Justia Criminal Law Opinion Summaries

Two major airline crashes in 2018 and 2019 involving Boeing 737 MAX aircraft led to the deaths of hundreds of passengers and crew. Investigations revealed that Boeing had concealed important safety information about modifications to the planes’ flight control system, contributing to the crashes. The Department of Justice (DOJ) charged Boeing with conspiracy to defraud the United States but later entered a Deferred Prosecution Agreement (DPA) in 2021, requiring Boeing to pay significant penalties and undertake compliance measures. After Boeing allegedly breached the DPA, the DOJ pursued a Non-Prosecution Agreement (NPA) in 2025, again imposing penalties and compliance obligations in exchange for dismissing the criminal charge. Family members of crash victims challenged both agreements, asserting violations of their rights under the Crime Victims’ Rights Act (CVRA).The United States District Court for the Northern District of Texas found that while the DOJ had originally failed to confer with families before the 2021 DPA due to a legal error, there was no bad faith, and the court lacked authority to modify or review the substance of the DPA or NPA. The district court later granted the DOJ’s motion to dismiss the prosecution against Boeing after the NPA, finding the DOJ’s actions were not in bad faith and were adequately explained.On appeal, the United States Court of Appeals for the Fifth Circuit held that the families’ challenge to the 2021 DPA was moot since the agreement was no longer in effect after Boeing’s breach. Addressing the NPA, the Fifth Circuit concluded the DOJ had fulfilled its obligation to confer with the families and had not misled them. The court also determined it lacked jurisdiction under the CVRA to substantively review the district court’s dismissal of the prosecution. The petitions for writ of mandamus were denied. View "Ryan v. USA" on Justia Law

In this case, the petitioner was convicted by a jury in Puerto Rico in 1996 for four counts of first-degree murder and related charges, stemming from a shooting known as the "Piñones Massacre." The prosecution’s case relied in part on the testimony of Regino Burgos-Torres, who implicated the petitioner in ordering the killings as revenge for the deaths of his brothers, allegedly at the hands of three of the victims. Many years later, the petitioner discovered that the prosecution had not disclosed affidavits from two eyewitnesses to his brothers’ murders. These affidavits implicated two other individuals and did not mention the three victims, potentially undermining the prosecution’s theory of motive.The petitioner sought a new trial in the Puerto Rico court, arguing that the suppression of the affidavits violated the rule established in Brady v. Maryland. The court denied his motion after holding an evidentiary hearing, finding that the affidavits would not have altered the verdict because what mattered was the petitioner’s belief about who killed his brothers, not who actually did. The intermediate appellate court and the Puerto Rico Supreme Court declined further review.The petitioner then filed a federal habeas corpus petition in the United States District Court for the District of Puerto Rico under 28 U.S.C. § 2254, presenting the same Brady claim. The district court dismissed the petition without reviewing key portions of the state court record, namely the trial testimony of Burgos-Torres. Upon remand from the United States Court of Appeals for the First Circuit to correct this error, the district court again denied relief without obtaining the necessary transcript or a narrative summary of the testimony.The United States Court of Appeals for the First Circuit vacated the district court’s judgment. The court held that the district court could not reasonably evaluate the state court’s adjudication of the Brady claim under § 2254 without the transcript or a narrative summary of Burgos-Torres’s testimony. The case was remanded with instructions to obtain that record and reconsider the petition accordingly. View "Crespo-Morales v. Caro-Delgado" on Justia Law

