Justia Criminal Law Opinion Summaries

Petitioner was convicted of first-degree murder based on the testimony of a single eyewitness. During state postconviction proceedings, petitioner obtained police files containing statements by the eyewitness contradicting his testimony. Petitioner argued that the prosecution's failure to disclose those statements violated Brady v. Maryland. The Court held that Brady required that petitioner's conviction be reversed where the eyewitness's testimony was the only evidence linking petitioner to the crime and the eyewitness's undisclosed statements contradicted his testimony. The eyewitness's statements were plainly material, and the State's failure to disclose those statements to the defense thus violated Brady.

In 2005, respondent was charged with delinquency under the Federal Juvenile Delinquency Act, 18 U.S.C. 5031 et seq., for sexually abusing a boy for approximately two years until respondent was 15 years old and his victim was 12 years old. Respondent was sentenced to two years of juvenile detention followed by juvenile supervision until his 21st birthday. In 2006, while respondent remained in juvenile detention, Congress enacted the Sex Offender Registration and Notification Act (SORNA), 42 U.S.C. 16902 et seq. In July 2007, the District Court determined that respondent had failed to comply with the requirements of his prerelease program. On appeal, respondent challenged his "special conditio[n]" of supervision and requested that the Court of Appeals "reverse th[e] portion of his sentence requiring Sex Offender Registration and remand with instructions that the district court ... strik[e] Sex Offender Registration as a condition of juvenile supervision." Over a year after respondent's 21st birthday, the Court of Appeals handed down its decision and held that the SORNA requirements violated the Ex Post Facto Clause of the Constitution, Art. I, section 9, cl. 3, when applied to juveniles adjudicated as delinquent before SORNA's enactment. The Court held that the Court of Appeals had no authority to enter that judgment because it had no live controversy before it where respondent had turned 21 and where the capable-of-repetition exception to mootness did not apply in this case. Accordingly, the judgment of the Ninth Circuit was vacated and the case remanded with instructions to dismiss the appeal.

The Sentencing Reform Act of 1984 ("Act"), 18 U.S.C. 3551 et seq., called for the creation of Sentencing Guidelines to inform judicial discretion in order to reduce unwarranted disparities in federal sentencing. The Act allowed retroactive amendments to the Guidelines for cases where the Guidelines became a cause of inequality. When a retroactive Guideline amendment was adopted, section 3682(c)(2) permitted defendants sentenced based on a sentencing range that had been modified to move for a reduced sentence. In this case, petitioner was indicted for various crimes, including possessing with intent to distribute cocaine base, and entered into a Federal Rule of Criminal Procedure 11(c)(1)(C) agreement to plead guilty to all charges where the Government, in return, agreed to a 106 month sentence. At issue was whether defendants who enter into plea agreements that recommended a particular sentence as a condition of the guilty plea could be eligible for relief under section 3682(c)(2). The Court held that the text and purpose of the statute, Rule 11(c)(1)(C), and the governing Guidelines policy statements compelled the conclusion that the district court had authority to entertain section 3582(c)(2) motions when sentences were imposed in light of the Guidelines, even if the defendant entered into an Rule 11(c)(1)(C) agreement. The Court also held that petitioner's sentencing hearing transcript revealed that the District Court expressed its independent judgment that the sentence was appropriate in light of the applicable Guidelines range. Therefore, the District Court's decisions was "based on" that range within section 3682(c)(2)'s meaning. Accordingly, the judgment of the Court of Appeals was reversed and the case remanded for further proceedings.

Petitioner was arrested on charges of driving while intoxicated ("DWI") and the principal evidence against him was a forensic laboratory report certifying that his blood alcohol concentration was well above the threshold for aggravated DWI. At trial, the prosecution did not call as a witness the analyst who signed the certification and, instead, called another analyst who was familiar with the laboratory's testing procedures but had neither participated in nor observed the test on petitioner's blood sample. At issue was whether the Confrontation Clause permitted the prosecution to introduce a forensic laboratory report containing a testimonial certification, made for the purpose of proving a particular fact, through the in-court testimony of a scientist who did not sign the certification or perform or observe the test reported in the certification. The Court held that surrogate testimony of that order did not meet the constitutional requirement where the accused's right was to be confronted with the analyst who made the certification, unless that analyst was unavailable at trial and the accused had an opportunity, pretrial, to cross-examine that particular scientist. Accordingly, the judgment of the New Mexico Supreme Court was reversed and the case remanded for further proceedings.

Petitioner was indicted for violating 18 U.S.C. 229, which forbid knowing possession or use, for nonpeaceful purposes, of a chemical that "can cause death, temporary incapacitation or permanent harm to humans," and which was part of a federal act implementing a chemical weapons treaty ratified by the United States. At issue was whether a person indicted for violating a federal statute had standing to challenge its validity on grounds that, by enacting it, Congress exceeded its powers under the Constitution, thus intruding upon the sovereignty and authority of the States. The Court held that petitioner had standing to challenge the federal statute where there was no basis in precedent or principle to deny petitioner's standing to raise her claims. The ultimate issue of the statute's validity turned in part on whether the law could be deemed "necessary and proper for carrying into Execution" the President's Article II, section 2 Treaty Power. Accordingly, the Court expressed no view on the merits of the argument and noted that it could be addressed by the Court of Appeals on remand. Therefore, the judgment of the Court of Appeals was reversed and the case remanded for further proceedings.

