Justia Criminal Law Opinion Summaries

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

In early September 2023, Niya Ross left her dog, Cinnamon, in her car for over an hour on a hot day. The car was parked in the shade with the windows slightly open. A passerby, Zachary Vasile, heard the dog barking and called emergency services. Responders, including firefighters and an animal control officer, arrived and released the dog from the car. The dog showed no signs of distress according to the animal control officer. Ross was later arrested and charged with animal cruelty.The Superior Court of the District of Columbia found Ross guilty of animal cruelty after a bench trial. The court concluded that Ross knew the potential harm of leaving the dog in the car due to the open windows and the hot weather. The court also noted that expert testimony was not necessary to determine that leaving a dog in a hot car for over an hour constituted a failure to provide proper protection from the weather.The District of Columbia Court of Appeals reviewed the case and reversed the conviction. The court held that the evidence was insufficient to prove beyond a reasonable doubt that the dog suffered or would have suffered due to the conditions in the car. The court noted the lack of evidence regarding the actual temperature inside the car and the absence of symptoms of heat-related distress in the dog. The court emphasized that common knowledge and inferences could not substitute for concrete evidence in proving the elements of the crime. The court remanded the case with instructions to enter a judgment of acquittal. View "Ross v. United States" on Justia Law

The case involves William Donnette Sanders, who was convicted of multiple possessory offenses related to drugs, a gun, and other paraphernalia found in his car. The police discovered these items during a search of Sanders' person and vehicle after executing a search warrant at an apartment. Sanders was present at the apartment and was detained and questioned by the police, during which he made statements about his car. Sanders challenged the admissibility of these statements, arguing they were obtained in violation of his Miranda rights. He also filed a post-conviction motion alleging ineffective assistance of counsel for failing to file a motion to suppress evidence obtained from the search of his person.The Superior Court of the District of Columbia denied Sanders' motion to suppress his statements, concluding there were no Miranda violations. The court also denied his Section 23-110 motion, finding that his trial counsel was not deficient and that the search was lawful. Sanders was convicted by a jury on all counts and sentenced to seventy-two months of imprisonment with five years of supervised release.The District of Columbia Court of Appeals reviewed the case and determined that Sanders was in custody for Miranda purposes when he made statements to the police without receiving Miranda warnings. However, the court found that the error in admitting these statements was harmless because there was no reasonable possibility that the statements contributed to Sanders' conviction, given the strong evidence connecting him to the contraband.The court also affirmed the denial of Sanders' Section 23-110 motion, concluding that a motion to suppress the key fob and $1,000 would have been unsuccessful and that Sanders was not prejudiced by his trial counsel's performance. The court found sufficient evidence to support Sanders' convictions for constructive possession, noting his ownership of the car, proximity to the contraband, and the presence of his personal belongings interspersed with the contraband.The District of Columbia Court of Appeals affirmed Sanders' convictions and the trial court's denial of his Section 23-110 motion. View "Sanders v. United States" on Justia Law

In this case, the appellant, Mr. McClam, was charged with first-degree premeditated murder while armed and two counts of assault with intent to kill while armed (AWIKWA) following two shootings that occurred within seconds of each other. The first shooting involved Mr. McClam firing at a car as it drove away, and the second shooting occurred shortly after when the car circled back. One of the bullets from these shootings killed an eleven-year-old boy, K.B., who was in the car.At trial, the United States presented the case to the jury on the theory that the fatal shot was fired during the first shooting, while the shots giving rise to the AWIKWA charges were fired during the second shooting. The jury found Mr. McClam not guilty of first-degree premeditated murder and could not reach a unanimous verdict on the lesser-included homicide charges and the AWIKWA charges. Before the retrial, Mr. McClam moved to bar the United States from proceeding on the theories that the shots giving rise to the AWIKWA charges were fired during the first shooting and that the fatal shots were fired during the second shooting. The trial court denied this motion.The District of Columbia Court of Appeals reviewed the case and reversed the trial court's decision. The appellate court held that the Double Jeopardy Clause precludes the United States from arguing at retrial that the fatal shot was fired during the second shooting, as the United States had elected to proceed at the first trial solely on the theory that the fatal shot was fired during the first shooting. The court also accepted the United States' concession that the Double Jeopardy Clause precludes arguing that the shots giving rise to the AWIKWA charges were fired during the first shooting. The case was remanded for further proceedings consistent with this opinion. View "McClam v. United States" on Justia Law

Rodney Hill Alleyne was involved in a road rage incident where, after a car crash caused by his aggressive driving, he pulled the other driver, Henry Steven Romero-Guardado, out of his car and took his wallet. Alleyne then left the scene without returning the wallet. He was convicted of robbery under D.C. Code § 22-2801.In the Superior Court of the District of Columbia, Alleyne was found guilty of robbery. He argued on appeal that the trial court erred by not instructing the jury that he must have intended to permanently deprive Romero-Guardado of his wallet and that such intent must have existed at the moment he took the wallet. He also contended that the government provided insufficient evidence of his intent to steal the wallet.The District of Columbia Court of Appeals reviewed the case. The court held that the evidence was sufficient for the jury to find that Alleyne intended to return the wallet only upon the satisfaction of a condition, which satisfies the intent element for robbery. The court also found that the trial court's instructions sufficiently informed the jury of the concurrence requirement, meaning Alleyne did not suffer harm to his substantial rights. Additionally, the court concluded that any error in the trial court’s instructions regarding the duration of the intent to deprive did not affect Alleyne’s substantial rights.The District of Columbia Court of Appeals affirmed Alleyne’s conviction for robbery. View "Alleyne v. United States" on Justia Law

Sylvester Toyer was arrested by Metropolitan Police Department officers after a Washington Area Law Enforcement System (WALES) check revealed an outstanding warrant for his arrest. During a search incident to his arrest, officers found $1,500 in cash and fourteen baggies of crack cocaine on him. Toyer was subsequently charged and convicted of possession with intent to distribute cocaine. He appealed the conviction, challenging the denial of his motion to suppress the evidence, the admission of his bank records, and the sufficiency of the evidence supporting his conviction.The Superior Court of the District of Columbia denied Toyer's motion to suppress the cash and drugs, ruling that the WALES check was lawful and the subsequent search incident to arrest was valid. The court also admitted bank records showing Toyer's monthly social security deposits and withdrawals, which the government argued were relevant to his financial status and potential drug dealing activities. Toyer contended that the records were irrelevant and prejudicial, but the court allowed their admission, finding them probative.The District of Columbia Court of Appeals reviewed the case and upheld the lower court's decisions. The appellate court found that the WALES check did not require reasonable suspicion or probable cause and that the arrest warrant provided sufficient grounds for the search. The court also determined that the bank records were relevant and not unfairly prejudicial, as they provided context for Toyer's financial situation. Finally, the court concluded that the evidence presented at trial, including expert testimony on drug distribution, was sufficient for a reasonable jury to find Toyer guilty beyond a reasonable doubt of possession with intent to distribute cocaine.The Court of Appeals affirmed Toyer's conviction, holding that the trial court did not err in its rulings and that the evidence supported the jury's verdict. View "Toyer v. United States" on Justia Law