Justia Criminal Law Opinion Summaries

Kenneth H. Eastwood was convicted of murder after the body of Cara Hodges was found strangled in a wooded area. Eastwood was the last person seen with the victim and, after being interviewed by police, he confessed to the crime both to his employer and later to law enforcement. During the investigation, Eastwood took a polygraph test and was told by police that he had failed. He subsequently confessed to the murder, describing details of the crime and disposal of evidence. At trial, Eastwood did not testify but presented a false confession expert who opined that his confession was consistent with an internalized false confession, citing factors such as alcohol use, sleep deprivation, and being confronted by police with allegedly objective evidence of guilt.The case was tried in the Circuit Court for Orangeburg County. Eastwood sought to introduce evidence through his expert that police told him he failed the polygraph, arguing it was relevant to his false confession defense. The trial court excluded this evidence, relying on Rule 702 and Rule 403 of the South Carolina Rules of Evidence, finding that polygraph evidence was unreliable and that its admission would confuse the jury and potentially prejudice Eastwood by bolstering the confession’s truthfulness.On appeal, the Supreme Court of South Carolina reviewed whether exclusion of the polygraph evidence was error. The court held that the trial court erred in excluding the evidence under Rule 702, as Eastwood was not offering scientific proof of the polygraph’s reliability but rather the fact that police told him he failed. The Supreme Court found the evidence relevant to the defense and not substantially outweighed by confusion or prejudice under Rule 403. However, the court concluded that the error did not affect the jury’s verdict, as the expert was able to present the core theory of false confessions. The conviction was therefore affirmed. View "The State v. Eastwood" on Justia Law

Four police officers entered a Pittsburgh rowhouse searching for a missing person. Inside, Vincent Smith, the appellant, started a fire that endangered the officers, who escaped unharmed. Smith was rescued and treated for smoke inhalation. The bodies of two men, previously killed by Smith, were found in the residence. Smith admitted to the killings and to starting the fire in a suicide attempt. He was charged with two counts of voluntary manslaughter and four counts of arson endangering persons (AEP), one for each officer present.Smith pled guilty to all charges in the Allegheny County Court of Common Pleas. The trial court sentenced him to consecutive terms for each manslaughter and each AEP count, totaling 26 to 52 years. Smith challenged the legality of receiving multiple sentences for AEP based on a single act of arson that endangered multiple people. The trial court, relying on Commonwealth v. Frisbie, held that each endangered person constituted a separate unit of prosecution under the AEP statute.Smith appealed to the Superior Court of Pennsylvania, arguing that only one sentence for AEP should be imposed per arson, regardless of the number of people endangered. Initially, a panel vacated three AEP sentences, but after reargument, the en banc Superior Court affirmed the trial court, holding that the unit of prosecution was each endangered person.The Supreme Court of Pennsylvania reviewed the case to determine the correct unit of prosecution for AEP under 18 Pa.C.S. § 3301(a)(1)(i). The Court held that the unit of prosecution is each act of arson, not each person endangered. It found the statute ambiguous and applied the rule of lenity, strictly construing it in favor of the defendant. The Supreme Court reversed the Superior Court’s decision, vacated Smith’s sentence, and remanded for resentencing consistent with its holding. View "Commonwealth v. Smith" on Justia Law

