Justia Criminal Law Opinion Summaries

A hospital employee discovered that someone had posted on social media a screenshot from the hospital’s internal system, revealing Supreme Court Justice Ruth Bader Ginsburg’s name, dates of ten medical visits, and the types of services she received. The post, which first appeared on an anonymous online forum, fueled conspiracy theories regarding the Justice’s health. The hospital investigated and identified two employees who had inappropriately searched for the Justice’s information, ultimately focusing on Trent Russell, who worked for a non-profit with access to patient records. Forensic analysis linked Russell’s home computer to the search, and evidence showed he formatted his hard drive after his access was revoked. He was charged with unlawfully obtaining health information, unlawfully destroying records, and disclosing health information.The United States District Court for the Eastern District of Virginia denied Russell’s motion to suppress statements made to federal agents during an interview at his workplace. The court found no coercion despite the presence of his employer’s CEO. The court also limited cross-examination of an agent regarding Russell’s explanations for the search, sustaining a hearsay objection but allowing other avenues to explore bias. At trial, the jury convicted Russell of obtaining individually identifiable health information and destroying records, but acquitted him of disclosing health information. The district court sentenced him to 24 months’ imprisonment.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that Russell’s interview statements were voluntary, as there was no evidence of coercion or threats. The court found no abuse of discretion in the district court’s limitation of cross-examination, and any error was harmless given the other evidence of bias. It also held that the information Russell obtained qualified as “individually identifiable health information” under federal law. The Fourth Circuit affirmed the judgment in full. View "US v. Russell" on Justia Law

The defendant owned and operated a company that provided paycard services to restaurant employees, allowing them to receive wages on debit cards. Over time, he misused the funds entrusted to his company by transferring payroll money to his personal brokerage account and engaging in risky options trading, without disclosing these actions to his clients. When losses mounted and funds were missing, he misled both the client company and cardholders about the shortfall, imposed new fees retroactively, and restricted access to account information under the guise of privacy concerns. After the business relationship ended and his company lost its only client, he applied for a Paycheck Protection Program loan using falsified bank records, misrepresenting his company’s operations, and diverted those funds to his brokerage account as well.The United States District Court for the Eastern District of Virginia indicted him on multiple counts of wire and mail fraud based on both the paycard and PPP loan schemes. He moved to sever the count relating to the PPP loan, arguing that combining the two schemes in one trial was improper and prejudicial, but the district court denied severance, finding the counts properly joined and prejudice curable. After a jury convicted him on all counts, the district court applied a sentencing enhancement for the use of sophisticated means, resulting in an 87-month prison sentence.On appeal, the United States Court of Appeals for the Fourth Circuit held that the evidence was sufficient to support the jury’s finding of fraudulent intent and that the sophisticated-means sentencing enhancement was supported by the record. The court also found that joinder of the paycard and PPP fraud schemes was proper, as there were material overlaps in method and evidence, and affirmed the district court’s discretion in denying severance. The judgment was affirmed. View "US v. Lawrence" on Justia Law

After a traffic stop for a cracked windshield, law enforcement officers discovered that the defendant, a passenger in the car, possessed open containers of alcohol and attempted to hide a pipe containing methamphetamine residue. A further search uncovered another pipe for marijuana and several grams of marijuana, which the defendant admitted owning. The defendant, a Mexican national who had previously been removed from the United States in 2011 but later reentered illegally, was charged with multiple offenses. He ultimately pleaded guilty to felony possession of a controlled substance and felony destruction of evidence, in exchange for which the State agreed to recommend probation and to drop two misdemeanor charges.The District Court of the Seventh Judicial District in Bingham County presided over sentencing. Both the defense and the State recommended probation, noting factors in the defendant’s favor, such as his lack of prior criminal history and his ongoing substance abuse treatment. However, the district court questioned whether the defendant could comply with probation, given his unlawful presence in the United States and his history of reentering after removal. Concluding that the defendant could not comply with federal law—a standard probation condition—the court denied probation and imposed an indeterminate five-year prison sentence with eligibility for parole at any time.On appeal, the Idaho Supreme Court reviewed whether the district court abused its discretion by denying probation based solely on the defendant’s undocumented status. The Idaho Supreme Court held that a sentencing court may consider a defendant’s immigration status when assessing the ability to comply with standard probation conditions, but immigration status alone does not make a defendant ineligible for probation. Because the district court based its decision on the defendant’s inability to comply with federal law due to his ongoing unlawful presence, not merely his immigration status, the Idaho Supreme Court affirmed the district court’s sentence. View "State v. Garcia" on Justia Law

