Justia Criminal Law Opinion Summaries

The New Mexico Supreme Court addressed the enforceability of a guilty plea, particularly because the plea did not expressly, affirmatively state on the record, the accused plead guilty. The Court of Appeals concluded that, where the words, "I plead guilty," are not spoken, the plea is not enforceable no matter the circumstances of the plea proceeding, the overall context of the plea colloquy, or the clarity with which a defendant otherwise manifested an intent to plead guilty. The Supreme Court found this was incorrect. "Whether a plea is knowing and voluntary must be assessed from the totality of the circumstances. No magic words are either required or adequate to resolve that inquiry." View "New Mexico v. Yancey" on Justia Law

Defendant Lloyd Aguilar was tried on an indictment charging a number of offenses related to a carjacking in which the victim was beaten and shot to death. Several of the charged offenses had complex alternative theories of culpability, which likely resulted in the jury's confusion at issue in this case. After deliberation, the jury submitted executed verdict forms to the presiding trial judge. Noticing an apparent conflict in the verdicts, the trial judge, without the knowledge or participation of the parties, returned the forms to the jurors and directed them to read the instructions again and clarify their verdicts. The jury subsequently returned revised verdict forms, which the trial judge accepted in open court with the participation of the parties before the jury was discharged. On the following day, the trial judge notified the parties of his previously undisclosed ex parte contact with the jury. After a post-trial hearing on this issue, the trial court ordered a new trial on all charges on which the jury had returned final verdicts of guilty. Both the State and Defendant appealed the trial court’s order. The State argued the trial court’s grant of a new trial was made in error, and Defendant argued that while the grant of a new trial was appropriate, the principles of double jeopardy barred retrial on the counts of murder and armed robbery. The New Mexico Supreme Court held: (1) the trial court’s new trial order was not an abuse of discretion; and (2) retrial of the counts on which the jury ultimately returned guilty verdicts would not constitute double jeopardy. View "New Mexico v. Aguilar" on Justia Law

The Supreme Court in this case considered two certified questions regarding West Virginia's kidnapping statute, W. Va. Code 61-2-14a. Defendant was indicted for kidnapping. During pretrial proceedings, the parties discussed (1) whether, under Alleyne v. United States, 570 U.S. 99 (2013), the judge or the jury would need to make additional determinations when considering a kidnapping charge and (2) the propriety of special interrogatories to the jury in a kidnapping case. Defendant's trial was continued so that these issues could be brought to the Supreme Court for consideration. The Court answered, for a person convicted of kidnapping, (1) the trial judge, rather than the jury, is vested with the authority under the kidnapping statute to determine those facts that reduce the minimum and maximum penalty of life imprisonment without eligibility for parole; and (2) in the absence of a statutory or constitutional requirement that special interrogatories be submitted to a jury in a kidnapping case, a trial court exceeds its authority and abuses its discretion in submitting special interrogatories to determine those facts that reduce the minimum and maximum penalty of life imprisonment without eligibility for parole. View "State v. Scruggs" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Petitioner relief on his second petition for writ of habeas corpus, holding that Petitioner was not entitled to relief on his three arguments on appeal. Petitioner was convicted of burglary by entering without breaking and other offenses. In his second habeas corpus petition Petitioner raised four grounds for relief. The circuit court summarily dismissed the petition. The Supreme Court affirmed, holding that the errors Petitioner raised in this appeal were either not raised below and therefore waived or were previously and finally adjudicated on the merits and not clearly wrong. View "Lewis v. Ames" on Justia Law

The Fourth Circuit affirmed defendant's conviction for sex trafficking and related crimes, holding that the warrantless forensic searches of defendant's digital devices did not violate his Fourth Amendment rights. Where a search at the border is so intrusive as to require some level of individualized suspicion, the object of that suspicion must bear some nexus to the purposes of the border search exception in order for the exception to apply. The court agreed with defendant that the border search exception did not extend to the challenged searches, because no such nexus existed here. However, the court held that the good faith exception to the exclusionary rule barred suppression. In this case, law enforcement relied on an established and uniform body of precedent allowing warrantless border searches of digital devices at the time of the search. View "United States v. Aigbekaen" on Justia Law

Marlon Howell was convicted of possession of a controlled substance and sentenced to three years in the custody of the Mississippi Department of Corrections. In 2019, Howell filed a motion to vacate his three year sentence, claiming that his three year sentence was illegal because it exceeded the statutory maximum penalty in effect at the time of his conviction. The State filed a motion to dismiss, arguing that he did not have standing because his sentence had expired. The circuit court granted the motion, found that Howell did not have standing, and dismissed the case for lack of jurisdiction. Howell appealed, arguing that the circuit court erred. On the narrow question presented, interpreting Mississippi Code Section 99-39-5(1), the Mississippi Supreme Court held Howell had standing. View "Howell v. Mississippi" on Justia Law

