Justia Criminal Law Opinion Summaries

In this case, the defendant, along with two codefendants, was involved in a series of crimes in 1983 that included kidnapping, robbery, sexual assault, and murder. The three men armed themselves and kidnapped two victims from a park, holding one victim in the trunk and sexually assaulting the other. Both victims were eventually shot in the head—one survived, the other was killed. The defendant admitted to participating in the crimes, including the use of a firearm, and pleaded guilty to first-degree murder, oral copulation in concert, and rape in concert as part of a plea agreement. In exchange, special circumstance allegations were dropped, and other counts were dismissed.The Superior Court of Los Angeles County originally sentenced the defendant to 27 years to life. Decades later, following the enactment of Senate Bill No. 1437, which limited felony-murder liability, the defendant petitioned for resentencing under Penal Code section 1172.6, arguing he was not a major participant who acted with reckless indifference to human life. The Superior Court denied his petition, finding him ineligible for relief because he was a major participant and acted with reckless indifference. On appeal, the Court of Appeal reversed and remanded for an evidentiary hearing, as required by recent case law.After an evidentiary hearing, which included testimony from a retired detective and the defendant’s own statements at a parole hearing, the Superior Court again denied the resentencing petition. The California Court of Appeal, Second Appellate District, reviewed the record under the substantial evidence standard and affirmed the Superior Court’s ruling. The appellate court held that substantial evidence supported the finding, beyond a reasonable doubt, that the defendant was a major participant in the underlying felonies and acted with reckless indifference to human life, making him ineligible for resentencing under section 1172.6. The order denying resentencing was affirmed. View "People v. Grandberry" on Justia Law

In this case, the defendant was convicted by a jury of two counts of first-degree murder with special circumstances, two counts of burglary, and one count of robbery, stemming from a 1986 home invasion burglary in which two victims were killed. The jury imposed the death penalty for each murder, and the trial court sentenced the defendant to death as well as a consecutive determinate term of seven years, which included a one-year enhancement for a prior prison term. The California Supreme Court affirmed the judgment in 1995, and subsequent federal habeas corpus petitions were denied.Years later, the California Department of Corrections and Rehabilitation identified the defendant as potentially eligible for resentencing under Penal Code section 1172.75, because the one-year enhancement for a prior prison term was no longer valid under current law. The defendant requested a full resentencing, including the possibility of striking the special circumstance findings and modifying the death sentence. The People objected, arguing that section 1172.75 did not authorize resentencing of a death sentence, which could only be challenged by a writ of habeas corpus under section 1509. Despite the objection, the Ventura County Superior Court recalled the entire sentence, including the death penalty.The California Court of Appeal, Second Appellate District, Division Six, reviewed the matter. The court held that while Penal Code section 1172.75 authorized recall and resentencing for invalid prior prison term enhancements, it did not empower a trial court to recall or resentence a final, affirmed death sentence. The court found that such action would amount to a collateral attack on the judgment of death, which section 1509—enacted by voter initiative—explicitly reserves for habeas corpus proceedings. The appellate court reversed the trial court’s order recalling the death sentence, affirmed the order as to the noncapital portions, and remanded for resentencing on those noncapital portions only. View "People v. Cain" on Justia Law

In 2008, the petitioner was convicted by a jury of multiple counts, including attempted first degree murder, attempted murder of police officers, infliction of corporal injury on a cohabitant, and attempted arson. The trial court sentenced him to lengthy prison terms and imposed an $8,000 restitution fine under Penal Code section 1202.4, in addition to direct victim restitution and a court security fee. Over a decade later, the California Legislature enacted a statute making restitution fines imposed under section 1202.4 unenforceable and uncollectible after 10 years, and stating that the portion of the judgment imposing such fines is vacated.After the new law took effect, the petitioner sought relief in the Superior Court by filing a habeas corpus petition, arguing that the statutory vacatur of the restitution fine required a full resentencing. When this was denied, he filed a further petition for a writ of habeas corpus in the California Court of Appeal, Fourth Appellate District, Division Two.The California Court of Appeal held that the statute’s vacatur of the restitution fine after 10 years does not entitle the petitioner to a full resentencing. The court reasoned that this change only affects the fine and does not alter the interdependent components of the aggregate prison term. Instead, the court concluded that the proper procedure for reflecting the vacated fine is to file a postjudgment motion in the trial court to correct the abstract of judgment, so it conforms to the judgment as modified by statute. The appellate court denied the petition for writ of habeas corpus, explaining that habeas relief was unavailable because an adequate legal remedy exists—a motion to correct the abstract of judgment in the trial court. View "In re Mattison" on Justia Law

