Justia Criminal Law Opinion Summaries

The Eighth Circuit affirmed defendant's conviction of possession with intent to distribute a controlled substance. The court held that defendant's motion to suppress was properly denied where defendant had no objectively reasonable expectation of privacy in the trash, which had been left for collection in an area accessible to the public; the evidence was sufficient to support defendant's conviction; and defendant's remaining ten arguments in his pro se supplemental brief were without merit. View "United States v. Thompson" on Justia Law

The Eighth Circuit affirmed defendant's conviction of committing a hate crime in violation of the Matthew Shepard and James Byrd, Jr., Hate Crimes Prevention Act of 2009, 18 U.S.C. 249(a)(1). The court held that the district court did not err in denying defendant's motion to dismiss the indictment on constitutional grounds where Congress rationally determined, in light of the Thirteenth Amendment, that racially motivated violence constitutes a badge and incident of slavery; the district court did not abuse its discretion in refusing to give the proposed jury instruction on character evidence; and the evidence was clearly sufficient to support the conviction. View "United States v. Metcalf" on Justia Law

The State of Alabama petitioned the Alabama Supreme Court for a writ of mandamus to direct the presiding judge of the Montgomery Circuit Court to exercise his power of superintendence over the Montgomery District Court, and to order that court to vacate its order granting Kentory Brown's discovery request. In 2015, Brown was charged with third-degree burglary and second-degree theft of property. Brown filed a motion requesting the appointment of an attorney, a bond hearing, and a preliminary hearing. Thereafter, Brown moved for the State to turn over all discovery permitted by Rule 16.1, Ala. R. Crim. P.; the district court granted the discovery motion on the same day it was filed. However, the State failed to provide the requested discovery. In refusing to produce the requested discovery, the State argued (1) that the case was under active investigation and that nothing had been turned over to the district attorney's office by the Montgomery Police Department, (2) that the demand for discovery was premature because no indictment had been issued, and (3) that the district court had limited jurisdiction in felony criminal cases and, not being the trial court, could not order discovery. The district court indicated that it would issue an order requiring the State to produce the requested discovery, but the court proceeded with the preliminary hearing. On the same day as the preliminary hearing, the court found probable cause that the offenses had been committed and bound over both cases to the Montgomery County grand jury. When the district court issued the order to compel the State to produce the discovery, the State petitioned for mandamus relief. The Supreme Court granted the writ: “Simply, the jurisdiction granted district courts in felony cases is limited.” The district court here exceeded the scope of its authority when it entered a discovery order in this case, and the Montgomery Circuit Court erred in refusing to direct the district court to vacate its order. View "Ex parte State of Alabama." on Justia Law

The Supreme Court affirmed the order of the trial court convicting Defendant on a charge of first-degree arson. On appeal, Defendant argued that the district court abused its discretion when, at trial, it admitted evidence of other acts, in violation of Wyo. R. Evid. 404(b). The Supreme Court disagreed, holding (1) the district court did not commit plain error when it conducted its Rule 404(b) Gleason analysis after the disputed Rule 404(b) evidence had been admitted and after the close of the evidence; and (2) the district court did not abuse its discretion when it admitted evidence of other acts at trial. View "Garrison v. State" on Justia Law

The Supreme Court affirmed the order of the trial court convicting Defendant on a charge of first-degree arson. On appeal, Defendant argued that the district court abused its discretion when, at trial, it admitted evidence of other acts, in violation of Wyo. R. Evid. 404(b). The Supreme Court disagreed, holding (1) the district court did not commit plain error when it conducted its Rule 404(b) Gleason analysis after the disputed Rule 404(b) evidence had been admitted and after the close of the evidence; and (2) the district court did not abuse its discretion when it admitted evidence of other acts at trial. View "Garrison v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Thomas M. Overton’s motion filed under Fla. R. Crim. P. 3.851, holding that Overton was not entitled to relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and this court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). Overton was convicted of two counts of murder. Overton was sentenced to death on both counts following a jury’s recommendation for death by a vote of nine to three on one count and a vote of eight to four on another count. Overton’s sentence of death became final in 2002. The Supreme Court held that Hurst did not apply retroactively to Overton’s sentence of death and, accordingly, affirmed the denial of Overton’s motion. View "Overton v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Thomas M. Overton’s motion filed under Fla. R. Crim. P. 3.851, holding that Overton was not entitled to relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and this court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). Overton was convicted of two counts of murder. Overton was sentenced to death on both counts following a jury’s recommendation for death by a vote of nine to three on one count and a vote of eight to four on another count. Overton’s sentence of death became final in 2002. The Supreme Court held that Hurst did not apply retroactively to Overton’s sentence of death and, accordingly, affirmed the denial of Overton’s motion. View "Overton v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Norberto Pietri’s motion filed under Fla. R. Crim. P. 3.851, holding that Pietri was not entitled to relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and this court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). Pietri was sentenced to death following a jury’s recommendation for death by a vote of eight to four. Pietri’s sentence of death became final in 1995. The Supreme Court held that Hurst did not apply retroactively to Pietri’s sentence of death and, accordingly, affirmed the denial of Pietri’s motion. View "Pietri v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Norberto Pietri’s motion filed under Fla. R. Crim. P. 3.851, holding that Pietri was not entitled to relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and this court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). Pietri was sentenced to death following a jury’s recommendation for death by a vote of eight to four. Pietri’s sentence of death became final in 1995. The Supreme Court held that Hurst did not apply retroactively to Pietri’s sentence of death and, accordingly, affirmed the denial of Pietri’s motion. View "Pietri v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Alvin Leroy Morton’s motion filed under Fla. R. Crim. P. 3.851, holding that Morton was not entitled to relief pursuant to the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and this court’s decision on remand in Hurst v. State (Hurst), 202 So. 3d 40 (Fla. 2016). Morton was convicted of two counts of first-degree murder and sentenced to death following a jury’s recommendation for death by a vote of eleven to one on both counts. Derrick’s sentence of death became final in 2001. The Supreme Court held that Hurst did not apply retroactively to Morton’s sentence of death and, accordingly, affirmed the denial of Morton’s motion. View "Morton v. State" on Justia Law