Jaron Starkey pleaded guilty to a federal drug-trafficking offense and was sentenced to 300 months in prison. His sentence was enhanced under the career-offender provision of the United States Sentencing Guidelines, based on two prior felony drug-distribution convictions in Delaware from 2012 and 2019. Starkey challenged the use of these convictions as predicates for the enhancement, contending that the Delaware statutes under which he was convicted criminalized attempted drug distribution, which, according to Fourth Circuit precedent prior to a 2023 Guidelines amendment, would not qualify as “controlled substance offenses” under the Sentencing Guidelines.The United States District Court for the Eastern District of Virginia rejected Starkey’s argument and applied the career-offender enhancement, concluding that his prior Delaware convictions qualified as predicate offenses under the Guidelines. Starkey appealed this determination.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s judgment. The Fourth Circuit held that the Delaware statutes under which Starkey was convicted define “delivery” to include “attempted transfers,” but this does not mean they criminalize attempted delivery as an inchoate offense. Instead, the offense of delivery encompasses completed acts that may include attempted transfers, which are distinct from mere attempts prosecuted under separate attempt statutes. The court found that Delaware law does not prosecute inchoate attempted deliveries under its drug-distribution statutes. Therefore, Starkey’s prior convictions properly qualified as controlled substance offenses for the career-offender enhancement. The Fourth Circuit affirmed the judgment of the district court. View "US v. Starkey" on Justia Law

The defendant pleaded guilty to a federal offense that prohibits possession of a firearm by a convicted felon. During sentencing, his presentence report recommended an enhanced base offense level because of a prior 2008 conviction under Virginia Code § 18.2-53.1 for using a firearm in the commission of a felony, specifically robbery. This enhancement was based on the conclusion that the prior conviction constituted a “crime of violence” as defined by the Federal Sentencing Guidelines. The defendant, through counsel, objected, arguing that his prior conviction did not meet the Guidelines’ definition of a crime of violence, and the parties’ written and oral arguments focused primarily on whether the elements clause or the enumerated offense clause of the Guidelines applied.The United States District Court for the Eastern District of Virginia overruled the defendant’s objection and applied the enhancement, basing its conclusion on the elements clause. The court’s reasoning mirrored the elements clause language, and its supporting citations were to cases addressing that clause or similar provisions. The resulting advisory Guidelines range was higher, and the defendant received a 33-month sentence. On appeal, he argued that the court erred in finding his prior conviction qualified as a crime of violence. The government defended the application of the elements clause and also raised arguments under the enumerated offense clause and harmless error doctrine.The United States Court of Appeals for the Fourth Circuit held that the district court erred in concluding the prior Virginia conviction satisfied the elements clause, adopting circuit precedent holding that Virginia robbery does not categorically require the use, attempted use, or threatened use of physical force against another. The Fourth Circuit found the government had not demonstrated harmless error and declined to affirm based on the enumerated offense clause. The court vacated the sentence and remanded for resentencing. View "US v. Scott" on Justia Law

The defendant was indicted for first-degree murder and several related offenses stemming from the killing of Keith Crump. He filed a motion under the Racial Justice Act to bar the death penalty, but the case proceeded as a capital trial. In December 2011, a jury convicted him on all counts, including first-degree murder, and recommended a death sentence, which the Superior Court of Stanly County imposed. The defendant appealed directly to the Supreme Court of North Carolina, as is standard in cases involving a death sentence.After his conviction, the defendant filed further motions under the Racial Justice Act and successfully moved to stay appellate proceedings in the Supreme Court of North Carolina, pending resolution of those motions. While the appeal was pending, he sought clemency from the governor. On December 31, 2024, the governor commuted his death sentence to life imprisonment without parole. The defendant then requested that the Supreme Court of North Carolina dissolve the appellate stay and remand his case to the North Carolina Court of Appeals, arguing that his case was no longer a capital case and thus should not be reviewed by the Supreme Court.The Supreme Court of North Carolina examined whether it retained jurisdiction for direct appeal under N.C.G.S. § 7A-27(a)(1) after the governor’s commutation. The court held that the statutory right to direct appeal to the Supreme Court exists to prevent arbitrary or unjust executions and applies only while a death sentence is active. Because the commutation eliminated the possibility of execution, the legislative intent underlying direct Supreme Court review no longer applied. Therefore, the court dissolved its stay and remanded the case to the Court of Appeals for review under the ordinary appellate procedure for non-capital cases. View "State v. Robinson" on Justia Law

