Justia Criminal Law Opinion Summaries

A married couple who had served as foster parents were indicted for capital murder in connection with the death of an infant, E.E., who had been placed in their care by the Marshall County Department of Human Resources due to his medical needs and his parents’ inability to care for him. The child, who required a feeding tube and frequent hospitalization, died while in their custody. In July 2024, a Blount County grand jury indicted both individuals for capital murder, and they were denied bail by the Blount Circuit Court after evidentiary hearings.The petitioners each moved for bail, arguing that the State had the burden to present evidence sufficient to show they were not entitled to bail. The State countered that, in capital cases, the indictment itself creates a presumption of guilt for purposes of bail, and the burden shifts to the defendants to overcome this presumption. The Blount Circuit Court agreed with the State, denied bail, and found that the evidence did not overcome the presumption arising from the indictment. The Court of Criminal Appeals subsequently denied habeas petitions challenging the denial of bail.Upon review, the Supreme Court of Alabama reaffirmed the longstanding “presumption rule,” which holds that, in capital cases, an indictment creates a presumption of guilt for purposes of bail, and the defendant must overcome this presumption by presenting sufficient evidence. The Court declined to overturn this rule, citing stare decisis and legislative acquiescence, especially in light of recent constitutional and statutory amendments. The Court held that the trial court did not err in denying bail because the petitioners had not overcome the presumption of guilt, and it denied both petitions for writs of habeas corpus. View "State of Alabama v. Grimes" on Justia Law

The case concerns allegations of sexual abuse committed by the defendant against a complainant when she was between the ages of four and ten during visits to the defendant’s home. The complainant testified that the defendant engaged in multiple acts of sexual assault over several years, including threats to her and her family to ensure her silence. After the complainant disclosed the abuse to her mother, law enforcement became involved, which led to the defendant’s indictment on multiple charges, including pattern aggravated felonious sexual assault, felonious sexual assault, and criminal threatening.In Superior Court, the defendant moved for in camera review of the complainant’s counseling records, which the court partially granted. The State successfully moved to allow the complainant to testify by two-way live video feed from outside the defendant’s presence, arguing that testifying in front of the defendant would cause her trauma and render her unavailable. During the trial, the complainant testified remotely. After the State rested, several charges were dismissed or nol prossed by agreement, and the jury ultimately convicted the defendant on the remaining counts.The Supreme Court of New Hampshire reviewed the case. It held that allowing the complainant to testify remotely, outside the defendant’s presence, violated his confrontation right under Part I, Article 15 of the New Hampshire Constitution as interpreted in State v. Warren. The court found that this right requires a face-to-face, in-person meeting between the accused and the witness. The court also held that the evidence was insufficient to support the conviction for one pattern aggravated felonious sexual assault charge involving sexual intercourse, as the complainant’s testimony did not establish that the acts occurred over the required statutory period. The court reversed the conviction on that charge and remanded the remaining convictions for further proceedings, vacating the trial court’s discovery order in part for additional review in light of a recent precedent. View "State v. Brousseau" on Justia Law

The petitioner was convicted in 2005 of multiple non-murder offenses, including assault with intent to kill, for shooting at police officers when he was twenty years old. He received consecutive sentences totaling thirty-one to forty-three years in state prison, making him eligible for parole after thirty-one years, followed by probation. In 2024, the petitioner sought resentencing, arguing that his aggregate sentence exceeded the parole eligibility period now required for emerging adults convicted of first-degree murder, relying on recent case law recognizing heightened constitutional protections for such offenders.The Massachusetts Appeals Court previously affirmed the petitioner’s convictions. In the resentencing proceedings, the petitioner retained a forensic psychologist who conducted a personal examination and produced a report suggesting he was rehabilitated. After disclosing this report to the Commonwealth, the Commonwealth successfully moved in the Superior Court for a reciprocal, court-ordered psychiatric examination by its own expert, arguing that the petitioner had put his mental health at issue. The Superior Court’s order was based on the expectation that the petitioner would rely on expert testimony at the resentencing hearing. Before the examination was conducted, the petitioner sought relief from this order in the Supreme Judicial Court for Suffolk County, but a single justice denied the petition.On appeal, the Supreme Judicial Court of Massachusetts reviewed whether a judge may permit limited reciprocal discovery, such as a psychiatric evaluation, in a postconviction resentencing proceeding when the petitioner intends to rely on expert opinion derived from a personal examination. The court held that when a petitioner makes a prima facie showing for postconviction resentencing and elects to present psychological expert evidence based on a personal evaluation, the Commonwealth may be permitted a reciprocal examination to ensure fairness and accurate fact-finding, subject to appropriate protections. The judgment of the single justice was affirmed. View "Berry v. Commonwealth" on Justia Law

