Justia Criminal Law Opinion Summaries

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

The case involves Amaka Oji and Oji Fit World, LLC (OFW), who were approved as Medicaid providers by the D.C. Department of Health Care Finance (DHCF) in 2011. Between 2012 and 2015, they submitted over 24,000 claims for reimbursement for wellness services provided to Medicaid beneficiaries. Investigations by DHCF, the Office of the Inspector General for the Centers for Medicare and Medicaid Services, and the FBI revealed that Oji and OFW regularly overbilled Medicaid, often charging for a full hour of service regardless of the actual time spent or whether the service was provided at all.The District of Columbia filed a lawsuit in April 2021 under the D.C. False Claims Act and the common law doctrine of unjust enrichment. The Superior Court of the District of Columbia granted summary judgment in favor of the District, finding that Oji and OFW had submitted false claims and falsified records. The court awarded the District $1,001,362.50 in treble damages and $497,000 in civil penalties. Oji and OFW's various procedural defenses, including claims of laches and statute of limitations, were deemed waived due to their failure to raise them in a timely manner.The District of Columbia Court of Appeals reviewed the case and affirmed the summary judgment order. However, the court remanded the case for further consideration of the damages and penalties. The appellate court found that the Superior Court had not provided sufficient explanation or analysis for the awarded amounts, making it difficult to review the decision. The appellate court emphasized the need for the trial court to explain its reasoning in detail to permit adequate appellate review. View "Oji Fit World, LLC v. District of Columbia" on Justia Law

In 1993, the appellant was convicted in Wisconsin of third-degree sexual assault and was required to register as a sex offender for fifteen years. After relocating to the District of Columbia, the Court Services and Offender Supervision Agency (CSOSA) notified him in 2019 that he must register as a sex offender for life under the District of Columbia Sex Offender Registration Act (SORA). The appellant filed a motion in Superior Court challenging this determination, arguing that his Wisconsin conviction was not substantially similar to any lifetime-registration offense under SORA.The Superior Court initially scheduled a hearing beyond the statutory sixty-day deadline set by SORA. At the hearing, the appellant contended that the United States had not proven that his Wisconsin conviction involved conduct substantially similar to first-degree or second-degree sexual abuse in the District, which require lifetime registration. The court granted the United States a continuance to obtain additional records from Wisconsin, over the appellant's objection. The additional evidence included transcripts from the preliminary hearing and sentencing, which detailed the appellant's use of force during the assault. The trial court found that the United States had proven by a preponderance of the evidence that the appellant's conduct involved the use of force, thus requiring lifetime registration.The District of Columbia Court of Appeals reviewed the case and affirmed the Superior Court's decision. The appellate court held that the trial court acted within its discretion in granting the continuance and that the failure to meet SORA's sixty-day deadline did not warrant reversal. The court also found that the evidence was sufficient to support the trial court's finding that the appellant's Wisconsin offense involved the use of force, justifying the lifetime registration requirement. View "Cox v. United States" on Justia Law

Dagoberto Machado was convicted by a jury of multiple offenses related to the inappropriate touching of I.A., his girlfriend’s young niece. The incidents allegedly occurred during the summers of 2016 and 2017 when I.A. was staying with Machado and his girlfriend. I.A. testified that Machado touched her inappropriately on several occasions, including at a public pool and in their home. She did not immediately report the incidents due to uncertainty and fear of affecting family relationships. The government introduced expert testimony from Dr. Stephanie Wolf, a child psychologist, to provide context for I.A.'s delayed reporting, including cultural barriers within Latino communities.The Superior Court of the District of Columbia admitted Dr. Wolf’s testimony over Machado’s objections. Machado argued that Dr. Wolf’s statements about “machismo” in Latino culture were prejudicial. The trial court qualified Dr. Wolf as an expert and allowed her to testify about cultural norms that might impede a child from disclosing abuse. Dr. Wolf mentioned that in Latino culture, men might have a higher standing, which could impact how sexuality and abuse are viewed. The jury found Machado guilty on all counts.The District of Columbia Court of Appeals reviewed the case and found that the trial court erred in admitting Dr. Wolf’s testimony about Latino culture. The court held that the testimony had minimal probative value and was substantially outweighed by its potential to unfairly prejudice the jury against Machado based on ethnic stereotypes. The court emphasized that such testimony could lead the jury to view Machado as more likely to have committed the abuse simply because of his ethnicity. Consequently, the court reversed Machado’s convictions and remanded the case for further proceedings. View "Machado v. United States" on Justia Law

Corey Nelson-White was barred from Rhode Island Row, a mixed-use development in Northeast D.C., which includes two buildings at 2300 and 2350 Washington Place NE. The barring notice directed him to stay off the property and grounds of Rhode Island Row. Officers explained the barring notice to Nelson-White, but did not provide him with a copy. Six days later, Nelson-White was found inside a parking garage attached to one of the Rhode Island Row buildings and was arrested for unlawful entry.The Superior Court of the District of Columbia convicted Nelson-White of unlawful entry, finding that he knew or should have known he was barred from the premises, including the parking garage. The trial court based its decision on the barring notice and the officers' instructions, despite Nelson-White's argument that the garage was not clearly marked as part of Rhode Island Row.The District of Columbia Court of Appeals reviewed the case and found the evidence insufficient to sustain Nelson-White's conviction. The court noted that there was no clear indication that the parking garage was part of the barred premises. The court highlighted the lack of signage or other markers that would inform a reasonable person that the garage was part of Rhode Island Row or 2350 Washington Place. The court concluded that a rational fact-finder could not determine beyond a reasonable doubt that Nelson-White knew or should have known the garage was included in the barring notice.The District of Columbia Court of Appeals reversed Nelson-White's conviction for unlawful entry, holding that the evidence did not support the conclusion that he was aware or should have been aware that the parking garage was part of the premises he was barred from entering. View "Nelson-White v. United States" on Justia Law

G.W. was convicted of simple assault in 2019 after allegedly grabbing the jacket of a Metropolitan Transit Police Department officer outside the Anacostia Metro Station. G.W. filed a notice of appeal, and the case was remanded to allow the trial court to set aside his conviction under the Youth Rehabilitation Act (YRA). Following the trial court's set-aside order and issuance of a new judgment and commitment order, G.W. filed a new notice of appeal, challenging his conviction.The Superior Court of the District of Columbia initially convicted G.W. of simple assault. G.W. timely filed a notice of appeal, and the case was stayed pending the outcome of the en banc decision in Perez Hernandez v. United States, which addressed the elements of an offensive touching assault. After the decision in Perez Hernandez, the stay was lifted, and G.W. sought an indicative ruling for a YRA set-aside. The trial court issued an indicative set-aside order, and the case was remanded. The trial court then issued a set-aside order and an amended judgment and commitment order, which G.W. appealed.The District of Columbia Court of Appeals reviewed the case and concluded that G.W.'s appeal was properly before the court. The court determined that the trial court had not applied the correct elements of an offensive touching assault as defined in Perez Hernandez. Specifically, the trial court did not consider whether G.W.'s actions would offend a person's reasonable sense of personal dignity and whether G.W. acted with the purpose of causing offense or knowing that his actions would cause offense. The court vacated the judgment and remanded the case for the trial court to make the necessary findings regarding G.W.'s mens rea and the nature of the touch. The court did not reach G.W.'s Rule 16 claim due to the decision to remand. View "G.W. v. United States" on Justia Law