The case involves a defendant who was charged with sexual assault by one in a position of trust and aggravated incest against his two minor children, N.L. and A.L. After their initial interviews with a social worker failed to produce accusations, both children later alleged sexual abuse by their father during forensic interviews with Kim Grimm. The defense’s theory was that the children’s maternal grandmother, who wanted to keep custody, had coached them to fabricate or form false memories of abuse. Throughout the trial, the defense repeatedly raised this coaching theory, supporting it with evidence and argument.After the jury found the defendant guilty on all counts, he appealed to the Colorado Court of Appeals. The division concluded that the expert’s testimony—that she perceived no indication of coaching during her interviews with the children—was inadmissible, as it amounted to improper vouching for the children’s credibility. However, the division upheld the trial court’s decision to allow this testimony under the “opening the door” doctrine, finding that the defense had clearly intended to suggest to the jury that the grandmother coached the children, thus permitting the otherwise inadmissible testimony for context.The Supreme Court of Colorado reviewed the case on the narrow question of whether the defense had “opened the door” to the challenged expert testimony. The court assumed, without deciding, that the testimony was otherwise inadmissible. It held that the defense’s persistent introduction of the coaching theory throughout trial opened the door to Grimm’s expert opinion that she saw no indication of coaching. The court affirmed the judgment of the Court of Appeals and remanded the case for further proceedings consistent with its opinion. View "Lopez v. People" on Justia Law

The defendant was arrested and charged with multiple sexual assault offenses involving a 16-year-old girl. After being released on bail, he failed to appear at a scheduled arraignment, leading to a bench warrant and a delay of more than six years before he was returned to custody and the case moved forward. During jury selection for his trial, a prospective juror (PJ183) identified herself as a newly graduated nurse. The prosecutor used a peremptory challenge to excuse her, stating, “she is a nurse.” Defense counsel objected, referencing California Code of Civil Procedure section 231.7, but did not argue that the prosecutor’s stated reason was presumptively invalid under the statute. The trial court overruled the objection, focusing only on the reason provided.A jury in the Superior Court of Orange County found the defendant guilty of all charges, and the court found aggravating factors true. He was sentenced to 26 years in prison. On appeal, the defendant argued that the prosecutor’s reason for excusing PJ183—a nurse—was presumptively invalid under section 231.7, subdivision (e)(10), because nursing is a field disproportionately occupied by women, a protected group under the statute. The Attorney General contended that the defendant forfeited this argument by not raising the presumptive invalidity at trial.The California Court of Appeal, Fourth Appellate District, Division Three, held that the defendant did not forfeit his argument. The Court explained that section 231.7 requires the trial court, when ruling on a peremptory challenge objection, to meaningfully consider whether any stated reason is presumptively invalid—even if not explicitly identified by the objecting party. Because the trial court failed to make this inquiry or create a record of doing so, the Court reversed the judgment and remanded the case for a new trial. View "P. v. Espiritu" on Justia Law

A Kentucky-based luxury car broker persuaded the owner of a Tennessee car dealership to wire over $80,000 for the purchase of a specific Mercedes vehicle. The broker, communicating through text messages and emails, sent an invoice and a bill of sale falsely representing ownership and authority to transfer the car. After receiving the funds, he neither delivered the vehicle nor returned the money. Instead, he spent portions of the funds on personal expenses, including a vacation. Despite multiple requests and promises to return the money, the broker did not fulfill his obligations.A Loudon County grand jury indicted the broker for theft of property over $60,000 under Tennessee law. The defendant moved to dismiss the indictment, arguing that Tennessee lacked territorial jurisdiction, but the Loudon County Criminal Court denied the motion. At trial, the defendant gave inconsistent testimony about his involvement. The jury found him guilty, and the trial court sentenced him to ten years, with part of the sentence to be served in prison and the remainder on probation, along with restitution. The defendant’s motion for a new trial was denied. On appeal, the Tennessee Court of Criminal Appeals affirmed the conviction, finding that territorial jurisdiction was proper because the crime was consummated in Tennessee and that the victim’s consent was ineffective because it was induced by deception.The Supreme Court of Tennessee reviewed the case and held that Tennessee courts had statutory territorial jurisdiction under Tennessee Code Annotated section 39-11-103(b) because the theft offense was consummated in Tennessee through electronic communications originating from Kentucky. The court also found that the evidence was sufficient to support the conviction, as the victim’s consent to transfer the funds was obtained through deception. The Supreme Court of Tennessee affirmed the judgment of the Court of Criminal Appeals. View "State of Tennessee v. Lacy" on Justia Law

The case involved a man who entered the on-base military residence of his estranged wife while holding a firearm, intending to retrieve his young daughter. Upon finding his wife and another service member together, he threatened the service member with the gun, ordering him to leave the house. The situation escalated, resulting in a police response and the man’s subsequent detention with his daughter and mother. He was charged with three felonies: two counts of assault with a dangerous weapon (against the service member and his wife) and one count of domestic violence, all within the special territorial jurisdiction of the United States.The United States District Court for the District of Kansas presided over the trial. The jury convicted the defendant of assault with a dangerous weapon against the service member but acquitted him of the other charges. The defendant filed a motion for a new trial based on newly discovered evidence suggesting the government’s key witnesses had lied about their relationship. The district court denied this motion, concluding that the defendant had not exercised reasonable diligence in discovering the evidence before trial. At sentencing, the district court imposed a 24-month sentence and two years of supervised release, citing the defendant’s status as a police officer as an aggravating factor.The United States Court of Appeals for the Tenth Circuit reviewed the case. It held that the district court did not abuse its discretion in denying the motion for a new trial, as the defendant failed to show reasonable diligence in uncovering the new evidence. However, the appellate court found that the district court plainly erred by relying on the defendant’s occupation as a police officer to justify a harsher sentence. The Tenth Circuit affirmed the denial of a new trial, vacated the sentence, and remanded the case for resentencing without consideration of the defendant’s professional status. View "United States v. Thompson" on Justia Law

