Justia Criminal Law Opinion Summaries

Tony Adams, Jr. was charged and convicted for the stabbing and shooting death of his mother, Belinda Woodson, in Dooly County, Georgia. On May 10, 2018, Adams lived with his mother and stepfather, Tyrone Woodson. After a day of escalating domestic tension and police visits, Adams stabbed and shot his mother following a dispute. Tyrone witnessed part of the assault, and neighbors heard gunshots and saw Adams outside with a firearm. Adams also shot himself in the arm and later told law enforcement conflicting stories about the events, eventually admitting to placing the gun in Woodson’s hand to create a defense. Physical evidence and Adams’s own statements linked him to the crime.After a jury trial in the Superior Court of Dooly County, Adams was found guilty on all counts, including malice murder, felony murder, aggravated assault, and possession of weapons during the commission of felonies. He was sentenced to life without parole and additional consecutive sentences. Adams’s initial motion for a new trial was denied by the trial court, which determined that Adams’s counsel did not render ineffective assistance, and found no reason to conduct a post-judgment competency hearing. The court relied on a pretrial mental health evaluation that found Adams competent and his symptoms feigned, and on counsel’s testimony that Adams showed no signs of incompetence.The Supreme Court of Georgia reviewed Adams’s appeal. It held that Adams’s trial counsel did not perform deficiently by failing to further investigate competency or raise an insanity defense, nor did his comments during direct examination prejudice the outcome. The Court also found no abuse of discretion in the trial court’s denial of a post-judgment competency hearing. However, the Supreme Court vacated Adams’s conviction and sentence for aggravated assault (Count 4) as it merged into the malice murder conviction, and vacated the sentence for possession of a knife during the commission of a felony (Count 6), remanding for resentencing on that count. The judgment was affirmed in part, vacated in part, and remanded. View "ADAMS v. THE STATE" on Justia Law

Tommy Joe Byrd was charged with malice murder, felony murder, and aggravated assault after Jerold Bowden died from stab wounds on May 4, 2020. The evidence showed that the stabbing occurred during a late-night altercation involving several individuals, including Byrd and Bowden, after a car accident and subsequent argument. Witnesses testified that Bowden was stabbed twice by Byrd after Bowden ran away and fell to the ground. Byrd and others then transported Bowden’s body to a relative’s house and left him in the driveway, where he was later discovered deceased. Byrd was arrested several days later and, after waiving his Miranda rights, admitted to stabbing Bowden.A Morgan County grand jury indicted Byrd on three counts. At trial in the Superior Court of Morgan County, the jury found Byrd not guilty of malice murder but guilty of felony murder and aggravated assault. The trial court sentenced Byrd to life without parole for felony murder and merged the aggravated assault conviction. Byrd’s motion for a new trial was denied following an evidentiary hearing.On appeal to the Supreme Court of Georgia, Byrd argued that his conviction should be reversed because the trial court abused its discretion by refusing to grant a mistrial after a State witness briefly mentioned Byrd’s recent release from prison. The Supreme Court of Georgia held that a passing, nonresponsive reference to prior incarceration does not place a defendant’s character in evidence and that the trial court properly exercised its discretion by sustaining the objection and striking the comment, especially since Byrd’s counsel declined a curative instruction. The Court affirmed Byrd’s conviction and sentence. View "BYRD v. THE STATE" on Justia Law

