Justia Criminal Law Opinion Summaries

On May 29, 2003, two Blaine County Sheriff’s deputies responded to a domestic disturbance involving Laurence Dean Jackson Jr. in Harlem, Montana. During a pursuit through a field, both deputies were shot; Deputy Rutherford died from a gunshot wound to the chest, and Deputy Janis was severely injured. Jackson, claiming an alcohol-induced blackout, could not recall the events, leaving Janis as the sole eyewitness. At trial, the State relied on Janis’s testimony and physical evidence to argue that Jackson shot both deputies after a struggle. Jackson’s defense presented expert testimony challenging the State’s account, including a theory that the fatal bullet may have been fired by Janis, not Jackson.Following a 17-day trial in October 2004, Jackson was convicted of deliberate homicide and attempted deliberate homicide, receiving life sentences without parole. The Montana Supreme Court affirmed his conviction in 2009, and the U.S. Supreme Court denied certiorari in 2010. In 2011, Jackson filed a petition for postconviction relief in the Seventeenth Judicial District Court, Blaine County, alleging ineffective assistance of counsel. The District Court allowed for additional evidence and expert review but ultimately denied the petition without an evidentiary hearing, finding Jackson’s claims lacked specific factual support as required by Montana law.The Supreme Court of the State of Montana reviewed whether the District Court abused its discretion by denying Jackson’s petition without a hearing. Applying the Strickland v. Washington standard, the Court held that Jackson failed to present established facts showing deficient performance or prejudice by counsel. The Court found Jackson’s claims speculative and unsupported by the record, concluding the District Court acted within its discretion. The Supreme Court affirmed the denial of postconviction relief. View "Jackson v. State" on Justia Law

The defendant, who had been receiving disability insurance benefits due to a medical diagnosis, operated a jewelry business while collecting these benefits. The Social Security Administration (SSA) began investigating after suspecting that the defendant was earning income that could affect his eligibility. The SSA asked the defendant whether he had worked or received income since his diagnosis, to which he responded negatively. However, evidence showed that he had significant gross income from jewelry sales, and the SSA determined that his countable income likely exceeded regulatory caps, making him ineligible for benefits. The defendant was subsequently charged with taking government property and making false statements.The United States District Court for the District of New Mexico presided over the trial. The government presented evidence of substantial gross income and efforts by the defendant to conceal earnings. The defendant did not provide information about business expenses that could have reduced his countable income. The jury convicted him on multiple counts related to theft of government property and false statements. At sentencing, the district court calculated the loss amount, including benefits paid to the defendant’s children and payments made outside the charged period, resulting in a 15-month prison sentence.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that the evidence was sufficient for a reasonable jury to find that the defendant’s countable income exceeded the regulatory caps, even without detailed expense information, given the high gross income and lack of contrary evidence. The court also found no reversible error in the jury instructions, as the defendant failed to timely challenge the district court’s reasoning. Regarding sentencing, the court held that it was proper to include reasonably foreseeable payments to the defendant’s children and payments outside the charged period in the loss calculation. Any error in including Medicare premiums was deemed harmless. The convictions and sentence were affirmed. View "United States v. Sandoval" on Justia Law

A confidential informant reported seeing Anthony Miller, known as “Thugsy,” carrying a handgun and selling drugs in Wilmington, Delaware. Police surveilled the area, observed Miller, and attempted to arrest him. Miller fled, resisted arrest, and was subdued. Officers recovered a loaded handgun and drugs, including pills that tested positive for MDMA and cocaine. Miller admitted to selling MDMA and possessing the firearm. He was initially indicted by a New Castle County grand jury for several offenses, including Drug Dealing MDMA (a Class B felony). A subsequent reindictment changed the main drug charge to Drug Dealing Methamphetamine (a Class C felony), reflecting the actual substance involved.Before his suppression motion was heard, Miller entered a plea agreement in the Superior Court of the State of Delaware, pleading guilty to Drug Dealing Methamphetamine, Possession of a Firearm During the Commission of a Felony, and Resisting Arrest. Due to clerical errors, the plea paperwork and colloquy incorrectly identified the drug dealing charge as a Class B felony with a higher sentencing range, even though the court read the correct substance and quantity from the reindictment. Miller was sentenced to a total of seven years of unsuspended prison time. He did not seek to withdraw his plea but appealed, arguing that his constitutional right to be indicted by a grand jury was violated because he pled guilty to an unindicted, more serious offense.The Supreme Court of the State of Delaware reviewed the case for plain error, as Miller had not raised the issue below. The court held that Miller’s substantial rights were not affected because he received significant benefits from the plea, including immediate sentencing and avoidance of a much longer potential sentence. The court found no plain error and affirmed the conviction, but remanded to the Superior Court to consider Miller’s pending motion for sentence reduction. View "Miller v. State" on Justia Law

