Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was convicted of murder. Defendant appealed, contending, among other things, that statements he made to the court during a pretrial hearing and at sentencing indicating dissatisfaction with the performance of his appointed counsel resulted in a clear and unequivocal request invoking the right to self-representation under the Sixth Amendment. The appellate court affirmed Defendant's conviction, concluding that Defendant's statements to the court did not develop into a clear and unequivocal request for self-representation. The Supreme Court affirmed, holding that the trial court did not violate Defendant's right to self-representation during the criminal proceedings. View "State v. Pires" on Justia Law

Petitioner entered conditional pleas of nolo contendere to several felony offenses. The appellate court affirmed. Petitioner filed an amended petition for a writ of habeas corpus, alleging that his counsel rendered ineffective assistance. Petitioner's appellate counsel, who also served as his trial counsel, failed to file a petition for certification with the Supreme Court challenging the propriety of the appellate court's judgment. The habeas court granted the petition in part and ordered that Petitioner's right to file a petition for certification to appeal to the Supreme Court be restored. The appellate court reversed, concluding that Petitioner failed to introduce evidence that he was prejudiced by counsel's deficiency. The Supreme Court reversed, holding that Petitioner's habeas action was not justiciable because it was not ripe for adjudication. Remanded with direction to dismiss the habeas petition. View "Janulawicz v. Comm'r of Corr." on Justia Law

After a jury trial, Defendant was convicted of burglary in the first degree. After Defendant was released from prison he was found to have violated the terms and conditions of his probation by engaging in criminal conduct. Accordingly, the trial court revoked Defendant's probation. Defendant appealed, claiming there was insufficient evidence to support the finding he had violated his probation. Before oral argument, however, Defendant pleaded guilty to the criminal charges upon which the finding rested. The appellate court subsequently dismissed as moot Defendant's appeal. Defendant appealed, arguing that his habeas corpus action collaterally attacking his criminal conviction revived the controversy such that mootness was averted. During the pendency of Defendant's appeal, the habeas court dismissed Defendant's habeas corpus action. The Supreme Court dismissed as moot Defendant's appeal, holding that dismissal of the habeas corpus action extinguished any claim to a live controversy in this appeal. View "State v. Milner" on Justia Law

After a jury trial, Defendant was convicted of eight counts of sexual assault in the first degree and eight counts of risk of injury to a child. The sixteen counts were predicated on four separate incidents. The Supreme Court affirmed, holding (1) the evidence was sufficient to support Defendant's conviction of each of the sixteen counts, as there was sufficient evidence to prove beyond a reasonable doubt that Defendant abused the complainant on four separate and distinct occasions; (2) the trial court did not abuse its discretion in withholding certain portions of the records of the Department of Children and Families relating to the complainant; and (3) the prosecutor did not engage in improper argument during closing argument. View "State v. Stephen J. R." on Justia Law

Petitioner was convicted of murder and related firearms offenses. The appellate court affirmed. Petitioner subsequently filed a petition for postconviction DNA testing, which the lower court denied. The Supreme Court affirmed. Thereafter, Petition filed a second petition for DNA testing. The lower court dismissed the petition on the basis of res judicata. The Supreme Court affirmed on an alternative ground, holding that the petition failed on the merits, as the reasonable probability standard, which requires access to DNA testing only if exculpatory results discovered by DNA testing would undermine confidence in the outcome of the trial, was not met in this case. View "State v. Dupigney" on Justia Law

After a jury trial, Defendant was convicted of operating a motor vehicle while under the influence of intoxicating liquor and operating a motor vehicle while having an elevated blood alcohol content. Defendant appealed, arguing that the trial court erred in admitting certain evidence of his refusal to answer questions from the police. The appellate court affirmed, concluding that Defendant opened the door to evidence of his refusal to answer. The Supreme Court affirmed, holding that the appellate court did not err in determining that defense counsel opened the door to the admission of the evidence at issue. View "State v. Brown" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the fourth degree and related crimes. Defendant appealed, contending that the trial court erred in precluding him from cross-examining the complainant about whether she had lied to the police on an unrelated matter in violation of his right to examine a witness' character for untruthfulness, his right to confrontation, and his right to present a defense. The trial court affirmed. The Supreme Court affirmed, holding that the appellate court properly determined the trial court reasonably concluded that inquiry into the collateral matter should not be permitted. View "State v. Annulli" on Justia Law

After a jury trial, Petitioner was convicted of murder and other offenses in connection with a shooting that left one man dead and two others seriously wounded. At trial, one of the victims testified falsely regarding the consideration he expected to receive in exchange for his testimony. Petitioner filed a petition for writ of habeas corpus, claiming that the State had deprived him of a fair trial by failing to correct the false testimony. The habeas court denied relief, concluding that Petitioner failed to demonstrate materiality. The appellate court reversed, finding that Petitioner was entitled to a new trial where there was a reasonable likelihood that the victim's testimony could have affected the jury's judgment. The Supreme Court affirmed, holding that the victim's perjurious testimony was significant enough that the State's failure to correct it warranted relief under the strict materiality standard applicable in this case. View "Adams v. Comm'r of Corr." on Justia Law

After a jury trial, Defendant was convicted of one count of criminally negligent homicide, two counts of cruelty to persons, and two counts of risk of injury to a child. The convictions arose from Defendant's restriction of fluids to a two-year-old child in order to correct certain behavioral problems. The child died of dehydration. Due to her low IQ, Defendant did not know that withholding liquids could cause the child to die, but Defendant did understand that depriving someone of fluids could cause dehydration. The appellate court affirmed the convictions. The Supreme Court affirmed, holding that the appellate court properly determined that the State presented sufficient evidence Defendant had the required mental state in order to convict her of the offenses. View "State v. Patterson" on Justia Law

After a jury trial, Defendant was convicted of, inter alia, promoting a minor in an obscene performance, risk of injury to a child, and possession of child pornography in the third degree. Defendant appealed, contending that the trial court erred in denying his motion to suppress evidence obtained from his Gmail account through the execution of a search warrant. Specifically, Defendant argued that the warrant was an extraterritorial search warrant for his Gmail account contained on Google's servers located in California. The Supreme Court affirmed without reaching the merits of Defendant's argument, holding that any impropriety in the issuance and execution of the warrant was, beyond a reasonable doubt, harmless error that did not affect the verdict. View "State v. Esarey" on Justia Law