Justia Criminal Law Opinion Summaries

After Hurricane Harvey in 2017, an individual applied for disaster relief from FEMA, claiming her Houston residence was damaged and providing supporting documentation for her claim, such as hotel receipts, utility bills, and repair estimates. FEMA awarded her approximately $33,000. Later, federal authorities investigated and alleged that the application was fraudulent, asserting that the listed residence did not exist as described, the applicant never lived in Houston, and the supporting documents were fabricated.The United States charged the applicant with disaster relief fraud and wire fraud in the United States District Court for the Southern District of Texas. During trial, the government revealed late disclosures of two items: civil recoupment letters sent to the defendant in 2020 and an email to a third-party contractor who had supposedly inspected the property. The defense argued these late disclosures violated the government's obligations under Brady v. Maryland. The district court ultimately dismissed the indictment without prejudice, citing its supervisory powers and referencing concerns over discovery violations in this and other recent cases before it, despite finding no intentional misconduct by prosecutors.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether the district court erred in dismissing the indictment. The appellate court held there was no Brady violation because the defense failed to show prejudice from the late-disclosed evidence, and the information could have been obtained through reasonable diligence. The court further found that, even assuming a Rule 16 violation, the district court had not properly considered the required factors or imposed the least severe sanction. The Fifth Circuit concluded that the district court abused its discretion in dismissing the indictment and therefore reversed the dismissal order, remanding with instructions to reinstate the indictment. View "USA v. Kuyoro" on Justia Law

In this case, a fatal shooting occurred outside a nightclub in Pima County, Arizona, in September 2020. Law enforcement responded quickly, pursuing a fleeing vehicle driven by the defendant, who was apprehended after a chase. Officers recovered a firearm from the vehicle and cocaine from the defendant. Investigators obtained surveillance footage that depicted the defendant firing shots in the direction of the victim. Bullets striking the victim were not recovered, but shell casings found at the scene were matched to the firearm via ballistics analysis. The defendant was charged with first degree murder and other offenses.The Superior Court in Pima County presided over the trial. During the trial, the prosecutor used leading questions and elicited technical testimony from non-expert witnesses. The defendant did not object during trial. The jury found the defendant guilty on all counts. On appeal, the Arizona Court of Appeals, Division Two, reviewed the claims for fundamental error due to the lack of objections. The majority held that while there was error in the use of leading questions and non-expert testimony, the cumulative effect did not warrant reversal because the errors did not profoundly distort the trial or render it fundamentally unfair. One judge concurred in the result but disagreed on whether leading questions amounted to prosecutorial error, and a dissent argued for a lower standard for cumulative error.The Supreme Court of the State of Arizona granted review to clarify: (1) whether establishing prosecutorial error requires proof of the prosecutor’s mental state, and (2) the proper application of the cumulative error standard set forth in State v. Escalante. The Court held that proof of the prosecutor’s mental state is not required to establish prosecutorial error. It further held that, although prosecutorial errors occurred, the defendant failed to show that the cumulative effect of those errors so profoundly distorted the proceedings as to make the trial fundamentally unfair. The Supreme Court affirmed the convictions and sentences, vacating the court of appeals’ opinion but upholding its disposition. View "STATE OF ARIZONA v. ROMERO" on Justia Law

