Justia Criminal Law Opinion Summaries

On a December evening, a Metropolitan Police Department officer responded to reports of disorderly groups in Southeast Washington, D.C., an area associated with frequent gun-related incidents. The officer observed four men walking and overheard a comment he interpreted as referring to gun violence. He monitored the group and began interacting with them, including Allen Grant, who voluntarily stated he had no guns. Grant carried a satchel, which he moved behind his back when questioned, prompting repeated requests from the officer to see it. Grant denied having anything in the satchel, continued walking, and ultimately threw the satchel over a fence. Another officer found a gun inside the satchel, after which Grant fled and was arrested approximately thirty minutes later.The Superior Court of the District of Columbia presided over the suppression hearing on Grant's motion to exclude evidence from the satchel, arguing an unlawful seizure. The trial court found that Grant had not been seized before discarding the satchel, as he continued walking and ultimately ran, and there was no show of force by officers. The trial court characterized the interaction as an investigatory conversation and denied the motion to suppress. Grant was subsequently convicted by a jury on several firearm-related charges and sentenced to imprisonment and supervised release.The District of Columbia Court of Appeals reviewed the case and affirmed the trial court’s denial of the suppression motion. The Court held that Grant was not seized within the meaning of the Fourth Amendment prior to discarding the satchel, as he did not submit to the officer’s show of authority. The evidence found in the satchel was not the fruit of an illegal seizure. The Court applied a de novo review to legal issues and deferred to factual findings unless clearly erroneous. The order denying suppression was affirmed. View "Grant v. United States" on Justia Law

A violent series of confrontations between residents of two Southeast D.C. neighborhoods resulted in several shootings, including two murders and multiple assaults, during 2016 and 2017. One defendant, a resident of Wahler Place, was implicated in these violent acts and was connected to the crimes through witness identifications, forensic ballistics, cell phone location data, and his possession of the firearm used in the shootings. The second defendant, an employee of the Metropolitan Police Department and longtime acquaintance of the first defendant, used her access to police databases to search for information related to the shootings and communicated with the first defendant after each incident.Following an investigation, both individuals were indicted in the Superior Court of the District of Columbia and faced numerous charges. The first defendant moved to suppress evidence based on alleged Fourth Amendment violations related to the seizure and search of his vehicle and cell phones, but the trial court denied these motions. After an eleven-week jury trial, the first defendant was convicted of multiple counts, including murder, assault with intent to kill, firearm offenses, and obstruction of justice. The second defendant was acquitted of the most serious charges but convicted of being an accessory after the fact (AAF) and obstruction of justice. Both appealed.The District of Columbia Court of Appeals affirmed the first defendant’s convictions for murder, assault, and related firearm offenses, concluding that the evidence was sufficient and that the searches satisfied Fourth Amendment exceptions or were admissible under the good-faith exception. However, the court reversed the second defendant’s AAF convictions, holding that the government failed to prove she had actual knowledge of the principal’s crimes when she provided assistance. The court also vacated all obstruction of justice convictions for both defendants, finding the statute did not apply to the proceedings at issue. The case was remanded for further proceedings consistent with these rulings. View "Jennings & Turner v. United States" on Justia Law

Three individuals, including the appellant, planned to rob a man they believed to be a drug dealer. The appellant drove the group to the meeting site and remained in the car while one co-defendant ultimately shot and killed the victim during the attempted robbery. All three were arrested and charged. One co-defendant cooperated with the government and received probation, while the appellant and the shooter proceeded to trial. The jury found the appellant guilty of first-degree (felony) murder while armed, attempted robbery while armed, and conspiracy. The Superior Court of the District of Columbia sentenced the appellant to an aggregate term of thirty years, with the sentences for conspiracy and attempted robbery running concurrently with the mandatory minimum for the murder conviction.The appellant appealed, arguing that being sentenced for both first-degree (felony) murder and the underlying felony violated the Double Jeopardy Clause. The District of Columbia Court of Appeals affirmed his convictions but remanded for resentencing to address the merger issue. On remand, the Superior Court considered whether it had discretion to vacate either the felony murder conviction or the underlying felony. The court indicated a preference for vacating the murder conviction due to the appellant’s lesser culpability but concluded, based on District of Columbia Court of Appeals precedent, that it was required to vacate the lesser underlying felony and retain the felony murder conviction.Upon renewed appeal, the District of Columbia Court of Appeals held that, when a defendant is convicted of both first-degree (felony) murder and the predicate felony, the trial court does not have discretion to choose which conviction to vacate. Instead, it must vacate the underlying felony and retain the felony murder conviction, unless legislative intent indicates otherwise. The court affirmed the Superior Court’s judgment. View "Hewitt v. United States" on Justia Law