Joseph Dwayne Matt was a passenger in Levi Gadaire’s vehicle when it was stopped by law enforcement for erratic driving. Both Matt and Gadaire were probationers, and Matt was flagged as an absconder with an active warrant for his arrest. During the stop, Gadaire admitted to recent methamphetamine use, which led to a search of the vehicle. Officers discovered multiple bags of methamphetamine and drug paraphernalia in the center console. Matt was charged with criminal possession of a dangerous drug with intent to distribute by accountability, and criminal possession of drug paraphernalia.The case proceeded to trial in the Montana First Judicial District Court, Broadwater County. The State’s evidence included testimony from the reporting driver, law enforcement officers, body cam footage, surveillance video, and phone records. Gadaire, who had given multiple inconsistent statements during the investigation, testified that Matt was present during the drug pick-up but later recanted aspects of his testimony. At the close of the State’s case, Matt moved for a directed verdict, arguing that the State’s evidence was insufficient because it relied on uncorroborated accomplice testimony. The District Court denied the motion, and the jury found Matt guilty of criminal possession of a dangerous drug, but not guilty of possession of drug paraphernalia.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court erred in denying Matt’s motion for a directed verdict due to insufficient corroborating evidence. The Supreme Court held that the State failed to provide independent evidence connecting Matt to the crime, apart from Gadaire’s testimony. Mere presence in the vehicle did not meet the statutory requirement for corroboration. The Supreme Court reversed Matt’s conviction, remanded the case, and ordered the District Court to vacate the judgment and dismiss the charges. View "State v. Matt" on Justia Law

Craig Medoff, after a history of violating federal securities laws and failing to comply with prior court orders and penalties, was subject to a 2016 consent judgment in the District of Massachusetts that barred him and any entity he controlled from participating in the issuance, offer, or sale of any security for ten years. Despite this, Medoff continued to control Nova Capital International LLC and engaged in securities-related activities, using an alias and receiving substantial fees in violation of the judgment. The SEC initiated civil contempt proceedings, but the district court, concerned about the futility of further civil sanctions given Medoff’s history and financial situation, instead initiated criminal contempt proceedings under 18 U.S.C. § 401(3) and Federal Rule of Criminal Procedure 42(a).The United States District Court for the District of Massachusetts appointed the U.S. Attorney to prosecute the criminal contempt case. Medoff’s counsel moved for the judge’s recusal under 28 U.S.C. § 455(a), arguing that the judge’s impartiality might reasonably be questioned due to his comments and conduct during the proceedings. The district court denied the recusal motion, finding no reasonable basis for doubting its impartiality, and proceeded with the criminal case. Medoff ultimately pleaded guilty to criminal contempt and was sentenced to twenty months in prison, a variance above the guideline range, and thirty-six months of supervised release, along with a fine.On appeal to the United States Court of Appeals for the First Circuit, Medoff challenged the denial of the recusal motion and the reasonableness of his sentence. The First Circuit held that the district court did not abuse its discretion in denying recusal, as the judge’s actions did not display deep-seated antagonism or favoritism. The court also found the sentence both procedurally and substantively reasonable, affirming the district court’s judgment. View "United States v. Medoff" on Justia Law

In this case, the defendant applied for U.S. citizenship in 2011 and, on his application and during an interview, denied ever having committed a crime for which he was not arrested. However, in 2013, he pleaded guilty in North Carolina state court to attempted statutory rape for conduct that occurred in 2008, admitting to engaging in a sexual act with a minor. He did not disclose this conduct on his naturalization application. Years later, a federal grand jury indicted him for naturalization fraud, alleging he knowingly concealed his criminal history to obtain citizenship.The United States District Court for the Western District of North Carolina denied the defendant’s motion to dismiss the indictment for unconstitutional preindictment delay, finding he had not shown actual prejudice from the delay. The court also denied his motion to suppress evidence of his state guilty plea, ruling that he could not collaterally attack the validity of his state conviction in federal court except for a deprivation of counsel, which did not apply here. At trial, the court limited the testimony of the defendant’s expert witness regarding his cognitive abilities, excluding certain opinions about his capacity to understand the application question. The jury convicted the defendant, finding he knowingly made a false statement, and the court sentenced him to six months in prison and revoked his citizenship.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that the defendant failed to demonstrate substantial actual prejudice from the preindictment delay, that the district court properly refused to suppress the state guilty plea, and that while the limitation of the expert’s testimony was error under recent Supreme Court guidance, the error was harmless given the other evidence presented. The conviction and sentence were therefore affirmed. View "US v. Palmer" on Justia Law

