Justia Criminal Law Opinion Summaries

The Supreme Court affirmed in part and reversed and remanded in part the district court’s denials of Defendant’s motion to suppress and motion in limine and the grant of the State’s motion in limine in this criminal case.Defendant was charged with aggravated driving under the influence (DUI), a felony, or, in the alternative, aggravated DUI per se, a felony. Defendant filed a motion to suppress field sobriety tests based on newly discovered evidence calling into question whether the arresting officer made accurate individualized reports of his traffic stops and whether he possessed sufficient particularized suspicion to investigate Defendant for DUI in this case. Defendant also filed a motion in limine requesting exclusion of his prior DUI convictions. The district court denied both motions. The Supreme Court held that the district court (1) did not err by denying Defendant’s motion to suppress; (2) abused its discretion by granting the State’s motion in limine and preventing Defendant from challenging the arresting officer’s credibility in front of the jury; and (3) erred when it denied Defendant’s motion in limine and allowed the evidence of his prior DUI convictions to establish the offense of aggravated DUI. View "State v. Zimmerman" on Justia Law

The Supreme Court affirmed Defendant’s conviction for deliberate homicide, holding that the prosecutor did not commit misconduct during closing argument that prejudiced Defendant’s right to a fair trial and warranted plain error review.A jury convicted Defendant of deliberate homicide. On appeal, Defendant argued that the prosecutor committed misconduct during closing argument. Because Defendant did not object to the statements, he sought plain error review. The Supreme Court affirmed, holding that Defendant did not demonstrate that failure to review the asserted errors would result in a miscarriage of justice, raise a question about the fundamental fairness of the proceedings, or compromise the integrity of the judicial process. View "State v. Lau" on Justia Law

The Supreme Court affirmed Defendant’s conviction for assault with a weapon, two counts of partner or family member assault, and unauthorized use of a motor vehicle. The Court held that the district court (1) did not abuse its discretion by granting the State’s motion to join the first and second cases for trial, after a mistrial in the first case; (2) did not abuse its discretion by concluding that the probative value of letters letters Defendant wrote to the victim from jail was not substantially outweighed by any prejudice to Defendant and by admitting the letters into evidence; and (3) did not act arbitrarily or exceed the bounds of reason by denying Defendant’s motion for a mistrial. View "State v. Ankeny" on Justia Law

The justice court did not err in concluding that Defendant waived his right to a jury trial when he failed to appear at his jury confirmation hearing.Defendant was found guilty by the justice court of driving while under the influence of alcohol and obstructing a peace officer. On appeal, Defendant argued that the justice court erred in determining that Defendant waived his right to a jury trial when he failed to appear at the jury confirmation hearing. The Supreme Court affirmed, holding that, under the circumstances, the justice court did not err in determining that Defendant waived his right to a jury trial by failing to attend his jury confirmation hearing. View "State v. Sherlock" on Justia Law

The Supreme Court affirmed Defendant’s conviction upon a nolo contendere plea for driving under the influence (DUI), holding that the arresting officer did not unreasonably impede Defendant’s right to obtain an independent blood test, and therefore, the district court did not err in denying Defendant’s motion to dismiss the DUI charge.On appeal, Defendant argued that not releasing her at the police station and instead driving her home, ten miles from the hospital, was a deviation from standard procedure that frustrated her ability to obtain an independent blood test. The Supreme Court disagreed, holding that, under the facts of this case, the officer did not unreasonably impede Defendant’s right to obtain an independent blood test. View "State v. Neva" on Justia Law

The Supreme Court affirmed Defendant’s conviction upon a nolo contendere plea for driving under the influence (DUI), holding that the arresting officer did not unreasonably impede Defendant’s right to obtain an independent blood test, and therefore, the district court did not err in denying Defendant’s motion to dismiss the DUI charge.On appeal, Defendant argued that not releasing her at the police station and instead driving her home, ten miles from the hospital, was a deviation from standard procedure that frustrated her ability to obtain an independent blood test. The Supreme Court disagreed, holding that, under the facts of this case, the officer did not unreasonably impede Defendant’s right to obtain an independent blood test. View "State v. Neva" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress evidence discovered in the course of a probationary search of the vehicle in which Defendant was a passenger, holding that, under the facts of this case, Defendant had no reasonable expectation of privacy in the vehicle or its contents. Therefore, there was no search.Defendant’s counsel moved to suppress the evidence seized as a result of the vehicle search on the grounds that there was no inquiry to determine if Defendant was the owner of or if he had control over the vehicle. The district court denied the motion, concluding that a probationer need not be a driver or owner of a vehicle in order for officers to initiate a probationary search of the vehicle, so long as the probationer was a passenger immediately prior to the search. The Supreme Court affirmed, holding (1) Defendant failed to show he had an actual expectation of privacy as a passenger in the vehicle; and (2) even though the vehicle was not Defendant’s, the probation officer had the authority to search it. View "State v. Conley" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress evidence discovered in the course of a probationary search of the vehicle in which Defendant was a passenger, holding that, under the facts of this case, Defendant had no reasonable expectation of privacy in the vehicle or its contents. Therefore, there was no search.Defendant’s counsel moved to suppress the evidence seized as a result of the vehicle search on the grounds that there was no inquiry to determine if Defendant was the owner of or if he had control over the vehicle. The district court denied the motion, concluding that a probationer need not be a driver or owner of a vehicle in order for officers to initiate a probationary search of the vehicle, so long as the probationer was a passenger immediately prior to the search. The Supreme Court affirmed, holding (1) Defendant failed to show he had an actual expectation of privacy as a passenger in the vehicle; and (2) even though the vehicle was not Defendant’s, the probation officer had the authority to search it. View "State v. Conley" on Justia Law

The Supreme Court affirmed the district court’s denial of Appellant’s petition for postconviction relief based on Appellant’s claim of actual innocence and held that the district court correctly determined that Appellant did not establish that his counsel was ineffective.Appellant pleaded guilty to the attempted mitigated homicide of his brother. Appellant later filed this petition for postconviction relief alleging that he had newly discovered evidence of his actual innocence and that his attorney was ineffective during plea negotiations. At the evidentiary hearing, Appellant’s brother testified that the incident in which he was injured was an accident. The district court denied the petition. The Supreme Court affirmed, holding (1) Appellant’s brother’s testimony, to which the district court attributed little value based on the brother’s lack of credibility, did not establish that Appellant’s sentence was constitutionally invalid because he was actually innocent of the crime; and (2) the district court properly found that Appellant’s guilty plea was not involuntary because he received ineffective assistance of counsel. View "Guillen v. State" on Justia Law

The Supreme Court affirmed Defendant’s sentence for three separate cases involving partner or family member assault against three different women to a combined twenty years, with eight suspended. The district court included conditions in all three cases that restricted contact between Defendant and his victims. On appeal, Defendant argued that the condition prohibiting contact between him and his second victim was an unreasonable sentencing condition and an unconstitutional restriction on his common-law marriage. The Supreme Court held (1) the contested condition was not an unreasonable sentencing condition; and (2) Defendant’s general objection to the restricted contact conditions was insufficient to preserve his argument that the conditions unconstitutionally infringe upon his marriage, privacy, and due process rights. View "State v. Parkhill" on Justia Law