While conducting a routine vehicle stop, police arrested petitioner, a passenger of the vehicle, for giving a false name. After handcuffing him and securing the scene, the police searched the vehicle and found petitioner's revolver. Petitioner was subsequently indicted on charges of being a felon in possession of a firearm. In a suppression motion, petitioner acknowledged that the search of the vehicle complied with existing Eleventh Circuit precedent interpreting New York v. Belton, but he raised a Fourth Amendment challenge to preserve the issue on appeal. The District Court denied the motion and petitioner was convicted. While his appeal was pending, the Court announced, in Arizona v. Gant, a new rule governing automobile searches incident to arrests of recent occupants. At issue was whether to apply the exclusionary rule when the police conducted a search in compliance with binding precedent that was later overruled. Because the suppression would do nothing to deter police misconduct in these circumstances, and because it would come at a high cost to both the truth and the public safety, the Court held that the searches conducted in objectionable reliance on binding appellate precedent were not subject to the exclusionary rule. Accordingly, the Court affirmed the suppression of the revolver and petitioner's conviction.

J.D.B., a thirteen-year-old seventh-grade student, was taken from his classroom to a closed-door conference room where uniformed police and school administrators questioned him for at least 30 minutes regarding two home break-ins nearby. Before beginning, they did not give J.D.B. Miranda warnings, the opportunity to call his legal guardian, or tell him he was free to leave the room. After J.D.B. subsequently confessed to the break-ins and wrote a statement at the request of police, two juvenile petitions were filed against him. J.D.B.'s public defender moved to suppress his statements and the evidence derived therefrom, arguing that he had been interrogated in a custodial setting without being afforded Miranda warnings and that his statements were involuntary. At issue was whether the age of a child subjected to police questioning was relevant to the custody analysis of Miranda v. Arizona. The Court held that it was beyond dispute that children would often feel bound to submit to police questioning when an adult in the same circumstances would feel free to leave. Seeing no reason for police officers or courts to blind themselves to that commonsense reality, the Court held that a child's age group properly informed the Miranda custody analysis. Accordingly, the Court reversed and remanded to the state courts to address whether J.D.B. was in custody when he was interrogated, taking account of all of the relevant circumstances of the interrogation, including his age at the time.

Petitioner was convicted of, inter alia, smuggling unauthorized aliens into the United States. The District Court imposed a 51 month prison sentence, reasoning that petitioner should serve that long in order to qualify for and complete the Bureau of Prisons' Residential Drug Abuse Program ("RDAP"). At issue was whether the Sentencing Reform Act ("SRA"), 18 U.S.C. 3582(a), precluded federal courts from imposing or lengthening a prison term in order to promote a criminal defendant's rehabilitation. The Court held that the text, context, and history of section 3582(a) precluded sentencing courts from imposing or lengthening a prison term to promote an offender's rehabilitation. The Court also held that Amicus' attempts to recast what the SRA said about rehabilitation were unavailing. The court further held that the record indicated that the District Court may have increased the length of petitioner's sentence to ensure her completion of RDAP, something a court could not do. Accordingly, the Court reversed and remanded for further proceedings and held that the Ninth Circuit was left to consider on remand the effect of petitioner's failure to object to the sentence when imposed.

Petitioner was convicted for distribution of 50 grams or more of cocaine base under section 841(a)(1) and (b)(1)(A)(iii) of the Anti-Drug Abuse Act of 1986 ("ADAA"), 21 U.S.C. 841(a)(1) and (b)(1)(A)(iii), and sentenced to the 120 months prison term mandated by the statute. At issue was whether the term "cocaine base" as used in the statute referred generally to cocaine in its chemically basic form or exclusively to what was colloquially known as "crack cocaine." The court held that "cocaine base," as used in section 841(b)(1), meant not just "crack cocaine," but cocaine in its chemically basic form where, at the time the statute was enacted, "cocaine" was commonly used to refer to powder cocaine, and the scientific and medical literature often used "cocaine" to refer to all cocaine-related substances, including ones that were not chemically basic; where Congress had good reason to include the term "cocaine" in clause (ii), and the slight inconsistency created by its use of "cocaine base" in clause (iii) was insufficient reason to adopt petitioner's interpretation of the statute; and where petitioner's additional arguments were unpersuasive. Accordingly, the court affirmed the judgment of the First Circuit adhering to its precedent holding that "cocaine base" referred to all forms of cocaine.

When petitioner pleaded guilty to being a felon in possession of a firearm, he had prior convictions for at least three felonies, including the state-law crime of "using a vehicle" to "knowingly or intentionally" "flee from a law enforcement officer" after being ordered to stop pursuant to Ind. Code 35-44-3-3(b)(1)(A). The Federal District Court decided that the prior convictions subjected petitioner to the 15-year mandatory minimum prison term that the Armed Career Criminal Act ("ACCT"), 18 U.S.C. 924(e), provided for an armed defendant who had three prior "violent felony" convictions. Rejecting petitioner's argument that his vehicle flight felony was not "violent" under the ACCA, the Seventh Circuit affirmed. The Court held that felony vehicle flight, as proscribed by Indiana law, was a violent felony for purposes of the ACCA where felony vehicle flight presented a serious potential risk of physical injury to another; where, because felony vehicle flight was not a strict-liability, negligence, or recklessness crime and was, as a categorical matter, similar in risk to the crimes listed in the residual clause, it was a violent felony; where Indiana treated subsection 35-44-3-3(b)(1)(A) and 35-44-3-3(b)(1)(B) as felonies of the same magnitude carrying similar prison terms; and where Congress had power to enact the residual clause to impose enhanced punishment for unlawful firearm possession when the relevant prior offenses involved a potential risk of physical injury similar to that presented by several enumerated offenses. Accordingly, the court affirmed the judgment of the Seventh Circuit.