Three individuals, all Cameroonian Americans, participated in a secretive group dedicated to sending firearms and ammunition from Maryland to Anglophone fighters in Cameroon. The group, known as the “Peanut Project,” operated out of a basement in Baltimore County, where they assembled, modified, and packaged weapons and ammunition for overseas shipment. Their concealment methods included obliterating serial numbers from firearms and hiding the items within compressor tanks and other cargo. In 2019, law enforcement intercepted a shipping container en route to Nigeria containing over 35,000 rounds of ammunition and 39 firearms, many with defaced serial numbers. A subsequent search of the group’s base revealed a full-scale operation for manufacturing and preparing firearms for export.A federal grand jury in the United States District Court for the District of Maryland indicted the defendants on five counts, including conspiracy, illegal exportation, transportation of firearms with obliterated serial numbers, and smuggling. After a ten-day jury trial, the defendants were convicted of conspiracy, transporting firearms with obliterated serial numbers, and smuggling, but acquitted on the exportation counts. The district court denied post-trial motions challenging the sufficiency of the evidence and various trial rulings. At sentencing, the court applied enhancements for the number of firearms involved and for trafficking, sentencing each defendant to 63 months’ imprisonment and two years of supervised release.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the convictions and sentences. The court held that the evidence was sufficient to support the jury’s findings, the district court did not abuse its discretion in evidentiary or instructional rulings, and the sentencing enhancements were properly applied. The court also found no error in the oral and written pronouncement of supervised release conditions. The judgments of the district court were affirmed. View "US v. Nji" on Justia Law

Several individuals associated with the Reccless Tigers, a Northern Virginia-based drug gang, were charged with a range of offenses, including drug trafficking, racketeering, kidnapping, and murder. The gang was involved in distributing marijuana and cocaine, and members targeted those who failed to pay drug debts or cooperated with law enforcement. The case centered on the murder of Brandon White, who owed a drug debt and had testified against a gang member. Evidence showed that gang members, including the defendants, orchestrated White’s abduction and murder, with some directly participating in the killing.The United States District Court for the Eastern District of Virginia presided over a joint trial. The court denied several pretrial motions, including requests for continuances, motions to substitute counsel, and a motion to dismiss based on alleged violations of the Speedy Trial Act and the Sixth Amendment. The jury convicted three defendants—Lamborn, Yoo, and Peter—of racketeering conspiracy, murder in aid of racketeering, kidnapping conspiracy, kidnapping resulting in death, drug conspiracy, and killing while engaged in drug trafficking, with Lamborn also convicted of using a firearm resulting in death. Tony was convicted of racketeering and drug conspiracy but acquitted of destructive device charges. The court sentenced Lamborn, Yoo, and Peter to life imprisonment and Tony to 312 months.The United States Court of Appeals for the Fourth Circuit reviewed the case. It affirmed the convictions and most sentences, finding no abuse of discretion in the denial of continuances or substitution of counsel, and sufficient evidence supported the convictions. The court also upheld the district court’s application of sentencing enhancements and rejected the Speedy Trial Act and Sixth Amendment claims. However, it vacated the sentences of Lamborn, Yoo, and Peter due to inconsistencies between the oral pronouncement and written judgments regarding supervised release conditions, remanding for resentencing on that issue. View "US v. Lamborn" on Justia Law