On June 14, 2021, a shooting incident occurred near the Wilson Apartments in Muscogee County, Georgia, resulting in the deaths of Saiveon Pugh and Jesse Ransom and injuries to Wandray Harris and Ta'Journey Lee. The victims, associated with the Zohannon Gang, were driving in the area when they were fired upon by Terrence Upshaw, Roderick Glanton, and Homer Upshaw, who were later identified as members of the Marlo Gang. The investigation revealed surveillance footage and physical evidence linking the defendants to the shooting and to drug-related activities in the neighborhood.The Muscogee County Grand Jury indicted all three defendants on multiple charges, including malice murder, aggravated assault, violations of the Georgia Street Gang Terrorism and Prevention Act, criminal damage to property, and weapons offenses. Homer Upshaw faced additional charges. Following a joint jury trial, all three were convicted on all counts. Terrence and Glanton received concurrent life sentences for murder and additional consecutive sentences for related charges; Homer received life without parole and further consecutive sentences. Motions for new trial were denied by the trial court. The defendants timely appealed their convictions and sentences.The Supreme Court of Georgia reviewed the appeals, addressing claims regarding sufficiency of the evidence, evidentiary rulings, and alleged trial court errors. The Court found the evidence sufficient to support the convictions for malice murder and Gang Act violations, holding the jury was authorized to reject the justification defense. It also held that the trial court did not abuse its discretion in admitting prior criminal acts under OCGA § 24-4-418, nor in its other evidentiary rulings. The Supreme Court of Georgia affirmed all convictions and sentences. View "UPSHAW v. THE STATE" on Justia Law

Travis Smith was convicted of malice murder and other related offenses following the shooting death of Cortez Dowell at a social gathering in Fulton County, Georgia. The incident occurred during a dice game when Smith and Dowell engaged in a verbal and physical altercation, culminating in Smith shooting Dowell three times. Multiple witnesses provided varying accounts: one initially told police she saw Smith shoot Dowell, though at trial she only heard the shots; another reported seeing Smith with a gun and described the fight; and a third heard gunshots after witnessing a confrontation. Dowell died from gunshot wounds to the abdomen.Following the indictment, Smith was tried before a jury in the Superior Court of Fulton County in June 2016. He was found guilty of malice murder, felony murder, aggravated assault, possession of a firearm by a convicted felon, and possession of a firearm during the commission of a felony. The court sentenced him to life without parole plus additional concurrent and consecutive terms for the firearm charges. The felony murder counts were vacated by operation of law. Smith filed several amended motions for a new trial, all of which were denied after a hearing in 2025.On direct appeal, the Supreme Court of Georgia reviewed Smith's claims of evidentiary errors, denial of mistrial motions, and ineffective assistance of counsel. The Court held that Smith failed to preserve many of his evidentiary objections and did not demonstrate plain error regarding the admission of certain testimony and photographic evidence. It found no abuse of discretion in denying Smith's motions for mistrial and concluded that Smith did not receive ineffective assistance of counsel. The Court also rejected his claim of cumulative error and affirmed the judgment against Smith. View "SMITH v. THE STATE" on Justia Law

On the evening of April 2, 2019, Thedarious Mitchell was shot and killed at a motel in DeKalb County. Security footage captured two men entering Mitchell’s room, followed by a violent altercation and Mitchell’s attempt to flee. As he ran, one of the men shot him in the back. Witness R.W., present during the incident, testified that the shooter was known to her as “Baldhead” or “Chris,” later identifying Christopher Sellers both in a photo lineup and at trial. Another witness, Calvin Leslie, recounted that while incarcerated, Sellers admitted to shooting a man in a Georgia motel. Evidence found at the scene and testimony at trial supported the prosecution’s theory that Sellers was the shooter.A DeKalb County grand jury indicted Sellers on multiple charges, including malice murder and firearm offenses. Following a jury trial in the Superior Court of DeKalb County, Sellers was found guilty on all counts. The court sentenced him to life imprisonment without parole for malice murder, with additional consecutive sentences for firearm offenses. Sellers’ motion for a new trial was denied, and he appealed to the Supreme Court of Georgia.Reviewing the case, the Supreme Court of Georgia affirmed both Sellers’ conviction and his sentence. The Court held that the evidence was constitutionally sufficient to support the malice murder conviction, as a rational jury could have found Sellers guilty beyond a reasonable doubt. The trial court did not plainly err in instructing the jury on parties to a crime, as there was at least slight evidence supporting such a theory. Finally, the sentence of life without parole was not found to be cruel and unusual punishment under the Eighth and Fourteenth Amendments, nor grossly disproportionate to the crime, and thus was affirmed. View "SELLERS v. THE STATE" on Justia Law

