Justia Criminal Law Opinion Summaries

The defendant was charged with inflicting corporal injury on his girlfriend, along with possessing drug paraphernalia and a controlled substance. The incident occurred when the defendant, under the influence and agitated, choked his girlfriend with a guitar amp cord while she was driving, endangering both her and their unborn child as well as others on the freeway. After being arrested, the defendant sought pretrial mental health diversion, submitting evidence of his participation in a residential treatment program and a forensic psychological evaluation diagnosing multiple mental health and substance use disorders.In the Superior Court of Los Angeles County, the trial judge determined that the defendant met the eligibility criteria for mental health diversion under Penal Code section 1001.36, but found him unsuitable for diversion. The court concluded that the defendant posed an unreasonable risk of danger to public safety if treated in the community, citing both the facts of the charged offense—specifically, the use of a weapon in a dangerous manner—and a pattern of domestic violence in the defendant’s past, including a prior conviction and an uncharged incident. The defendant pleaded no contest to the corporal injury charge pursuant to a negotiated plea, was placed on formal probation with a treatment requirement, and appealed the denial of diversion.The California Court of Appeal, Second Appellate District, Division Three, reviewed the trial court’s denial for abuse of discretion. The appellate court held that substantial evidence supported the trial court’s finding that the defendant posed an unreasonable risk of committing a violent felony (a “super strike”) if treated outside custody. The appellate court affirmed the judgment, concluding that the trial court did not abuse its discretion by denying mental health diversion. View "People v. Henn" on Justia Law

Two individuals participated in a criminal conspiracy to manufacture and distribute counterfeit pills resembling the anti-anxiety medication Xanax. Over several years, they helped produce and sell millions of these fake pills—made to appear as legitimate generic Xanax—on the dark web and through other illegal channels. Both individuals pleaded guilty to conspiracy and substantive counterfeiting charges. One of them was sentenced to 80 months in prison and agreed to a forfeiture judgment of nearly $7 million, while the other received a 45-month sentence.Prior to the present appeal, a co-conspirator was sentenced by the United States District Court for the Eastern District of Kentucky to 90 months’ imprisonment. That sentence was affirmed by the United States Court of Appeals for the Sixth Circuit in United States v. Wala, which addressed the calculation of “loss” under the Sentencing Guidelines and the application of enhancements for risk to human life. Subsequently, both appellants were sentenced using pre-2024 versions of the Sentencing Guidelines, as stipulated in their plea agreements, and neither objected to this approach at sentencing. Both defendants then appealed their sentences, challenging aspects of the loss calculation, sentencing enhancements, and, in one case, the forfeiture order.The United States Court of Appeals for the Sixth Circuit reviewed the appeals and affirmed the district court’s judgments. The court held that both appellants had waived any argument for applying the 2024 Guidelines by affirmatively agreeing to use earlier versions. The calculation of “loss” and the application of sentencing enhancements were upheld based on binding circuit precedent and the facts found by the district court. The court also determined that the appellant who challenged the forfeiture order had knowingly and voluntarily waived any right to contest it, rendering the challenge unreviewable. The court found no error in the lower court’s rejection of a downward variance based on one defendant’s immigration status. View "United States v. Basalyga" on Justia Law

