Justia Criminal Law Opinion Summaries

The Supreme Court held that the trial court erred by failing to summarily deny the applications for the issuance of a writ of habeas corpus submitted by Petitioners, Carlos Chavez and Luis Lopez, for its consideration in this case.A sheriff entered into an agreement with the United States Immigration and Customs Enforcement pursuant to section 287(g) of the Immigration and Nationality Act, 8 U.S.C. 1357, that certified deputies to perform specific immigration enforcement functions, including the detention of undocumented aliens. Petitioners, who were being held in pretrial detention pursuant to immigration-related arrest warrants and detainers, filed petitions seeking the issuance of a writ of habeas corpus. The trial court issued writs of habeas corpus. The court of appeals vacated the trial court orders, concluding that the trial court lacks jurisdiction to issue writs of habeas corpus for alien petitions not in state custody and held under federal authority. The Supreme Court reversed in part, holding that state judicial officials acting in counties in which the sheriff has entered into a 287(g) agreement with the federal government do not have the authority to grant applications for the issuance of writs of habeas corpus for and to order the release of individuals held pursuant to immigration-related arrest warrants and detainers. View "Chavez v. McFadden" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction for solicitation by computer or electronic device of a person believed to be fifteen years of age or younger for the purpose of committing an unlawful sex act and appearing at the location where he was supposed to meet the person he believed was a child, holding that the trial court committed prejudicial error by failing to instruct the jury on the defense of entrapment. On appeal, the court of appeals held that the trial court's refusal to instruct the jury on entrapment was not error because the evidence failed to support the instruction. The Supreme Court reversed, holding (1) Defendant presented evidence which a reasonable juror could find credible to demonstrate that he did not have a willingness or predisposition to engage in sexual activity with a minor; (2) Defendant's arguments at trial were consistent with the defense of entrapment and should not bar the availability of the defense; and (3) the trial court's failure to instruct the jury on entrapment was prejudicial, and Defendant was entitled to a new trial. View "State v. Keller" on Justia Law

The Supreme Court reversed the decision of the court of appeals that vacated Defendants' convictions for certain charges, holding that when the prosecutor moved to amend the arrest warrant to correctly state the name of the property owner and did so by filing a statement of charges form after arraignment, the superior court properly considered and allowed the change.At issue was whether the prosecutor lost the right to amend the criminal warrant in this case when the amendment was filed on a statement of charges form after Defendant's arraignment. The court of appeals held that because Defendant was tried under a statement of charges that was filed after arraignment and because the sufficiency of the original arrest warrant had not been contested, the statement of charges was untimely and the superior court had no jurisdiction to try the case under that charging document. The Supreme Court reversed, holding (1) regardless of the label, such a change is still an amendment and no statutory provision limits the filing of a statement of charges in this way; and (2) therefore, the trial court did not err in proceeding under the amended pleading. View "State v. Capps" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the order of the trial court denying Defendant's motion to suppress evidence seized during the execution of a search warrant, holding that the warrant supported by probable cause.Defendant pled guilty to the offense of trafficking in cocaine while preserving his right to appeal the denial of his motion to suppress. On appeal, Defendant argued that the trial court erred in denying his motion to suppress because the facts contained in the affidavit were insufficient to establish probable cause to search his residence. The court of appeals affirmed. The Supreme Court affirmed, holding that the affidavit contained facts that were sufficient to provide a nexus between the residence and suspected criminal activity, and therefore, the warrant was supported by probable cause. View "State v. Bailey" on Justia Law

The Supreme Court reversed Defendant's conviction, holding that the trial court clearly erred in ruling that Defendant failed to prove purposeful discrimination with respect to the State's use of peremptory challenges to strike three jurors without considering all of the evidence presented by Defendant.Defendant was found guilty of one count of first-degree murder and other crimes. On appeal, Defendant argued that the trial court erred by failing to grant three objections that he made under Batson v. Kentucky, 476 U.S. 79 (1986). The court of appeals affirmed Defendant's convictions. The Supreme Court reversed, holding (1) the court of appeals erred in its analysis of Defendant's Batson claims with respect to the three jurors; and (2) as to all three jurors, remand was required for reconsideration of whether Defendant proved purposeful discrimination in each case. View "State v. Hobbs" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the trial court's judgment convicting Defendant for conspiracy to commit harassment of a juror, holding that the trial court erred in denying Defendant's motion to dismiss the conspiracy charge for insufficient evidence.Defendant was convicted of conspiracy to commit harassment of a juror because of his actions at a courthouse following his twin brother's conviction for assault on a government official. On appeal, the court of appeals concluded that the trial court did not err in denying Defendant's motion to dismiss the conspiracy charge for insufficient evidence. The Supreme Court reversed, holding that the evidence in Defendant's trial was insufficient to raise anything more than mere conjecture that he had made an agreement with another person to threaten or intimidate a juror. View "State v. Mylett" on Justia Law

The Supreme Court reversed the decision of the Court of Appeals affirming the trial court's denial of Defendant's motion to suppress evidence, holding that there was no reasonable suspicion to justify the law enforcement officer's stop when Defendant signaled with his middle finger from the passenger side window of a moving vehicle.While assisting a stranded motorist, the officer turned his attention to another car traveling on the roadway, a white SUV. Defendant had his arm outside the passenger window and gestured with his middle finger, making an up-and-down motion. Believing that Defendant was committing the crime of disorderly conduct, the officer pursued and then stopped the SUV. At trial, Defendant moved to suppress the officer's testimony, arguing that there was no reasonable suspicion to justify the stop. The trial court denied the motion. Defendant pleaded guilty to resisting, delaying, or obstructing a public officer. The court of appeals affirmed the trial court's denial of Defendant's motion to suppress. The Supreme Court reversed, holding that the specific, articulable facts did not establish reasonable suspicion of the crime of disorderly conduct. View "State v. Ellis" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing judgments entered by the superior court convicting and sentencing Defendant on five separate counts for violation of N.C. Gen. Stat. 14-269.2(b) based on an incident in which he was discovered on the grounds of a school in possession of five guns, holding that, under the rule of lenity, Defendant could only lawfully be convicted on one firearm count.Defendant's convictions arose from an incident in which he was discovered on the grounds of a school in possession of five guns. At issue was whether section 14-259.2(b) was ambiguous as to whether multiple convictions are permitted for the simultaneous possession of more than one firearm on a single occasion. The Supreme Court invoked the rule of lenity and held that Defendant could be convicted of only a single violation of the statute. View "State v. Conley" on Justia Law

The Supreme Court modified and affirmed the decision of the court of appeals affirming Defendant's convictions, holding that Defendant preserved his challenges to the sufficiency of the evidence for appeal but that the State presented sufficient evidence to support the convictions.A jury found Defendant guilty of obtaining property worth less than $100,000 by false pretenses, accessing a government computer, altering court records, and unlicensed bail bonding. On appeal, Defendant argued that the State presented insufficient evidence that he aided and abetted another and that he obtained a thing of value. The court of appeals concluded that Defendant waived his challenge to the sufficiency of the State's evidence of aiding and abetting and that Defendant waived his right to appellate review to the sufficiency of the State's evidence that he obtained a thing of value. The Supreme Court affirmed as modified, holding (1) Defendant preserved each of his challenges to the sufficiency of the evidence; and (2) the State presented sufficient evidence that Defendant aided and abetted another and that he obtained a thing of value. View "State v. Golder" on Justia Law

The Supreme Court reversed the judgment of the court of appeals awarding Defendant a new trial after he was convicted of first-degree murder, holding that the trial court did not commit prejudicial error when it overruled Defendant's objections to the State's closing argument.A jury found Defendant guilty of first-degree murder by premeditation and deliberation and/or by lying in wait. On appeal, Defendant argued that the trial court abused its discretion when it failed to sustain his objections to comments made by the prosecutor during closing argument about race. The court of appeals agreed, holding that the trial court committed prejudicial error by overruling Defendant's objections to the prosecutor's comments and by failing to instruct the jury to disregard the comments or to declare a mistrial. The Supreme Court reversed, holding that, assuming without deciding that the prosecutor's comments were improper, Defendant was not prejudiced by the error. View "State v. Copley" on Justia Law