Justia Criminal Law Opinion Summaries

In this case, the defendant was convicted in 2003 of felony murder and aggravated battery following the death of his two-month-old son, based on a diagnosis of Shaken Baby Syndrome (SBS). At trial, the prosecution relied on the then-prevailing medical consensus that a specific triad of symptoms in infants was diagnostic of SBS and indicative of abuse. Years later, the defendant sought a new trial, arguing that significant developments in medical science had undermined the reliability of the SBS diagnosis, and presented new expert testimony suggesting alternative, non-abusive causes for his son’s injuries and death.After the original conviction was affirmed on direct appeal, the defendant filed an extraordinary motion for new trial in the Superior Court of the county of conviction, citing newly discovered evidence in the form of updated expert analysis and medical literature. The trial court initially denied the motion without a hearing, but the Supreme Court of Georgia vacated that decision and remanded for an evidentiary hearing. On remand, after hearing extensive expert testimony from both sides, the trial court again denied the motion, finding that the evidence was not newly discovered, that the defendant had not exercised due diligence, and that the evidence was not material.The Supreme Court of Georgia reviewed the trial court’s decision and held that the trial court failed to apply the correct legal framework in evaluating the extraordinary motion for new trial. Specifically, the Supreme Court found that the trial court erred in its analysis of whether the evidence was newly discovered, whether the defendant exercised due diligence, and whether the new evidence was material. The Supreme Court vacated the trial court’s order and remanded the case for reconsideration under the proper legal standards. View "SMITH v. THE STATE" on Justia Law

Law enforcement in Montana began investigating drug trafficking activities involving shipments from California to Butte. Their investigation led them to a residence where a controlled delivery of a package containing fentanyl was made. After the package was delivered and seized, a cooperating witness, Trevor Handy, identified Eric Ramirez as being involved in drug distribution activities and described his association with the residence and other individuals under investigation. Law enforcement obtained and executed a search warrant at an Airbnb where Ramirez was staying, finding drugs, cash, and a loaded handgun in a bedroom linked to Ramirez by physical evidence, including his DNA. Ramirez was charged with criminal possession with intent to distribute fentanyl, methamphetamine, and heroin.The case proceeded to trial in the Montana Second Judicial District Court, Butte-Silver Bow County. During trial, Ramirez testified that he was merely visiting friends and denied involvement in drug distribution. He requested two jury instructions: one on “mere presence,” arguing that being present at the scene was not enough for conviction, and another on witness accountability, seeking to have the jury view the testimony of the cooperating witness with distrust. The District Court denied both requests, finding that the instructions given already adequately covered the law and Ramirez’s theory of defense. The jury convicted Ramirez on the fentanyl and methamphetamine charges but acquitted him on the heroin charge.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court erred in denying the requested jury instructions. The Supreme Court held that the District Court did not abuse its discretion, as the instructions provided fully and fairly instructed the jury on the applicable law and allowed Ramirez to argue his defense. The Court affirmed the convictions, concluding that Ramirez’s substantial rights were not prejudiced by the denial of the proposed instructions. View "State v. Ramirez" on Justia Law

Four defendants were members of a Detroit-based gang involved in drug distribution and violent crimes, including homicides, during the 1980s and 1990s. They were indicted in 1995 for conspiracy to distribute cocaine and crack cocaine, intentional killings in furtherance of a continuing criminal enterprise, and firearms offenses. Juries convicted all four on all counts in two separate trials. The district court sentenced each to concurrent life terms for the drug and homicide convictions, plus consecutive terms for the firearms offenses, following the then-mandatory Sentencing Guidelines. Their convictions and sentences were affirmed on appeal.Years later, after Congress enacted the Fair Sentencing Act and the First Step Act, which allowed for reduced sentences for certain crack cocaine offenses, the defendants moved for sentence reductions under the First Step Act. The United States District Court for the Eastern District of Michigan initially denied some motions, reasoning that the homicide convictions were not “covered offenses” under the Act. On appeal, the United States Court of Appeals for the Sixth Circuit vacated the denial as to the drug conspiracy count for one defendant, holding he was eligible for a reduction on that count. On remand, the district court reduced the sentences for both the drug and homicide convictions for all four defendants, concluding it had discretion to do so under the First Step Act and the sentencing-package doctrine.The United States Court of Appeals for the Sixth Circuit held that the First Step Act authorizes a district court to reduce a sentence for a non-covered offense only if it was part of a sentencing package with a covered offense. The court vacated the reduced sentences and remanded for the district court to determine whether the homicide sentences were truly part of such a sentencing package with the covered drug offense, and to proceed accordingly. View "United States v. Dale" on Justia Law