During an encounter near a closed homeless shelter, law enforcement officers in Boise, Idaho, cited several people, including the defendant, for disorderly conduct. While processing the citation, police discovered an outstanding warrant for the defendant’s arrest. Upon searching him incident to arrest, officers found methamphetamine in the left pocket of a jacket he was wearing, marijuana in the right pocket, and a metal tube with residue in his pants pocket. The defendant, who was homeless at the time, intended to testify that the jacket had been obtained from a homeless shelter and that he was unaware of the items in its pockets.Prior to trial, the District Court of the Fourth Judicial District ruled, under Idaho Rule of Evidence 403, that any evidence revealing the defendant’s homelessness or the shelter origin of the jacket would be excluded, reasoning the probative value was outweighed by the risk of unfair prejudice from potential jury sympathy. The defendant’s counsel objected but complied with the ruling at trial. The jury convicted the defendant of possession of methamphetamine and acquitted him of possession of drug paraphernalia. The district court subsequently sentenced him and denied his post-trial motion for leniency. On appeal, the Idaho Court of Appeals affirmed the conviction, concluding that the lower court had not abused its discretion by excluding the evidence.The Supreme Court of the State of Idaho reviewed the case. It held that the district court abused its discretion by not properly weighing the significant probative value of the excluded evidence—specifically, the defendant’s explanation of how he acquired the jacket—against any risk of unfair prejudice. The Supreme Court determined that the error was not harmless, as the excluded evidence was highly relevant to the essential knowledge element of the offense. Accordingly, the judgment of conviction was vacated and the case remanded for further proceedings. View "State v. Hardt" on Justia Law

A woman was stopped by police in Idaho for driving with an expired vehicle registration. During the traffic stop, a drug detection dog named Edo was deployed to conduct a “free-air sniff” around her vehicle. While sniffing, Edo briefly touched the vehicle’s door handle with the tip of his nose and alerted to the presence of drugs. Based on this alert, officers searched the vehicle and discovered methamphetamine, marijuana, alprazolam, and drug paraphernalia, leading to her arrest and subsequent charges for possession.After an earlier appeal concerning discovery issues related to Edo’s performance records, the defendant moved to suppress the evidence from the stop, arguing that the dog’s contact with her vehicle transformed the sniff into a trespassory search in violation of the Fourth Amendment. The District Court of the Fourth Judicial District in Ada County heard testimony and reviewed video evidence, ultimately granting the motion to suppress. The court concluded that the brief nose contact constituted trespassing and an unlawful search under Idaho precedent, specifically State v. Dorff, 171 Idaho 818, 526 P.3d 988 (2023).The State appealed, and the Idaho Court of Appeals reversed the district court’s suppression order, finding that the contact was not trespassory and that Edo’s alert provided probable cause for the search. The defendant then petitioned for review, which was granted by the Supreme Court of the State of Idaho. The Supreme Court held that the drug dog’s fleeting, momentary nose contact did not amount to “intermeddling” or trespassory conduct under the property-based Fourth Amendment analysis established in Dorff. Therefore, the contact did not transform the free-air sniff into a search, and the district court erred in granting the motion to suppress. The suppression order was reversed and the case remanded for further proceedings. View "State v. Pendleton " on Justia Law

The defendant, after pleading guilty to being a felon in possession of a firearm, received a below-Guidelines prison sentence followed by supervised release. Upon commencing supervision, he repeatedly violated its conditions, including using illegal drugs, failing to report for drug testing, skipping required addiction recovery meetings, and not paying a special assessment. After admitting these violations at a revocation hearing, he requested a return to supervision, while the government urged a significant term of imprisonment. The district court ultimately imposed a nine-month prison term followed by additional supervised release.Previously, the United States District Court for the Eastern District of Virginia considered the parties’ arguments, with the defense contending that the court could not consider the need to sanction the defendant’s breach of trust when imposing a revocation sentence. The court rejected this argument, relying on circuit precedent from United States v. Lewis, and imposed the revocation sentence. The defendant then appealed, arguing that the Supreme Court’s subsequent decision in Esteras v. United States abrogated the Fourth Circuit’s approach in Lewis.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court reaffirmed that its prior decision in Lewis remains valid, holding that a district court may lawfully impose a revocation sentence to sanction a defendant’s breach of the court’s trust. The Fourth Circuit explained that Esteras did not abrogate Lewis, as Esteras only barred consideration of retribution for the original offense, not the need to sanction a breach of supervised release conditions. The court concluded that the district court had not procedurally erred and that the revocation sentence was reasonable. Accordingly, the Fourth Circuit affirmed the judgment of the district court. View "US v. Chafin" on Justia Law

