Justia Criminal Law Opinion Summaries

Federal law enforcement officers executed a search warrant at a residence in Dayton, Ohio, after learning that Nathan Goddard was storing large quantities of fentanyl and cocaine in the basement. Goddard, his associate Cahke Cortner, and others were present when officers entered. Goddard, using a pistol acquired and equipped with a laser sight with Cortner's help, fired at Officer Jorge Del Rio, fatally wounding him. Cortner, armed, retreated to a back room. Both men surrendered after the incident. Evidence showed Goddard’s long history of drug trafficking and that Cortner had participated in drug-related communications and activities.The United States District Court for the Southern District of Ohio reviewed pretrial motions, including Goddard’s motion to suppress evidence from the search, which it denied, and granted the government’s motion to exclude evidence concerning the DEA’s operational plan. Combs, a co-defendant, pled guilty; Goddard and Cortner proceeded to trial. The jury convicted both on all counts, including conspiracy to possess and distribute drugs, possession with intent to distribute, and, for Goddard, murder of a federal officer and intentional killing during a drug-trafficking offense. Cortner was convicted of intentional killing under Pinkerton liability. Both received life sentences.The United States Court of Appeals for the Sixth Circuit affirmed the convictions and sentences. It held that probable cause supported the search warrant, the exclusion of operational-plan evidence was not an abuse of discretion, and sufficient evidence supported all convictions. The court found Pinkerton liability applicable to Cortner’s intentional killing charge and rejected arguments about procedural and substantive unreasonableness in sentencing. The court’s main holdings were to affirm the convictions and sentences for both defendants, upholding the district court’s rulings and jury findings. View "United States v. Goddard" on Justia Law

The case involved a defendant who installed a camera in his living room and surreptitiously photographed a sexual encounter with the victim, who was unaware of the camera’s presence. The victim only learned of the existence of the photograph two weeks later, when the defendant sent it to him via text message. There was no evidence that the victim consented to being photographed or that he noticed the camera at the time. The defendant argued at trial that the recording was accidental and that the camera had been installed for security purposes.After being charged in the Edgartown Division of the District Court Department with photographing an unsuspecting nude person and disseminating the resulting photograph, the defendant was tried before a jury. The trial judge denied the defendant’s motion for a required finding of not guilty at the close of the Commonwealth’s case. The jury found the defendant guilty on both counts. The judge imposed concurrent sentences of ninety days, with ten days to serve and the rest suspended, along with probation. The defendant appealed, and the Supreme Judicial Court of Massachusetts granted direct appellate review.The Supreme Judicial Court of Massachusetts affirmed the conviction for photographing an unsuspecting nude person, holding that sufficient evidence supported the jury’s finding that the defendant acted willfully and intended to secretly photograph the victim. The Court also found no error in the jury instructions regarding willfulness. However, the Court reversed the conviction for disseminating the photograph, holding that sending an image solely to the depicted victim does not constitute “dissemination” under the relevant statute, which requires dispersal to at least one third party. The disposition was to affirm the conviction under G. L. c. 272, § 105(b) and reverse the conviction under § 105(c), entering a judgment of not guilty on the latter charge. View "Commonwealth v. Goncalves" on Justia Law

The defendant was arrested following allegations of sexual assault against a minor, G.L., which reportedly began when the family lived in Wyoming and continued after relocating to Montana. After the arrest, law enforcement seized electronic devices from the defendant’s residence, and forensic analysis of these devices became central to the pretrial proceedings. The defendant was unable to post bail and remained incarcerated for an extended period, during which he consistently objected to trial delays and asserted his right to a speedy trial.The Eighth Judicial District Court in Cascade County presided over the case. The State requested multiple trial continuances due to ongoing forensic analysis and other administrative issues, including staff absences and problems with jury pool formation. Defense counsel did not object to most continuances but requested additional time for preparation after new counsel was appointed. The District Court found that a total of 630 days elapsed between arrest and trial, attributing most of the delay to the State but classifying all as institutional delay. The District Court denied the defendant’s motion to dismiss for violation of his speedy trial right, finding no oppressive pretrial conditions beyond the baseline prejudice of detention and no impairment of the defense.The Supreme Court of the State of Montana reviewed the case de novo. It held that the District Court erred by misapplying the relevant speedy trial factors, particularly by failing to recognize periods of State negligence and by using an excessively demanding standard for oppressive incarceration. The Supreme Court found that the State was responsible for most of the delay, that the defendant had persistently asserted his right, and that the prolonged, burdensome pretrial detention constituted prejudice. The Court reversed the District Court’s denial of the motion to dismiss, reversed the conviction, and remanded with instructions to dismiss the charge. View "State v. Yuste" on Justia Law

