Justia Criminal Law Opinion Summaries

Federal agents arrested a man after a sting operation involving a confidential informant. The informant identified the defendant as someone involved in drug transactions and arranged a meeting where agents observed the defendant accepting sham cocaine. Upon arrest, agents found heroin, crack cocaine, and cash in the defendant’s vehicle. The defendant admitted to prior drug dealings with the informant. He was charged with possession of heroin with intent to distribute and went to trial, where a jury convicted him.Before the United States District Court for the Northern District of Illinois, the defendant’s sentencing included two enhancements: one under 21 U.S.C. § 841(b)(1)(B) for a prior felony drug conviction and another under § 4B1.1 of the Sentencing Guidelines for being a career offender. Defense counsel did not challenge these enhancements. The defendant was sentenced to 20 years in prison and 8 years of supervised release. On direct appeal, his conviction was affirmed by the United States Court of Appeals for the Seventh Circuit. He subsequently filed a motion for postconviction relief under 28 U.S.C. § 2255, arguing ineffective assistance of counsel for failure to object to the sentencing enhancements and to certain testimony at trial. The district court denied relief, finding the enhancements valid and counsel’s performance reasonable.On collateral review, the United States Court of Appeals for the Seventh Circuit found that counsel’s failure to challenge the § 841(b)(1)(B) statutory enhancement was objectively unreasonable and prejudicial, as it affected both the advisory Guidelines range and mandatory minimums. However, the court rejected claims regarding the career-offender enhancement and admission of the agent’s testimony, finding no prejudice or legal error. The Seventh Circuit vacated the sentence and remanded for resentencing, while affirming the conviction. View "Cherry v USA" on Justia Law

Jeremy Michael Weekley was indicted by the Tyler County Grand Jury for sex crimes allegedly committed against a minor, A.M., in February 2018. The indictment did not specify the exact date, and A.M. did not disclose the alleged assault until 2023. At trial in January 2026, A.M. testified that the incident occurred on February 24, 2018. The defense argued that the specific date had not been disclosed prior to trial and moved to dismiss the charges, but the Circuit Court of Tyler County denied the motion and granted a mistrial. The defense then sought to disqualify the Tyler County Prosecuting Attorney’s Office, asserting that Assistant Prosecutor Kyle Elliot was a necessary witness regarding the timing of the date’s disclosure by A.M.’s mother.The Circuit Court of Tyler County found no prosecutorial misconduct and concluded that Assistant Prosecutor Elliot’s testimony was immaterial to the elements of the charged offenses or the credibility of the witness. Nevertheless, the court disqualified the prosecutor’s office and appointed a special prosecutor as a preemptive measure to avoid further motions from the defense related to evidence disclosure and to expedite proceedings. The State petitioned the Supreme Court of Appeals of West Virginia for a writ of prohibition, arguing that the disqualification lacked valid legal or factual justification and infringed upon the prosecuting attorney’s constitutional duties.The Supreme Court of Appeals of West Virginia held that disqualifying an elected prosecuting attorney and his office without valid reasons was clearly erroneous and exceeded the circuit court’s legitimate authority. The court granted the writ of prohibition, modified precedent to clarify that the State may challenge such disqualifications, and ordered the circuit court to permit the Tyler County Prosecuting Attorney’s Office to remain as counsel for the State. View "State ex rel. State v. Wilson" on Justia Law