Law enforcement in St. Louis received a tip that an individual, later identified as Antone Little, was distributing drugs from a residence. Surveillance confirmed drug transactions, including sales of crack cocaine and fentanyl. Upon executing a search warrant, officers found firearms, drug paraphernalia, and over 1,600 pills marked as oxycodone but containing fentanyl. During an interview, Little made statements indicating he knew the pills were counterfeit oxycodone containing fentanyl. Little was indicted on multiple counts and entered a plea agreement, pleading guilty to being a felon in possession of a firearm and possession of a controlled substance with intent to distribute.The United States District Court for the Eastern District of Missouri held a sentencing hearing at which conflicting testimony was presented regarding Little’s knowledge and intent. The court found that Little knowingly possessed and marketed fentanyl pills as oxycodone, applied a four-level sentencing enhancement under USSG § 2D1.1(b)(13)(A), and sentenced Little to 235 months in prison. The court also found Little permanently ineligible for federal benefits under 21 U.S.C. § 862(a)(1)(C). Little appealed both the enhancement and the denial of benefits.The United States Court of Appeals for the Eighth Circuit reviewed the sentence. The appellate court held that the district court did not clearly err in crediting the evidence that Little marketed fentanyl as oxycodone, nor did it err in applying the four-level enhancement. The appellate court also found that any error in applying the enhancement would have been harmless because the district court would have imposed the same sentence as an alternative. However, the appellate court held that the district court erred in permanently denying federal benefits, as Little did not have the requisite prior convictions for distribution offenses. The Eighth Circuit affirmed the prison sentence but vacated the permanent denial of federal benefits. View "United States v. Little" on Justia Law

Bailey Belt and Theodora Belt were charged under the Major Crimes Act for assaulting and murdering Elijah Morrison on the Cheyenne River Sioux Indian Reservation. On the night in question, an argument between the parties escalated into violence, culminating in Elijah being beaten and run over by a car. Surveillance footage from a nearby residence captured portions of the incident, but the video contained gaps. Key physical evidence included Elijah’s blood on Theodora’s car and a DNA mixture on the car’s windshield.The case was tried before the United States District Court for the District of South Dakota. At trial, the government introduced the surveillance footage despite defense objections regarding its authenticity, particularly because the camera owner was deceased and could not testify about the gaps in the video. The jury convicted both Bailey and Theodora. At sentencing, the district court applied a “vulnerable victim” enhancement, finding Elijah was especially susceptible to harm at the time he was run over.Bailey and Theodora appealed to the United States Court of Appeals for the Eighth Circuit, challenging the admission of the surveillance footage and, in Bailey’s case, the application of the vulnerable victim sentencing enhancement. The Eighth Circuit found that the district court did not abuse its discretion in admitting the surveillance footage, concluding that the government met the low bar for authentication based on the totality of the circumstances and corroborating evidence. The court further held that the vulnerable victim enhancement was properly applied, as Elijah became unusually vulnerable during the course of the offense, and this vulnerability was not a factor already incorporated in the relevant sentencing guideline. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Belt" on Justia Law

The case involves a defendant who was charged with felony theft after taking a 2021 Kia Telluride, with the alleged owner identified as Cable Dahmer Kia. The defendant entered into a diversion agreement with the State, which included several stipulated facts, most notably that Cable Dahmer Kia was the owner of the stolen vehicle. After the defendant failed to comply with the terms of the diversion agreement—by not paying fees, failing to obtain a drug and alcohol evaluation, and not maintaining employment or school enrollment—the State moved to revoke the agreement. The defendant stipulated to these violations.Following the revocation, the Wyandotte District Court found the defendant guilty of felony theft based on the stipulated facts and sentenced him to imprisonment, but suspended the sentence in favor of probation and restitution. The defendant appealed to the Kansas Court of Appeals, arguing that the evidence was insufficient because the stipulation did not specify whether Cable Dahmer Kia was a legal “person” as required by statute for ownership. The Court of Appeals affirmed the conviction, finding the stipulation sufficient.On review, the Supreme Court of the State of Kansas considered whether the stipulation that Cable Dahmer Kia was the “owner” of the vehicle was factually and legally adequate to support the felony theft conviction. The court held that, in a trial based on stipulated facts, a defendant may not later contest those facts, and that the stipulation sufficiently established the ownership element required by statute. The court found that the argument about Cable Dahmer Kia’s legal status was unpersuasive, as ownership under the relevant statute was a factual question, not a legal one. The Supreme Court affirmed the judgment of both the Court of Appeals and the district court. View "State v. Cooper " on Justia Law