After cashing a substantial check, Michael Biggs spent time with Brandon Beckman and others, gambling and making purchases. On January 13, Biggs, Beckman, and Robert Harvel were seen together at a casino before departing in Harvel’s car. Later that morning, witnesses encountered Beckman and Harvel near an access road where Biggs’s body was found the next day, showing signs of robbery and concealment. Beckman subsequently purchased a vehicle with cash and made other expenditures. Investigators found physical evidence linking Beckman to the scene and recovered cash from both Beckman and Harvel. Beckman’s statements to police about his movements and contacts with Harvel were inconsistent and changed during interviews.The First Judicial District Court, Lewis and Clark County, presided over Beckman’s jury trial. Harvel, facing similar charges, was compelled to testify with use immunity. At the close of the State’s case, Beckman moved for a directed verdict, arguing that Harvel’s testimony lacked sufficient independent corroboration and that the remaining evidence could not support conviction. The District Court denied the motion, concluding that the independent evidence, viewed favorably to the State, could allow a rational jury to find Beckman guilty. The jury acquitted Beckman of deliberate homicide under one subsection but convicted him of felony murder and tampering with evidence. He was sentenced to 100 years for felony murder and ten years for tampering.The Supreme Court of the State of Montana reviewed whether the District Court erred in denying Beckman’s motion for dismissal based on insufficient evidence. The Supreme Court held that there was sufficient independent evidence tending to connect Beckman to the robbery and concealment, thus satisfying the corroboration requirement for accomplice testimony under Montana law. The Court affirmed the District Court’s denial of the motion to dismiss and upheld Beckman’s convictions. View "State v. Beckman" on Justia Law

A criminal defendant was charged with multiple counts of theft. At arraignment, his attorney and the prosecution stipulated to setting bail at $50,000, with the requirement that, upon posting bail, the defendant would be placed on GPS monitoring through the bail bond company. The trial court adopted this agreement, specifying that GPS monitoring was required and at the defendant’s expense. United States Fire Insurance Company, through its agent, posted the bail bond, but it appears that GPS monitoring was not arranged. The defendant was released, later failed to appear in court, and the court forfeited the bond and issued a bench warrant.After forfeiture, the Superior Court of Orange County entered summary judgment against the surety for $50,000. United States Fire Insurance Company moved to set aside the judgment, arguing that the defendant’s release without GPS monitoring constituted a unilateral change to the bail contract, voiding the bond. The trial court denied the motion, finding that arranging GPS monitoring was the responsibility of the bail bond company, and not the sheriff’s department or jail, and that there was no change to the terms of the bond after its execution.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the denial of the motion to set aside summary judgment under the abuse of discretion standard. The appellate court held that substantial evidence supported the trial court’s finding that the bail bond company was responsible for ensuring GPS monitoring as a condition of release. The court distinguished this case from People v. Lexington National Ins. Corp., concluding there was no unilateral change to the bond terms. The appellate court affirmed the trial court’s order, holding that the trial court did not abuse its discretion, and awarded costs on appeal to the respondent. View "People v. U.S. Fire Ins. Co." on Justia Law

A man was subject to a one-year protective order issued by a family court. He was later charged with two counts of violating this order, based on allegations that he approached the petitioner’s workplace and contacted her in prohibited ways. The man had attended the hearing at which the protective order was issued. At trial, after the State presented its case, the defense argued that personal service of the order was required for a violation, even though the man was present when the order was issued. The State argued that his presence at the hearing provided sufficient notice.The Family Court of the Second Circuit agreed with the defense, concluding that personal service was an element of the offense and that the State had not established this element. The family court acquitted the defendant, entering a judgment of acquittal and dismissing the case. The State appealed, contending that the judgment of acquittal was actually an order sustaining a motion to dismiss and was therefore appealable. The Intermediate Court of Appeals (ICA) disagreed, holding that the ruling was an acquittal based on the court’s determination that the State failed to prove an element of the charge, making the appeal unreviewable.The Supreme Court of the State of Hawai‘i reviewed the case on certiorari. It held that service is not an element of the offense of violating an order for protection under HRS § 586-11. The court found that the family court erred in interpreting the statute but that the acquittal, even if based on legal error, barred retrial under Article I, Section 10 of the Hawai‘i Constitution. The Supreme Court affirmed the ICA’s dismissal of the State’s appeal. View "State v. Chau" on Justia Law

A father, motivated by religious beliefs and alleged divine messages received by a companion, took his three-year-old, disabled son from the child’s mother, who was the primary caregiver. Along with several family members and associates, he transported the boy from Georgia to New Mexico, leaving the mother behind and without her consent. The group settled on a remote property, where the father and others performed physically intrusive religious rituals on the child, resulting in the child’s death. The group then adopted apocalyptic beliefs, trained with firearms, and fortified their compound in anticipation of conflict with government agencies. Law enforcement eventually raided the compound, arrested several adults, and discovered the child’s body.The United States District Court for the District of New Mexico presided over a joint trial for four defendants. The mother’s siblings and brother-in-law were convicted by a jury of conspiracy to commit kidnapping and kidnapping resulting in death under 18 U.S.C. § 1201. The father, exempt from kidnapping charges as a parent, was convicted (along with another) of conspiracy to provide material support for and to kill federal officers, after representing himself at trial. The trial court sentenced all four to life imprisonment.On appeal, the United States Court of Appeals for the Tenth Circuit examined several issues, most centrally the definition of “unlawfully” in the context of federal kidnapping. The Tenth Circuit held that the jury instructions incorrectly defined “unlawfully” and that the government had not presented sufficient evidence that the co-defendants’ actions were contrary to law, given that the father had lawful parental rights at the time of the interstate transport. The court reversed the kidnapping convictions for those defendants. The Tenth Circuit also held that the pro se defendants’ Sixth Amendment rights were violated when they were excluded from a jury-note conference of tactical importance, vacating their convictions on material support and conspiracy-to-kill counts and remanding for further proceedings. View "United States v. Wahhaj" on Justia Law