Koby Don Williams, a supervisor with U.S. Immigration and Customs Enforcement, was charged with attempted online enticement of a minor after engaging in an undercover operation where he believed he was communicating with a thirteen-year-old girl named “Rebecca.” In reality, “Rebecca” was a persona created by law enforcement. Williams exchanged nearly 100 texts and several phone calls, during which “Rebecca” repeatedly stated her age. Williams negotiated sexual acts and payment, offered to travel with “Rebecca,” and ultimately arranged a meeting, bringing cash, alcohol, and generic Viagra. When arrested, Williams claimed he was conducting a human trafficking investigation.The United States District Court for the Eastern District of Washington presided over Williams’s trial. Williams’s primary defense was that he never believed “Rebecca” was a minor, asserting that he thought he was communicating with an adult. He filed pretrial motions to suppress or authenticate the decoy advertisement and, after conviction, moved for acquittal and a new trial, arguing insufficient evidence and statutory misinterpretation. The district court denied these motions. At sentencing, the court imposed a two-level obstruction-of-justice enhancement under the Sentencing Guidelines, based on Williams’s alleged perjury, without making specific factual findings.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that sufficient evidence supported the conviction for attempted enticement of a minor under 18 U.S.C. § 2422(b), rejecting Williams’s argument that the statute required proof he attempted to “transform or overcome the will” of a minor. The Ninth Circuit also found no plain error in the government’s failure to produce the original decoy advertisement. However, the court vacated Williams’s sentence, concluding the district court erred by not making explicit findings required to support the obstruction-of-justice enhancement, and remanded for resentencing. The conviction was affirmed. View "USA V. WILLIAMS" on Justia Law

The case concerns a defendant who was indicted for sex trafficking minors and faced serious federal charges. Over the course of three years between his indictment and trial, the defendant was represented by five different court-appointed attorneys. He repeatedly refused to cooperate with his lawyers, frequently submitted pro se motions, and violated court orders prohibiting him from contacting victims and witnesses. Twice, after comprehensive hearings in line with Faretta v. California, the defendant knowingly and voluntarily waived his Sixth Amendment right to counsel and elected to represent himself, despite being warned by the judge that no further attorneys would be appointed if he changed his mind again.Throughout the pretrial proceedings, the United States District Court for the Northern District of Illinois patiently allowed several changes in representation, including the appointment of standby counsel. However, when the defendant again requested an attorney during trial, after previously waiving counsel and being warned that further appointments would not be made, the district judge denied the request. After a jury trial, the defendant was found guilty on all counts, and his posttrial motions—including a challenge to the denial of his midtrial request for counsel—were denied.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the district judge abused his discretion in denying the midtrial request for a sixth appointed lawyer. The Seventh Circuit held that, after a valid Faretta waiver, district judges may require a defendant to abide by his choice to proceed pro se, especially if the request for counsel is made after trial has begun. The court further held that there is no constitutional requirement to reassess the defendant’s motives or the likely delay caused by such a request under these circumstances. The judgment of the district court was affirmed. View "USA v Perry" on Justia Law

The case concerns a defendant who was convicted of two counts of aggravated sexual assault against his niece, N.H., based on events that occurred between 2005 and 2011, when N.H. was a child. The charges alleged both oral and penetrative sexual contact. The main evidence at trial included N.H.’s testimony describing multiple assaults, with a focus on specific incidents that occurred in the defendant’s barn, particularly an incident when N.H. was in the sixth grade. N.H. also testified that the assaults stopped when she was around eleven or twelve years old.After the jury convicted the defendant on both counts in the Superior Court, Addison Unit, Criminal Division, the defendant appealed. He argued that there was insufficient evidence to prove that N.H. was under thirteen at the time of the barn assault (Count Two), that the trial court’s jury instruction on reasonable doubt violated his constitutional rights, and that the admission of prior-bad-act evidence was an abuse of discretion. The trial court had previously denied his motion for acquittal on Count Two, finding there was enough evidence for the jury to find him guilty beyond a reasonable doubt.The Vermont Supreme Court reviewed the case. It held that the evidence was sufficient for a reasonable jury to conclude that N.H. was under thirteen at the relevant time, affirming the denial of acquittal. However, the Court determined that the trial court’s instruction defining “beyond a reasonable doubt” as “great certainty” impermissibly lowered the government’s burden of proof, violating the defendant’s federal due process rights. This was deemed plain error, requiring reversal of the convictions and a remand for a new trial. The Court did not address the evidentiary issue regarding prior bad acts. The main holding is that defining “beyond a reasonable doubt” as “great certainty” constitutes plain error warranting reversal and a new trial. View "State v. Kolts" on Justia Law