Justia Criminal Law Opinion Summaries

A jury found defendant Jeremiah Williams guilty of first degree robbery, four counts of making a criminal threat, two counts of forcible rape, sexual penetration by use of force, forcible oral copulation, burglary of an inhabited dwelling, battery and assault, as lesser offenses of sodomy by use of force, assault with a deadly weapon, and false imprisonment by violence. The first eight counts were committed against Jane Doe 1; the remaining counts against Jane Doe 2. The jury found defendant committed all counts but one: forcible sexual offenses against more than one victim. The trial court sentenced defendant to a term of 100 years to life plus 86 years two months. It also imposed a $10,000 restitution fine, and a matching suspended parole revocation restitution fine (and other fees and assessments). Defendant raised six enumerations of error at trial, but finding none, the Court of Appeal affirmed. View "California v. Williams" on Justia Law

The Supreme Court reversed the judgment of the court of criminal appeals and reinstated the judgment of the trial court suspending a bonding company for violating a local rule of court requiring an agent of the bonding company to be present at court appearances of defendants for whom the bonding company serves as surety, holding that the local rule is valid and enforceable. The bonding company in this case conceded that it violated the local rule but asserted that the local rule was inconsistent with Tennessee statutes and was arbitrary and capricious. The court of criminal appeals concluded that the part of the local rule requiring an agent of the bonding company to attend all court appearances was arbitrary, capricious, and illegal. The Supreme Court reversed, holding (1) the local rule does not conflict with state statutes and is not arbitrary, capricious, or unreasonable; and (2) the trial court did not err by suspending the bonding company for violating the local rule. View "In re Cumberland Bail Bonding" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Petitioner's petition for habeas corpus, holding that Petitioner was not entitled to habeas relief. Petitioner was convicted of second-degree murder, death of a child by a guardian or custodian, and child abuse resulting in injury. The Supreme Court affirmed the convictions and sentences. Petitioner then filed a self-represented petition for writ of habeas court, alleging, primarily, that his counsel provided him with ineffective assistance. The circuit court ultimately denied the habeas corpus petition. The Supreme Court affirmed, holding (1) the circuit court did not err in finding that Defendant failed to show prejudice under the second prong of Strickland/Miller; and (2) there were no errors in the trial court's proceedings that would warrant application of the cumulative doctrine to the facts of this case. View "Meadows v. Mutter" on Justia Law

Schillinger, a Wisconsin prisoner, was assaulted by another inmate as the prisoners were returning to their housing unit after recreation. He suffered a fractured skull, broken teeth, cuts, and other serious injuries. Schillinger sued three guards under 42 U.S.C. 1983. The district judge screened the complaint and permitted Schillinger to proceed on a claim that the officers failed to take preventive action after learning of hostility between Schillinger and his attacker during the recreation period shortly before the attack. The judge later ruled that Schillinger had not exhausted his administrative remedies on that claim and entered summary judgment for the defendants. The Seventh Circuit affirmed, rejecting Schillinger’s arguments that the judge should have gleaned from his complaint two additional factual grounds for a failure-to-protect claim: that the officers did not respond fast enough to an alarm about a medical emergency on his unit once the attack was underway and they stood by without intervening to stop the attack. Upholding the exhaustion ruling, the court reasoned that while Schillinger pursued a complaint through all levels of the prison’s inmate-complaint system, he never mentioned the claim he raised in litigation: that the officers were aware of threatening behavior by the attacker before the assault and failed to protect him. View "Schillinger v. Kiley" on Justia Law

