Justia Criminal Law Opinion Summaries

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Jacob Ray Owens was convicted for conspiring to possess with intent to distribute 50 grams or more of actual methamphetamine and was sentenced to 324 months in prison, followed by a five-year term of supervised release. Owens appealed his sentence, arguing that his trial and appellate counsel were ineffective for failing to challenge the purity of methamphetamine attributed to him. The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision.Owens and a co-conspirator, Brian Edward Stowe, were involved in a drug trafficking operation. After Owens was arrested, he continued to work with Stowe to maintain their business. The methamphetamine attributed to Owens was based on the drugs seized during his arrest and those he transported with Stowe from Mexico. Owens's base offense level was 36, with a total offense level of 37 and a criminal history category of V, leading to his sentencing guideline range of 324 to 405 months.Owens challenged his sentence, arguing his counsel was ineffective for failing to challenge the purity of the methamphetamine attributed to him. However, the court held that Owens failed to show that he was prejudiced by his counsel's performance, noting that the district court could make plausible inferences based on the evidence at hand. The court noted that even if the objection were made, the district court would have adopted the same guideline range and imposed the same sentence. Therefore, Owens could not show a reasonable probability that the result would have been different if his counsel had objected or raised the argument on appeal. View "United States v. Owens" on Justia Law

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This case involves the appeal of an order to transfer a juvenile, Miguel R., from the juvenile court system to the criminal court system in California. Miguel was originally charged with murder and other offenses when he was 17 years old. After a juvenile wardship petition was filed, the juvenile court granted a motion to transfer Miguel to the criminal court. The defendant appealed this order, but it was affirmed by the appellate court.Subsequently, changes in legislation led to the case being transferred back to the juvenile court to address the statutory amendments. The juvenile court, applying the new standard of proof, again ordered Miguel to be transferred to the criminal court. Miguel appealed this second order, arguing that the juvenile court misapplied the statutory changes and that the prosecution did not meet its burden under the clear and convincing evidence standard.The appellate court affirmed the order of the juvenile court. It clarified certain points about the recent amendments to the relevant statute, stating that the statute does not require any one factor to be given more weight than others when determining whether a minor is suitable for rehabilitation under the juvenile court's jurisdiction.The appellate court also found that the juvenile court's decision to transfer Miguel to the criminal court was supported by substantial evidence, and that it was not reasonably probable that the juvenile court would have reached a different conclusion even if it had applied the most recent version of the statute. The court's ruling was based on factors such as Miguel's degree of criminal sophistication, his potential for rehabilitation before the expiration of the juvenile court's jurisdiction, the success of previous attempts to rehabilitate him, and the circumstances and gravity of his offenses. View "In re Miguel R." on Justia Law

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In the State of California, a defendant, Kevin Lunsted, sought a writ of mandate to compel the trial court to grant his motion to quash a subpoena from the prosecution. The prosecution subpoenaed Lunsted's case file (c-file) from the California Department of Corrections and Rehabilitation to prepare for his resentencing hearing under Penal Code section 1172.75. Lunsted argued that the request for his entire c-file was overbroad and sought privileged and immaterial medical and mental health records. The trial court denied the motion, stating that the c-file was likely to contain information relevant to the resentencing hearing.Lunsted appealed, arguing that the trial court failed to apply the factors set out in Facebook, Inc. v. Superior Court (Touchstone) (2020) to determine whether the prosecution made a sufficient demonstration of good cause to defeat his motion to quash.The Court of Appeal of the State of California Fourth Appellate District Division Two agreed with Lunsted. It held that the trial court had applied an incorrect legal standard by failing to apply the seven-factor test set out in the Facebook case. The Court therefore granted Lunsted's petition and remanded the case for the lower court to reconsider the motion to quash under the correct legal standard. The Court clarified that the Facebook factors apply to subpoenas issued not only by the defense but also by the prosecution. View "Lunsted v. Super. Ct." on Justia Law

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The case involved Garrett Joseph Hurst, who was charged with knowingly engaging in a sexual act with a minor, in violation of various sections of the United States Code. At sentencing, the district court imposed the maximum term of imprisonment of 180 months, followed by a thirteen-year term of supervised release, which was higher than the advisory Guidelines imprisonment range.Hurst appealed, arguing that the district court erred in rejecting a Federal Rule of Criminal Procedure 11(c)(1)(C) plea agreement proposed by the parties, incorrectly concluded that he was ineligible for a two-point reduction for acceptance of responsibility, imposed a substantively unreasonable sentence, and committed plain error by failing to explain why it selected a thirteen-year term of supervised release.The United States Court of Appeals for the Tenth Circuit affirmed the judgment of the district court. The court held that the district court had not erred in rejecting the plea agreement, correctly concluded Hurst was ineligible for a two-point reduction for acceptance of responsibility, and did not impose a substantively unreasonable sentence. The court also found that while the district court had erred in failing to explain its reasons for the term of supervised release, this error did not affect Hurst's substantial rights. View "United States v. Hurst" on Justia Law

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The Supreme Court of Arkansas affirmed the verdict of the Ashley County Circuit Court convicting Robert J. Williams, Jr. of capital murder and aggravated assault and sentencing him to life imprisonment without parole and a term of twenty-eight months’ imprisonment, respectively. Williams appealed on three grounds: the circuit court's granting of the State's motion for continuance; violation of his speedy-trial rights; and the circuit court's denial of his Batson challenge during voir dire.The Supreme Court found no error in the circuit court's decisions. It held that the State had shown due diligence in procuring unavailable witnesses and that the affidavit filed by the State complied with the requirements set forth by law. It also held that Williams was brought to trial within the twelve-month period required by law, as periods of delay were properly excluded from the calculation. Finally, it held that the circuit court properly allowed the State to strike a juror during voir dire and that its decision to deny the Batson claim was not clearly against the preponderance of the evidence.The Supreme Court reviewed all objections, motions, and requests made by either party that were decided adversely to Williams, and found no prejudicial error. Therefore, the circuit court's decision was affirmed. View "WILLIAMS v. STATE OF ARKANSAS" on Justia Law

