Justia Criminal Law Opinion Summaries

The case concerns an incident between two individuals who were in a dating relationship and living together. After an argument, the altercation escalated in their bedroom, where the defendant allegedly struck the victim on the nose and grabbed her by the throat, pushing her against a window. The victim managed to escape after kicking the defendant and reported the incident to the police, who documented redness and marks on her neck. The defendant, when interviewed, denied any physical altercation and suggested the victim had previously injured herself.The District Court of the Seventh Judicial District, Bingham County, presided over the trial. At trial, two police officers testified that, based on their training and experience, the marks on the victim’s neck were consistent with attempted strangulation. The defendant objected, arguing this constituted expert testimony for which there had been no pretrial disclosure, as required by Idaho law. The district court overruled these objections and admitted the testimony. The jury ultimately found the defendant guilty of attempted strangulation but acquitted him of domestic battery.The Court of Appeals of the State of Idaho reviewed the case and determined that the district court erred by permitting the officers to testify as experts without proper disclosure. The appellate court explained that the officers’ opinions about the marks on the victim’s neck were based on specialized training and experience, constituting expert rather than lay testimony. Because the error was not harmless—given the significance of the officers’ testimony to the State’s case and the limited number of witnesses—the court vacated the conviction for attempted strangulation and remanded the case for a new trial. View "State v. Hinkel" on Justia Law

A man was arrested in Maine after a controlled drug purchase arranged by law enforcement. During his arrest, officers found an iPhone under his car seat, along with drug-related items. A state search warrant was obtained to investigate the phone for evidence of drug trafficking. While searching the phone, officers discovered videos depicting the man engaging in sexual acts with a minor. This discovery led to federal charges for sexual exploitation of a minor.At trial in the United States District Court for the District of Maine, the defendant sought to suppress the videos, arguing the state search warrant lacked probable cause and specificity, and that officers exceeded its scope by investigating the videos. The district court denied these motions. The defendant also requested specific voir dire questions about juror bias against interracial relationships and sought to introduce evidence that he believed the minor was of age, but the court rejected these efforts. The jury convicted the defendant on both counts, and he was sentenced to 216 months in prison and ten years of supervised release.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s rulings. The appellate court held that the state search warrant was supported by probable cause and was sufficiently particular. The court found that officers did not exceed the warrant’s scope by viewing the videos, which were relevant to the drug investigation, nor was there a bar on using evidence lawfully found in the course of one investigation for another crime. The First Circuit also concluded that the voir dire was adequate, the exclusion of mistake-of-age evidence was correct since such a defense is not available under 18 U.S.C. § 2251(a), the jury instructions were not plainly erroneous, and the evidence was sufficient for conviction. The court affirmed the convictions. View "US v. Deschambault" on Justia Law

A defendant was arrested in August 2023 in Ohio County, West Virginia, on charges of possession with intent to distribute multiple controlled substances. Unable to post bond, the defendant remained in jail. Over the following months, the defendant waived a prompt preliminary hearing and later sought a continuance of that hearing, citing ongoing plea negotiations. After eventually being bound over for trial in February 2024, the defendant remained incarcerated because of inability to meet the reduced bond set by the court. The State conceded that it would not be able to seek an indictment until the September 2024 term due to the grand jury schedule and laboratory delays.The Circuit Court of Ohio County denied the defendant’s motion for discharge from pre-indictment confinement, ruling that the statutory two-term time limit for pre-indictment detention did not begin until the defendant was bound over after the preliminary hearing, rather than from the date of arrest and jailing. The court also found that the defendant’s own actions in waiving or continuing the preliminary hearing tolled the two-term period. After the court’s denial, the State supported the defendant’s position but was unable to secure immediate relief. The defendant then sought a writ of habeas corpus from the Supreme Court of Appeals of West Virginia. Meanwhile, the defendant was eventually indicted and pleaded guilty, making the habeas petition technically moot.The Supreme Court of Appeals of West Virginia held that the statutory two-term rule is triggered when a defendant is arrested and jailed, not when bound over after a preliminary hearing. The court further held that the term of court in which the defendant is arrested does not count toward the two-term limit. If a defendant is not indicted by the end of the second full term after arrest, immediate discharge from pre-indictment confinement is mandatory. The Supreme Court granted the writ, finding the lower court erred, though no relief was available due to mootness. View "State ex rel. Butler v. Adams" on Justia Law

A cattle owner in Cabell County, West Virginia, discovered that one of his calves had been shot with two arrows and was gravely injured. After following a blood trail to a neighboring residence, the owner confronted the neighbor, who denied involvement. Law enforcement and an animal control officer responded, ultimately euthanizing the calf due to the severity of its injuries. During the investigation, the neighbor admitted to shooting the calf, providing shifting explanations that included annoyance at the animal entering his property and fear for his safety. He was subsequently indicted for felony animal cruelty, specifically for unlawfully, feloniously, and intentionally torturing, mutilating, or maliciously killing an animal.During trial in the Circuit Court of Cabell County, the defendant requested a jury instruction for misdemeanor animal cruelty as a lesser included offense, arguing that the jury could find his conduct did not rise to the level of “malicious” or intentional torture, but constituted cruel mistreatment. The circuit court denied this request, finding that misdemeanor animal cruelty was not a lesser included offense of the felony charge. The jury convicted the defendant of felony animal cruelty. The court denied his motion for a new trial and sentenced him to a term of imprisonment, which was suspended for probation and home incarceration, and ordered restitution.On appeal, the Supreme Court of Appeals of West Virginia reviewed whether the circuit court erred in denying the requested jury instruction. The court held that, applying the strict elements test, misdemeanor animal cruelty (mistreating an animal in a cruel manner) is not a lesser included offense of felony malicious killing of an animal, because it is possible to commit the felony without committing the misdemeanor. The court affirmed the conviction and the circuit court’s decision. View "State v. Stevens" on Justia Law