The defendant pleaded guilty to Hobbs Act Robbery and Armed Bank Robbery, after being indicted on eleven counts. As part of a plea agreement, he waived his right to appeal except in limited circumstances, and the government dropped nine counts from the indictment. Despite the waiver, the defendant appealed his sentence, challenging the district court’s designation of him as a career offender under the sentencing guidelines. He argued that his prior Louisiana conviction did not qualify as a predicate offense because the state law included hemp, which was not covered under the federal definition.The United States District Court for the Eastern District of Louisiana classified the defendant as a career offender and summarily overruled his objection. The defendant appealed, but the United States Court of Appeals for the Fifth Circuit initially dismissed the appeal, concluding that the waiver was knowing and voluntary and applied to the circumstances. The Fifth Circuit also rejected the argument for a miscarriage-of-justice exception, noting that the circuit had not adopted such an exception for appeal waivers.The Supreme Court vacated the Fifth Circuit’s judgment and remanded the case in light of Hunter v. United States, which established that appeal waivers are unenforceable when enforcement would result in a miscarriage of justice—defined as egregious errors that would bring the judicial system into disrepute. Upon remand, the Fifth Circuit found that while the district court erred in classifying the defendant as a career offender, the error did not rise to the level of a miscarriage of justice. The error was not extreme, obvious, or egregious as required by the new standard. The Fifth Circuit enforced the appeal waiver and dismissed the appeal. View "USA v. Chaney" on Justia Law

C.M., a 16-year-old, was the subject of a juvenile wardship petition alleging attempted murder and assault with a deadly weapon, along with a personal infliction of great bodily injury. C.M. admitted to assault with a deadly weapon and the great bodily injury allegation, while the attempted murder charge was dismissed. After jurisdiction was transferred from Riverside County to Los Angeles County, the Los Angeles Superior Court found that C.M. had completed all terms of probation and ordered the record sealed under Welfare and Institutions Code section 786.Prior to the current appeal, the Los Angeles Superior Court issued the sealing order over the People’s objection. The People argued that section 786, subdivision (d), prohibits sealing records for offenses listed in section 707, subdivision (b), and claimed that assault with a deadly weapon should be treated as equivalent to “assault by means of force likely to produce great bodily injury,” which is listed in section 707(b)(14). The Superior Court disagreed, and the People sought review by petitioning for a writ of mandate.The Court of Appeal of the State of California, Second Appellate District, Division Five, reviewed the case. The court concluded that assault with a deadly weapon is not expressly listed in section 707, subdivision (b), and that section 786 only prohibits sealing for offenses actually adjudicated as section 707(b) offenses. The court held that the statutory language does not permit courts to reclassify offenses for sealing purposes based on conduct, and that legislative history supports a streamlined process limited to adjudicated offenses listed in section 707(b). Therefore, the Court of Appeal denied the People’s petition for writ of mandate, affirming the juvenile court’s sealing order. View "P. v. Superior Court" on Justia Law

The defendant was indicted for possession with intent to distribute methamphetamine and fentanyl, unlawful possession of a firearm, and possession of a firearm in furtherance of a drug trafficking crime. After his motion to suppress evidence was denied, he pleaded guilty to possession with intent to distribute. As part of his plea agreement, he waived his right to appeal his conviction and sentence, and both he and his trial counsel affirmed that he had been advised of the agreement’s contents. Six months after sentencing, he filed a pro se motion under 28 U.S.C. § 2255, alleging ineffective assistance of counsel because his trial lawyer failed to file an appeal despite being directed to do so.The United States District Court for the District of Idaho ordered the government to respond and requested a declaration from the defendant’s trial counsel, who denied that the defendant asked him to file an appeal. The district court denied the § 2255 motion without holding an evidentiary hearing, concluding that the defendant merely “discussed” his desire to appeal after sentencing but did not directly instruct his counsel to file an appeal. The court also found that trial counsel’s affidavit contradicted any claim that the defendant had given such instructions, and determined that a hearing would be futile since the defendant had knowingly waived his appeal rights.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s decision. The panel held that the defendant’s pro se allegations, when liberally construed, sufficiently claimed ineffective assistance by asserting he directed counsel to appeal. The Ninth Circuit determined that the district court abused its discretion by resolving the credibility dispute between conflicting sworn statements without an evidentiary hearing. The panel vacated the district court’s order denying relief and remanded for an evidentiary hearing to assess the credibility of both the defendant and his trial counsel. View "USA V. ANDERSON" on Justia Law