Police in Manatee County, Florida, began investigating an individual known as “Dre” following a tip that he was selling drugs and collecting payments through Cash App. Surveillance linked “Dre” to a residence in Bradenton, which was then associated with Andre Adams Jr. Officers observed frequent, brief visits to the home and witnessed Adams hand items to visitors. Trash recovered from the property contained evidence of drugs, and Cash App records revealed Adams received over $67,000 in small payments, with some transactions referencing drug slang. Adams had no reported employment during this period. A search warrant was obtained for the residence, where officers found substantial evidence of drug trafficking, including narcotics, cash, firearms, and paraphernalia. A subsequent search of a storage unit rented by Adams uncovered more drugs, cash, and firearms.A federal grand jury indicted Adams on charges of possessing drugs with intent to distribute, possessing a firearm in furtherance of a drug trafficking crime, and possessing a firearm as a convicted felon. Adams moved to suppress evidence, arguing the search warrant affidavit omitted material information, and sought a hearing under Franks v. Delaware. A magistrate judge recommended denying his motions, finding Adams failed to submit a sworn statement as required, and the district court adopted this recommendation. Adams’s evidentiary objections to the introduction of his financial records and employment history were also denied, as was his request for a specific jury instruction on “mere presence.” At trial, the jury convicted Adams on all counts.The United States Court of Appeals for the Eleventh Circuit reviewed and affirmed the district court’s decisions. The appellate court held that Adams was not entitled to a Franks hearing, the evidentiary rulings were proper or harmless, the jury instructions were adequate, the evidence was sufficient to support the convictions, and the 228-month sentence was substantively reasonable. View "USA v. Adams" on Justia Law

The defendant was responsible for the care of five minor girls, including his former stepdaughter, and used his access to sexually abuse and surreptitiously record them, often while they were nude. The abuse came to light when one of the victims, a seven-year-old, disclosed inappropriate conduct to her parents, prompting a law enforcement investigation. Officers obtained search warrants and discovered secret videos and images of the minors, some recorded in the defendant’s home bathroom using a hidden camera. A grand jury indicted the defendant on multiple counts for production, attempted production, and possession of child pornography based on these depictions.In the United States District Court for the District of Kansas, the defendant was tried before a jury. The evidence included testimony from law enforcement, parents, and one of the victims, as well as review of the illicit images and videos. The jury found the defendant guilty on all counts, and the district judge sentenced him to eighty years in prison. On appeal, the defendant raised several arguments, including challenges to evidentiary sufficiency, jury instructions, the admission of uncharged sexual abuse evidence, multiplicity of counts, and cumulative error.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that, under its precedent, a depiction of a minor can be considered a “lascivious exhibition” based on how the depiction is created by the defendant, regardless of the minor’s awareness or intent. The court found sufficient evidence for all convictions, determined the jury instructions were not erroneous, and upheld the use of the Dost factors as a jury aid. The court also found no reversible error in the admission of evidence, held that the counts were not plainly multiplicitous, and rejected the cumulative error argument. The convictions and sentence were affirmed. View "United States v. Morgan" on Justia Law

The case concerns James Guzman, who was convicted of the murder of David Colvin. Guzman has been tried three times for Colvin's murder, with the most recent conviction occurring in 2016. Following this conviction, Guzman has undergone four penalty-phase proceedings, each resulting in a death sentence. The current appeal focuses on the fourth penalty phase and the resulting death sentence, which followed a unanimous jury recommendation. During that penalty phase, Guzman moved to disqualify the judge based on her prior employment at the law firm (Rice and Rose) that represented him in his first appeal, though she did not work on his case or any criminal matters at the firm.Previously, the Circuit Court for the Seventh Judicial Circuit conducted the penalty phase, presided over jury selection, and ruled on Guzman's motion to disqualify the judge, finding it legally insufficient. The jury found four aggravating factors and recommended death, and the judge imposed the sentence after considering both aggravating and mitigating circumstances. Guzman appealed, raising issues regarding the judge’s disqualification, the jury instructions on victim impact testimony, and the constitutionality of the death penalty.The Supreme Court of Florida reviewed the case and affirmed the lower court’s decisions. The Court held that Guzman’s motion to disqualify the judge was legally insufficient, as the allegations did not establish an objectively reasonable fear of bias or prejudice. The Court also found Guzman’s challenge to the jury instructions regarding victim impact testimony was unpreserved and, even if preserved, meritless, since the instructions given were adequate. Finally, the Court rejected Guzman’s argument that the death penalty is inherently cruel and unusual, citing longstanding precedent. The disposition by the Supreme Court of Florida was to affirm Guzman’s sentence of death. View "Guzman v. State of Florida" on Justia Law

