Justia Criminal Law Opinion Summaries

The appellant was convicted of two counts of simple assault and one count of attempted possession of a prohibited weapon. The incidents involved an altercation with his girlfriend, Ms. Williams, and her daughter, M.W. Ms. Williams testified that the appellant slapped her at a Metro station, and later, after an argument, he kicked in her apartment door, punched her, and hit M.W. with a belt. Ms. Williams also claimed the appellant had a gun, which he used to hit her. The police arrived shortly after the incident, and body-worn camera footage captured Ms. Williams's statements and visible injuries.The Superior Court of the District of Columbia found the appellant guilty of both counts of simple assault and attempted possession of a prohibited weapon. The court credited Ms. Williams's testimony and found the video evidence, particularly Exhibit 7, significant in showing the appellant holding his belt while running out of the building. The court did not credit the appellant's testimony and found the injuries on Ms. Williams consistent with being hit rather than a fall.The District of Columbia Court of Appeals reviewed the case. The court accepted the United States' concession that the evidence was insufficient to support the conviction for attempted possession of a prohibited weapon and reversed that conviction. The court found the evidence sufficient to support the assault convictions but held that the trial court erred in admitting Exhibit 7, which was harmful error regarding the conviction for assaulting M.W. Consequently, the court vacated that conviction and remanded the case for further proceedings. The court affirmed the conviction for assaulting Ms. Williams, finding any error in admitting the video exhibits harmless concerning that conviction. View "Ransom v. United States" on Justia Law

In 2002, the appellant was convicted of armed robbery and assault with a dangerous weapon. He later filed two motions for post-conviction relief under D.C. Code § 23-110. The first motion, filed in 2017, claimed ineffective assistance of trial counsel and alleged that he was beaten by U.S. Marshals during his trial, rendering him unable to participate meaningfully in his defense. He attached an affidavit and medical records to support his claims. The second motion, filed pro se, argued ineffective assistance of post-conviction counsel during a 2016 sentence reduction hearing.The Superior Court of the District of Columbia denied the first § 23-110 motion after an evidentiary hearing. The court found that the appellant's absence from the hearing meant his affidavit was inadmissible hearsay and that the medical records did not sufficiently demonstrate that he was unable to participate in his trial. The court concluded there was no evidence, aside from the inadmissible affidavit, to support the claim that the appellant was too emotionally or physically impaired to assist in his defense.The appellant's second § 23-110 motion was also denied by the Superior Court. The court found that the appellant had not demonstrated prejudice from his post-conviction counsel's performance during the Rule 35 sentence reduction hearing. The appellant appealed both denials.The District of Columbia Court of Appeals reviewed the case. It affirmed the denial of the first § 23-110 motion, agreeing with the lower court that the appellant's affidavit was inadmissible and that the medical records did not prove his inability to participate in his trial. The court dismissed the appeal of the second § 23-110 motion as moot because the appellant had already completed his term of imprisonment, and his term of supervised release was statutorily unalterable. View "Thompson v. United States" on Justia Law