In this case, the defendant was charged with abusive sexual contact of a minor in Indian Country, based on conduct that occurred between 1998 and 2000, when the victim was approximately 15 or 16 years old. The victim reported the abuse to the FBI in 2021, stating that she had previously disclosed it to a therapist at a rape crisis center, but no action was taken at that time. The alleged abuse took place within the Navajo Nation, and the defendant did not contest his status as an enrolled member of the Navajo Nation or the location of the offense.The United States District Court for the District of New Mexico denied the defendant’s motion to dismiss the superseding indictment, which argued that the prosecution was barred by the statute of limitations. The district court found that the extended statute of limitations for sexual offenses against children under 18, as set forth in 18 U.S.C. § 3283, applied to the case. The defendant then entered a conditional guilty plea to a lesser offense—abusive sexual contact in Indian Country—reserving his right to appeal the statute of limitations issue.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed de novo whether the categorical approach or a case-specific analysis should be used to determine the applicability of § 3283’s extended statute of limitations. The court held that the categorical approach, typically used in sentencing and immigration contexts, does not apply to pretrial statute of limitations challenges under § 3283. Instead, a case-specific approach is appropriate, focusing on the facts and charges in the indictment. The court concluded that the offense charged involved the sexual abuse of a minor, so § 3283’s extended limitations period applied. The Tenth Circuit affirmed the district court’s denial of the motion to dismiss. View "United States v. Tso" on Justia Law

Late one night, a homeowner called 911 to report that her security camera showed a Black man and woman taking items from her back porch. Within minutes, a police officer arrived and encountered Michael Campbell near the reported location. Campbell claimed to live at the residence and was uncooperative with the officer’s instructions, repeatedly dropping his hands and reaching for his wallet despite being told not to. The officer noticed what appeared to be a gun magazine in Campbell’s waistband and, after a brief exchange, frisked Campbell, discovering a firearm and a knife. Campbell was subsequently indicted for being a felon in possession of a firearm.The United States District Court for the Western District of Oklahoma denied Campbell’s motion to suppress the firearm, finding that the officer had reasonable suspicion to detain and frisk Campbell and that this suspicion had not dissipated before the frisk. Campbell was convicted at trial. At sentencing, the district court determined that Campbell’s five prior Oklahoma armed robbery convictions qualified as violent felonies under the Armed Career Criminal Act (ACCA), subjecting him to a 15-year mandatory minimum sentence. Campbell was sentenced to 240 months, above the statutory maximum for the felon-in-possession offense but below the Guidelines range.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s denial of the suppression motion and upheld the constitutionality of the felon-in-possession statute. However, the Tenth Circuit held that Oklahoma armed robbery can be committed with a reckless state of mind and therefore does not categorically qualify as a violent felony under the ACCA’s elements clause. The court vacated Campbell’s sentence and remanded for resentencing, while affirming his conviction. View "United States v. Campbell" on Justia Law

