Justia Criminal Law Opinion Summaries

In June 2013, a masked individual robbed a bank in Aurora, Colorado, taking cash and using a bank bag containing a GPS device. The GPS led police to a car belonging to the estranged wife of Jamale D. Townsell. Evidence collected included clothing, shoes, and a mask, many of which were forensically tested and matched Townsell’s DNA. Cell phone records also placed Townsell near the scene. At trial, Townsell’s defense relied on the mistaken belief that only one piece of evidence—the pantyhose—had been tested for DNA, leading to a trial strategy that did not address the full extent of the DNA evidence. The jury convicted Townsell, and he was sentenced to thirty-two years in prison.The Colorado Court of Appeals affirmed Townsell’s conviction on direct appeal. Townsell subsequently filed a pro se motion for postconviction relief under Crim. P. 35(c), arguing ineffective assistance of counsel due to his attorney’s failure to adequately investigate DNA evidence and to seek further testing of untested items. The postconviction court denied the motion without appointing counsel, finding Townsell had failed to allege facts sufficient to show prejudice. The Court of Appeals affirmed, concluding that Townsell did not explain how additional DNA testing would have overcome the evidence against him or how a DNA expert would have aided his defense.Upon review, the Supreme Court of Colorado affirmed the appellate court’s judgment. The court held that, to warrant appointment of postconviction counsel based on ineffective assistance of counsel, a defendant must allege with some factual basis how counsel’s deficiency caused prejudice under Strickland v. Washington. Because Townsell’s allegations regarding prejudice were conclusory and lacked supporting facts, his claim was deemed wholly unfounded, and the postconviction court did not err in denying his request for counsel. View "Townsell v. People" on Justia Law

Two individuals confronted a man outside a liquor store over an alleged debt. Surveillance footage showed the three men walking into an alley, after which one of the confrontors reemerged, followed by a flash of light and another man running away. The victim was later found in the alley, having suffered fatal gunshot wounds. The prosecution charged one of the confrontors with first degree murder and added crime of violence sentence enhancers, alleging he caused the victim’s death as the shooter.At trial in the Denver District Court, the prosecution was permitted to discuss complicity during jury selection, but the court later rejected a complicity instruction for lack of evidentiary support. The jury convicted the defendant of the lesser included offense of second degree murder, and answered special interrogatories: it found he did not use or possess and threaten to use a deadly weapon, but did cause serious bodily injury or death. The defendant moved to vacate the verdict, arguing the interrogatory responses were inconsistent with the conviction. The trial court denied the motion, finding no logical or legal inconsistency, as use of a deadly weapon was not an element of second degree murder.On appeal, a split panel of the Colorado Court of Appeals vacated the conviction, concluding that the jury’s findings were inconsistent and negated the elements of identity and causation, rendering the verdict infirm. The majority relied on precedent and structural error principles, while a dissenting judge argued the interrogatory did not negate any element, but agreed the verdicts were logically inconsistent absent a complicity instruction.The Supreme Court of Colorado held that the jury’s finding regarding deadly weapon use did not negate any element of second degree murder and that the verdict reflected the jury’s unambiguous intent. Finding no legal or logical inconsistency, the Court reversed the judgment of the Court of Appeals and remanded for consideration of any unresolved issues. View "People v. Shockey" on Justia Law

A woman was convicted of misdemeanor theft and, as part of her sentence, the trial court imposed a one-year term of probation with several conditions. Among these conditions, the court prohibited her from using drugs and alcohol and from entering a bar. At sentencing, she objected to the drug and alcohol monitoring conditions, arguing they were not reasonably related to her theft offense and therefore improper under the legal standard set by an earlier Ohio Supreme Court decision.Following her objection, she appealed to the Eleventh District Court of Appeals. That court agreed with her and vacated the sentence, finding that the probation conditions related to drug and alcohol use violated the three-part test outlined in State v. Jones, 49 Ohio St.3d 51 (1990), because there was no evidence that drugs or alcohol were involved in her theft. The appellate court held that all three prongs of the Jones test must be satisfied for a probation condition to be valid and determined that the trial court abused its discretion in this case.The Supreme Court of Ohio reviewed the case to decide whether the Jones test remains applicable to probation conditions expressly authorized by statute. The Supreme Court held that when the legislature has specifically enumerated certain probation conditions in statute, such as drug and alcohol use monitoring under R.C. 2929.27(A)(8), the Jones test does not apply. Instead, appellate review is limited to whether the trial court abused its discretion. The Supreme Court found that the trial court did not act unreasonably, arbitrarily, or unconscionably in imposing the challenged conditions. As a result, the Supreme Court reversed the Eleventh District’s judgment and reinstated the trial court’s sentencing order. View "State v. Ballish" on Justia Law