The appellant pled guilty to assault with a dangerous weapon and assault with intent to kill while armed, pursuant to a plea agreement under Rule 11(c)(1)(C) which specified a twelve-year sentence. Before sentencing, the appellant moved to withdraw his guilty plea, arguing that one of his attorneys had incorrectly advised him that the judge could reduce the agreed-upon sentence to eight years. Testimony at the motion hearing established that this inaccurate advice was provided, and the trial court credited the attorney who testified to the miscommunication.Following the guilty plea, the Superior Court of the District of Columbia considered the motion to withdraw. The trial court found that although the appellant did not have competent counsel at all times, he failed to show that he would not have taken the plea but for the incorrect advice. The trial court applied the Strickland v. Washington standard, requiring a reasonable probability that the attorney’s deficient performance caused the plea, and denied the motion to withdraw.The District of Columbia Court of Appeals reviewed the trial court’s decision. The appellate court clarified that, under the standard for presentence withdrawal of guilty pleas, a defendant need not show strict Strickland prejudice, especially when the request is made before sentencing. The appellate court held that the trial court erred by requiring such a showing and by not properly weighing the competency of counsel with other relevant factors such as promptness of withdrawal and assertion of legal innocence. The District of Columbia Court of Appeals vacated the trial court’s ruling and remanded the case for reconsideration, instructing the trial court to reassess whether justice demands the withdrawal of the guilty plea based on the correct legal standard. View "Jackson v. United States" on Justia Law

An individual was convicted following a bench trial for unlawful entry after refusing to leave a convenience store when asked to do so by a Metropolitan Police Department officer at the request of a store clerk. The arrest occurred shortly after the discovery of a deceased person in the store’s back room, which led to the defendant expressing frustration that the store had not been closed to customers. The responding officer testified at trial, recounting that the store clerk asked for assistance in removing the defendant, and body-worn camera footage corroborated the clerk’s request and the officer’s repeated instructions for the defendant to leave.The case was originally tried in the Superior Court of the District of Columbia. The defense moved for a judgment of acquittal, arguing that the government failed to prove that a person with authority asked the defendant to leave, that it relied on inadmissible hearsay, and that the defendant did not refuse to leave the premises. The trial court credited the testimony of the police officer and found the defendant guilty of unlawful entry.On appeal, the District of Columbia Court of Appeals reviewed the conviction. The appellant argued that the clerk’s statement was inadmissible hearsay, that the government failed to show lawful authority to request his removal, and that there was insufficient evidence of refusal to leave. The Court of Appeals held that the clerk’s statement was properly admitted as nonhearsay because it was introduced to show its effect on the officer and to explain the officer's actions, not to prove the truth of the matter asserted. The court also found sufficient evidence that the clerk had lawful authority over the premises and that the defendant refused to leave after being repeatedly instructed. The conviction was affirmed. View "Hinton v. United States" on Justia Law

After a woman sold drugs to an undercover officer and left in a car driven by the defendant, police arrested the defendant and recovered nearly $700—including prerecorded bills from the drug purchase—and a bag containing thirty-three grams of a white, powder-like substance from his person. Police also found a firearm, a scale, and additional currency in the car. The defendant was indicted on multiple drug and gun charges, including possession with intent to distribute (PWID) cocaine while armed and unlawful possession of a firearm by a felon (FIP). Before trial, the government dismissed several charges, dropped the while armed enhancement, and elected to proceed on attempted PWID cocaine as a lesser included offense. The defense did not object to these changes.During trial in the Superior Court of the District of Columbia, two officers testified that the bag contained a substance consistent with cocaine, but the court sustained defense objections to testimony that the substance was definitively cocaine, as no testing evidence was presented. After the government stated it was resting its case, the defense moved for judgment of acquittal, arguing insufficient proof regarding both the controlled substance and the firearm charge. The trial court permitted the government to reopen its case to admit a stipulation—previously agreed to by the parties—that the defendant had a prior felony conviction and knew of it, curing a deficiency on the FIP charge. The court denied the acquittal motion, finding the evidence sufficient.On appeal, the District of Columbia Court of Appeals held that the trial court did not abuse its discretion in allowing the government to reopen its case to admit the stipulation. The appellate court affirmed the FIP conviction. Regarding the attempted PWID charge, the court concluded that, because the jury convicted the defendant of attempted PWID of an unspecified controlled substance (rather than cocaine specifically), the felony conviction and sentence for attempted PWID cocaine was improper. The appellate court vacated the felony conviction and remanded for entry of a misdemeanor conviction and resentencing. View "Pritchett v United States" on Justia Law

In this case, the appellant and her son were charged in connection with an assault and shooting that took place in the stairwell of an apartment building in Southeast Washington, D.C. The incident followed a dispute earlier in the evening between the appellant and the victim, Shawn Watts. After being told to leave the apartment, the appellant returned with her son, who was armed. Together, they assaulted Mr. Watts, with the son ultimately shooting him in the leg. The appellant was tried separately from her son and faced several charges, including conspiracy to commit assault with a dangerous weapon, aggravated assault while armed, and possession of a firearm during a crime of violence (PFCV).The Superior Court of the District of Columbia presided over the jury trial. The jury convicted the appellant of conspiracy to commit assault with a dangerous weapon, aggravated assault while armed (including a “while armed” sentencing enhancement), and PFCV, but acquitted her on other counts. She was sentenced to seventy-two months of imprisonment, followed by supervised release. On appeal, she challenged the sufficiency of the evidence for the PFCV conviction and the “while armed” enhancement, and she also raised issues regarding the trial court’s handling of witness testimony and jury instructions.The District of Columbia Court of Appeals reviewed the case. The court concluded that there was insufficient evidence to sustain the appellant’s conviction for PFCV under an aiding-and-abetting theory, as there was no evidence that the victim posed a threat of disarming the gunman, or that the appellant’s actions were undertaken with the requisite guilty knowledge. However, the court found sufficient evidence for the “while armed” enhancement to the aggravated assault conviction, as the appellant knew about the gun and continued to participate in the assault. The court affirmed the convictions for conspiracy and aggravated assault with the enhancement, but reversed the PFCV conviction. View "Chandler v. United States" on Justia Law