Enrique Aguilar was involved in a shootout with San Diego Police Department officers after leading one officer on a foot chase during which he brandished a gun. Although Aguilar was wounded, none of the officers were hit, and a bullet fired from Aguilar’s direction struck a nearby store door. Aguilar was charged with multiple offenses, including attempted voluntary manslaughter, assaulting peace officers with a semiautomatic firearm, shooting at an occupied building, possessing methamphetamine while armed, and being a felon in possession of a firearm. At trial in September 2023, a jury convicted him of all charges and the court sentenced him to a lengthy prison term.During jury selection in the Superior Court of San Diego County, the prosecutor used a peremptory challenge to strike a Latina juror (Juror 1), claiming she struggled to understand the concept of intent, as revealed by her responses to a hypothetical question. Aguilar objected, arguing that the prosecutor was improperly excluding Hispanic and Latina jurors. The trial court accepted the prosecutor’s explanation, found Juror 1’s answers equivocal and overruled Aguilar’s objection, determining that ethnicity was not a factor in the challenge.On appeal, the California Court of Appeal, Fourth Appellate District, Division One, reviewed the denial of Aguilar’s objection de novo, as required by Code of Civil Procedure section 231.7. The appellate court found no substantial evidence supporting the trial court’s finding that Juror 1 was confused about intent; her answers were clear and consistent. The court held that “juror confusion” is a presumptively invalid reason for a peremptory challenge under section 231.7, and that the prosecution failed to rebut this presumption. The judgment was reversed and the case remanded for a new trial. View "P. v. Aguilar" on Justia Law

The appellant was convicted of two felonies in the District Court for Lancaster County, Nebraska, and was sentenced to concurrent one-year terms of imprisonment, followed by 18 months of post-release supervision. Afterward, the appellant was convicted in the District Court for Saline County and received a consecutive two-year prison sentence. The appellant completed both periods of incarceration and subsequently filed a motion in Lancaster County District Court to terminate his post-release supervision, arguing that his progress during incarceration and the imposition of separate sentences warranted terminating supervision.Upon receiving the motion, the Lancaster County District Court held a hearing in which the appellant presented evidence of his progress and support system. The court denied the motion, citing the statutory requirement for post-release supervision, and entered a formal order of denial. The appellant then filed a timely appeal from this order.The Nebraska Supreme Court reviewed the case, first confirming appellate jurisdiction by finding that the denial of the motion to terminate post-release supervision constituted a final, appealable order. On the merits, the court interpreted relevant statutory language and held that post-release supervision is a mandatory period following incarceration and cannot be served while an individual is still imprisoned for another consecutive sentence, regardless of whether the sentences were imposed in different counties. The court further found that the appellant’s progress during incarceration did not provide a legal basis to terminate the statutorily required post-release supervision. Applying an abuse of discretion standard, the Nebraska Supreme Court held that the district court did not err or abuse its discretion in denying the appellant’s motion and affirmed the lower court’s order. View "State v. Jackson" on Justia Law

The case concerns Armon K. Rejai’s conviction for second degree murder following a shooting outside his apartment in Lancaster County, Nebraska, on January 21, 2023. The victim, Julian Martinez, was his 18-year-old neighbor. The incident began with a dispute over dogs being off-leash, escalated to Rejai pepper spraying Martinez and his roommates, and culminated with Martinez pounding on Rejai’s door. Rejai claimed that Martinez lunged at him when he opened the door, prompting him to shoot Martinez in the chest. Martinez later died at the hospital as a result of the gunshot wound.Initially charged with first degree murder and other offenses, Rejai ultimately entered a no contest plea to second degree murder under a plea agreement, and the other charges were dismissed. The District Court for Lancaster County accepted the plea and ordered a presentence investigation report (PSR), which included psychological evaluations revealing that Rejai had autism spectrum disorder, generalized anxiety disorder, and post-traumatic stress disorder. The PSR also showed he had no prior convictions, despite a previous acquittal for terroristic threats. At sentencing, the court imposed the maximum penalty of life imprisonment.The Nebraska Supreme Court reviewed the case after Rejai appealed, arguing that the sentence was excessive. The court held that the district court did not abuse its discretion in weighing mitigating factors, considering the PSR’s contents, or imposing the sentence. The Nebraska Supreme Court reaffirmed that appellate courts are not required to conduct comparative analyses of sentences from other cases and expressly disapproved a contrary statement in State v. Iromuanya. The holding was that Rejai’s life sentence was not excessive and did not constitute an abuse of discretion. The judgment of the district court was affirmed. View "State v. Rejai" on Justia Law