In this case, federal agents used a confidential informant to conduct two controlled purchases of crack cocaine from a person known as “Black.” The informant, Luis Villegas, met “Black” in a courthouse and later identified him as Antwan Eiland through a driver’s license photograph provided by an ATF agent. Subsequent drug deals were arranged and recorded, but the video evidence did not clearly capture Eiland’s face. Additional testimony came from the informant, the ATF agent, and a woman who drove Eiland to one transaction; all identified Eiland as the dealer. Eiland did not testify and argued at trial that he was not “Black.”A grand jury indicted Eiland on two counts of distributing a controlled substance in violation of 21 U.S.C. § 841(a)(1). After a jury trial in the United States District Court for the Northern District of Illinois, Eastern Division, Eiland was found guilty on both counts. Post-verdict, Eiland moved for acquittal based on insufficient evidence and for a new trial arguing juror bias, citing a juror’s remarks about his silence and mask-wearing. The district court denied both motions, finding the evidence sufficient and the juror’s comment inadmissible under Federal Rule of Evidence 606(b).The United States Court of Appeals for the Seventh Circuit reviewed the case. The appellate court held that the evidence was sufficient for a rational jury to find Eiland guilty beyond a reasonable doubt and declined to reassess witness credibility. It found no plain error in the prosecutor’s rebuttal argument, determining that the comments did not improperly reference Eiland’s silence. The court also ruled that the juror’s post-trial comment was inadmissible and did not justify a new trial or evidentiary hearing. The Seventh Circuit affirmed the district court’s judgment. View "USA v Eiland" on Justia Law

After being convicted in 2012 of drug and firearm offenses, a man was sentenced to 180 months in prison and six years of supervised release. He completed his prison term and began supervised release in 2022, but soon violated several conditions, including failing to notify his probation officer of changes in residence and employment, misrepresenting his place of residence, leaving his job without notice, and failing multiple drug tests. These violations led his probation officer to petition for revocation of his supervised release.The United States District Court for the Northern District of Indiana held a revocation hearing in February 2025, where the defendant admitted to the violations. The court determined that the applicable Sentencing Guidelines range was 18 to 24 months. The government sought 30 months’ imprisonment with additional supervised release, while the defendant requested 18 months without further supervision, arguing that supervision would be futile. The court ultimately revoked supervised release and imposed a 36-month prison sentence, citing the seriousness and number of violations, the defendant’s criminal and personal history, and his stated refusal to comply with supervision, while also noting the need for correctional treatment.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the district court improperly lengthened the sentence for rehabilitative purposes, which is prohibited under Tapia v. United States, 564 U.S. 319 (2011). The appellate court found that, although the district court mentioned correctional treatment, it had considered multiple proper grounds for the sentence, including accountability and the defendant’s refusal to comply with supervision. The Seventh Circuit held that there was no Tapia error and affirmed the district court’s judgment. View "USA v Richards" on Justia Law

Three individuals visiting Las Vegas became involved in a confrontation in a casino parking garage, leading to a physical altercation. The appellant joined the fight, and after security intervened, the victims attempted to leave in their car. The appellant pursued them in a rented vehicle, exited to brandish a gun, and later chased them onto a nearby street. Shots were fired into the victims’ vehicle during the pursuit, resulting in the deaths of two individuals and wounding a third. Evidence, including surveillance footage, ballistics, and phone records, implicated the appellant. He admitted to being present and pointing a BB gun but denied participating in the shooting.The Eighth Judicial District Court of Clark County conducted a jury trial, which found the appellant guilty on two counts of murder with the use of a deadly weapon and one count of attempted murder with the use of a deadly weapon. The parties waived the penalty phase, and the court imposed a sentence of life without parole.The Supreme Court of Nevada reviewed several arguments on appeal, including sufficiency of the evidence, prosecutorial misconduct, improper admission of text messages, autopsy photographs, sentencing errors, jury instructions, and cumulative error. The court determined that the evidence supported the jury’s verdict and found no prosecutorial misconduct. It held that the district court erred by admitting unauthenticated text messages, as the State failed to establish their authorship. However, the court concluded this error was harmless given the overwhelming evidence of guilt. The Supreme Court of Nevada found no abuse of discretion in admitting autopsy photographs, sentencing, or jury instructions, and it rejected the claim of cumulative error. The court affirmed the judgment of conviction. View "Talley v. State" on Justia Law

In 1998, a jury convicted Travis Scott Frederickson of two counts of first-degree murder, found that he personally used a firearm, and found true a special circumstance of multiple murder. He was sentenced to life without the possibility of parole. Following changes in California law that gave courts discretion to strike certain firearm enhancements, Frederickson petitioned for resentencing. In 2024, Frederickson asked the Superior Court of Orange County to recall his sentence and resentence him under the amended law. The prosecution agreed that the court could resentence as to the firearm enhancement, but argued that the court could not take any action that would effectively strike or dismiss the special circumstance finding.The Superior Court, however, reduced Frederickson’s convictions from first-degree to second-degree murder and imposed sentences on those lesser charges, including firearm enhancements. The trial court explicitly stated it was not striking or dismissing the special circumstance findings, but rather vacating the first-degree murder convictions; since the special circumstance only attaches to first-degree murder, it no longer applied once those convictions were vacated. The court entered new judgments for second-degree murder and imposed sentences accordingly.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. It held that the trial court did not violate Penal Code section 1385.1—which prohibits judges from striking or dismissing special circumstance findings—by vacating the first-degree murder convictions and resentencing on the lesser offenses under section 1172.1. The appellate court reasoned that when a conviction is validly vacated, the attached special circumstance falls away by operation of law, not by judicial action proscribed by section 1385.1. The Court of Appeal affirmed the judgment. View "People v. Frederickson" on Justia Law