A police officer stopped a driver after observing him speeding and failing to maintain his lane. Upon approaching the vehicle, the officer smelled marijuana and alcohol, noticed the driver’s slurred speech and bloodshot eyes, and administered field sobriety tests, which indicated impairment. The driver was arrested, and a search of the vehicle revealed marijuana and two open containers of alcohol. He was charged with operating while intoxicated and possession of a controlled substance, both first offenses.At trial in the Iowa District Court for Worth County, the defendant moved for a judgment of acquittal at the close of the State’s evidence, which the district court denied. The jury convicted him on both counts. Afterward, he filed a combined motion in arrest of judgment and for a new trial, arguing both that the verdict lacked sufficient evidence and was contrary to the weight of the evidence. The district court denied the motion, issuing oral and written rulings that referenced both sufficiency and weight-of-the-evidence arguments, but predominantly applied sufficiency-based terminology.On appeal, the Iowa Court of Appeals concluded the district court only ruled on the sufficiency challenge, not the weight-of-the-evidence challenge, and held the defendant failed to preserve error on the new trial motion. The defendant sought further review, which was granted by the Iowa Supreme Court.The Iowa Supreme Court held that the district court erred by applying the sufficiency-of-the-evidence standard, rather than the proper weight-of-the-evidence standard, in ruling on the motion for new trial. The court vacated the Court of Appeals’ decision, conditionally affirmed the district court’s judgment, and remanded with instructions for the district court to reconsider the motion for new trial under the correct legal standard. If the motion is denied on remand, the convictions and sentence will stand. View "State of Iowa v. Jackson" on Justia Law

The case concerns a defendant who was convicted in Mobile Circuit Court of both pharmacy robbery and first-degree robbery. Because he had four prior felony convictions, the State invoked Alabama’s Habitual Felony Offender Act (HFOA) during sentencing. For the pharmacy-robbery conviction, the trial court sentenced him to life imprisonment without the possibility of parole, believing this sentence was mandatory due to the interplay between the HFOA and the Pharmacy Robbery Act, which generally makes those convicted of pharmacy robbery ineligible for parole. For the first-degree robbery conviction, he received a 240-month prison sentence.The defendant appealed to the Alabama Court of Criminal Appeals. That court affirmed the pharmacy-robbery conviction and the accompanying sentence, while reversing the first-degree robbery conviction and remanding with instructions to vacate it. On return to remand, the Court of Criminal Appeals affirmed the judgment in its entirety. The defendant then sought review from the Supreme Court of Alabama, challenging the portion of the Court of Criminal Appeals’ decision affirming his sentence for pharmacy robbery.The Supreme Court of Alabama held that, under the plain language of the HFOA, when that law is properly invoked, the trial court has discretion to sentence a qualifying offender either to life imprisonment with the possibility of parole or to life imprisonment without the possibility of parole. The Supreme Court found that the trial court erred by concluding it was required to impose a sentence without parole, and that the lower appellate court erred in upholding this approach. Accordingly, the Supreme Court reversed the judgment of the Court of Criminal Appeals as to the pharmacy-robbery sentence and remanded the case for further proceedings consistent with its opinion. View "Ex parte Spencer" on Justia Law

