Justia Criminal Law Opinion Summaries

A fatal traffic collision occurred when Joseph Feghhi, driving at nearly 130 miles per hour, rear-ended another vehicle, resulting in the death of Vanessa Arellano. Law enforcement officers at the scene observed signs of alcohol impairment in Feghhi and conducted field sobriety tests. Feghhi initially refused to submit to a chemical test but later expressed willingness to take a breath test. Officers obtained a search warrant for a blood sample, which was taken over three hours later and revealed a blood alcohol concentration of 0.14 percent. Feghhi was charged with multiple offenses, including murder, gross vehicular manslaughter, and driving under the influence causing injury.A magistrate found sufficient evidence to hold Feghhi to answer on all charges. Feghhi then moved in the Santa Clara County Superior Court to quash and traverse the search warrant and suppress the blood evidence, arguing that the officer’s affidavit omitted his willingness to take a breath test, thereby misleading the magistrate who issued the warrant. The prosecution opposed, contending that probable cause existed regardless of the alleged omission. The trial court granted Feghhi’s motion, concluding that the magistrate would not have issued the warrant had it been aware of Feghhi’s consent to a breath test, and suppressed the blood test evidence.The California Court of Appeal, Sixth Appellate District, reviewed the case after the prosecution sought a writ of mandate. The appellate court held that, even if the officer’s failure to include Feghhi’s willingness to take a breath test was a deliberate omission, correcting the affidavit would not have changed the probable cause analysis or rendered the warrant unreasonable under the Fourth Amendment. The court directed that a peremptory writ of mandate issue, ordering the trial court to vacate its order granting the motion to traverse and suppress, and to enter a new order denying the motion. View "People v. Super. Ct." on Justia Law

The defendant was indicted on six federal charges related to two separate incidents—one on November 18, 2021, and another on June 6, 2022. He was ultimately acquitted of all charges arising from the first incident but convicted on three counts stemming from the June 6 event. On that date, law enforcement arrested him in a parking lot after receiving a tip from a confidential informant. Officers discovered a firearm on the driver’s seat of a car he had just exited, along with substantial quantities of drugs, cash, and items commonly associated with drug distribution. During the trial, the prosecution introduced evidence of a prior firearm conviction after defense questioning “opened the door.” The jury found him guilty on charges of being a felon in possession of a firearm, possessing controlled substances with intent to distribute, and possessing a firearm in furtherance of a drug trafficking crime.The United States District Court for the Middle District of Tennessee denied the defendant’s motions for acquittal, a new trial, and a request to interview a juror who had expressed concerns during deliberations. It also denied claims of ineffective assistance of counsel based on an alleged conflict arising after trial, when one of the defense attorneys briefly represented a crime analyst involved in the case.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the sufficiency of the evidence de novo, the admission of prior conviction evidence for abuse of discretion, and conflict of interest claims de novo for legal conclusions. The appellate court held that sufficient evidence supported all convictions, the district court did not abuse its discretion by admitting the prior conviction, there was no actual conflict of interest affecting trial counsel’s performance, and the district court properly denied post-verdict juror interviews. The Sixth Circuit affirmed the lower court’s judgment. View "United States v. London" on Justia Law

A law enforcement officer conducted a traffic stop of an individual suspected of participating in a series of armed robberies. During the stop, the suspect, D’Juantez Mitchell, did not comply with police orders and drove his vehicle into the officer and toward another officer. In response, the officer shot and killed Mitchell. Mitchell’s estate and children challenged the officer’s use of deadly force, alleging violations of constitutional rights and Kentucky law.The United States District Court for the Western District of Kentucky granted the officer qualified immunity on federal claims brought under 42 U.S.C. § 1983, concluding there was no violation of clearly established federal law. However, the district court denied the officer’s motion for summary judgment on the state-law claims, finding a genuine dispute as to whether the officer acted in subjective good faith, and thus denied Kentucky qualified official immunity.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of qualified official immunity under Kentucky law de novo. The appellate court held that the officer’s use of deadly force constituted a discretionary act under Kentucky law and that the plaintiffs failed to provide evidence sufficient to rebut the presumption that the officer acted in good faith. The court found that neither purported inconsistencies in the officer’s testimony nor affidavits concerning his general racial animus created a genuine issue of material fact regarding his subjective intent during the incident. The court emphasized that the video evidence showed the officer and another were in imminent danger when the vehicle moved, supporting the officer’s stated belief that deadly force was necessary.The Sixth Circuit reversed the district court’s denial of qualified official immunity, holding that the officer was entitled to immunity from the state-law claims. View "Mitchell v. Conrad" on Justia Law