Two individuals, Roberto Miranda and Roberto Orellana, traveled together to a restaurant parking lot, where a casino employee handed them a box containing $352,000. The employee had been deceived into surrendering the money, which belonged to the Standing Rock Sioux Tribe. Both men were charged with federal crimes related to transporting stolen money and aiding and abetting that offense. Orellana also faced a charge for illegal reentry into the United States. Each pleaded guilty to the relevant offenses.The United States District Court for the District of South Dakota sentenced Miranda to seventy months’ imprisonment, an upward variance from the Sentencing Guidelines range of 41–51 months, based in part on findings that Miranda minimized his involvement and was not candid. Orellana received a fifty-month sentence, also exceeding his Guidelines range of 30–37 months. Both defendants had entered plea agreements containing broad appeal waivers, though each preserved limited rights to appeal the substantive reasonableness of a sentence above the Guidelines range.On appeal, the United States Court of Appeals for the Eighth Circuit ruled that Miranda knowingly and voluntarily waived his right to challenge the district court’s calculation of his Sentencing Guidelines range and dismissed that part of his appeal. The appellate court found no abuse of discretion in Miranda’s sentence and affirmed it. With respect to Orellana, the Eighth Circuit concluded that the district court committed plain error by speculating, without record support, that Orellana was involved with Mexican drug cartels and that this speculation was a principal basis for the sentence imposed. The court determined this error affected Orellana’s substantial rights and the fairness of the proceedings. Accordingly, the Eighth Circuit vacated Orellana’s sentence and remanded his case for resentencing. View "United States v. Orellana" on Justia Law

The petitioner, a noncitizen born in Venezuela who later overstayed a travel visa in the United States, became involved in a drug conspiracy led by her abusive husband. She was charged with conspiracy to distribute controlled substances. Her primary concern throughout the criminal proceedings was remaining in the United States, as she had two children who were U.S. citizens. Her court-appointed counsel assured her that accepting a plea agreement would allow her to "work out" any immigration issues after serving her sentence, despite warnings in the plea agreement and at the plea hearing that she "may" be deported. Relying on this advice, she pleaded guilty and was sentenced to 84 months' imprisonment and three years of supervised release.After completing her sentence, the petitioner received a removal notice, prompting her to seek legal assistance. Upon learning that her conviction rendered her mandatorily removable and permanently inadmissible to the United States, she filed a petition for a writ of coram nobis in the United States District Court for the District of New Hampshire. The district court held an evidentiary hearing and found that she had adequately explained her delay in seeking relief, the counsel's advice was constitutionally deficient under Padilla v. Kentucky, and she suffered prejudice because she would not have pleaded guilty if properly advised. The court granted the writ and vacated her conviction, concluding that equitable considerations favored relief.The United States Court of Appeals for the First Circuit reviewed the district court’s grant of coram nobis relief. Applying de novo review to legal conclusions and clear error to factual findings, the First Circuit affirmed the district court’s decision. The main holding is that the petitioner met all requirements for coram nobis relief: timely explanation for delay, ongoing collateral consequences, fundamental error due to ineffective assistance of counsel, and equitable grounds justifying relief. View "Morillo v. US" on Justia Law