The case involved a defendant charged with several crimes, including first degree murder, for which the State sought the death penalty. The State’s charging documents included notice of three aggravating circumstances relevant to the potential imposition of the death penalty. After being served with the information, the defendant filed multiple pretrial motions, including motions to quash the information and amended informations on grounds related to alleged defects in the aggravating circumstances and constitutional challenges to Nebraska’s death penalty statutes. Each motion was accompanied by a request for a pretrial hearing. The procedural timeline included multiple amended informations, motions for a bill of particulars, motions for discovery, and a motion to suppress, with corresponding hearings and arraignment dates postponed at the defendant’s request or with his consent.The District Court for Washington County found several periods of delay excludable from the six-month speedy trial calculation under Nebraska’s speedy trial statute, Neb. Rev. Stat. § 29-1207. The court excluded time for the defendant’s motions and continuances, ultimately determining that the defendant’s motion for absolute discharge on speedy trial grounds was premature because the statutory period had not expired.The Nebraska Supreme Court independently reviewed the undisputed facts and the application of the speedy trial statute. It held that all three defense motions to quash—challenging the aggravating circumstances—were pretrial motions resulting in periods of delay excludable under § 29-1207(4)(a), and that its previous decision in State v. Covey did not apply to the facts here. Additionally, the Court found that delays stemming from the defendant’s requests to postpone arraignments for the purpose of filing and litigating these motions were continuances excludable under § 29-1207(4)(b). The Court affirmed the district court’s denial of the defendant’s motion for discharge. View "State v. Collins" on Justia Law

In 2004, a man was convicted by a jury of two counts of first-degree felony murder and one count of attempted first-degree felony murder, all under an aiding-and-abetting theory. The convictions stemmed from a shooting at a home in Saint Paul, Minnesota, where two people were killed and a third was seriously injured. The prosecution's evidence included eyewitness testimony identifying the man as an active participant, testimony that all three assailants were armed, and evidence of the man’s actions before, during, and after the shooting. The defendant presented his own testimony and that of a co-defendant, both claiming he did not have a gun and was unaware of the shooter’s intent. The jury found him guilty on all counts.After his convictions were affirmed on direct appeal by the Supreme Court of Minnesota in 2006, and after several unsuccessful postconviction petitions, the defendant sought to vacate his first-degree felony murder convictions in 2024 under a newly enacted statute. This law allows individuals convicted under prior aiding-and-abetting felony murder statutes to challenge their convictions if they can prove, by a preponderance of the evidence, that they did not act with intent to kill. The district court denied his petition after an evidentiary hearing, finding that he failed to meet his burden of proof.On appeal, the Supreme Court of Minnesota reviewed the district court’s denial for abuse of discretion. The court held that the district court did not abuse its discretion in denying the petition to vacate, and that it properly weighed the evidence presented. The court clarified that the district court was not required to resolve uncertainties in favor of the petitioner at the evidentiary hearing stage. Accordingly, the Supreme Court of Minnesota affirmed the district court’s decision. View "Green vs. State" on Justia Law

Steven Wilmot worked distributing business cards for a bail company near a police station. Early one morning, Wilmot confronted Franklin Washington, who was in a tent on the street, about allegedly selling him fake methamphetamine. The confrontation escalated in three stages, with Wilmot making demands for a refund or replacement, Washington responding with threats, and eventually brandishing what Wilmot believed was a knife. After a brief retreat, Wilmot returned, stabbed Washington in the chest, and fled. Wilmot testified he intended only to injure Washington, not kill him, citing anger from the confrontation and fear for his own safety, and was surprised to learn Washington had died.The Superior Court of Los Angeles County presided over Wilmot’s trial, where a jury acquitted him of first degree murder but convicted him of second degree murder. During the trial, the court modified the standard CALCRIM jury instruction for voluntary manslaughter, adding language that told the jury they could convict Wilmot of voluntary manslaughter only if they found he “unintentionally” killed Washington in the heat of passion. The court underlined “unintentionally” for emphasis. Wilmot appealed, arguing this addition was prejudicial legal error as it improperly limited the jury’s ability to consider voluntary manslaughter for intentional killings committed in the heat of passion.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. The appellate court held that the trial court’s modification was erroneous because, under established California Supreme Court precedent, voluntary manslaughter can include intentional killings committed in the heat of passion or with a reckless disregard for life. The appellate court found the error was not cured by other jury instructions or arguments by counsel and could have affected the verdict. The court vacated Wilmot’s conviction and remanded the case for a new trial. View "People v. Wilmot" on Justia Law