Law enforcement officers stopped an individual for a traffic violation and, during the stop, discovered a small amount of cocaine and marijuana in his vehicle, along with over $23,000 in cash hidden in various locations. After his arrest, the individual admitted to law enforcement that he had purchased and distributed controlled substances and that about half of the seized money was from drug sales, with the remainder allegedly from a 401k and insurance settlement. A subsequent search of another vehicle he owned, prompted by his statements, led to the discovery of additional drugs and over $31,000 in cash. In total, $54,226 was seized. The individual was charged with and pled guilty to two counts of misdemeanor possession of a controlled substance.The State of Wyoming initiated a civil forfeiture action in the District Court of Carbon County, seeking to forfeit the seized currency under the Wyoming Controlled Substances Act. The State alleged the money was either proceeds from drug sales or intended to facilitate further violations of the Act. After a bench trial, the district court ordered the forfeiture of the currency, applying a preponderance of the evidence standard to determine that the money was subject to forfeiture. The individual appealed, arguing that the district court applied the wrong burden of proof and improperly considered offenses beyond those for which he was convicted.The Supreme Court of Wyoming held that the district court erred by applying the preponderance of the evidence standard rather than the statutorily required clear and convincing evidence standard to determine whether the currency was subject to forfeiture. The court reversed the forfeiture order and remanded for further proceedings under the correct standard. The court also clarified that, in forfeiture proceedings, the district court may consider violations of the Wyoming Controlled Substances Act beyond the specific offenses for which the individual was arrested or convicted. View "In the Matter of U.S. Currency Totaling $54,226.00" on Justia Law

A father was charged with multiple offenses after his daughter reported that he had sexually assaulted her repeatedly over many years, with the earliest incident she could recall occurring when she was in second grade. The prosecution focused on three specific incidents of sexual assault that took place when the victim was sixteen, each on a different date and in different locations. The victim provided detailed testimony about these three incidents, and additional evidence included an audio recording made by the victim during one of the assaults. After the victim disclosed the abuse to her mother, law enforcement became involved, and a grand jury indicted the defendant on nine counts: three counts each of gross sexual assault, domestic violence assault, and endangering the welfare of a child, each set corresponding to one of the three incidents.The case proceeded to a jury trial in the Sagadahoc County Unified Criminal Docket. The jury initially reported a partial deadlock but, after receiving a standard instruction for deadlocked juries, returned guilty verdicts on all nine counts. At sentencing, the court grouped the charges by incident date, imposed concurrent sentences within each group, and ordered the groups to run consecutively, resulting in an aggregate sentence of twenty-seven years, with all but seventeen years suspended and three years of probation. The defendant appealed both his convictions and his sentence, arguing that the trial court erred by not giving a specific unanimity instruction to the jury and by double counting the multiplicity of assaults during sentencing.The Maine Supreme Judicial Court reviewed the case and affirmed the judgment. The Court held that a specific unanimity instruction was not required because each count was tied to a distinct incident on a specific date, and the jury instructions sufficiently ensured unanimity. The Court also held that the sentencing court did not err by considering the number of assaults at different points in its analysis, as this was consistent with established sentencing practices and did not constitute impermissible double counting. View "State v. Chase" on Justia Law

Brandon Williams was charged with multiple crimes, including two counts of malice murder, following the deaths of Natalie Nation and her son, Cole Nation. Williams lived with his father and Natalie, while Cole sometimes stayed with them. On the night of the incident, witnesses heard Williams yelling threats at Natalie, including statements like “I’m going to kill all of you.” Later, Williams’s father found Natalie and Cole unconscious in Natalie’s room, with a towel tied around Natalie’s neck. Both victims died from asphyxia, and Cole also suffered blunt-force trauma. Williams was arrested at a nearby gas station, and his DNA was found on the towel used in the crime.After a jury trial in the Superior Court of Gwinnett County, Williams was found guilty on all counts. He was sentenced to consecutive life sentences without parole for the malice murder convictions. The trial court merged the remaining counts with the malice murder counts, though the felony murder counts were vacated by law and the cruelty to children count should not have merged. Williams’s motion for a new trial was denied, and he appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Williams’s claim that the trial court erred by admitting a hearsay statement under the residual hearsay exception. The statement, made by Natalie to a friend, described a prior incident in which Williams had choked her. The Supreme Court held that the trial court did not abuse its discretion in admitting the statement, finding it met the requirements of trustworthiness, materiality, and probative value under OCGA § 24-8-807. The Supreme Court of Georgia affirmed Williams’s convictions. View "Williams v. State" on Justia Law

A group of teenagers and young adults devised a plan to rob and murder a man, