Justia Criminal Law Opinion Summaries

Defendant was indicted on one count each of driving under the influence, reckless driving, reckless endangerment with a motor vehicle, and violation of the implied consent law. The video recording of the arresting officer's pursuit and stop of Defendant's vehicle was lost before trial. Defendant filed a motion to dismiss the indictment due to the State's alleged failure to preserve potentially exculpatory evidence. Following an evidentiary hearing, the trial court dismissed several of the charges. The court of criminal appeals affirmed. After applying a de novo standard of review, the Supreme Court affirmed, holding (1) based on the record, the trial court did not err by finding it would be fundamentally unfair to require Defendant to go to trial without the video recording; and (2) the trial court did not abuse its discretion in choosing dismissal of several charges as a remedy for the State's loss of the video recording. View "State v. Merriman" on Justia Law

After a jury trial, Defendant was convicted of aggravated statutory rape and sentenced to four years incarceration. Defendant appealed, arguing that the evidence was insufficient to support his conviction because the testimony of the victim, a consenting accomplice in the crime, was not adequately corroborated by other proof. The court of appeals affirmed, holding that the victim qualified as an accomplice to the crime but that her testimony was sufficiently corroborated by the evidence. The Supreme Court affirmed, holding (1) the testimony of a victim of statutory rape does not require corroboration; and (2) the evidence presented at trial, including the victim's testimony, was sufficient to sustain Defendant's conviction. View "State v. Collier" on Justia Law

After a jury trial, Defendant was convicted of false imprisonment and assault and sentenced to concurrent sentences of six months. While Defendant's case was pending on appeal, the Supreme Court filed its opinion in State v. White, which requires trial courts to provide a more specific instruction on kidnapping charges as to whether the removal or confinement of a victim is essentially incidental to any accompanying offense. On appeal, the court of appeals affirmed, holding that although the White instruction was not given at trial, the jury was correctly instructed and the evidence was sufficient to support both convictions. The Supreme Court reversed the conviction for false imprisonment, holding that the omission of the White instruction was not harmless beyond a reasonable doubt. Remanded for a new trial. View "State v. Cecil" on Justia Law

Defendant was arrested on federal and state charges and taken into federal custody. After a trial in federal court, Defendant was convicted. Defendant was subsequently indicted by a Gibson County grand jury on the related state charges. After he was sentenced in federal court, Defendant was transported to Gibson County for an arraignment. Defendant was arraigned and then transferred back into federal custody. Defendant filed a motion to dismiss the state indictment for violations of the Interstate Agreement on Detainers (IAD), articles III and IV. Under article IV, an official of one jurisdiction may seek custody of a prison serving a term of imprisonment in another jurisdiction, but the prisoner must be tried within 120 days of arrival in that jurisdiction and cannot be shuttled back to the original place of imprisonment before the trial. The trial court denied the motion, and Defendant entered a conditional guilty plea. The court of criminal appeals affirmed the trial court's denial of Defendant's motion to dismiss. The Supreme Court reversed, vacated Defendant's conviction, and dismissed the indictment against Defendant with prejudice, holding that article IV of the IAD was violated when Defendant was transferred back to the federal detention center before being tried for the state charges. View "State v. Springer" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and tampering with physical evidence. The court of criminal appeals upheld Defendant's convictions and sentences. Defendant appealed, arguing (1) the trial court erred in declining his request for a jury instruction on defense of a third person, and (2) his abandonment of the murder weapon did not amount to tampering with physical evidence. The Supreme Court (1) affirmed Defendant's conviction for first degree murder, holding that the trial court properly denied Defendant's request for an instruction on defense of a third person; and (2) reversed Defendant's conviction for tampering with physical evidence, holding that Defendant did not "conceal" the murder weapon within the meaning of the relevant statute by tossing the murder weapon over a fence where it could be easily observed and recovered. View "State v. Hawkins" on Justia Law

After a jury trial, Defendant was convicted of first degree premeditated murder and sentenced to life imprisonment. The court of criminal appeals affirmed the conviction and sentence but granted permission to appeal to address whether a discharged alternate juror's communication to the jury foreman entitled Defendant to a new trial. The Supreme Court affirmed, holding (1) the State presented sufficient, admissible evidence to rebut the presumption of prejudice that accompanies an improper outside influence upon the jury, and because there was no reasonable possibility that the note from the discharged alternate juror to the foreman affected the verdict, Defendant was not entitled to relief on this issue; (2) the trial court did not err with respect to the admission of evidence or its jury instructions; and (3) the evidence was sufficient to convict Defendant of first degree premeditated murder. View "State v. Adams" on Justia Law