Two men were apprehended by the United States Coast Guard in international waters south of Puerto Rico after being observed jettisoning bales of cocaine from a vessel that lacked any indication of nationality. The Coast Guard recovered approximately 306 kilograms of cocaine and eventually transported the men, including the appellant, to St. Thomas in the U.S. Virgin Islands. The government asserted that the men were never brought to Puerto Rico, though the appellant disputed this. A grand jury in the District of the Virgin Islands indicted the appellant on multiple drug trafficking charges under the Maritime Drug Law Enforcement Act (MDLEA), as well as related offenses.The appellant moved to dismiss the indictment for improper venue, arguing that the MDLEA’s “any district” venue provision was unconstitutional and that venue was proper in Puerto Rico, where he claimed he was first brought. He also sought a pretrial evidentiary hearing on venue and the issuance of subpoenas for Coast Guard witnesses. The United States District Court of the Virgin Islands denied these motions, holding that the MDLEA’s venue provision was constitutional and that the Virgin Islands was a proper venue. The court also found that mere passage through Puerto Rico’s territorial waters did not constitute being “first brought” there under 18 U.S.C. § 3238, and denied the request for an evidentiary hearing, finding no colorable factual dispute that would affect the outcome.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s decisions. The Third Circuit held that the MDLEA’s “any district” venue provision is constitutional, both facially and as applied, for offenses committed on the high seas. The court also found that the District Court did not abuse its discretion in denying a pretrial evidentiary hearing on venue. Accordingly, the Third Circuit affirmed the District Court’s orders. View "USA v. Cuevas-Almonte" on Justia Law

Police officers investigating a recent carjacking and kidnapping at an Oklahoma City motel received information from the motel manager that a man matching the suspect’s description was staying in a particular room. Upon arrival, one officer looked through a one-inch gap in the window curtains from an open-air walkway outside the room and saw the defendant, Cameron Watkins, sitting on a bed next to a handgun with an extended magazine. This observation led to Watkins’s arrest and the subsequent discovery of a firearm and ammunition in the room. Watkins was later charged with being a felon in possession of a firearm and, in a superseding indictment, with being a felon in possession of ammunition found at a separate crime scene.The United States District Court for the Western District of Oklahoma denied Watkins’s motion to suppress the evidence, finding that the officer’s observation was made from a public area—the motel’s exterior walkway—which was accessible to other guests and staff, and not part of the room’s curtilage. The court concluded there was no Fourth Amendment violation because the officer did not intrude upon a protected area or the defendant’s reasonable expectation of privacy. Watkins pleaded guilty to the firearm charge, reserving his right to appeal the suppression ruling, and was convicted by a jury on the ammunition charge.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed both convictions. The court held that the officer’s visual observation through the window gap, made from a public walkway using only his unaided senses, did not constitute a search under the Fourth Amendment. The walkway was not curtilage, and the defendant did not have a reasonable expectation of privacy against such observation. The court therefore upheld the district court’s denial of the suppression motion and affirmed the convictions. View "United States v. Watkins" on Justia Law

The case concerns a man who, after being separated from his wife of six months, engaged in repeated and escalating contact with her, including hostile voicemails, text messages, and physically aggressive behavior such as banging on her door and damaging property. After being served with divorce papers, his conduct intensified, including following her, driving by her residence and her mother’s house, and sending threatening messages. One particular text message stated he had “nothing to lose,” would “go back to prison,” and would “die before I go back.” Law enforcement was contacted, and during a recorded conversation with an officer, he again referenced the possibility of returning to prison.The District Court of Sheridan County charged him with felony stalking, based on his conduct and a prior stalking conviction. The prosecution sought to introduce evidence under Wyoming Rule of Evidence 404(b), including the text and recorded statement referencing prison, to show intent, motive, and consciousness of guilt. The district court held a hearing, conducted the required analysis under Gleason v. State, and admitted the text and recorded statement for the stated purposes, while excluding other references to his prior conviction. At trial, the jury found him guilty, and he was sentenced to four to eight years in prison.On appeal, the Supreme Court of Wyoming reviewed whether the district court abused its discretion in admitting the text and recorded statement under W.R.E. 404(b). The court held that the district court properly admitted the evidence, as it was relevant to show intent, motive, and consciousness of guilt, and its probative value was not substantially outweighed by unfair prejudice. The Supreme Court of Wyoming affirmed the conviction. View "Bragdon v. The State of Wyoming" on Justia Law

A sheriff’s deputy in Geary County, Kansas, stopped a vehicle driven by Brian Beck after observing that a license plate frame partially obscured the state name on the plate. Beck was not committing any driving infractions. During the stop, Beck appeared nervous and gave an unusual explanation for his travel route. A canine unit was called, and after the dog alerted, Beck consented to a search of his car, which led to the discovery of over two pounds of methamphetamine. Beck was charged with possession with intent to distribute, possession without a drug tax stamp, and interference with law enforcement. He moved to suppress the evidence, arguing the stop was not supported by reasonable suspicion, but the Geary District Court denied the motion. At trial, Beck renewed his objection, which was again overruled, and a jury convicted him on all counts.On appeal, the Kansas Court of Appeals affirmed the convictions, holding that the partial obstruction of the state name justified the stop under Kansas law, specifically K.S.A. 8-133, which requires license plates to be “clearly visible” and “clearly legible.” The appellate panel reasoned that covering half of the state name violated the statute, regardless of whether the plate could otherwise be identified.The Supreme Court of the State of Kansas reviewed only the statutory interpretation issue. It held that Kansas law does not require the state name to be clearly legible on license plates, except as it appears on registration decals. The court found that the lower courts had misapplied the statute by treating the obscured state name as a violation. The Supreme Court reversed the decisions of both the district court and the Court of Appeals on this issue and remanded the case for further proceedings consistent with its interpretation of the statute. View "State v. Beck " on Justia Law