A masked individual entered Plato’s Closet in Jonesboro, Arkansas, threatened employees with what appeared to be a handgun, and stole $598 before fleeing in a gray Mercury sedan. Shortly after, law enforcement stopped Pierre Wright, who was driving a vehicle matching the description. Officers found clothing matching the suspect’s, an imitation firearm, and a Plato’s Closet bag containing $598 in the car. Additional evidence, including GPS and cell-phone data, further linked Wright to the crime.The State charged Wright with aggravated robbery and theft of property and sought to classify him as a habitual offender based on prior Tennessee convictions. At trial in the Craighead County Circuit Court, Wright moved for directed verdicts, arguing insufficient evidence of his identity as the robber. The circuit court denied these motions, and the jury found Wright guilty. During sentencing, the State introduced certified records of Wright’s prior Tennessee convictions—one for aggravated robbery and two for aggravated burglary—and argued that the Tennessee aggravated-burglary offenses were comparable to Arkansas’s aggravated residential burglary, making Wright eligible for a mandatory life sentence under Arkansas Code Annotated section 5-4-501(d). The circuit court agreed and imposed the life sentence.On appeal to the Supreme Court of Arkansas, Wright raised three arguments: the sufficiency of the evidence, the comparability of his Tennessee convictions to Arkansas offenses for sentencing enhancement, and the propriety of his mandatory life sentence. The Supreme Court of Arkansas held that the evidence was sufficient to support the convictions, that the circuit court did not abuse its discretion in finding the Tennessee aggravated-burglary convictions comparable to the Arkansas statute, and that the mandatory life sentence was proper. The Court affirmed the judgment and sentence. View "WRIGHT v. STATE OF ARKANSAS" on Justia Law

On October 18, 2022, a fatal shooting occurred in the parking lot of The Ridge apartment complex in Little Rock, Arkansas. The evidence at trial established that Ferrad McCoy traveled with Mason Abraham from Memphis to Little Rock, where Abraham, as the passenger in a white Infiniti, shot and killed Broderick Blueford. Law enforcement later pursued the same vehicle on Interstate 40, resulting in a high-speed chase and crash. Both McCoy and Abraham fled on foot but were apprehended nearby. Physical evidence, including firearms, shell casings, a cell phone, and a hoodie matching McCoy’s attire, as well as video footage and cell phone records, linked both men to the crime and location.The Pulaski County Circuit Court presided over a jury trial in which McCoy was convicted of capital murder, first-degree unlawful discharge of a firearm from a vehicle, and firearm enhancements. He received life imprisonment plus additional years for the enhancements. McCoy challenged the sufficiency of the evidence and objected to the admission of several items, including photographs, firearms, video footage, and a “BOLO” flyer. He also raised issues regarding jury instructions and the Confrontation Clause.The Supreme Court of Arkansas reviewed the case, applying the substantial evidence standard and broad discretion for evidentiary rulings. The Court held that there was substantial evidence to support the convictions, properly admitted the contested evidence, and found no reversible error in the circuit court’s rulings. The Court also determined that McCoy’s jury instruction and Confrontation Clause arguments were either waived or without merit. The convictions and sentences imposed by the Pulaski County Circuit Court were affirmed. View "MCCOY v. STATE OF ARKANSAS" on Justia Law

The case centers on a man who shot and killed his wife in their Little Rock home. In the days leading up to the incident, he sent her a series of threatening and incoherent text messages, suggesting jealousy and intent to cause harm. On the day of the shooting, a family friend visited the home and left his .40-caliber Glock handgun on the couch. After an argument between the husband and wife, the friend heard gunshots as he was leaving. He returned to find the wife dead and the husband present but the handgun missing. The husband fled the scene and was later apprehended in Texas, having changed his appearance. During his time in jail, he instructed his daughter to lie to investigators about the nature of his relationship with his wife and whether there had been any conflict.The Pulaski County Circuit Court presided over the trial. During the proceedings, the defendant requested to dismiss his retained counsel midtrial, expressing dissatisfaction with his representation, but had not arranged for another attorney and did not wish to represent himself. The circuit court denied the request, citing the length of time the case had been pending and the absence of substitute counsel. At trial’s conclusion, the jury found him guilty of first-degree murder, a lesser-included offense of the original capital murder charge, and imposed a sentence of life imprisonment plus fifteen years for a firearm enhancement.On appeal, the Supreme Court of Arkansas reviewed whether the circuit court erred in denying the motion to change counsel and whether there was sufficient evidence to support the conviction. The Supreme Court held that substantial evidence supported the verdict and that the circuit court did not abuse its discretion in denying the last-minute motion to change counsel. The conviction and sentence were affirmed. View "BROWN v. STATE OF ARKANSAS" on Justia Law