A Black man was charged with two counts of first-degree sexual abuse and one count of attempted robbery after allegedly assaulting a white woman. During jury selection, the government used its peremptory strikes to remove all six nonwhite prospective jurors—four Black, one Asian, and one Hispanic—from a venire of thirty-six, resulting in an all-white jury. The defense objected, arguing that the prosecutor’s actions were racially discriminatory and violated the precedent established in Batson v. Kentucky. The government provided purportedly race-neutral reasons for the strikes of the Black jurors, such as concerns about their ability to understand scientific testimony or responses during voir dire. The trial court accepted these explanations, found them credible and race-neutral, and denied the Batson challenge.A jury in the Superior Court of the District of Columbia acquitted the defendant of attempted robbery but convicted him on both sexual abuse counts. On appeal, a division of the District of Columbia Court of Appeals affirmed the convictions, concluding that the trial court had adequately scrutinized the government’s justifications for the jury strikes. The defendant sought en banc review, and the division’s decision was vacated pending review by the full District of Columbia Court of Appeals.The District of Columbia Court of Appeals, sitting en banc, held that the trial court’s Batson analysis was insufficient because it failed to rigorously scrutinize the prosecutor’s explanations in the context of the entire record, including statistical evidence and the racially charged nature of the case. The court found that at least one of the government’s strikes was more likely than not racially discriminatory. Accordingly, it reversed the defendant’s convictions and remanded for a new trial. View "Smith v. United States" on Justia Law

Police officers encountered a man at a playground in a public park while he was with his daughter and partner. The officers were conducting a patrol and had observed a group they suspected of smoking marijuana. The man had walked away from the group to rejoin his family. Five armed, uniformed officers approached and encircled him, with two officers standing within arm's reach and three others positioned nearby. One officer asked if the man had a firearm, and he admitted that he did; officers then frisked him and recovered a gun from his waistband.The Superior Court of the District of Columbia held a hearing on a motion to suppress the firearm. The trial court found that the defendant was not seized until after he admitted to possessing a firearm and officers physically restrained him. The court emphasized the officers’ cordial tone, the brief nature of the encounter, and the public setting, and denied the motion to suppress. The case proceeded to trial, and a jury convicted the defendant of unlawful possession of a firearm, carrying a pistol without a license, and possession of an unregistered firearm.The District of Columbia Court of Appeals reviewed the case. It held that the defendant was seized for Fourth Amendment purposes before he admitted to possessing a firearm—specifically, when five officers encircled and focused exclusively on him, blocking his exits and asking accusatory questions. The court concluded that this seizure was unsupported by reasonable articulable suspicion and thus unlawful. It reversed all convictions, holding that the firearm should have been suppressed as the fruit of the unlawful seizure, and remanded the case for further proceedings. View "Ervin v. United States" on Justia Law

The appellant committed a series of violent crimes in 1982, including first-degree murder, rape, and armed robbery, when he was eighteen years old. He entered into a global plea agreement, receiving a sixty-five years to life sentence. During his forty-three years of incarceration, he took part in a wide range of educational and rehabilitative programs, maintained employment, and generally avoided violent infractions, with only one such infraction in 1999. However, he did receive a disciplinary infraction for “stalking” female prison staff in 2016, which was characterized by repeated grievances and derogatory language rather than physical or sexual misconduct. He was not referred to, nor did he complete, sex offender treatment, though a psychological expert opined this was not necessary for his rehabilitation.After serving the minimum time required, the appellant filed a motion in the Superior Court of the District of Columbia seeking sentence reduction under the Incarceration Reduction Amendment Act (IRAA). At the evidentiary hearing, he presented evidence of his rehabilitation and low risk of recidivism, including a favorable PATTERN score and a psychologist’s report. The trial court denied the motion, finding he failed to prove he was no longer dangerous, placing significant weight on his lack of sex offender treatment and the 2016 infraction, and referencing factors such as the seriousness of his original offenses and deterrence.The District of Columbia Court of Appeals vacated the trial court’s decision and remanded the case. The appellate court held that the trial court abused its discretion by relying on an unsupported assumption that the appellant needed sex offender treatment to demonstrate non-dangerousness, despite expert evidence to the contrary. The appellate court also found error in the trial court’s interests of justice analysis by relying on factors outside those enumerated in the IRAA, including seriousness of the offense. The case was remanded for further proceedings consistent with the appellate opinion. View "Davidson v. United States" on Justia Law