Justia Criminal Law Opinion Summaries

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

Police officers observed three men in a public park known for PCP use and sales. As officers approached, Devon Greenfield walked away, prompting the officers to follow him. They detected a strong smell of PCP, which intensified as they neared Greenfield. When questioned, Greenfield admitted to drinking beer and allowed officers to look inside his backpack, revealing alcohol. The officers then arrested Greenfield and found three vials of liquid PCP in a small zippered case within his bag.Greenfield was charged with possession of an open container of alcohol (POCA) and attempted possession of PCP. He moved to suppress the evidence, arguing the searches were illegal. The Superior Court of the District of Columbia denied the motion, finding the officers had reasonable suspicion to stop Greenfield and that he consented to the initial search. After a bench trial, Greenfield was convicted on both charges.On appeal to the District of Columbia Court of Appeals, Greenfield argued that the trial court erred in denying his motion to suppress, that there was insufficient evidence to prove his intent to possess PCP, and that the trial court improperly allowed the government to introduce the vials as rebuttal evidence. The Court of Appeals held that the officers had probable cause to arrest Greenfield for POCA based on his admission of drinking beer in the park, which justified the search of his bag incident to arrest. The court also found sufficient evidence to support Greenfield's conviction for attempted possession of PCP, given the distinctive smell and packaging of the vials. Lastly, the court ruled that the trial court did not abuse its discretion in admitting the vials as evidence, even if it was technically a reopening of the government's case rather than rebuttal. The Court of Appeals affirmed Greenfield's convictions. View "Greenfield v. United States" on Justia Law

In 1997, a sixteen-year-old, referred to as John Doe, fatally shot his ex-girlfriend and her male companion. He was convicted of first-degree murder while armed, second-degree murder while armed, and two counts of possession of a firearm during a crime of violence. He was sentenced to an aggregate term of seventy-five years to life, later corrected to fifty-five years to life. In 2023, Doe filed a motion under the Incarceration Reduction Amendment Act (IRAA) seeking immediate release. The government did not oppose the motion. The trial court found Doe not dangerous and deserving of a sentence reduction but denied immediate release, reducing his sentence by twenty-two years, making him eligible for release in eighteen months.The Superior Court of the District of Columbia held hearings on Doe’s IRAA motion, during which it heard from the parties and the victims' family members. The court found that Doe had met the burden for IRAA relief, determining he was no longer a danger and that the interests of justice warranted a sentence reduction. However, the court proceeded to a "second step" of resentencing, applying an unrelated statute and considering the seriousness of Doe’s offenses, ultimately reducing his sentence but not granting immediate release.The District of Columbia Court of Appeals reviewed the case. The court held that the trial court erred by applying an unrelated statute and considering the seriousness of the offenses as a standalone factor. The IRAA requires the court to consider specific enumerated factors and does not permit a separate resentencing analysis. Despite these errors, the appellate court affirmed the trial court’s order, concluding that the errors did not cause substantial prejudice to Doe and were therefore harmless. View "Doe v. United States" on Justia Law

Clifton A. Browne was involved in a physical altercation with Luther Brooks in the basement unit of a house owned by Valerie Mann. The altercation began after Browne, who was helping Mann with repairs, confronted Brooks about vacating the unit. During the fight, Browne repeatedly punched Brooks, who later fell and hit his head on concrete. Brooks was taken to the hospital, never regained consciousness, and died from multiple blunt force injuries. Browne was charged with second-degree murder.The Superior Court of the District of Columbia ruled that Browne's prior convictions in Maryland for second-degree assault could be used to impeach his credibility if he testified. Browne objected but chose not to testify. The jury found him not guilty of second-degree murder but guilty of voluntary manslaughter.The District of Columbia Court of Appeals reviewed the case. Browne argued that his Maryland convictions should not be used for impeachment because Maryland law does not allow such use for second-degree assault, and the offense is equivalent to simple assault in D.C., which is not impeachable. The court held that under D.C. Code § 14-305(b)(1), the plain language of the statute allows for impeachment with convictions punishable by more than one year of imprisonment, regardless of the jurisdiction's specific rules on impeachment.The court affirmed the Superior Court's ruling, stating that the statute's bright-line rule was intended by Congress to avoid the discretionary approach and that the predictable consequences of this rule do not constitute absurdities. Therefore, Browne's conviction for voluntary manslaughter was affirmed. View "Browne v. United States" on Justia Law

T.B., a juvenile, was adjudged delinquent by the Superior Court of the District of Columbia for carrying a pistol without a license and possessing unregistered ammunition. The case arose from two Instagram live videos observed by Officer Moore of the Metropolitan Police Department. In the first video, T.B. was seen displaying a black Glock-style handgun. In the second video, T.B. was seen with a light-colored object in his waistband, which officers believed to be a firearm. When officers arrived at the scene, they found a tan-gold-colored pistol on the ground near where T.B. had been standing.The Superior Court incorporated Officer Moore’s testimony from a suppression hearing into the trial. Officer Moore testified about the events leading to T.B.'s arrest and the officers' observations from the Instagram videos. Officer Laielli also testified, describing T.B.'s behavior in the second video as characteristic of an armed gunman. The court found the evidence sufficient to prove beyond a reasonable doubt that T.B. possessed the tan-gold-colored pistol and committed him to the Department of Youth Rehabilitation Services for up to one year.On appeal, T.B. argued that the evidence was insufficient to support the court’s findings and that the trial court erred in admitting the officers’ testimony. The District of Columbia Court of Appeals reviewed the case and found that the evidence, including the Instagram videos and the officers’ observations, was sufficient to support the trial court’s findings. The appellate court also concluded that any error in admitting the officers’ testimony was harmless, as the trial court’s findings were based on its own viewing of the video evidence. The Court of Appeals affirmed the judgment of delinquency. View "In re T.B." on Justia Law