A driver caused a multi-vehicle collision in Las Vegas, during which he struck another vehicle’s trailer, triggering a chain reaction. After the crash, he remained at the scene for around 35 minutes, interacted with several Nevada Highway Patrol officers, provided his identifying information, and stayed until emergency personnel had arrived and begun treating the injured. He was not detained or told to stay by police, but left the scene after medical professionals took over care of the injured. Later, he was charged with reckless driving resulting in substantial bodily harm and violating the duty to stop at the scene of a crash involving personal injury.The Eighth Judicial District Court, Clark County, presided over a jury trial. The jury acquitted the driver of driving under the influence, but found him guilty of reckless driving resulting in substantial bodily harm and violating the duty to stop at the scene of a crash involving personal injury. The district court sentenced him to concurrent prison terms of two to five years for each conviction. The driver appealed both convictions, raising issues including sufficiency of the evidence, constitutionality of the statutes, prosecutorial misconduct, and exclusion of evidence.The Supreme Court of Nevada reviewed the case. It held that Nevada’s duty-to-stop statutes require a driver to stop, provide identification, and render reasonable assistance, but do not require the driver to remain until police formally dismiss them. The court found insufficient evidence to support the duty-to-stop conviction, concluding the driver fulfilled all statutory obligations before leaving. Therefore, it reversed the conviction for violating the duty to stop and affirmed the reckless driving conviction. The court remanded the case to the district court to consider all available sentencing options for reckless driving and to enter an amended judgment of conviction. View "CARTER VS STATE" on Justia Law

A man was convicted in California state court of first-degree murder, rape, and sodomy arising from the 1988 killing of a woman at an apartment lodge where both lived. On the day of the crime, the man consumed large amounts of alcohol and interacted repeatedly with the victim, ultimately assaulting and killing her in her apartment. Physical evidence and the man’s own detailed post-arrest confessions were central to the prosecution’s case; he admitted to deliberating about ensuring the victim’s death after an initial assault. The defense at trial argued intoxication, but the jury convicted him of first-degree murder and found a special circumstance, leading to a death sentence.After the California Supreme Court affirmed the convictions and special circumstances (but reversed a robbery charge), the man pursued state and federal habeas relief. His federal habeas petition alleged, among other things, that the prosecution withheld exculpatory blood-alcohol test results (a Brady claim) and that trial counsel was ineffective for failing to investigate and present additional evidence of intoxication and mental impairment (Strickland claims). The U.S. District Court for the Central District of California initially denied most relief but later set aside the murder conviction and special circumstance finding based on the Brady and Strickland claims.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court. The Ninth Circuit held that under AEDPA’s deferential standards, the California Supreme Court could reasonably have concluded that there was insufficient factual support for the existence of undisclosed blood-alcohol test results and that counsel’s alleged failures did not prejudice the defense. The Ninth Circuit directed the district court to deny habeas relief as to the convictions and special circumstances, remanding solely for resolution of any remaining penalty-phase claims. View "BRADFORD V. VANG" on Justia Law

A woman, A.H., went to the residence of Leif Buck, with whom she shares two children, to discuss a parenting plan. During the visit, Buck became physically aggressive, holding A.H. on the couch and dragging her across the floor. When A.H. stated she would call the sheriff, Buck took her cell phone from her pocket, which prevented her from immediately contacting authorities. A.H. then told Buck she would go to the sheriff’s office, to which Buck responded he would not be present when she returned. A.H. subsequently reported the incident to the sheriff’s office and sought medical attention.Buck was charged with, among other offenses, interfering with the reporting of domestic violence under RCW 9A.36.150. At trial in the Superior Court, the jury was instructed that it could convict Buck if it found he prevented or attempted to prevent A.H. from calling 911, obtaining medical assistance, or making a report to law enforcement. The jury found Buck guilty. On appeal to the Washington Court of Appeals, Division Three, Buck argued that the statute created an alternative means crime, requiring jury unanimity as to the specific means, and cited State v. Nonog, a Division One decision to this effect. Division Three disagreed, holding that the statute did not create alternative means, and affirmed the conviction.The Supreme Court of the State of Washington granted review to resolve conflicting appellate decisions. The Supreme Court held that RCW 9A.36.150(1)(b) defines a single crime—interfering with the reporting of domestic violence—and does not establish three alternative means based on the method of reporting. The Court reasoned that the statute focuses on the defendant’s conduct, not the actions of the victim or witness, and does not present distinct criminal acts. The Supreme Court affirmed Division Three’s decision and expressly overruled the contrary holding in Division One’s Nonog decision. View "State v. Buck" on Justia Law

A jury found the defendant guilty of third-degree rape in September 2020. The circuit court entered a judgment of conviction in January 2021, sentencing him to ten years in the penitentiary with seven years suspended. The defendant did not appeal his conviction or sentence. He was released from the penitentiary on parole in March 2022. In January 2023, while still on parole, the defendant moved for a sentence reduction, requesting a suspended imposition of sentence. The circuit court granted this motion, placing him on probation.The State objected, first moving for reconsideration on the grounds that the circuit court lacked authority to grant a suspended imposition of sentence after a judgment of conviction and that this would improperly remove the defendant from executive supervision. The circuit court denied the State’s motion and entered an order granting the suspended imposition of sentence. The State appealed, but the Supreme Court of South Dakota dismissed the appeal for lack of statutory appellate jurisdiction. The State then filed a motion to correct an illegal sentence, which the circuit court again denied. The State petitioned for a discretionary appeal, which the Supreme Court of South Dakota granted.The Supreme Court of South Dakota held that the circuit court erred in concluding that res judicata barred the State’s challenge, as the State had not previously had an opportunity for appellate review. The Supreme Court further held that neither SDCL 23A-27-19 nor SDCL 23A-31-1 authorized a circuit court to vacate a judgment of conviction in order to grant a suspended imposition of sentence after a sentence has been imposed. Accordingly, the Supreme Court reversed the circuit court’s order suspending the imposition of the defendant’s sentence. View "State v. Pickner" on Justia Law

An eight-year-old girl, A.R., disclosed to her mother that she had been sexually abused by her thirty-year-old half-brother, Tell Cadotte, over a two-year period. After reporting the abuse to the police, A.R. underwent a forensic interview, during which she described the abuse and produced drawings depicting the incidents. Law enforcement obtained a search warrant for Cadotte’s home, where they seized several electronic devices. Forensic examination of these devices revealed over 300 images and videos of child pornography, including multiple pictures that apparently depicted A.R. being abused. Cadotte was charged with multiple counts of first-degree rape and one count of sexual contact with a minor.After a federal conviction for possession of child pornography, Cadotte proceeded to trial in the Circuit Court of the Seventh Judicial Circuit in Pennington County, South Dakota. During trial, defense counsel objected to the admission of certain sanitized photographs, arguing the State had committed a discovery violation by not providing all the images intended for use. The defense also objected to testimony from a detective recounting the victim’s mother’s identification of A.R. in the photographs, claiming it was inadmissible hearsay. The court admitted the evidence, and the jury convicted Cadotte on nine counts of first-degree rape and one count of sexual contact with a minor. The court acquitted him on one rape count for insufficient evidence and sentenced him to seventy years, concurrent with a ten-year term for sexual contact, but consecutive to his federal sentence.On appeal, the Supreme Court of the State of South Dakota held that there was no discovery violation because the State had complied with its statutory obligations, and the defense had access to the evidence in question. The court also held that even if the detective’s testimony was hearsay, its admission was not prejudicial since it was cumulative of other admissible testimony. The convictions were affirmed. View "State v. Cadotte" on Justia Law

Marcus Roland Maye was convicted of robbery with a deadly weapon in May 2002 and received a mandatory life sentence under Florida’s Prison Releasee Reoffender (PRR) statute. He later filed a motion under Florida Rule of Criminal Procedure 3.800(a), arguing that the procedures of the PRR statute were unconstitutional. Specifically, he claimed that the statute allowed a judge, rather than a jury, to make findings that exposed him to a mandatory minimum sentence, in violation of the rules set out in Apprendi v. New Jersey and Alleyne v. United States.The State opposed Maye’s motion, contending that rule 3.800(a) was not the proper procedural mechanism to challenge a statute's constitutionality and that existing district court precedent foreclosed his claim. The circuit court, bound by precedent holding section 775.082(9) constitutional, denied the motion. On appeal, the Sixth District Court of Appeal affirmed the denial, citing the same precedent.Upon review, the Supreme Court of Florida approved the Sixth District’s result but based its decision on a different ground. The court held that claims of error under Apprendi and its progeny (such as Alleyne) are not cognizable under rule 3.800(a) because those claims are subject to harmless error review and do not constitute “illegal sentences” as contemplated by the rule. The court receded from its earlier decision in Plott v. State, which had allowed such claims to be raised under rule 3.800(a). Accordingly, the Supreme Court of Florida ruled that Maye’s Apprendi claim could not be raised in a rule 3.800(a) motion and affirmed the result below on that basis. View "Maye v. State of Florida" on Justia Law

The case centers on an altercation between Khari Alston and his former partner, Fataya Bigesby. On July 18, 2023, outside Ms. Bigesby’s apartment building, Alston snatched her purse from her hands, followed her while demanding attention, pushed her, and eventually threw her purse and remaining contents into a busy street, resulting in the destruction of the items. Some belongings, such as keys and a wallet, were later returned, but the purse and other contents were never recovered. Surveillance footage captured portions of the incident. Ms. Bigesby testified that the event left her feeling harassed and unsafe.The Superior Court of the District of Columbia conducted a bench trial, finding Mr. Alston guilty of second-degree theft and simple assault. The court concluded that Alston had the intent to deprive Ms. Bigesby of her property either when he took her purse or, at the latest, when he threw it into the street. For assault, the court found that taking the property from her constituted an offensive touching. After Alston appealed, the District of Columbia Court of Appeals remanded the record for clarification on the trial court’s findings regarding the timing and nature of Alston’s intent and conduct. The trial court reaffirmed its findings, specifically noting Alston’s intent to permanently deprive Ms. Bigesby of her property, and that his conduct was offensive.Upon review, the District of Columbia Court of Appeals affirmed both convictions. The court held that sufficient evidence supported the theft conviction because the statute covers wrongful use or disposition of property with intent to deprive, which was established when Alston threw the purse into traffic. For assault, the court held that nonsexual offensive touching—such as snatching a purse—constitutes assault without the need to prove intent to cause physical injury. The convictions were affirmed. View "Alston v. United States" on Justia Law