Justia Criminal Law Opinion Summaries

Mark Stubblefield was charged with multiple offenses related to two separate bank robberies in October and November 2022. He was tried for the October robbery, where he was accused of armed robbery and making threats. The jury found him guilty of both charges. Subsequently, Stubblefield pled guilty to a robbery charge related to the November incident.In the Superior Court of the District of Columbia, Stubblefield was convicted of armed robbery and threats for the October robbery. He later entered a guilty plea for the November robbery. The plea agreement included a waiver of his right to appeal the convictions, but it was ambiguous whether this waiver applied to the October convictions. The trial court sentenced him to concurrent terms of imprisonment for the October and November offenses and informed him of his right to appeal the jury trial convictions.The District of Columbia Court of Appeals reviewed the case. The court concluded that the plea agreement was ambiguous regarding the waiver of appellate rights for the October convictions and allowed the appeal to proceed. On the merits, the court found that the evidence was insufficient to support the armed robbery conviction. The government failed to prove that Stubblefield was actually armed with a bomb or that the bank tellers subjectively believed he had a bomb. The court reversed the armed robbery conviction and remanded for entry of a lesser included robbery conviction. The rest of Stubblefield's convictions were affirmed. View "Stubblefield v. United States" on Justia Law

Derek J. Morris was convicted of unlawful entry after refusing to leave the United States Supreme Court Clerk’s Office while attempting to file a pro se petition for a writ of certiorari. The Supreme Court has specific procedures for in-person filings, requiring documents to be delivered to the Supreme Court Police for security screening. Morris had previously been informed of these procedures but insisted on filing directly at the Clerk’s Office, leading to his arrest after multiple refusals to leave.The Superior Court of the District of Columbia instructed the jury using the model instruction for unlawful entry on public premises. Morris proposed an additional element to the instruction to clarify the need for an independent justification for the order to leave, but he later withdrew this request, agreeing that the existing instruction sufficed. The jury found Morris guilty based on the given instructions.The District of Columbia Court of Appeals reviewed the case, focusing on whether the jury instruction adequately conveyed the requirement for an independent justification for the order to leave public property. The court held that the model instruction failed to clearly explain this requirement, constituting an error. However, the court determined that this error did not affect Morris’s substantial rights, as the parties’ arguments had sufficiently highlighted the need for an independent justification, and the evidence overwhelmingly supported the government’s case. Consequently, the court affirmed Morris’s conviction. View "Morris v. United States" on Justia Law

Rubin Delphonso Holman was convicted of robbery, assault with intent to rob (AWIR), and simple assault. The incident occurred on a Metro train where Holman and his friend, Mr. Black, engaged in inappropriate behavior towards Domini Dotson. After Dotson moved to another train car and reported the incident, Holman followed her, threatened her, and attempted to take her phone. When Dotson resisted, Holman assaulted her, and during the altercation, he took her phone. Holman later threw the phone onto the Metro tracks when approached by police.The Superior Court of the District of Columbia convicted Holman of the charges. Holman appealed, arguing that his convictions for simple assault and AWIR should merge with his robbery conviction under the Double Jeopardy Clause. He also contended that there was insufficient evidence to support his robbery conviction.The District of Columbia Court of Appeals reviewed the case. The court agreed with Holman that his convictions for simple assault and AWIR should merge with his robbery conviction, as robbery requires proof of assault, and thus, the lesser offenses are included within the greater offense of robbery. The court also found that there was sufficient evidence to support Holman’s robbery conviction, as a reasonable jury could infer that Holman intended to permanently deprive Dotson of her phone.The Court of Appeals reversed Holman’s convictions for simple assault and AWIR, affirmed his robbery conviction, and remanded the case for entry of a new judgment and commitment order reflecting only the robbery conviction. The court noted that resentencing was unnecessary as the trial court had imposed concurrent sentences. View "Holman v. United States" on Justia Law

Darrell Jones was charged with assault with intent to kill (AWIK) while armed and related counts after repeatedly stabbing his friend, Wayne Pitt. Jones claimed self-defense and argued that his extreme intoxication, from consuming alcohol, marijuana, and PCP, precluded him from forming the specific intent to kill. The trial court precluded Jones from introducing evidence of his PCP use without expert testimony on the drug’s effects. Jones was convicted on all counts and appealed, arguing that the trial court erred in excluding the PCP evidence.The Superior Court of the District of Columbia precluded Jones from presenting evidence of his PCP use, interpreting the case Jackson v. United States to mean that evidence of PCP use requires expert testimony. Jones argued that Jackson was inapplicable because it involved PCP use many hours before the incident, whereas he and Pitt used PCP shortly before the stabbing. The trial court denied Jones’s request to reconsider its ruling, and Jones was convicted by a jury.The District of Columbia Court of Appeals reviewed the case and found that the trial court erred in precluding evidence of Jones’s PCP use. The court held that the evidence was highly relevant to Jones’s intoxication defense and that there was no overriding unfair prejudice to the government. The court clarified that Jackson did not establish a categorical rule requiring expert testimony for PCP use evidence. The court vacated Jones’s AWIK while armed conviction but affirmed his other convictions for aggravated assault and carrying a dangerous weapon. The case was remanded for further proceedings consistent with the opinion. View "Jones v. United States" on Justia Law