Russell Craig appealed a trial court's denial of his motion to withdraw his guilty plea to murder. In 2006, Craig was charged with murder. A year later, he was sentenced to life without the possibility of parole. Craig testified when he arrived at the Department of Corrections and Rehabilitation (DOCR) he received a case plan stating he was eligible for parole in 20 years based on his life expectancy of 67 years less his then-current age of 44. In 2007 Craig wrote a letter requesting reduction of his sentence. In the letter Craig wrote the district court “Currently on a life sentence [I] have to [s]erve 85 [percent] of 30 years. I would be able to see the p[a]role board in 26.5 years . . . .” The court treated the letter as a motion for reduction of sentence and denied the requested relief. In 2017, the district court clerk sent Craig a letter regarding a statutory change requiring a calculation of life expectancy for life sentences with the possibility of parole. In 2018, Craig filed a motion to withdraw his guilty plea because he believed he was eligible for parole after 20 years as outlined on his DOCR case plan which calculated his remaining life expectancy at 23 years, and not 85 percent of his remaining life expectancy of 33.8 years under the State’s calculation based on N.D. Sup.Ct. Admin. R. 51. Craig argues his sentence was illegal, the district court violated the prohibition on ex post facto punishment, and the district court erred by denying Craig’s motion to withdraw his plea. The North Dakota Supreme Court affirmed, finding the evidence established Craig understood his plea deal, including that he had to serve a minimum of 30 years less reduction for good conduct. Therefore, the district court did not abuse its discretion in finding a manifest injustice did not exist. View "North Dakota v. Craig" on Justia Law

Jeffrey Krogstad was convicted by jury of gross sexual imposition on a six-year-old victim. Krogstad argued on appeal that: (1) admission of video of the victim’s forensic interview violated his Sixth Amendment right to confrontation; (2) the district court abused its discretion in admitting the video under N.D.R.Ev. 803(24); and (3) there was insufficient evidence to sustain the guilty verdict. Finding no reversible error, the North Dakota Supreme Court affirmed. View "North Dakota v. Krogstad" on Justia Law

The Eighth Circuit affirmed defendant's conviction for conspiring to distribute 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine. The court held that, even if the district court erroneously admitted evidence, the errors did not affect defendant's substantial rights as required by the plain-error standard because the evidence of his guilt was overwhelming. The court also held that the evidence was sufficient to support the jury's verdict. View "United States v. Loomis" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for conspiracy to possess with intent to distribute methamphetamine. The court held that the evidence was sufficient to support defendant's conviction; the district court's jury instructions did not constructively amend, or vary from, count one of the superseding indictment; the district court did not err in refusing to give buyer-seller and mere-presence instructions; the district court did not abuse its discretion by permitting the government to elicit testimony showing that defendant and his coconspirator knew one another when they were incarcerated in state prison and that the coconspirator helped defendant while the two were in prison; the district court did not err in applying the murder cross-reference under USSG 2D1.1(d)(1); and defendant's sentence was not substantively unreasonable. View "United States v. Shavers" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to vacate his sentence under 18 U.S.C. 117 for the crime of domestic assault by a habitual offender in Indian country. The court held that defendant's prior 2013 conviction under Bismarck Municipal Court for simple assault was for an offense which, if subject to federal jurisdiction, would qualify as an assault against an intimate partner under section 117(a)(1). Consequently, defendant cannot show that he is "actually innocent" of the offense to which he pleaded guilty, and his challenge to the sentence is procedurally defaulted. View "Silk v. United States" on Justia Law

The Supreme Court affirmed the judgment of the district court granting Defendant's motion to dismiss the State's case against him, holding that the district court applied the incorrect burden and standard when adjudicating Defendant's motion to dismiss, but the error was harmless. Defendant was charged with one count of first degree murder. The district court dismissed the case under Wyo. Stat. Ann. 6-2-602(f), which the legislature had recently added to the self-defense statutes. The Supreme Court granted the State's petition for writ of review to address matters of first impression regarding the statute's meaning and application. The Supreme Court held (1) section 6-2-602(f) is a mandatory immunity provision carrying with it a judicial gatekeeping function after the preliminary hearing; (2) the accused must present a prima facie showing that section 6-2-602(f) applies, and if the accused satisfies this minimal burden, the burden shifts to the State to establish by a preponderance of the evidence that section 6-2-602(f) does not apply; and (3) while the district court applied a different burden and standard when it adjudicated Defendant's motion to dismiss, its error was harmless. View "State v. John" on Justia Law