The appellant was charged as a habitual offender with kidnapping, rape, and aggravated assault following an incident where he forcibly assaulted and raped a fifteen-year-old girl in Columbia County, Arkansas. The State agreed to a plea deal, which would dismiss the kidnapping charge and recommend concurrent sentences of thirty years for rape, twenty years suspended, and six years for aggravated assault. During the plea hearing, the appellant acknowledged the terms and facts of the case, as well as his prior felony convictions. The circuit court found the plea voluntary and knowing, but ultimately imposed a life sentence for rape and six years for aggravated assault, deviating from the recommended plea agreement terms.After the court accepted the plea but before entry of judgment, the appellant moved to withdraw his guilty plea under Arkansas Rule of Criminal Procedure 26.1, arguing that he had not been given notice that the court would reject the recommended sentence and had not been given an opportunity to withdraw his plea. The Columbia County Circuit Court held a hearing on the motion and found that the plea had been entered voluntarily, with effective assistance of counsel, and with knowledge of the nature of the charges and possible sentences. The court determined that it had not indicated concurrence with the plea agreement and that no manifest injustice warranting withdrawal of the plea had been shown. The sentencing order was entered, and the appellant filed a timely appeal.The Supreme Court of Arkansas reviewed the circuit court’s denial of the motion to withdraw the guilty plea for abuse of discretion. It held that, because the circuit court had not indicated concurrence with the plea agreement, Rule 26.1(b)(v) did not apply, and the appellant did not prove manifest injustice. Arguments regarding lack of notice under Rule 25.3 and involuntariness under Rule 26.1(b)(iii) were not preserved for appellate review. The court affirmed the circuit court’s decision. View "DAVIS V. STATE OF ARKANSAS" on Justia Law

The defendant was convicted in 2012 of first degree murder for a crime allegedly committed in 1994 and sentenced to life in prison without parole. After an appeal affirmed the conviction, he sought postconviction relief, which was partly granted, leading to an evidentiary hearing. While awaiting retrial following a stipulation to vacate his conviction, he learned of alleged misconduct by the DNA analyst involved in his case. He supplemented his motion, claiming entitlement to a new trial based on this new information. Subsequently, he served the Colorado Bureau of Investigation (CBI) with a subpoena requesting documents from cases handled by the analyst, seeking to support claims for a motion to dismiss based on alleged outrageous governmental conduct.The Boulder County District Court initially denied CBI’s motion to quash, finding that the requested materials "may have relevance" to the defendant's anticipated motion. The court clarified the scope of the subpoena after a motion to reconsider but maintained its order for production. The district court’s reasoning relied on both the Colorado Rules of Criminal Procedure and the Colorado Forensic Science Integrity Act (FSIA), suggesting the materials could be relevant to the defendant’s claims, but did not address all required legal factors or procedural prerequisites under the governing rules and statute.The Supreme Court of Colorado reviewed the district court’s orders under its original jurisdiction, applying both abuse of discretion and de novo standards of review. The court held that the district court erred by denying CBI's motion to quash because the subpoena exceeded the allowable scope under both Crim. P. 17 and the FSIA. The defendant had not satisfied the procedural requirements for discovery under the FSIA, nor all five factors of the Spykstra test. The order to show cause was made absolute, and the case was remanded for further proceedings consistent with the opinion. View "People v. Clark" on Justia Law