A woman from North Carolina was found raped and murdered in a Washington, D.C. apartment in March 2017. The victim’s body was discovered bound and stabbed, with evidence of sexual assault. Surveillance footage and ATM records showed her car and credit cards being used in the days following her death. The investigation led to the arrest of El Hadji A. Toure, whose DNA was found at the crime scene and on items used to bind the victim. Video evidence placed Toure near the victim’s apartment shortly before the crime, and he was later seen using her credit and debit cards, always entering the correct PIN. After the murder, Toure’s financial situation improved markedly, as he paid cash for a hotel stay and a car.A jury in the Superior Court of the District of Columbia convicted Toure of multiple offenses, including first-degree murder, sexual abuse, kidnapping, and related charges. He was sentenced to life without release. While his appeal was pending, Toure moved for a new trial, arguing that the government failed to timely disclose disciplinary records (QCARs) for forensic witnesses, in violation of Brady v. Maryland. The Superior Court denied the motion, finding that, even assuming suppression of favorable evidence, there was no reasonable probability the outcome would have been different given the strength of the other evidence.The District of Columbia Court of Appeals reviewed both the convictions and the denial of a new trial. The court held that, although the government failed to timely disclose impeachment evidence, the suppressed material was not material under Brady because the remaining evidence against Toure was overwhelming. The court also found that the prosecutor’s conduct in eliciting certain testimony violated Toure’s confrontation and due process rights, but concluded that any error was harmless beyond a reasonable doubt. The convictions and denial of a new trial were affirmed, with a remand for merger and resentencing as necessary. View "Toure v. United States" on Justia Law

The appellant, Michael J. Patschak, was convicted of robbery following an altercation with Officer Davon Todd during a protest. Officer Todd testified that Patschak initiated the altercation by shoving him, causing him to fall, and then twisted and removed Todd's body-worn camera (BWC) from his vest. Patschak then picked up the BWC and placed it in his backpack. Patschak testified that Todd ran into him, causing him to fall, and that he only briefly touched the BWC, which was already twisted. He admitted to picking up the BWC and placing it in his backpack shortly after the altercation.The Superior Court of the District of Columbia found Patschak guilty of robbery. Patschak appealed, arguing that the evidence was insufficient to support the conviction and that the trial court's responses to two juror notes were inadequate. The trial court had instructed the jury that the act of taking the property must be accompanied by the intent to steal, and later clarified that the intent to steal must exist at the time of the taking.The District of Columbia Court of Appeals reviewed the case. The court held that the evidence was sufficient to support the conviction, as a rational juror could find that Patschak's actions constituted a sudden or stealthy seizure or snatching of the BWC from Officer Todd's immediate actual possession. The court also found that the trial court's responses to the juror notes, while not perfect, did not constitute plain error. The court concluded that the trial court's instructions, taken as a whole, adequately addressed the jury's questions.The District of Columbia Court of Appeals affirmed the judgment of the Superior Court, upholding Patschak's conviction for robbery. View "Patschak v. United States" on Justia Law

In 2008, a cab driver committed a series of violent attacks against four other cab drivers in the District of Columbia. The attacks included puncturing tires, brandishing a knife, ramming vehicles, and attempting to run over victims. The perpetrator was arrested in March 2009 and found guilty by a jury in June 2011 on thirteen counts, including assault with a deadly weapon, aggravated assault while armed, and destruction of property.The Superior Court of the District of Columbia sentenced the defendant to an aggregate of 290 months of imprisonment and imposed a total of $1,000 in assessments under the Victims of Violent Crime Compensation Act (VVCCA). The defendant appealed, challenging the trial court's decisions on various grounds. The District of Columbia Court of Appeals addressed these issues, resulting in a remand for resentencing on certain counts. The trial court subsequently resentenced the defendant, but the total term of imprisonment remained unchanged.The defendant then filed a pro se motion in January 2022, arguing that his convictions should be dismissed. The trial court denied the motion as procedurally barred, and the defendant appealed.The District of Columbia Court of Appeals reviewed the case and held that the VVCCA assessments did not constitute fines. The court reasoned that the assessments were mandatory and separate from the punishment imposed, serving primarily to fund the Crime Victim’s Compensation Program. The court affirmed the trial court's imposition of the VVCCA assessments, concluding that the sentence was legal. View "Tornero v. United States" on Justia Law