A group of individuals was involved in drug-related activities at a house in Kansas City, Kansas, with Brandon West operating as a seller and user of methamphetamine supplied by his cousin David Carr, who sourced the drugs from James Poterbin. On April 18, 2019, after a drug purchase went awry and money was lost, West contacted Carr and Poterbin, believing that Mariah Vieni had stolen drug proceeds. Vieni’s boyfriend, D.B., was held at the house and, upon Carr and Poterbin’s arrival, was subjected to violence including beating, stabbing, and being shot. The incident led to federal charges against several participants, including Poterbin.The United States District Court for the District of Kansas tried Poterbin alongside Carr. The jury convicted Poterbin on all counts: conspiracy to distribute and possess methamphetamine, kidnapping, and using a firearm in furtherance of a drug-trafficking crime. The district court sentenced him to a total of 480 months' imprisonment and five years of supervised release. Poterbin challenged his convictions and sentence on appeal, raising arguments about the admission of certain evidence, sufficiency of the evidence, and procedural reasonableness of his sentence, among other issues.The United States Court of Appeals for the Tenth Circuit reviewed the case. It held that any error in admitting evidence under Federal Rule of Evidence 404(b) regarding Poterbin’s post-conspiracy drug sales was harmless, given the overwhelming evidence of guilt and limiting instructions provided to the jury. The court found sufficient evidence supporting all convictions, rejected arguments regarding the credibility of witnesses, and determined that the district court’s application of sentencing enhancements did not amount to plain error. The court dismissed Poterbin’s ineffective assistance of counsel claims without prejudice, allowing them to be raised in a collateral proceeding. Ultimately, the Tenth Circuit affirmed Poterbin’s convictions and sentence. View "United States v. Poterbin" on Justia Law

Antonio Eugenio Medina entered a guilty plea following the denial of his motion to suppress evidence in a criminal case. Medina, his attorney, the prosecutor, and the district court discussed and appeared to agree that his plea was conditional, allowing him to reserve the right to appeal the suppression ruling. However, the written judgment did not specify that the plea was conditional as required by the applicable procedural rule.The District Court of Grand Forks County, Northeast Central Judicial District, presided over Medina’s plea hearing and subsequent proceedings. Despite indications in the transcript that all parties consented to a conditional plea, the court did not issue a written order or judgment expressly stating that the plea was conditional, nor did the record contain written consents as required by N.D.R.Crim.P. 11(a)(2). Medina appealed, arguing that his plea should be recognized as conditional so that he could pursue an appeal of the suppression decision.The Supreme Court of North Dakota reviewed the record and found that while the transcript reflected substantial compliance with the requirements for a conditional plea, the absence of a written order and a judgment specifying that the plea was conditional did not satisfy the explicit requirements of N.D.R.Crim.P. 11(a)(2), as amended in 2017. The Supreme Court remanded the case to the district court with instructions to clarify whether it accepted a conditional plea and, if so, to enter an order and correct the judgment to properly reflect the conditional nature of the plea. The Supreme Court retained jurisdiction pending the district court’s clarification. The holding requires district courts to strictly comply with the procedural requirements for conditional pleas under Rule 11(a)(2), including written consents, a court order, and a judgment specifying the plea is conditional. View "State v. Medina" on Justia Law