Justia Criminal Law Opinion Summaries

Appellant Tonya Miller appeals her convictions for malice murder and concealing the death of another relating to the death of Cheryl Miranda. Appellant challenged the sufficiency of the evidence presented against her at trial, and that the trial court erred in admitting certain hearsay evidence. Finding no reversible error, the Georgia Supreme Court affirmed Miller’s conviction. View "Miller v. Georgia" on Justia Law

The Georgia Supreme Court granted certiorari in this case to consider whether an affidavit executed in support of an application for a search warrant that does not specifically say that the residence to be searched was the residence of the suspect could nevertheless be sufficient to establish that connection based on inferences drawn from the affidavit and thus were sufficient to establish a nexus between the evidence to be seized and the place to the searched. The Supreme Court concluded that an affidavit may be sufficient to connect the suspect to the residence based on inferences that can be drawn from the affidavit. View "Taylor v. Georgia" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court upholding that decision of the trial court denying Petitioner’s petition for a new trial on the basis of newly discovered evidence. In his petition, Petitioner claimed that new DNA testing demonstrated that he did not commit the murder for which he was convicted. The lower courts ruled that Petitioner was not entitled to relief. The Supreme Court affirmed, holding (1) the Appellate Court should have engaged in a de novo review under the specific circumstances of this case; but (2) applying a de novo standard of review, Petitioner was not entitled to a new trial. View "Jones v. State" on Justia Law

This appeal sought the proper standard for appellate review of pretrial detention decisions under the Criminal Justice Reform Act (CJRA), N.J.S.A. 2A:162-15 to -26. In a complaint-warrant, the State charged defendant S.N. with first-degree aggravated sexual assault on a person under the age of thirteen; fourth-degree lewdness; and second-degree child endangerment. Following defendant’s arrest, a pretrial services officer prepared a Public Safety Assessment (PSA) that rated defendant a 1 out of 6, the lowest possible risk score, for both failure to appear and new criminal activity. Despite the low risk scores, the PSA concluded “No Release Recommended.” The State then moved for pretrial detention. The prosecution certified that there was a “serious risk” that “defendant will not appear in court,” and “defendant will pose a danger to any other person or the community.” The certification stated, “[d]efendant’s victim is his step-daughter. Defendant is a risk to harm and intimidate his victim and her mother and to obstruct justice by interfering with the investigation and witnesses. Defendant is a risk of flight because his biological mother and sister live in Canada.” The trial court found that the State had established probable cause that defendant committed the charged offenses. The court specifically found that defendant was eligible for detention under the statute. The court gave “great weight to [the No Early Release Act]NERA, the fact that this is a NERA offense and first degree, the dual citizenship, due to the extensi[ve] exposure of incarceration if convicted, the fact that release was not recommended, and the fact that this is considered a violent offense.” The Appellate Division reversed and released defendant with conditions, finding the trial court abused its discretion by not considering defendant’s age, level of prior criminal involvement and ties to the community.” The Appellate Division required as part of defendant’s release that “defendant must report to pretrial detention as frequently as necessary to determine his compliance with restraining orders prohibiting him from having any contact with the victim or her family . . . . [and] must surrender his passport.” The Supreme Court agreed that the trial court abused its discretion, finding that the trial court’s decision rested on an “impermissible basis,” “fail[ed] to take into consideration all relevant factors,” including defendant’s characteristics as he stood before the court, and “reflects a clear error in judgment.” The next appropriate procedural step was to remand the matter to the trial court to determine the suitable conditions of release: Remand is required because the trial court has the opportunity at a detention hearing to “hear and see witnesses” and gain a “'feel’ of the case which a reviewing court cannot enjoy.” View "New Jersey v. S.N." on Justia Law

The Appellate Division reversed defendant Tormu Prall’s conviction, finding that: (1) his prior threat to kill his girlfriend, Jessie Harley, was admitted in error and without a limiting instruction; (2) the State improperly utilized prior bad act evidence in closing; and (3) statements by defendant’s brother John Prall to John’s girlfriend Kimberly Meadows were inadmissible hearsay and did not qualify as dying declarations or excited utterances. Defendant was convicted for the arson murder of his brother. The New Jersey Supreme Court granted the State’s petition for certification and reversed the Appellate Division and reinstated defendant’s convictions. The Supreme Court agreed with the appellate panel’s legal conclusions that the trial court erred by allowing evidence that defendant threatened to burn down Jessie’s homes and by admitting John’s hearsay statements to Kimberly that defendant was responsible for the arson. However, the Court found the errors were not capable of producing an unjust result because of the overwhelming weight and quality of the evidence against defendant. View "New Jersey v. Prall" on Justia Law