Charles Summers was convicted in New York of first-degree attempted rape of a 13-year-old girl. After serving his prison sentence and parole, he was warned about sex offender registration requirements. Summers moved to New Jersey, where he failed to register as a sex offender, violating the Sex Offender Registration and Notification Act (SORNA). He was arrested in New Jersey for this federal offense, pleaded guilty, and was sentenced in the United States District Court for the District of New Jersey.In the District Court, Summers was classified as a Tier III sex offender under SORNA, the most serious category, which carries lifetime registration and more frequent in-person reporting. The District Court also calculated his Criminal History under the Sentencing Guidelines, determining his Guidelines range and imposing a sentence of 24 months’ imprisonment and 60 months’ supervised release. Summers appealed the Criminal History calculation and his Tier III SORNA classification to the United States Court of Appeals for the Third Circuit. While his appeal was pending, he completed his jail sentence and began serving supervised release.The United States Court of Appeals for the Third Circuit found that the Criminal History issue was moot because Summers had finished his prison term and was already serving the mandatory minimum supervised release, so no effectual relief could be granted on that point. However, the SORNA tiering issue remained live due to its ongoing consequences for registration requirements. The Third Circuit adopted a hybrid categorical approach to compare the New York conviction with federal offenses and concluded that Summers’s conviction matched the federal crime of attempted sexual abuse, justifying Tier III classification. The court dismissed the appeal as to the Criminal History, otherwise affirmed the judgment, and remanded for the limited purpose of correcting the judgment to reflect the Tier III designation. View "USA v. Summers" on Justia Law

The petitioner was convicted of capital murder in 2008 and sentenced to death. Following this, the New Hampshire Supreme Court conducted a mandatory appellate review of the conviction and sentence, including a comparative proportionality review as required by state statute. The court affirmed both the conviction and the death sentence. In 2016, the petitioner filed a habeas corpus petition in the superior court, later amended, challenging his conviction and sentence. In 2019, New Hampshire repealed the death penalty, but the repeal applied only to persons convicted of capital murder on or after the effective date of the act.After the repeal, the petitioner further amended his habeas petition in the superior court, arguing that the legislative change rendered his sentence unconstitutional and seeking a renewed comparative proportionality review of his death sentence. The Warden moved to dismiss, asserting that the Supreme Court had already conducted such a review and was not authorized to do so again. The Superior Court stayed its ruling on the motion to dismiss, determining that the Supreme Court had exclusive jurisdiction over the statutory proportionality review, and the petitioner subsequently sought original jurisdiction in the New Hampshire Supreme Court.The Supreme Court of New Hampshire addressed whether the petitioner was entitled to a renewed comparative proportionality review under RSA 630:5, X and XI(c). The court held that the statute authorizes only a single automatic comparative proportionality review as part of the mandatory appellate process and does not permit successive reviews. The court found that the repeal of the death penalty did not apply retroactively to the petitioner. Therefore, the petition for a successive comparative proportionality review was dismissed. View "Petition of Addison" on Justia Law

The defendant was involved in a domestic violence incident with a former romantic partner with whom he continued to live as a roommate. On September 18, 2022, after drinking heavily, the defendant assaulted the victim by choking, hitting, and threatening her. The victim, fearing further violence, submitted to sexual acts. After the defendant fell asleep, the victim left, sought medical attention, and reported the incident to police. The defendant was arrested and, while detained pending trial, communicated with the victim numerous times, encouraging her to lie and withhold information from authorities, and discouraging her from testifying.The Hillsborough-northern judicial district Superior Court conducted a jury trial. The jury acquitted the defendant of some charges but convicted him of aggravated felonious sexual assault-domestic violence, stalking-domestic violence, indirect criminal contempt, witness tampering, criminal restraint, second degree assault-domestic violence, and simple assault-domestic violence. The defendant appealed these convictions.The Supreme Court of New Hampshire reviewed the case. It affirmed the aggravated felonious sexual assault convictions, holding that there was sufficient evidence to find the victim was confined and did not freely consent to the sexual acts due to fear provoked by prior assaults. The court reversed the stalking and indirect criminal contempt convictions, concluding that the bail statute in effect at the time did not authorize no-contact orders for detained defendants, rendering the evidence insufficient for those charges. The court found no double jeopardy violation regarding multiple witness tampering convictions, determining that each attempt to influence the victim constituted a separate offense. Other double jeopardy claims were rejected due to insufficient demonstration of plain error. The Supreme Court of New Hampshire affirmed the remaining convictions and reversed the stalking and contempt convictions. View "State v. Sales" on Justia Law