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The Supreme Court of Kansas affirmed the convictions of Todge Anton Anderson for first-degree felony murder, second-degree intentional murder, aggravated robbery, distributing or possessing with intent to distribute a controlled substance, and criminal possession of a weapon. The court held that the trial court did not abuse its discretion by not excluding evidence of a jail call as a sanction for a discovery violation, given that the evidence was disclosed before the start of the trial and the defendant had reviewed it. The prosecutor did commit error during closing arguments by suggesting that the burden of proof was on the defendant; however, the court determined that this error did not affect the outcome of the trial. The court also found there was sufficient evidence to support Anderson’s conviction for distributing synthetic marijuana or possessing it with intent to distribute. Lastly, the court vacated the trial court's order for Anderson to pay $5,000 in attorney fees without considering the burden of payment on the defendant, and remanded for reconsideration of that issue. View "State v. Anderson" on Justia Law

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In the United States Court of Appeals for the Eighth Circuit, Defendant Ledra Craig appealed his conviction for various counts related to the distribution of fentanyl. On August 2, 2020, Craig sold fentanyl to two men, R.P. and N.B., at a casino in Missouri. R.P. and N.B. were later found unconscious and R.P. ultimately died. Craig was then arrested and made a statement to officers after waiving his Miranda rights, which was later used as evidence during his trial.Craig raised three main points of contention in his appeal. First, he argued that text messages between him and an unidentified co-conspirator, "Glenn," were wrongly admitted under Federal Rule of Evidence 801(d)(2)(E). The court disagreed, stating that the texts, which discussed drug deals, were made during and in furtherance of a conspiracy. Second, Craig claimed that the court improperly denied him the right to present a complete defense by restricting his ability to question an officer about the circumstances surrounding his inculpatory statement. The court also rejected this argument, noting that Craig had been able to conduct a thorough cross-examination of the officer. Finally, Craig contended that evidence of his prior drug conviction was erroneously admitted under Federal Rule of Evidence 404(b) as it was irrelevant to the current case and served as improper propensity evidence. The court disagreed, stating that the prior conviction was relevant to his intent to engage in the charged conspiracy to distribute drugs. Based on these reasons, the court affirmed Craig's conviction. View "United States v. Craig" on Justia Law

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In 2024, the United States Court of Appeals for the District of Columbia Circuit presided over a case involving an appellant, Larry Brock, who had been convicted for his participation in the January 6th riot at the United States Capitol. Brock was convicted of six crimes, including obstructing Congress’s certification of the electoral count under 18 U.S.C. § 1512(c)(2). The district court applied a three-level sentencing enhancement to Brock’s conviction, arguing his conduct resulted in “substantial interference with the administration of justice[.]” Brock challenged the interpretation of Section 1512(c)(2)’s elements and the sufficiency of the evidence supporting his conviction.The Court of Appeals affirmed Brock’s conviction, agreeing with the district court’s interpretation of the elements of Section 1512(c)(2) and finding the evidence sufficient to support the conviction. However, the court concluded that the three-level sentencing enhancement for interfering with the “administration of justice” was inapplicable to interference with the legislative process of certifying electoral votes. As a result, the court vacated Brock’s sentence and remanded the case to the district court for resentencing without the application of the sentencing enhancement. View "USA v. Brock" on Justia Law

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This case revolves around whether the Supreme Court of the State of Kansas can exercise jurisdiction over an appeal that was not filed within the statutory time limit. The appellant, Leroy L. Perry, was convicted of murder in the 1990s and filed a self-represented motion in district court to modify his life sentence. The court denied the motion and, a year and a half later, Perry filed a notice of appeal, asserting that he had never received the order denying his motion.The Supreme Court remanded the case to the district court to make factual findings about the notice of appeal's untimeliness. The district court found that Perry did receive the order shortly after it was mailed to him and held that Perry could not show excusable neglect for his failure to timely appeal. Perry appealed to the Supreme Court, arguing that he didn't receive the order until after receiving a report in October 2019.The Supreme Court affirmed the district court's findings. It reasoned that Perry would not have known there was a decision to appeal, nor the precise date the order was filed, unless he had received the order shortly after the clerk sent it to him. The court concluded that Perry's appeal was untimely under Kansas state statute and dismissed it for lack of jurisdiction. The court did not reach the State's excusable neglect argument. View "State v. Perry" on Justia Law

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This case revolves around the appellant, Sheldon James Thompson, who was convicted for the brutal murders of his girlfriend, her 20-month-old son, and her unborn child. Thompson was convicted by a jury for eight offenses, including first-degree premeditated murder for each victim. The jury's decision was based on the prosecution's argument, which included statements about Thompson's motive and activities before, during, and after the murders. Thompson appealed his conviction, asserting that the prosecutor committed unobjected-to misconduct during the closing argument, which affected his substantial rights. He also contended that the court should order a new trial as prosecutors continued to make speculative statements during closing arguments.The Minnesota Supreme Court, however, affirmed the conviction. The court held that the State had met its burden to show that Thompson’s substantial rights were not affected by any alleged plain error in the prosecutor’s closing argument. The court also determined that Thompson had failed to establish that speculative statements were a widespread form of prosecutorial misconduct; thus, a prophylactic reversal was not warranted. This conclusion was based on the strength of the evidence against Thompson, the limited extent of the alleged misconduct, and the opportunity Thompson had to rebut any improper remarks. View "State of Minnesota vs. Thompson" on Justia Law