A confidential informant arranged a drug buy from a co-defendant. The co-defendant arrived in his truck with Defendant and another passenger. The three men were arrested, and a consensual search of the truck yielded 153 grams of cocaine and 8.6 grams of marijuana in close proximity to where Defendant had been seated. Police subsequently searched the co-defendant's residence, which yielded 293.5 grams of cocaine and drug paraphernalia. The State consolidated the weight of the cocaine and charged Defendant with possession with intent to sell 300 grams or more of cocaine, among other offenses. The jury convicted Defendant of possession with intent to sell 300 grams or more of cocaine and possession of drug paraphernalia. The Supreme Court affirmed in part and reversed in part, holding (1) the evidence was sufficient to support a finding that Defendant constructively possessed the cocaine in the co-defendant's truck, but the evidence was insufficient to support a finding that Defendant constructively possessed the cocaine or drug paraphernalia in the co-defendant's residence; and (2) therefore, the cocaine conviction should be reduced to possession with intent to sell 26 to 299 grams of cocaine and the conviction for possession of drug paraphernalia should be vacated. Remanded for resentencing. View "State v. Robinson" on Justia Law

After a jury trial, Defendant was convicted of premeditated first degree murder. During the penalty phase of the trial, Defendant refused to allow his lawyers to present mental health mitigation evidence. The trial court ruled that Defendant was competent to waive the presentation of expert mental health testimony. The jury sentenced Defendant to death. The court of criminal appeals affirmed Defendant's conviction and sentence. The Supreme Court affirmed, holding primarily that (1) a mentally competent defendant may waive the presentation of mitigation evidence during the penalty phase of a capital trial; (2) the trial court did not err in ruling that Defendant was mentally competent to waive the presentation of mitigation evidence; and (3) the death sentence in this case was not imposed in an arbitrary fashion and was not disproportionate to the penalty imposed in similar cases. View "State v. Johnson" on Justia Law

Defendant was charged with and convicted of first-degree premeditated murder and abuse of a corpse. On appeal, the court of criminal appeals modified Defendant's first degree murder conviction to second degree murder. The court also affirmed the trial court's denial of Defendant's motion to suppress. Defendant appealed, contending that the trial court erred in denying his motion to suppress his statements to the police on the grounds that they were elicited in violation of his constitutional right to counsel and were involuntary. The Supreme Court vacated Defendant's convictions, holding (1) Defendant's statements were erroneously admitted into evidence because Defendant did not invoke his constitutional right to counsel and did not waive his Miranda rights; (2) the physical evidence discovered as a result of Defendant's statements was properly admitted into evidence because the totality of the circumstances showed that Defendant's statements were voluntary and not coerced; and (3) the State failed to establish that the erroneous admission of Defendant's statements was harmless beyond a reasonable doubt. Remanded. View "State v. Climer" on Justia Law

A grand jury returned an indictment charging Defendant with especially aggravated burglary, especially aggravated kidnapping, first degree premeditated murder, and first degree felony murder. That same day, the grand jury returned a superseding indictment re-charging Defendant and her husband with the same offenses but adding a charge of criminal conspiracy as to each. After Defendant's step-daughter testified before the grand jury, a second superseding indictment was issued charging all offenses in the first indictment and adding a charge of accessory after the fact against Defendant's husband. After a jury trial, Defendant was convicted of aggravated burglary, especially aggravated kidnapping, attempted first degree premeditated murder, and first degree felony murder. Defendant appealed, arguing that the trial court should have dismissed the charges because of prosecutorial abuse of the grand jury process. The court of criminal appeals affirmed. The Supreme Court affirmed, holding that Defendant failed to demonstrate that the prosecutor acted improperly by compelling the testimony of Defendant's step-daughter in the grand jury proceeding, and the trial court properly denied Defendant's motions alleging prosecutorial abuse of the grand jury process. View "State v. Mangrum" on Justia Law