The defendant traveled multiple times to the Philippines, where, according to the government, he solicited minors between the ages of eleven and seventeen to perform sex acts in exchange for money, gifts, and food. He was indicted on seven counts of traveling in foreign commerce to engage in sexual activity with minors and seven counts of sex trafficking of a minor. During his change-of-plea hearing, the defendant pleaded guilty to two counts of sex trafficking of a minor, confirming that he understood the plea agreement, was satisfied with his counsel, and entered the plea voluntarily. Afterward, he moved to withdraw his guilty plea, arguing that he felt pressured to sign the agreement the morning of the hearing and that taking the anxiety medication Clonazepam had impaired his cognition.The United States District Court for the Eastern District of Wisconsin held an evidentiary hearing on the motion to withdraw. The district court found that neither the plea colloquy nor the evidence supported the defendant’s claim that his plea was not knowing and voluntary; it relied on his in-court statements, his demeanor, and written admissions in the plea agreement. The district court denied the motion to withdraw his plea.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial for abuse of discretion and its factual findings for clear error. The appellate court concluded that the district court did not abuse its discretion. It found the defendant’s own statements and conduct during the plea hearing, as well as the signed plea agreement, adequately demonstrated that the plea was knowing and voluntary. The court also determined that the defendant’s evidence regarding the effects of his medication was insufficient to justify withdrawal. Therefore, the judgment was affirmed. View "United States v. Stenson" on Justia Law

The case concerns Melvin Trotter, who was convicted of the 1986 first-degree murder of Virgie Langford, a 70-year-old store owner. Trotter stabbed and robbed Langford, resulting in her death several hours after emergency surgery. Following a jury’s recommendation, Trotter was sentenced to death; this sentence was initially reversed, but after a new penalty phase, the trial court again imposed the death penalty, finding multiple aggravating factors and both statutory and nonstatutory mitigation. Trotter’s conviction and sentence became final in 1997, and he has unsuccessfully challenged his death sentence in various state and federal courts since then.After the Governor signed his death warrant in January 2026, Trotter filed a successive motion for postconviction relief and a motion for stay of execution in the Circuit Court for Manatee County. He raised two claims: first, that alleged failures by the Florida Department of Corrections to follow lethal injection procedures violated his constitutional rights, and second, that executing him at age 65 constituted cruel and unusual punishment due to his advanced age. The circuit court summarily denied both claims and denied the stay of execution.On appeal, the Supreme Court of Florida reviewed the circuit court’s summary denial de novo. The Court held that Trotter’s claims regarding lethal injection procedures were speculative and failed to demonstrate a substantial and imminent risk of serious harm, nor did he identify an alternative method of execution as required by precedent. The Court also rejected Trotter’s argument for a categorical exemption from execution based on age, reaffirming prior holdings that only those under 18 at the time of the crime are exempt. The Supreme Court of Florida affirmed the circuit court’s denial of postconviction relief, denied Trotter’s habeas petition as procedurally barred and lacking merit, and declined to stay the execution. View "Trotter v. State" on Justia Law

The case centers on an individual who immigrated to the United States and became involved in a transnational drug trafficking and money laundering conspiracy. His role was to travel across the country collecting large sums of drug proceeds, which he then laundered through a business that purchased used cell phones. These phones were sent to a contact in China as payment for precursor chemicals vital to the drug operation. During one such trip, law enforcement observed him receiving nearly $200,000 in cash and, upon stopping his vehicle, discovered an unloaded firearm and loaded magazine in the van. He admitted to bringing the gun for protection due to the large sums of money he was transporting.He was convicted of money laundering and conspiracy to launder money in the United States District Court for the Eastern District of Kentucky, receiving a 90-month prison sentence and three years of supervised release. His conviction and sentence were affirmed on appeal. While his appeal was pending, the U.S. Sentencing Commission amended the Guidelines to allow certain first-time offenders a two-level reduction in offense level, with exceptions including possession of a firearm “in connection with” the offense. He moved for a sentence reduction under the new provision, but the district court denied the request, finding his possession of the firearm during the offense made him ineligible.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial. The appellate court held that the “in connection with” language should be interpreted broadly and that the close proximity of the firearm to the drug proceeds, along with the defendant’s own admission that the gun was for protection during his criminal activity, established the necessary nexus. The court affirmed the district court’s decision, finding no error in deeming him ineligible for the reduced sentence. View "United States v. Tajwar" on Justia Law

The defendant participated in the robbery of a business known as Cash Express, which offers check cashing, short-term loans, and related financial services. With assistance from his then-girlfriend, the defendant orchestrated the robbery, during which he physically restrained the clerk, brandished a firearm, and escaped with $2,680. Shortly after his arrest, the defendant pleaded guilty to Hobbs Act robbery as part of a plea agreement. Eleven days after signing the agreement, an image implying retaliation against informants was posted on his Facebook profile, which became relevant at sentencing.The United States District Court for the Eastern District of Tennessee sentenced the defendant. The court applied several sentence enhancements: it determined Cash Express was a "financial institution" under the Sentencing Guidelines, imposed a leadership role enhancement, and declined to grant a reduction for acceptance of responsibility due to the defendant's conduct after the plea. The court rejected certain enhancements related to obstruction of justice and reckless endangerment, resulting in a Guidelines range of 151 to 188 months, and sentenced the defendant to 188 months' imprisonment. The defendant appealed, challenging the application of the financial institution and leadership enhancements, the denial of the acceptance of responsibility reduction, and the reasonableness of his sentence.The United States Court of Appeals for the Sixth Circuit reviewed the case. It held that Cash Express qualifies as a "financial institution" under the plain meaning of the term in the Guidelines, affirmed the district court's finding that the defendant acted in a leadership role, and upheld the denial of the acceptance of responsibility reduction due to conduct inconsistent with remorse. The court also found that the sentence was procedurally and substantively reasonable and that the government did not breach the plea agreement. The judgment of the district court was affirmed. View "United States v. Glover" on Justia Law