Around 2:00 a.m. in February 2023, Officer Clifford Vanterpool of the District of Columbia Metropolitan Police Department responded to a dispatch call about a suspicious vehicle. Upon arrival at a residential parking lot, he saw two individuals flee from a parked car, leaving its rear door open. The car then began to back out of its spot. Officer Vanterpool blocked the car's exit, exited his vehicle, drew his weapon, and ordered the driver, R.W., to put his hands up. R.W. was subsequently arrested based on evidence obtained after this encounter.R.W. moved to suppress all evidence obtained after Officer Vanterpool's command, arguing that the officer lacked reasonable articulable suspicion to seize him. The Superior Court of the District of Columbia denied the motion, citing the dispatch call, the flight of the two individuals, the late hour, and R.W.'s movement of the car with the door open as justifications for the seizure. R.W. was convicted of multiple offenses and appealed the denial of his motion to suppress.The District of Columbia Court of Appeals reviewed the case and found that the trial court made two legal errors. First, it improperly considered the radio dispatch without information about its source and reliability. Second, it wrongly imputed the flight of R.W.'s companions to him without evidence suggesting a suspicious joint venture. The appellate court concluded that the remaining factors—the late hour and the slight movement of the car—did not provide reasonable articulable suspicion of criminal activity.The Court of Appeals held that the exclusion of all evidence obtained after the unlawful seizure was warranted. Consequently, it vacated R.W.'s convictions and remanded the case for further proceedings. View "In re R.W." on Justia Law

Desean Hattix was convicted of attempted failure to register a firearm after police executed a search warrant at his home and found two unregistered handguns. Following his conviction, the District of Columbia Housing Authority (DCHA) sought to evict him from his federally subsidized housing unit, alleging that his possession of an unregistered firearm violated the federal "one-strike" provision in his lease, which prohibits tenants from engaging in criminal activity that threatens the health, safety, or peaceful enjoyment of the property. The trial court found that Mr. Hattix's unlawful possession of a firearm violated this provision and issued a nonredeemable judgment against him.The magistrate judge found that Mr. Hattix's possession of an unregistered firearm threatened the safety of other residents and issued a nonredeemable judgment against him. An associate judge of the Superior Court upheld this decision, finding that Mr. Hattix's gun possession posed both a per se and an individualized threat to the health and safety of other residents. The reviewing judge noted that the District's registration requirements were designed to ensure firearms were not in the hands of dangerous and untrained individuals, and by ignoring this law, Mr. Hattix placed the public at risk.The District of Columbia Court of Appeals reviewed the case and disagreed with the lower courts. The court held that possession of an unregistered firearm does not constitute a per se threat to residents' health, safety, or right to peaceful enjoyment of the property. The court also found that DCHA did not present sufficient evidence that Mr. Hattix's conduct posed an individualized threat to residents' health, safety, or right to peaceful enjoyment of the property. Consequently, the judgment of the Superior Court was reversed, and the case was remanded for further proceedings consistent with this opinion. View "Hattix v. District of Columbia Housing Authority" on Justia Law

In the early morning of November 8, 2015, Charmagne Eccles was robbed at gunpoint by two men near the intersection of 55th Street and Eastern Avenue in Northeast D.C. The assailants stole two iPhones and, after a struggle, Eccles managed to gain possession of the shotgun used in the robbery. The robbers fled but returned with a third man, demanding the shotgun back. Eccles flagged down a police vehicle, and the three men fled. Police used an iPhone tracking application to locate Maurice Ricks, who was found with the stolen phones. A perimeter was established, and a K-9 unit found DeAngelo Parker and Delonta Rollerson hiding in a backyard within the perimeter. Eccles identified Parker and Rollerson in a show-up identification.In the Superior Court of the District of Columbia, Parker, Rollerson, and Ricks were charged with armed robbery and related gun possession charges. Ricks was also charged with assault with intent to kill (AWIK). The defendants filed motions to suppress evidence from the stops and identifications, arguing lack of reasonable suspicion and suggestive identification procedures. The trial court denied these motions, finding reasonable suspicion for the stops and reliability in the identifications. Motions to sever the trials were also denied, as the court found no manifest prejudice from a joint trial. During the trial, the court managed witness testimony and jury questions, including a note about the AWIK charge against Ricks, which the court addressed without granting a mistrial.The District of Columbia Court of Appeals reviewed the case and affirmed the trial court's decisions. The court held that the police had reasonable suspicion to stop Parker and Rollerson based on the totality of the circumstances, including their suspicious behavior and the timing and location of the stop. The court also found that the show-up identifications were not unduly suggestive and were reliable. The denial of severance was upheld, as the defendants did not show manifest prejudice. The court also ruled that the trial court did not abuse its discretion in managing witness testimony and responding to the jury's note. View "Parker & Rollerson v. United States" on Justia Law