A cardiovascular intensive care nurse was accused of intentionally causing the deaths of several post-operative patients and injuring others by injecting air into their arterial lines during his overnight shifts at a Texas hospital. The incidents occurred between January 2017 and January 2018, and each victim experienced unexpected strokes with a unique pattern of brain injury that was later traced to air embolisms. Evidence presented at trial showed that the defendant was present or nearby during each patient’s medical crisis, often without being assigned to their care. Suspicion arose when these incidents stopped after he was removed from the hospital schedule.A jury in the 114th Judicial District Court of Smith County convicted the defendant of capital murder for killing one named victim and at least one of three other named victims in separate criminal transactions, but as part of the same scheme or course of conduct. Based on the jury’s answers to special sentencing issues, the trial court imposed the death penalty. The defendant raised thirteen points of error on direct appeal, arguing issues including jury unanimity, voir dire limitations, admission of extraneous offense evidence, denial of lesser included offense instructions, improper prosecutorial argument, violation of his right against self-incrimination, and the constitutionality and application of Texas’s capital sentencing statute.The Court of Criminal Appeals of Texas reviewed the case. It held that the jury instructions did not violate state or federal unanimity requirements, the admission of extraneous offense evidence was proper, and the evidence supported the jury’s finding of future dangerousness. The court also rejected constitutional challenges to the Texas death penalty scheme and found no reversible error in the trial proceedings. Accordingly, the court affirmed the conviction and sentence of death. View "DAVIS v. STATE OF TEXAS" on Justia Law

In 2001, after a failed business partnership, an individual kidnapped and killed his former partner. The police investigation began when the victim’s family reported him missing and started receiving ransom calls, which were traced to the accused. Upon arrest, the accused gave a false account, alleging he had been kidnapped, but evidence contradicted his story. Surveillance footage, ballistic evidence, and the eventual discovery of the victim’s body all implicated the accused. At trial, the jury convicted him on multiple charges, including kidnapping and first-degree manslaughter, and recommended a life sentence, which the court imposed.Following his conviction, the accused pursued various appeals and collateral challenges. On direct appeal, he explicitly waived his right to counsel and chose to proceed pro se, despite warnings from the Kentucky Supreme Court and the Department of Public Advocacy. The Kentucky Supreme Court ultimately affirmed his conviction and sentence. Subsequent collateral attacks under Kentucky Rule of Criminal Procedure 11.42 were largely unsuccessful, though he did secure a resentencing on one count, which resulted in the same effective sentence. Further attempts to challenge his conviction, including a second belated appeal and additional Rule 11.42 motions, were denied as untimely or successive, with these decisions upheld on appeal.The United States Court of Appeals for the Sixth Circuit reviewed two claims from his federal habeas petition: whether he was improperly allowed to proceed pro se on direct appeal, and whether trial counsel was constitutionally ineffective during closing arguments. The court held that the accused knowingly and intelligently waived his right to appellate counsel. On the ineffective assistance claim, the court found it procedurally defaulted and not subject to any exception, as the claim lacked merit and he had not shown prejudice. The court affirmed the district court’s dismissal of the habeas petition. View "Gaither v. Lane" on Justia Law