The First Circuit affirmed the district court’s dismissal of three federal post-conviction relief petitions filed under 28 U.S.C. 2255, holding that the three petitions were untimely.Petitioners in these consolidated appeals each pled guilty to a federal firearm offense, and each had a history of Maine state burglary convictions. Each petitioner filed a federal habeas petition alleging that they no longer qualified for a sentence enhancement under the Armed Career Criminal Act (ACCA) because the ACCA’s residual clause was invalidated by Johnson v. United States, 576 U.S. __ (2015) (Johnson II). All three petitions filed their habeas petitions outside of the one-year statute of limitations under 28 U.S.C. 2255(f)(1). Specifically, Petitioners alleged that their petitions were timely because Johnson II, which is retroactively applicable, was the source of their claims. The district court dismissed the petitions. The First Circuit affirmed, holding that the federal habeas petitions were untimely because they raised Mathis v. United States, 579 U.S. __ (2016), claims, not Johnson II claims, and Mathis does not reset the statute of limitations under section 2255(f)(3). View "Dimott v. United States" on Justia Law

The First Circuit affirmed the district court’s dismissal of three federal post-conviction relief petitions filed under 28 U.S.C. 2255, holding that the three petitions were untimely.Petitioners in these consolidated appeals each pled guilty to a federal firearm offense, and each had a history of Maine state burglary convictions. Each petitioner filed a federal habeas petition alleging that they no longer qualified for a sentence enhancement under the Armed Career Criminal Act (ACCA) because the ACCA’s residual clause was invalidated by Johnson v. United States, 576 U.S. __ (2015) (Johnson II). All three petitions filed their habeas petitions outside of the one-year statute of limitations under 28 U.S.C. 2255(f)(1). Specifically, Petitioners alleged that their petitions were timely because Johnson II, which is retroactively applicable, was the source of their claims. The district court dismissed the petitions. The First Circuit affirmed, holding that the federal habeas petitions were untimely because they raised Mathis v. United States, 579 U.S. __ (2016), claims, not Johnson II claims, and Mathis does not reset the statute of limitations under section 2255(f)(3). View "Dimott v. United States" on Justia Law

Hill’s death penalty sentence was imposed in 1986. Hill brought a habeas petition, arguing that he may not be executed because he is “intellectually disabled,” as defined in subsequent Supreme Court cases. In 2002 the Sixth Circuit remanded for consideration of the Supreme Court’s opinions on the subject. The Sixth Circuit subsequently concluded that the Ohio courts unreasonably applied the Supreme Court’s three-part standard, which requires three separate findings for a diagnosis of intellectual disability: the individual exhibits significant deficits in intellectual functioning—indicated by an IQ score “approximately two standard deviations or more below the mean,” roughly 70; the individual exhibits significant adaptive skill deficits—such as “the inability to learn basic skills and adjust behavior to changing circumstances” in specified skill sets; and the deficits arose while the individual was still a minor. Hill’s IQ ranges from 48 to 71; his disability was documented before he reached age 18. Ohio courts gave undue weight to Hill’s behavior in prison. Hill was universally considered to be intellectually disabled by teachers, administrators, and the juvenile court system. Hill consistently performed very poorly in school; there was consistent documentation that he had trouble maintaining proper hygiene despite reminders; he had trouble making friends and responding appropriately to authority figures; he was described as vulnerable to exploitation. View "Hill v. Anderson" on Justia Law

Caudill and Goforth broke into White’s home and beat her to death with a hammer when she refused to give them money to buy drugs. After ransacking her home, they loaded her body in the trunk of her car, drove to an empty field, doused the car with gasoline, and set it on fire. A Kentucky jury convicted the two of murder, robbery, burglary, arson, and tampering with evidence. The Kentucky Supreme Court affirmed Caudill’s convictions and death sentence and denied collateral relief. The district court denied Caudill’s federal habeas petition. The Sixth Circuit affirmed, finding that the state courts reasonably rejected her Batson claim and that her lawyers did not provide ineffective assistance by choosing not to call additional witnesses during the penalty phase. Caudill’s claim made too much of Batson’s “sensitive” inquiry language. The Supreme Court has never directed courts to make detailed findings or to solicit the defense attorney’s views before ruling on a Batson motion. Caudill’s jury selection lasted several days. The judge was there the entire time. He observed the demeanor of the jurors and heard their answers. He listened to the prosecutor’s questions, watched the strikes, and considered the prosecutor’s race-neutral explanations. The state judge could have explained more fully why those explanations convinced him that no discrimination was involved but the ruling did not violate clearly established law. View "Caudill v. Conover" on Justia Law

Mark and Ornella Hammerschmidt were convicted of charges related to their involvement in two schemes to obtain fraudulent tax refunds from the Treasury through the IRS. Mark was sentenced to 135 months in prison and Ornella was sentenced to 48 months in prison. The Eighth Circuit vacated defendant's sentence, holding that the district court did not make the findings required to increase Mark's offense level for being a manager or supervisor and it should not have assessed criminal history points for a 2008 purged disposition of civil contempt. The court affirmed Ornella's sentence, holding that the district court did not err in applying an enhancement for being in the business of preparing or assisting in the preparation of tax returns. Furthermore, the district court did not err in relying on victim impact statements and Ornella's criminal history. View "United States v. Hammerschmidt" on Justia Law