A police officer with the Metropolitan Police Department in Washington, D.C., was involved in two separate incidents within five days, during which he used neck restraints—specifically, trachea and carotid artery holds—on two individuals while on duty. Both incidents occurred at McDonald’s restaurants, and in each case, the officer initiated physical contact and applied prohibited neck restraints, despite the individuals not posing an immediate threat or actively resisting arrest. The officer was aware that such holds were forbidden by department policy, and in one instance, had been warned about his conduct just days before repeating it.A grand jury indicted the officer on five charges related to these events. Before trial, three charges were dropped. The United States District Court for the District of Columbia conducted a jury trial, after which the officer was convicted on two counts of depriving individuals of their rights under color of law, in violation of 18 U.S.C. § 242. The jury found that the officer acted willfully, used excessive force, and caused bodily injury. The court sentenced him to concurrent six-month prison terms and supervised release. The officer moved for acquittal and a new trial, arguing, among other things, that the jury instructions on willfulness were improper and that the evidence was insufficient. The District Court denied these motions.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the officer’s challenges. The court held that the jury instructions on willfulness were not plainly erroneous, as precedent allows conviction under § 242 for conduct done in reckless disregard of constitutional rights. The court also found sufficient evidence supported the jury’s findings of excessive force and willfulness, and that no impermissible amendment or variance of the indictment occurred. The appellate court affirmed the District Court’s evidentiary rulings and the officer’s convictions. View "USA v. Clark" on Justia Law

The case involved a defendant who was charged with first degree sexual assault of a child, incest with a person under age 18, and tampering with physical evidence. The victim was the defendant’s daughter, who was under 12 years old at the time of the alleged incident. The events in question occurred in the early morning hours, when the child’s mother observed the defendant leaving the children’s bedroom and later questioned her daughter, leading to a disclosure of sexual abuse. The mother examined the child and noticed redness, and the child was subsequently taken to a hospital and a child advocacy center for examination and forensic interviews. The defendant pleaded not guilty, and the case proceeded to a jury trial.The District Court for Douglas County presided over the trial. During the proceedings, the defense objected to certain hearsay testimony and to questions by the prosecution regarding a separate alleged incident of sexual assault. The court overruled some hearsay objections and sustained others, but did not provide limiting instructions or grant a mistrial. The jury found the defendant guilty of first degree sexual assault of a child and incest, but not guilty of tampering with evidence. The court sentenced the defendant to consecutive prison terms within statutory limits. The defendant, represented by new counsel at sentencing, appealed, raising issues including sufficiency of the evidence, evidentiary rulings, prosecutorial misconduct, sentencing, and ineffective assistance of trial counsel.The Nebraska Supreme Court reviewed the case. It held that the evidence was sufficient to support the convictions, as the child’s testimony and corroborating circumstances met the required elements. The court found that any hearsay admitted was cumulative and its admission was harmless beyond a reasonable doubt. Claims of prosecutorial misconduct were reviewed for plain error due to lack of a mistrial motion, and no plain error was found. The sentences were within statutory limits and not an abuse of discretion. The court found the record insufficient to resolve two claims of ineffective assistance of counsel, but rejected the others. The judgment of the district court was affirmed. View "State v. Hagens" on Justia Law

A man was convicted of multiple sexual offenses involving his long-term romantic partner’s daughters. The offenses included three counts against his biological daughter and six counts against his partner’s youngest daughter from a previous relationship. The abuse occurred over several years while the family lived in various residences in the Bay Area. The allegations came to light in 2018 after the mother observed suspicious behavior and questioned her daughters, who then disclosed the abuse. The police were notified, and the children underwent forensic interviews and examinations. The defendant was arrested and charged with several counts, including lewd acts, forcible lewd acts, sexual penetration, and oral copulation with minors under the age of 14 and 10.The case was tried before a jury in the Superior Court of Alameda County. The prosecution presented testimony from the victims, their mother, and expert witnesses on child sexual abuse. The prosecution also introduced evidence of uncharged acts of abuse involving other children in the defendant’s extended family. The defense called character witnesses and challenged the reliability of the victims’ accounts. The jury found the defendant guilty on all but two counts, for which the prosecutor later dismissed the charges after a deadlock. The defendant was sentenced to 54 years to life in prison.On appeal, the California Court of Appeal, First Appellate District, Division Four, reviewed several claims, including alleged errors in jury selection, admission of evidence of uncharged acts, admission of prior statements, prosecutorial misconduct, jury instructions, and expert testimony. The court held that the trial court properly overruled the objection to the prosecution’s peremptory challenge of a Black juror, finding no substantial likelihood that race was a factor. The court also found no abuse of discretion in admitting evidence of uncharged acts, prior statements, or expert testimony, and rejected claims of instructional error and prosecutorial misconduct. The judgment was affirmed. View "People v. Garcia" on Justia Law