrying a weapon while committing a felony, as the gun had the potential to facilitate the sexual assault. The court also found no error in the jury instruction, as the relationship between the carrying of the weapon and the sexual assault was self-evident. Therefore, the court affirmed both of Lafayette's convictions.However, the court agreed with Lafayette's contention that certain probation conditions were overbroad and unduly restrictive. The court remanded the case to the trial court to strike one probation condition and to make findings, modify, or strike portions of two other challenged conditions. View "State v. Denzel Lafayette" on Justia Law

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In this case, the State of Vermont appealed the superior court’s dismissal of charges against defendant Michael Armstrong on speedy-trial grounds. It had been more than nineteen years since the charges against defendant were first brought and more than fifteen years since defendant was adjudicated incompetent to stand trial. The trial court dismissed the charges, finding that the State had failed in its obligation to reevaluate defendant’s competency, thereby violating defendant’s constitutional right to a speedy trial. The Vermont Supreme Court reversed the trial court's decision, finding that the delay was primarily due to defendant's incompetency, which was not attributable to the State, and the State had no duty to seek a reevaluation of the defendant's competency absent an indication of changed circumstances. The Court concluded that the defendant did not make a sufficient claim of denial of his right to a speedy trial, reversed the trial court’s dismissal of the charges, and remanded for further proceedings. View "State v. Armstrong" on Justia Law

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This case involves an appeal from the United States District Court for the District of South Dakota filed by the defendant, Nathaniel Crawford. Crawford was involved in a domestic dispute with his ex-girlfriend at an apartment complex, which led to concerned residents calling 911, reporting that Crawford was threatening to shoot a person or burn the complex. After officers arrived at the scene, Crawford fled but returned later to threaten his ex-girlfriend with a firearm. He fled again before officers could arrive; however, they found him and his vehicle in a nearby parking lot. Officers identified a wooden object protruding from the vehicle's center console, which they inferred to be a firearm. Crawford was subsequently charged with being a prohibited person in possession of a firearm due to his prior felony and misdemeanor domestic violence convictions.Crawford moved to suppress the firearm, arguing that officers lacked probable cause to search his vehicle. The district court denied his motion, leading to Crawford's appeal. The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision, agreeing that the 911 calls, the ex-girlfriend's statements, and the wooden object established probable cause for the vehicle search. The court ruled that the officers' search was supported by probable cause based on the combination of these factors, establishing probable cause to search Crawford's vehicle for a firearm. The court also rejected Crawford's arguments that the search was unreasonable due to the officers' original investigation of him for a different crime and their lack of knowledge about his status as a prohibited person under federal law. The court maintained that the government can search for evidence of one crime and charge the suspect with a different crime based on what it later learns. The court concluded that the "fruit of the poisonous tree" was admissible because the tree in this case was not poisonous. View "United States v. Crawford" on Justia Law

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In Kansas, the appellant, Darnell D. Coleman, was convicted of first-degree premeditated murder and appealed his conviction. He raised four issues on appeal: (1) the prosecutors made incorrect statements of law and fact about premeditation during closing arguments, (2) the court failed to give a modified jury instruction on premeditation that had been approved in previous cases, (3) the court erred by not removing his trial counsel after a breakdown in communication, and (4) cumulative errors deprived him of a fair trial.The Supreme Court of the State of Kansas found that the prosecutors made three errors during closing arguments that disregarded the cognitive component of premeditation, but these errors did not individually or cumulatively affect the outcome of the trial. The court also held that the trial judge did not err in the instructions given to the jury on premeditation, and did not abuse discretion by not removing Coleman's trial counsel. The court concluded that the cumulative effect of the errors did not affect the jury's verdict. Consequently, Coleman's conviction was affirmed by the court. View "State v. Coleman" on Justia Law