Justia Criminal Law Opinion Summaries

D.W. was convicted of several firearm offenses and appealed his convictions, arguing that the trial court erroneously denied his motion to suppress evidence. The incident occurred when officers from the Metropolitan Police Department Crime Suppression Team (CST) were patrolling the Geraldine Apartment Complex, known for high crime. D.W. fled upon seeing the officers, leading to a chase during which he discarded a firearm. The trial court denied the motion to suppress, crediting the officers' testimony about the high-crime nature of the area and concluding that D.W.'s flight provided reasonable suspicion for the stop.The Superior Court of the District of Columbia found that the officers' testimony about the Geraldine being a high-crime area was credible and sufficient, despite the lack of specific crime statistics. The court also found that D.W.'s immediate and headlong flight upon seeing the officers, without any provocation, indicated consciousness of guilt. Consequently, the court ruled that the officers had reasonable, articulable suspicion to stop D.W. and denied the motion to suppress. D.W. was subsequently found guilty at a stipulated trial.The District of Columbia Court of Appeals reviewed the case, focusing on the general locational crime evidence and D.W.'s flight. The court applied the principles from its en banc decision in Mayo v. United States, which emphasized the need for specific and well-grounded evidence of crime in the area and the context of flight. The court found that the general locational crime evidence in this case was weak and did not provide useful context. Additionally, the court held that unprovoked flight alone, without more, does not justify a stop. Therefore, the court vacated the judgment of the Superior Court and remanded the case for further proceedings. View "D.W. v. United States" on Justia Law

In 2004, Gregory Terrell was convicted by a jury of assault with intent to kill while armed (AWIKWA), aggravated assault while armed (AAWA), and related offenses for the shooting of Darren Marshall. Terrell was sentenced to 27 years in prison. During sentencing, Marshall provided a victim impact statement claiming severe injuries, including impotence. Terrell later discovered that Marshall had fathered another child and was convicted of rape, suggesting that Marshall's statement was false.Terrell filed multiple post-conviction motions over nine years. His first Rule 35(b) motion to reduce his sentence, based on the alleged falsity of Marshall's statement, was denied. The trial court found that the new information did not warrant a sentence reduction. Terrell's first Section 23-110 motion, which included claims of ineffective assistance of counsel and the false victim impact statement, was also denied. The trial court did not address the victim impact statement claim in its denial. Terrell's second Rule 35(b) motion, citing his rehabilitation and difficult childhood, was denied as procedurally barred and lacking substantive merit.In 2022, Terrell filed a second Section 23-110 motion, arguing that the trial court's reliance on Marshall's false statement violated his due process rights. The trial court denied the motion, ruling it was procedurally barred and successive, as it raised the same claim as his first Rule 35(b) motion.The District of Columbia Court of Appeals affirmed the trial court's decision, holding that Terrell's second Section 23-110 motion was successive. The court adopted the rule from Sanders v. United States, which allows a motion to be deemed successive if it asserts an identical ground for relief as a previous motion, even if supported by different legal or factual arguments. The court found that Terrell's second motion raised the same ground for relief as his first Rule 35(b) motion, which had been denied on the merits. View "Terrell v. United States" on Justia Law

In 1996, when Riley was sixteen, he and two older teenagers drove around the District of Columbia looking for members of a rival group and ended up shooting and killing two young brothers. A few weeks earlier, Riley and the same teenagers had committed a similar crime in Maryland, resulting in another death. Riley pled guilty to first-degree murder in Maryland and was sentenced to life in prison. In D.C., a jury convicted him of two counts of first-degree murder while armed, assault with intent to kill while armed, and possession of a firearm during a crime of violence. He received sentences totaling seventy years to life, consecutive to his Maryland sentence.Riley's convictions were affirmed on direct appeal. In 2022, he filed a motion under the Incarceration Reduction Amendment Act (IRAA) seeking immediate release, arguing his rehabilitation and readiness to reenter society. The government did not oppose a sentence reduction but suggested a term of twelve years to life. The trial court held an evidentiary hearing and partially granted Riley's motion, reducing his sentence to time served plus three years and three months, relying on factors from the District’s determinate sentencing statute and voluntary sentencing guidelines.The District of Columbia Court of Appeals reviewed the case and found that the trial court erred by relying on non-IRAA statutes and factors, contrary to the recent decision in Doe v. United States. The court held that IRAA’s enumerated factors should exclusively guide the dangerousness and interests of justice inquiries. Consequently, the appellate court vacated the trial court’s decision and remanded for further proceedings consistent with IRAA’s statutory framework and the Doe decision. View "Riley v. United States" on Justia Law

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