Nichols admitted that he had sexually abused young girls on multiple occasions and sometimes documented the abuse in videos and photographs; videos and photographs in his possession depicted graphic scenes of adult men sexually abusing children as young as toddlers. Nichols pled guilty to receipt and possession of child pornography. The district court enhanced his sentence because some of his victims were “vulnerable,” U.S.S.G. 3A1.1(b)(1). If 3A1.1(b) did not apply, his guidelines range would be 210-262 months rather than 262-327 months. The court rejected Nichols’s argument that he also possessed material depicting “sexual abuse or exploitation of an infant or toddler,” U.S.S.G. 2G2.2(b)(4)(B), and that the commentary provides that “[i]f subsection (b)(4)(B) applies,” a court should not apply 3A1.1(b). The Sixth Circuit affirmed. Where multiple enhancements appear equally applicable, a court should use only the enhancement that “results in the greater offense level.” That is what the district court did, finding that Nichols possessed images depicting sadistic conduct as well as images depicting the sexual abuse of toddlers. View "United States v. Nichols" on Justia Law

In 2002, Beamus was convicted of conspiracy to possess 6.68 grams of crack cocaine with intent to distribute, 21 U.S.C. 841(b)(1)(B), and related firearms offenses, 18 U.S.C. 922(g)(1), 924(c)(1)(A)(i). He had prior convictions, ranging from misdemeanor unauthorized use of a motor vehicle to felony first-degree manslaughter, with many more in between. The judge imposed a 420-month sentence: 360 months for conspiracy to possess crack cocaine and 60 months for another related firearm offense, to be served consecutively, as required by statute. Since his conviction, the Fair Sentencing Act of 2010 modified the statutory range for crack cocaine convictions and there was a Guidelines reduction. Beamus moved for resentencing under the First Step Act of 2018. The district court held that his career-offender status under the Sentencing Guidelines made him ineligible. The Sixth Circuit reversed. Beamus was convicted of an offense for which the Fair Sentencing Act modified the statutory penalty, and he has not received a reduction in accordance with that Act or lost such a motion on the merits. The First Step Act contains no freestanding exception for career offenders. It makes retroactive the Fair Sentencing Act’s changes to the statutory range for crack cocaine offenses. View "United States v. Beamus" on Justia Law

The Supreme Court reversed the decision of the court of criminal appeals affirming the judgment of the trial court granting Defendants' motion to suppress, holding that the warrantless search of a probationer's residence who is subject to a search condition does not require officers to have reasonable suspicion of illegal activity prior to conducting the search. Law enforcement conducted a warrantless search of the residence of a probationer and her husband, resulting in the discovery of illegal drugs and drug-related contraband. Pursuant to probation conditions imposed in a previous case, the probationer had agreed to a warrantless search of her person, property, or vehicle at any time. In affirming the trial court's decision to grant Defendants' motion to suppress, the court of criminal appeals concluded that the State was required to have reasonable suspicion to support the probation search and that the State lacked such suspicion in this case. The Supreme Court reversed, holding (1) because of the probation conditions to which the probationer was subject, the probation search of portions of the probationer's residence was constitutionally allowable; and (2) the search of probationer's husband's personal belongings located within Defendants' shared bedroom was proper pursuant to the doctrine of common authority. View "State v. Hamm" on Justia Law

The Supreme Court affirmed in its entirety the judgment of the trial court convicting Defendant of two counts of first-degree murder and related crimes and sentencing Defendant to death for each of the murder convictions, holding that there was no reversible error in the proceedings below. Specifically, the Supreme Court held (1) there was substantial evidence to support the trial court's denial of Defendant's Batson/Wheeler challenge; (2) as to the admission of Defendant's confession, the investigator should have stopped the interrogation on April 21, 1999 sooner than he did, but the error did not compel the exclusion of the confession obtained on April 22, 1999 or thereafter; (3) Defendant's arguments involving testimony of Defendant's volitional impairment did not require reversal of the death sentence; (4) the trial court did not err in admitting testimony by Defendant's former girlfriend, a photograph of Defendant, and evidence that Defendant lied about shooting a person; and (5) Defendant was not entitled to relief on his remaining allegations of error. View "People v. Krebs" on Justia Law