The case concerns the fatal shooting of Caleb Adams in the bedroom of Wendy Hicks on June 13, 2017. Adams was shot twice in the back from more than six inches away, and evidence at the scene suggested he was attempting to leave when shot. Hicks was the only armed individual present. During her interactions with law enforcement and at trial, Hicks provided multiple, inconsistent accounts of the events leading up to the shooting. She claimed Adams was the aggressor and that a struggle over her phone and the gun occurred, but the crime scene and her physical condition did not show signs supporting her account of a violent struggle.After Hicks was convicted of second-degree murder by a jury in Randolph County Superior Court, she was sentenced to a lengthy prison term. On appeal to the North Carolina Court of Appeals, she argued, among other issues, that the trial court erred in admitting unredacted phone-extraction reports (Exhibits 174 and 175) into evidence without objection or limiting instruction. The Court of Appeals initially reversed her conviction on a different issue, but after remand from the Supreme Court of North Carolina, it vacated the judgment and ordered a new trial, finding plain error in the admission of the phone-extraction exhibits.Upon review, the Supreme Court of North Carolina held that Hicks had not met her burden to show that the admission of the phone-extraction reports constituted plain error. Applying the standard from State v. Lawrence, the Court found the remaining evidence of lack of justifiable self-defense to be substantial, and determined it was not probable the jury would have reached a different verdict absent the disputed evidence. Accordingly, the Supreme Court of North Carolina reversed the decision of the Court of Appeals. View "State v. Hicks" on Justia Law

Julie Ann Mincey operated a travel agency in New Bern, North Carolina, where she defrauded elderly clients by collecting payments for elaborate travel packages that she failed to deliver, resulting in financial losses exceeding $100,000. After her conduct was discovered, a grand jury indicted her on multiple felony charges—specifically, fourteen counts of embezzlement, two counts of obtaining property by false pretenses, and for attaining habitual felon status based on prior Colorado felony convictions. At her trial in Superior Court, Craven County, several charges were dismissed, and a jury convicted her on nine counts of embezzlement and one count of obtaining property by false pretenses. Ms. Mincey admitted to habitual felon status, and the trial court conducted a colloquy to confirm her understanding of the plea’s consequences before accepting her guilty plea.The North Carolina Court of Appeals reviewed Ms. Mincey’s appeal after she argued that the trial court failed to determine an adequate factual basis for her habitual felon guilty plea, particularly because one predicate offense had been reclassified as a misdemeanor in Colorado after her conviction. The Court of Appeals concluded that Ms. Mincey had a right to appeal under N.C.G.S. § 15A-1444(a2)(3) and affirmed the trial court’s judgment, finding the plea was supported by sufficient factual basis. A dissenting judge disagreed on the right to appeal and would have preferred granting certiorari to review the merits.The Supreme Court of North Carolina determined that Ms. Mincey did not have a statutory right to appeal her guilty plea to attaining habitual felon status. The court held that, absent certain exceptions, defendants who plead guilty may only seek appellate review through a writ of certiorari, which was not properly issued here. Accordingly, the Supreme Court reversed the Court of Appeals’ decision and remanded the case. View "State v. Mincey" on Justia Law

After observing a parked vehicle with a visible handgun in the driver’s door pocket in downtown Greensboro, law enforcement officers conducted surveillance. When four individuals entered the car and departed quickly, officers followed and initiated a traffic stop after pacing the vehicle at ten miles per hour over the speed limit. During the stop, officers noticed an odor of burnt marijuana and a strong, freshly sprayed perfume they identified as a cover scent. The officers conducted background checks revealing that one backseat passenger had previous drug distribution convictions and the other, Tyron Lamont Dobson, had a prior felony conviction and pending violent felony and firearm charges. A search of Dobson’s person and the vehicle led to the discovery of marijuana and a handgun.The Superior Court in Guilford County denied Dobson’s motion to suppress the evidence, finding that the traffic violation, marijuana odor, the driver's statements about possible marijuana exposure, and the presence of a cover scent provided probable cause for the search. After consulting with counsel, Dobson pleaded guilty to possession of a firearm by a felon while reserving his right to appeal the denial of his motion to suppress. The North Carolina Court of Appeals affirmed the trial court’s decision, holding that the detection of both marijuana odor and a cover scent together supported probable cause.The Supreme Court of North Carolina reviewed whether the Court of Appeals failed to properly apply the “totality of the circumstances” test and instead created a “double odor” rule. The Supreme Court held that the officers relied on more than just the two odors, including the traffic violation and criminal backgrounds. The Court affirmed that, under the totality of the circumstances, the search was supported by probable cause and was objectively reasonable, thus affirming the judgment of the Court of Appeals. View "State v. Dobson" on Justia Law