In this case, the defendant was charged with several violent offenses, including first-degree murder and voluntary manslaughter, stemming from incidents that took place over the course of about a year. The defendant entered into a plea agreement covering multiple cases, pleading guilty to first-degree murder, voluntary manslaughter, attempted second-degree murder, and criminal discharge of a firearm at occupied dwellings. In exchange, the State dismissed additional charges. Based on his criminal history and the plea agreement, the defendant faced a controlling sentence of 620 months for first-degree murder and 233 months for voluntary manslaughter, with these sentences to be served consecutively, while all other sentences would run concurrently.The Sedgwick County District Court accepted the plea, reviewed an expert report on the defendant’s drug abuse and mental health, and heard arguments regarding mitigating factors, including the defendant’s age and potential for reform. Despite these arguments, the district court imposed consecutive sentences for the first-degree murder and voluntary manslaughter convictions, citing the presence of two victims as its rationale. The defendant appealed, arguing that the district court abused its discretion by not giving sufficient weight to mitigating factors and by failing to provide a detailed explanation for the consecutive sentences.The Supreme Court of the State of Kansas reviewed the case for abuse of discretion. The court held that neither statute nor caselaw required the district court to consider mitigating factors or to provide a lengthy explanation for its sentencing decision. The court found that the district court’s brief statement—that there were two victims, each entitled to their own sentence—satisfied statutory requirements and was not unreasonable, arbitrary, or based on error. The Supreme Court of Kansas affirmed the judgment, holding that the district court did not abuse its discretion in imposing consecutive sentences. View "State v. Macormac " on Justia Law

Kyle Romey was charged with the first-degree premeditated murder of his mother after her body was found with extensive blunt-force injuries in the trailer home they shared. On the morning of the incident, Romey went to his sister’s house, displayed signs of distress, and admitted to having “hurt Mama . . . bad.” Romey’s sister observed him using methamphetamine and drinking “bong water” before they returned to the trailer and discovered their mother’s body. Romey claimed to have blacked out and not remembered the killing. Police later arrested him; forensic evidence showed blood and DNA from both Romey and his mother on weapons found at the scene.The District Court of Sedgwick County excluded evidence of Romey’s post-arrest drug use, finding it irrelevant to his mental state at the time of the killing due to intervening drug consumption. The court instructed the jury on first-degree premeditated murder and lesser included offenses but denied Romey’s request for a voluntary manslaughter instruction, concluding there was no evidence of sufficient provocation. Romey was convicted by a jury of first-degree premeditated murder and sentenced to life imprisonment with no parole eligibility for more than 54 years, based on a criminal-history score of A. He appealed directly to the Kansas Supreme Court.The Supreme Court of Kansas affirmed the conviction, holding that sufficient evidence supported the jury’s finding of premeditation and that the district court did not err in excluding evidence or refusing the manslaughter instruction. However, the court found that Romey’s criminal-history score was improperly calculated—certain convictions should not have been counted—requiring resentencing. The court also declined to consider Romey’s challenge to the calculation of jail credit because it was not properly preserved, but allowed for this issue to be addressed upon remand for resentencing. The conviction was affirmed, sentence vacated, and the case remanded with directions. View "State v. Romey " on Justia Law

A man was accused by his fiancée’s daughter, “Jane,” of sexually abusing her over several years, beginning when she was four years old. The allegations surfaced after Jane confided in a friend, leading to a criminal investigation. The investigation resulted in the discovery of web bookmarks with pornographic and incestuous titles on the man’s phone and computers. At trial, the prosecution presented testimony from Jane and others about sexual misconduct, as well as evidence of the bookmarks. The man denied the allegations, claiming Jane’s mother fabricated the accusations as part of a custody dispute.The Ellsworth District Court admitted the web bookmark evidence over the defense’s objection, finding it relevant to the charges requiring proof of sexual intent. The jury convicted the defendant on multiple counts, including aggravated criminal sodomy and related offenses. The district court sentenced him to life imprisonment without parole for 50 years, plus a consecutive term. On appeal, the Kansas Court of Appeals affirmed the convictions, upholding the admission of the web bookmarks and finding no prejudicial prosecutorial error or cumulative error.The Supreme Court of the State of Kansas reviewed the case after granting further review. The court held that the web bookmark evidence was properly admitted because it was material and probative to the charged offenses, particularly those requiring proof of sexual intent. The court also found that a prosecutor’s “golden rule” argument during closing was error but deemed it harmless in light of the strong evidence against the defendant. The court further held that, even considering another harmless evidentiary error identified by the Court of Appeals, there was no cumulative error sufficient to deny the defendant a fair trial. The Supreme Court affirmed both the Court of Appeals’ and the district court’s judgments. View "State v. Cunningham " on Justia Law