A group of individuals, including the petitioner, became involved in a series of drug-related activities centered around a home in Parkersburg, West Virginia. After the petitioner purchased drugs from Tiffany McCune, he became dissatisfied with their quality, leading to several confrontations and exchanges between the parties. The situation escalated when the petitioner returned to the McCune home, forcibly entered, and assaulted Tiffany with a pistol. During the ensuing chaos, Darren Salaam Sr., who was present in the house, was shot in the back and later died from his wounds. The petitioner fled the scene but was later apprehended. Upon arrest, he made racially charged statements, and photographs taken at booking displayed his swastika and Aryan Brotherhood tattoos.The Circuit Court of Wood County presided over the petitioner’s jury trial. The jury convicted him of felony murder, finding that the underlying felony was burglary. The petitioner was sentenced to life without the possibility of parole. During the trial, the court admitted evidence of the petitioner’s tattoos and statements, as well as Tiffany McCune’s statements to police and a 9-1-1 call, over the petitioner’s objections on various evidentiary and constitutional grounds. The petitioner’s post-trial motions for acquittal and a new trial—primarily challenging the sufficiency of the evidence on the burglary element—were denied.On appeal, the Supreme Court of Appeals of West Virginia reviewed the evidentiary rulings for abuse of discretion and the constitutional claims de novo. The court held that the tattoo evidence was relevant to motive and not unfairly prejudicial, Tiffany’s statements were admissible as excited utterances and not testimonial under the Confrontation Clause, and the evidence was sufficient to support the felony murder conviction. The court affirmed the circuit court’s judgment. View "State v. Thompson" on Justia Law

Three men were implicated in the shooting death of an individual inside a ransacked townhome, where stolen items and evidence of forced restraint were discovered. Investigators connected the suspects to the scene through surveillance footage, fraudulent use of a credit card, recovery of stolen items from their residences, and cell phone records indicating communications and location proximity to the crime. A rented maroon vehicle, tied to one defendant, was placed at the scene by GPS data. The suspects’ explanations at trial were contradicted by physical and circumstantial evidence.A Fulton County grand jury indicted all three for malice murder, felony murder, home invasion, burglary, armed robbery, aggravated assault, false imprisonment, firearm offenses, and related fraud crimes. At a joint jury trial in December 2018, two defendants were found guilty on all counts, while the third was acquitted of malice murder but convicted on other charges. The trial court imposed life sentences, some without parole, and additional concurrent and consecutive sentences for other offenses. The defendants filed motions for new trial, which were denied by the trial court in November 2024. They appealed to the Supreme Court of Georgia.The Supreme Court of Georgia affirmed the convictions and sentences. The Court held that the evidence was sufficient to support the convictions, both as a matter of federal constitutional due process and Georgia law, including circumstantial evidence standards. The Court found no prejudicial error regarding the use of leg restraints, missing trial exhibits, or jury instructions, and concluded that related claims were either unpreserved or without merit. Claims of ineffective assistance of counsel and cumulative error were rejected for lack of deficient performance, prejudice, or both. The denial of speedy appeal and other procedural claims was also affirmed. View "Gines v. State" on Justia Law

The defendant entered a bank in Baton Rouge, Louisiana, and gave a cashier a note demanding money and threatening harm to everyone present. Believing he was armed, the cashier complied, handing over approximately $20,000. The defendant was later arrested and pled guilty to bank robbery under federal law. In the presentence report, the probation officer recommended a career-offender sentencing enhancement based on two prior Louisiana convictions: one for armed robbery and another for attempted armed robbery.At sentencing, the United States District Court for the Middle District of Louisiana agreed with the presentence report's assessment and found that the defendant qualified as a career offender under the United States Sentencing Guidelines § 4B1.1(a). As a result, the defendant’s offense level and criminal history category were increased, resulting in a recommended guideline range of 151 to 188 months. The district court sentenced the defendant to 151 months in prison and three years of supervised release. The defendant objected, arguing that Louisiana armed robbery does not categorically qualify as a “crime of violence” for purposes of the Guidelines.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s determination de novo. The appellate court concluded that Louisiana’s armed robbery statute requires the intentional use, attempted use, or threatened use of physical force, and not merely reckless or negligent conduct. The court found that the defendant failed to show any realistic probability that Louisiana would apply its statute to unintentional acts. Therefore, the Fifth Circuit held that Louisiana armed robbery constitutes a “crime of violence” under the force clause of the Sentencing Guidelines and affirmed the district court’s sentence. View "USA v. Lanaute" on Justia Law