The defendant was involved in a fatal shooting after following the victim’s vehicle, approaching the victim, and engaging in a verbal confrontation that escalated. The defendant attempted to grab a BB gun from the victim, failed, and then fired four shots with his own firearm, striking and ultimately killing the victim. The defendant claimed he acted in self-defense, asserting he believed the victim was about to use deadly force against him. The evidence included eyewitness testimony and physical evidence regarding the sequence of events and the location of weapons at the scene.The case was initially tried in the Superior Court in the judicial district of New Haven. The jury found the defendant not guilty of murder but guilty of intentional manslaughter in the first degree with a firearm, carrying a pistol or revolver without a permit, and criminal possession of a firearm. The defendant was sentenced to thirty-three years of imprisonment. On appeal, he challenged only his conviction for intentional manslaughter, arguing that (1) the trial court had failed to instruct the jury to unanimously agree on which statutory disqualification to self-defense applied, (2) the jury instructions were misleading regarding the initial aggressor and recklessness-based offenses, and (3) the evidence was insufficient to disprove self-defense or establish intent.The Supreme Court of Connecticut reviewed the appeal. It held that, consistent with its reasoning in State v. Mekoshvili, the federal constitution does not require jurors to unanimously agree on which specific statutory disqualification to self-defense was established, so long as they unanimously reject self-defense. The Court also found no merit in the defendant’s claims of instructional error or insufficiency of evidence. The judgment of the Superior Court was affirmed. View "State v. Matheney" on Justia Law

The case concerns an individual convicted of felony murder, first-degree robbery, and conspiracy to commit first-degree robbery related to a shooting death during a transaction arranged via Craigslist. Key facts established that the victim met with the accused and another man, Marvin Mathis, to sell electronic tablets. The victim was shot and died, and evidence tied the accused and Mathis to the scene through phone records, witness statements, and the accused’s own admissions. A third individual, Thompson, also described a plan to rob the victim.After conviction, Mathis was separately tried and found not guilty by reason of mental disease or defect under Connecticut law, with the court finding he lacked capacity to appreciate the wrongfulness of his conduct or conform it to legal requirements. The petitioner then filed for habeas corpus, arguing that Mathis’ acquittal constituted newly discovered evidence of the petitioner’s actual innocence, since a conspiracy requires the intent of at least two parties.The Superior Court denied the habeas petition, holding that Mathis’ acquittal was irrelevant to the petitioner’s innocence. The Appellate Court disagreed with the legal analysis, holding that evidence from Mathis’ trial should be considered, but still affirmed the denial, finding that a conspiracy could have existed between the petitioner and Thompson.On further appeal, the Connecticut Supreme Court held that while the Appellate Court applied the correct standard by considering aggregate evidence, it erred in concluding that Mathis’ acquittal clearly proved he could not have intended to conspire. The Supreme Court explained that an insanity acquittal does not necessarily negate specific intent, as the underlying findings were made by a preponderance of the evidence, not clear and convincing evidence. Thus, the Court affirmed the judgment, concluding the petitioner had not met the burden to prove actual innocence. View "Moon v. Commissioner of Correction" on Justia Law

A federal prisoner serving a sentence for drug-related offenses sought compassionate release, arguing that he was the only available caregiver for his incapacitated father living in Honduras. The prisoner’s father had become bedridden and previously relied on the care of the prisoner’s former partner, who could no longer provide assistance due to her own health problems. The prisoner asserted that none of his five children could serve as caregivers: one was deceased, one’s whereabouts were unknown, two resided in the United States and could not relocate, and the remaining son, Elmer, lived four hours away in Honduras but faced logistical and economic barriers to providing care.The United States District Court for the Northern District of Florida initially denied the compassionate release motion, finding that the prisoner had not demonstrated the unavailability of other family members as caregivers. After the prisoner renewed his motion with more details, the district court again denied relief, concluding that Elmer, despite living several hours away and having work and family obligations, was nonetheless an available caregiver. The court reasoned that the practical burdens cited were not sufficient to show unavailability.On appeal, the United States Court of Appeals for the Eleventh Circuit addressed the meaning of “only available caregiver” under U.S.S.G. § 1B1.13(b)(3)(C). The court held that an inmate must show that no other person is both qualified and free to provide the needed care, and outlined relevant factors for district courts to consider in making this determination. Applying this standard, the Eleventh Circuit found no clear error in the district court’s determination that Elmer was available to provide care, and affirmed the denial of compassionate release. View "United States v. Robelo-Galo" on Justia Law