A commercial truck driver was stopped by police in Rankin County, Mississippi, for speeding and following too closely. During the stop, the officer noticed the driver was using paper logs instead of the electronic logs typically required for commercial vehicles, and observed inconsistencies in the logs. The driver, after initial denials, admitted to having over $100,000 in the vehicle, later specifying it was $225,000, which he claimed was for truck repairs or his life savings. The officer obtained consent to search the vehicle and found the cash packaged in multiple envelopes. Further investigation linked phone numbers provided by the driver to ongoing federal drug-trafficking investigations, and a trained narcotics dog showed interest in the cash. The State initiated civil forfeiture proceedings, alleging the money was connected to illegal drug activity.The Circuit Court of Rankin County held a bench trial, heard testimony from law enforcement and an expert in drug trafficking, and issued an order of forfeiture, finding by a preponderance of the evidence that the cash was connected to drug trafficking. The driver appealed, and the Mississippi Court of Appeals, in a split decision, reversed the trial court, concluding the State had not met its burden of proof under the relevant forfeiture statute.The Supreme Court of Mississippi reviewed the case on certiorari. Applying the substantial evidence/clearly erroneous standard, the court found that the trial court’s findings were supported by sufficient circumstantial evidence, including the manner of cash packaging, travel patterns, phone records, and the narcotics dog’s alert. The Supreme Court of Mississippi reversed the judgment of the Court of Appeals and reinstated and affirmed the judgment of the Circuit Court, holding that the State had met its burden to show the currency was more likely than not connected to illegal drug activity and thus subject to forfeiture. View "Chung v. State of Mississippi" on Justia Law

Carlos Jones, Jr. was convicted of attempted aggravated assault after an incident in which he became angry when a neighbor’s visitor honked a car horn, waking him from sleep. Jones confronted his neighbor, Niesha Russell, and after a verbal argument, retrieved a gun from a car, pointed it at Russell, and fired two shots as she fled toward her house. Russell testified that she saw Jones point the gun at her and heard the shots as she ran, though she was not injured. Jones left the scene immediately after the shooting. He later told police that he had fired into the air rather than at Russell.The case was tried in the Circuit Court of Coahoma County, where the State charged Jones with attempted aggravated assault. At trial, the jury heard testimony from Russell and law enforcement. Jones moved for a directed verdict, arguing that the evidence did not show he intended to harm Russell, but the motion was denied. The jury found Jones guilty, and he was sentenced to five years’ imprisonment, with three years to serve and two years of supervised probation. After his motion for a new trial was denied, Jones appealed.The Supreme Court of Mississippi reviewed the conviction. The court held that, when viewing the evidence in the light most favorable to the State, a rational juror could have found beyond a reasonable doubt that Jones intended to shoot Russell, based on the circumstantial evidence that he pointed the gun at her and fired. The court also found that the verdict was not against the overwhelming weight of the evidence, as the jury was entitled to resolve conflicting testimony regarding Jones’s intent. The Supreme Court of Mississippi affirmed the conviction and sentence. View "Jones v. State of Mississippi" on Justia Law

Late one night, a man called police twice, claiming he was being chased, and was found by officers pounding on a homeowner’s door in Beaumont, Mississippi. The man appeared erratic and admitted to drinking. He gave police permission to search his vehicle, which he referred to as “his” car. Inside, officers found a sunglasses case on the dashboard containing a glass pipe and a bag of methamphetamine. While being transported to jail, the man remarked that he “should have gotten rid of that shit before [he] called” the police. Subsequent testing confirmed the substance was methamphetamine, and he was indicted for possession of more than one-tenth gram but less than two grams of a Schedule II controlled substance.The case was tried in the Perry County Circuit Court, where a jury found the defendant guilty of possession of methamphetamine. The court sentenced him to three years in the custody of the Mississippi Department of Corrections. The defendant appealed, arguing that the evidence was insufficient to prove he constructively possessed the methamphetamine and that the verdict was against the weight of the evidence.The Supreme Court of Mississippi reviewed the case. Applying the standard of viewing evidence in the light most favorable to the State, the court held that a rational juror could find the defendant exercised dominion and control over the vehicle and knew about the methamphetamine, especially given his statements and behavior. The court distinguished this case from Ferrell v. State, 649 So. 2d 831 (Miss. 1995), finding additional incriminating circumstances beyond mere proximity. The court concluded that the evidence was sufficient and the verdict was not against the overwhelming weight of the evidence. The conviction and sentence were affirmed. View "Moody v. State of Mississippi" on Justia Law