Several Iraqi citizens detained at Abu Ghraib prison during the U.S. occupation of Iraq alleged that, between October and December 2003, they were subjected to severe abuse by military police. The plaintiffs claimed that employees of CACI Premier Technology, Inc., a contractor providing interrogation services to the U.S. military, conspired with military personnel to “soften up” detainees for interrogation, resulting in torture and cruel, inhuman, and degrading treatment (CIDT). While CACI’s contract required its personnel to operate under military supervision, evidence suggested inadequate oversight and that CACI employees directed some of the abusive tactics. Plaintiffs did not allege direct physical abuse by CACI interrogators, but asserted conspiracy liability.The case was initially filed in the United States District Court for the Eastern District of Virginia, advancing claims under both the Alien Tort Statute (ATS) and state law. Over time, the plaintiffs narrowed their suit to ATS claims for torture, CIDT, and war crimes, proceeding on conspiracy and aiding-and-abetting theories. The district court dismissed some claims and parties, and after two trials—one ending in mistrial—the jury found CACI liable for conspiracy to commit torture and CIDT, awarding significant compensatory and punitive damages.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed multiple legal challenges by CACI, including justiciability, immunity, preemption, and the state secrets privilege. The court held that application of the ATS was proper because the conduct at issue occurred within U.S.-controlled territory (Abu Ghraib during the CPA regime), was actionable under universal jurisdiction principles, and enough domestic conduct was involved. The court found that conspiracy liability and corporate liability are recognized under the ATS, and rejected CACI’s defenses and challenges regarding sovereign immunity, political question doctrine, preemption, and evidentiary rulings. The Fourth Circuit affirmed the judgment against CACI, vacated the district court’s judgment in favor of the United States on third-party claims due to sovereign immunity, and remanded with instructions to dismiss those claims. View "Al Shimari v. CACI Premier Technology, Inc." on Justia Law

The case involves a defendant who was convicted of two counts of felony murder after setting fire to his estranged girlfriend’s apartment, resulting in the deaths of her two roommates. The relationship between the defendant and his girlfriend was tumultuous, and on the night of the incident, after a series of arguments and threatening communications, the defendant poured gasoline on the apartment couch and set it ablaze. Surveillance footage placed him at the scene, and an arson investigator determined that accelerant had been used. Following his arrest, the defendant was interrogated by police and ultimately confessed to pouring the gasoline but denied intending to kill anyone.In Multnomah County Circuit Court, the defendant moved to suppress statements made during his police interrogation, arguing they were involuntary, and filed a demurrer contending that Oregon’s felony-murder statute, ORS 163.115(1)(b), violated due process by either creating an impermissible presumption regarding the mental state or by imposing strict liability for murder. The trial court denied both motions, finding the confession was voluntary under the totality of the circumstances and that the statute did not violate due process. The defendant was convicted, and the Oregon Court of Appeals affirmed, agreeing with the trial court’s rulings.The Supreme Court of the State of Oregon reviewed both issues. It held that the trial court did not err in declining to suppress the confession, emphasizing that, under the totality of the circumstances, the statements were voluntary and not the product of coercion or improper inducement. The court further held that Oregon’s felony-murder statute, as previously interpreted in State v. Blair, does not violate the Due Process Clause because it does not create a conclusive presumption regarding mental state or impose unconstitutional strict liability. The Supreme Court of Oregon affirmed the decisions of both the Court of Appeals and the circuit court. View "State v. Monaco" on Justia Law