In 2001, the defendant was accused of breaking into a residence and stealing various items, leading to charges of burglary and petit larceny. In 2003, he negotiated a binding plea agreement with the State under Rule 11(e)(1)(c) of the West Virginia Rules of Criminal Procedure. He pled guilty to burglary, with the agreement that he would receive a suspended sentence and probation, and the petit larceny charge would be dismissed. The circuit court found the guilty plea was entered knowingly and voluntarily, but deferred acceptance of the plea agreement pending a presentence report. The defendant failed to appear at the sentencing hearing, a capias warrant was issued, and he was not apprehended until 2023 after a traffic stop.The Circuit Court of Jefferson County, upon the defendant’s 2023 arrest, held status hearings where the defendant moved to withdraw his 2003 guilty plea. Both parties agreed to a new plea arrangement, but at the change of plea and sentencing hearing, the court concluded it lacked discretion to allow withdrawal of the original plea due to its “binding” nature. The court accepted the 2003 guilty plea and imposed the originally agreed sentence.The Supreme Court of Appeals of West Virginia reviewed the circuit court’s actions. It held that the circuit court erred by finding that the binding nature of the plea agreement precluded consideration of withdrawal prior to sentencing. The court clarified that under Rule 32(e), a defendant may seek withdrawal of a guilty plea before sentencing if a fair and just reason is shown, regardless of whether the plea agreement is binding. The circuit court failed to analyze whether such a reason existed. Accordingly, the Supreme Court of Appeals vacated the sentencing order and remanded for further proceedings, instructing the circuit court to apply the correct legal standard. View "State v. Page" on Justia Law

The petitioner was charged with two misdemeanor counts of driving under the influence in the Superior Court of Siskiyou County. After initially waiving the statutory speedy trial period, he withdrew his waiver on October 20, 2025. The court set a jury trial for December 15, 2025, which was the last permissible day under Penal Code section 1382. On that date, although the court heard pretrial motions, it did not have a jury available due to a standing policy of beginning jury empanelment only on Tuesdays. The petitioner objected to any continuance and moved to dismiss the case, arguing his statutory right to a speedy trial was violated. The court denied the motion, finding good cause for a one-day delay and reasoning that trial had effectively started with the pretrial proceedings.The trial court’s denial of the dismissal was followed by an oral motion by the petitioner on December 16, which was also denied. When jury selection began that day, the panel was dismissed due to contamination, and the trial was reset for January 6, 2026. The petitioner then filed for a writ of mandate in the California Court of Appeal, Third Appellate District, which stayed the trial and issued an order to show cause.The California Court of Appeal, Third Appellate District, held that the petitioner was not brought to trial within the statutory time limit because the absence of a jury on the last permissible day precluded a meaningful start of trial. The court found that the delay was caused by improper court administration, not by the petitioner or unforeseen circumstances, and that no good cause justified the continuance. The appellate court granted the petition for writ of mandate, directing the trial court to vacate its denial of the motion to dismiss and to enter an order granting dismissal. View "Nuanmanee v. Superior Court" on Justia Law

Police in Pittsburgh responded late at night to two ShotSpotter alerts that indicated five gunshots were fired near a specific residential address. Officer Powers arrived at the scene within seconds of the second alert and saw a parked car with its headlights on, occupied by the appellant in the driver’s seat and a woman in the passenger seat. As the officer approached with emergency lights on, the appellant exited the car and began walking toward a nearby house, while the passenger made movements inside the car. The officer ordered the appellant to return, and when he did not comply, police drew their weapons and forcibly detained him. Evidence subsequently obtained led to charges including driving under the influence and driving with a suspended license.The Court of Common Pleas of Allegheny County denied the appellant’s motion to suppress evidence, finding the investigative detention was supported by reasonable suspicion. At trial, the court found the appellant guilty on all charges. On appeal, the Superior Court affirmed, reasoning that the combination of the ShotSpotter alerts, the appellant’s proximity in time and space to the reported shots, his presence as one of only two people at the scene, his conduct upon police arrival, and the late hour supported reasonable suspicion for the stop.The Supreme Court of Pennsylvania reviewed whether the Superior Court gave too much weight to the appellant’s proximity to the ShotSpotter alerts in evaluating reasonable suspicion. The Supreme Court held that, although there was insufficient record support to consider the area a high-crime area, the totality of the circumstances—including the ShotSpotter alerts indicating gunfire, the rapid police arrival, the appellant and his companion being the only people present, and their evasive behaviors—provided reasonable suspicion for the investigative detention. The court therefore affirmed the Superior Court’s order upholding the denial of suppression. View "Commonwealth v. Foster" on Justia Law

