Justia Criminal Law Opinion Summaries

The State charged Appellant with aggravated assault and battery. At trial, Appellant claimed he had acted in self-defense. After a three-day trial, the jury found Appellant guilty. Appellant subsequently filed a motion for a new trial based on newly discovered evidence. Following a hearing on Appellant’s motion for a new trial, the district court denied the motion, concluding that Appellant had not demonstrated that the evidence was so material that it would probably produce a different verdict if a new trial was granted and that the evidence did not provide proper grounds for granting a new trial. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in denying Appellant’s motion for a new trial. View "Emerson v. State" on Justia Law

Defendant entered a plea of no contest to one count of delivery of methamphetamine. In 2011, the district court revoked Defendant’s probation and entered judgment on her no contest plea. The court sentenced Defendant to a term of years in prison but suspended the sentence and placed her on supervised probation. Defendant’s probation was set to expire in February 2014, but in January 2014, a probation agent filed a petition to extend her probationary term to August 2015. Defendant filed a document agreeing to the extension but was not represented by counsel. The district court subsequently entered an order extending probation. In February 2015, the State petitioned to revoke Defendant’s probation. Defendant argued that the probation extension had not been handled properly and if the probation extension had not been entered, Defendant’s probation would have expired prior to the February 2015 revocation hearing. The district court ruled that Defendant did not have the right to counsel during her probation extension proceeding. The court then revoked Defendant’s probation. The Supreme Court affirmed, holding that Defendant’s challenge to the probation extension entered more than one year before her probation was revoked was time barred. View "Poignee v. State" on Justia Law

Defendant pleaded guilty to misdemeanor breach of peace and misdemeanor interference with a peace officer. Two days later, the State filed an information charging Defendant with felony interference with a peace officer arising out of the same events as those underlying his misdemeanors convictions. Defendant entered an unconditional plea of no contest to a reduced charge of misdemeanor interference. Defendant appealed, arguing that his second misdemeanor conviction violated his double jeopardy protections. The Supreme Court affirmed, holding (1) Defendant did not waive his double jeopardy claim; and (2) because Defendant committed two separate acts of interference, one inside his home and one outside his home, Defendant could lawfully be prosecuted for each separate offense. View "Redding v. State" on Justia Law

After a jury trial, Defendant was convicted of aggravated assault and battery. Defendant appealed, arguing that the prosecutor committed prosecutorial misconduct by incorrectly instructing the jury regarding the presumption of innocence and by attempting to define “reasonable doubt” to the jury in his closing argument. The Supreme Court affirmed, holding (1) the prosecutor violated a clear and unequivocal rule of law when he made an incorrect statement regarding the presumption of innocence; (2) the prosecutor transgressed a clear and unequivocal rule of law when he defined reasonable doubt for the jury in his closing argument; but (3) while Defendant established that the prosecutor committed two errors that transgressed clear and unequivocal rules of law, the cumulative effect of these errors was not prejudicial. View "Watts v. State" on Justia Law

Defendant was charged with felony interference with a peace officer. Ultimately, the case was submitted to the jury. The jury deliberated for approximately four hours before it informed the district court that it was deadlocked. After discussion with counsel, the district court gave the jury a supplemental instruction asking the jurors to continue their deliberations. Less than one hour later, the jury returned a guilty verdict. Defendant appealed, arguing that the court’s supplemental instruction improperly coerced the jury and that his attorney provided ineffective assistance by failing to object to the instruction. The Supreme Court affirmed, holding (1) the supplemental instruction was not unduly coercive; and (2) defense counsel’s failure to object to the jury instruction did not constitute deficient performance. View "Carter v. State" on Justia Law

Defendant pleaded guilty to manslaughter and aggravated burglary. Defendant was sentenced to twelve to eighteen years for the manslaughter conviction and eight to ten years for the aggravated battery, to run concurrently, with a recommendation for the Youthful Offender Program (boot camp). After Defendant completed boot camp he moved for a sentence reduction to probation. The district court denied the motion but reduced Defendant’s sentence by two years. The Supreme Court affirmed, holding (1) following the successful completion of boot camp the sentencing court has discretion to reduce the sentence of an applicant upon completion of boot camp, and that discretion allows a reduction in sentence that could include probation but could also include other possibilities; (2) the district court did not abuse its discretion when it considered the nature of Defendant’s underlying crimes in Defendant’s motion for sentence reduction; and (3) the prosecutor did not violate the terms of the plea agreement when he argued against probation after completion of boot camp. View "Mendoza v. State" on Justia Law

In 2013, Appellant was convicted of ten felonies for acts perpetrated against his ex-girlfriend, their son, and Appellant’s six-year-old second cousin. The Supreme Court affirmed. In 2015, Appellant filed a motion for a new trial based on a recantation by his ex-girlfriend. The district court denied the motion. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Appellant’s motion for a new trial where the court found that the ex-girlfriend’s post-trial recantation was not credible and the court’s assessment that the ex-girlfriend’s “recantation of her recantation” constituted cumulative evidence relating to her credibility. View "Lindstrom v. State" on Justia Law

Appellant was convicted of kidnapping and felony stalking. The Supreme Court reversed the stalking conviction but affirmed the kidnapping conviction. On remand, the district court amended the sentencing order. Appellant subsequently filed a motion and a second motion to correct an illegal sentence, arguing that the amended sentence improperly increased his punishment for kidnapping, that the public defender who represented him at trial improperly approved the amended sentence, and that the jury had been improperly instructed at trial. The district court denied the motions. The Supreme Court affirmed the denial of Appellant’s motions, holding that Appellant failed to establish that his amended kidnapping sentence was illegal. View "Hawes v. Wyoming" on Justia Law

After a jury trial, Defendant was found guilty of five counts of reckless endangering, three counts of aggravated assault, and one count of eluding police. The Supreme Court affirmed, holding (1) there was sufficient evidence presented at trial to convict Defendant of aggravated assault; (2) the district court erred in admitting evidence of law enforcement officers’ subjective reactions to a fired shot, but the error was not prejudicial; (3) the district court did not abuse its discretion when it denied Defendant’s motion for mistrial based upon prosecutorial misconduct; and (4) the prosecutor’s comments during closing argument did not constitute plain error. View "Hill v. State" on Justia Law

Appellant pled guilty to felony shoplifting and was placed on supervised probation for four years. Three years later, the State filed a petition to revoke Appellant’s probation, alleging that she violated the conditions of her probation on two separate occasions. Appellant admitted to the allegations of the petition and was subsequently sentenced to not less than four nor more than six years’ incarceration. Thereafter, Appellant filed a motion for sentence reduction, arguing that her good behavior and rehabilitative progress while incarcerated warranted a reduction. The district court denied the motion. The Supreme Court affirmed, holding (1) Appellant’s productive behavior alone did not require the district court to grant her a sentence reduction; and (2) the district court did not abuse its discretion in denying Appellant’s motion without describing information Appellant provided in support of her request for a reduction. View "Hart v. State" on Justia Law