The case concerns an altercation between Blaine Dale Hague and Thomas “Tommy” Cass, culminating in Hague fatally shooting Cass in a cornfield where Cass and others were hunting doves. Hague, who operated a nearby horse rescue farm, had previously interacted with Cass regarding hunting and firearm use near his property. On the day in question, Hague approached the hunting party after hearing gunshots and finding his horses spooked. An argument ensued with Cass, who pushed Hague to the ground. Hague, claiming to fear for his life due to Cass’s actions and his knowledge of Cass’s felony status and history of carrying firearms, shot Cass. At trial, Hague asserted self-defense and sought to introduce evidence of Cass’s prior felony convictions to support the reasonableness of his fear.The Superior Court of Iredell County, presided over by Judge David L. Hall, excluded evidence of Cass’s prior felony convictions under Rules 404(a)(2) and 404(b) of the North Carolina Rules of Evidence and also redacted related statements from Hague’s 911 call. The jury found Hague guilty of first-degree murder. Hague appealed, and the North Carolina Court of Appeals reversed and vacated the conviction, holding that the trial court erred by excluding the prior convictions and remanded the case for a new trial. The Court of Appeals also found error in the trial court’s denial of Hague’s motion to dismiss but did not find error in the omission of a stand-your-ground jury instruction.The Supreme Court of North Carolina reviewed the case. It held that the trial court prejudicially erred by excluding evidence of Cass’s prior felony convictions under Rule 404(b), as this evidence was relevant to Hague’s state of mind and the reasonableness of his self-defense claim. The court remanded the case for a new trial, dismissed discretionary review of the jury instruction issue, and did not address the motion to dismiss. The court’s disposition was to modify and affirm the appellate decision. View "State v. Hague" on Justia Law

After observing a traffic violation, a sheriff’s deputy attempted to stop a driver who did not immediately pull over, instead proceeding to an apartment complex known for high criminal activity. The deputy observed the driver, who had prior narcotics and weapons convictions, behaving evasively and refusing to answer questions. Both the initial deputy and another responding officer detected the odor of marijuana emanating from the vehicle. During a frisk for weapons, an officer found what was believed to be a marijuana blunt in the driver’s pocket; the driver did not claim it was legal hemp. A subsequent warrantless search of the vehicle uncovered a firearm. The driver was indicted for carrying a concealed weapon and possession of a stolen firearm.In the Superior Court of Forsyth County, the defendant moved to suppress evidence from the searches, arguing that the odor and sight of marijuana could not, in light of the legalization of industrial hemp, provide reasonable suspicion or probable cause. The trial court denied the motion, citing the driver’s failure to stop, the high-crime location, prior convictions, evasive conduct, and the odor of marijuana as sufficient under the totality of the circumstances. The jury found the defendant guilty of carrying a concealed weapon but not guilty of possessing a stolen firearm.The North Carolina Court of Appeals affirmed, holding that the trial court did not err in denying the motion to suppress and that the defendant received a fair trial. On discretionary review, the Supreme Court of North Carolina held that under the totality of the circumstances—including but not limited to the odor of marijuana—officers had reasonable suspicion to frisk the defendant and probable cause to search the car. The odor of marijuana remains a relevant factor despite the existence of legal hemp. The decision of the Court of Appeals was modified and affirmed. View "State v. Rowdy" on Justia Law