In this case, the defendant participated in two incidents at a North Carolina bank: an armed robbery in which employees were assaulted with firearms, and a subsequent attempted armed robbery where the group was foiled when the bank manager recognized them and secured the building. The defendant was convicted by a jury of both armed bank robbery and attempted armed bank robbery under 18 U.S.C. § 2113(a) and (d), as well as for brandishing firearms during these crimes in violation of 18 U.S.C. § 924(c)(1)(A)(ii).Following his conviction and sentence, which were affirmed by the United States Court of Appeals for the Fourth Circuit in 2014, the defendant filed several postconviction motions in the United States District Court for the Middle District of North Carolina. These were denied. On appeal, the Fourth Circuit granted a certificate of appealability limited to the question of whether the defendant’s conviction for attempted armed bank robbery qualified as a “crime of violence” for purposes of supporting his related conviction under Section 924(c).The United States Court of Appeals for the Fourth Circuit reviewed de novo whether attempted armed bank robbery under 18 U.S.C. § 2113(d) categorically constitutes a crime of violence under 18 U.S.C. § 924(c)(3). The court held that because Section 2113(d) requires either assaulting another person or putting another’s life in jeopardy by use of a dangerous weapon or device during the course of an attempted bank robbery, the offense necessarily entails the use, attempted use, or threatened use of physical force. The court also found that the statute requires intentional, rather than merely reckless, conduct. Therefore, the court affirmed that attempted armed bank robbery under Section 2113(d) is categorically a crime of violence and affirmed the district court’s decision. View "US v. Straite" on Justia Law

The defendant was observed by a police officer driving recklessly in Ukiah, California, nearly hitting pedestrians and engaging in dangerous maneuvers while under the influence of alcohol. After a high-speed pursuit, she was arrested and charged with multiple felonies, including assault and reckless evasion, as well as misdemeanors related to driving under the influence. She had a prior robbery conviction, making her subject to enhanced sentencing under the Three Strikes law. Through a negotiated plea, she pled no contest to one felony and one misdemeanor, admitted her prior strike, and agreed to a stipulated upper-term sentence of three years (doubled to six years), with the remaining charges dismissed.After her conviction, but while her appeal was pending, California amended Penal Code section 1170 to require that aggravating facts justifying an upper-term sentence be either stipulated to by the defendant or found true beyond a reasonable doubt. The defendant argued on appeal that this amendment should apply retroactively to her nonfinal judgment, requiring reduction of her sentence since the new requirements were not met. The California Court of Appeal rejected her claim, holding that the amendment did not affect stipulated sentences from plea bargains, since no judicial discretion was exercised in those cases.The Supreme Court of California reversed the Court of Appeal. The Supreme Court held that defendants with nonfinal judgments who agreed to an upper-term sentence as part of a plea bargain are entitled to seek the retroactive benefit of amended section 1170(b). However, a stipulated upper-term sentence remains valid only if the defendant knowingly and voluntarily waives the new requirements. On remand, the defendant may either waive these requirements and reaffirm the plea (reinstating the original sentence), or invoke them, in which case the parties may renegotiate the plea or the defendant may withdraw her plea and proceed to trial. The Supreme Court of California thus vacated the lower court’s judgment and set forth these remedies. View "P. v. Mitchell" on Justia Law

A man drove his ten-year-old daughter from Oklahoma to Texas so she could participate in a gymnastics competition. While staying in a hotel together, he sexually abused her in the bathtub and later in bed. After the girl disclosed the abuse to her peers, three others—two of her half-sisters and her uncle, all minors at the time of their respective incidents—came forward with their own accounts of sexual abuse or inappropriate conduct by the same man. The evidence included testimony about prior incidents and hidden cameras used by the defendant to record his daughters.A federal grand jury in the United States District Court for the Eastern District of Oklahoma charged the defendant with three crimes: transporting a minor with intent to engage in criminal sexual activity under 18 U.S.C. § 2423(a), aggravated sexual abuse of a minor in Indian Country under 18 U.S.C. §§ 1151, 1152, and 2241(c), and coercion and enticement of a minor under 18 U.S.C. § 2422(b). After a jury trial, he was convicted on all three counts and sentenced to life imprisonment for each, to run concurrently. On appeal, he challenged the sufficiency of the evidence supporting his convictions for transportation of a minor and aggravated sexual abuse, arguing specifically that the government failed to prove that his “dominant purpose” in transporting his daughter was sexual activity and failed to establish his non-Indian status.The United States Court of Appeals for the Tenth Circuit held that, under § 2423(a), the government must prove only that the defendant transported the minor “with intent” that she engage in illegal sexual activity, not that this was his dominant purpose, and found the evidence sufficient. The court also held that unchallenged testimonial evidence from family members was sufficient to establish beyond a reasonable doubt that the defendant was a non-Indian. The convictions were affirmed. View "United States v. Thompson" on Justia Law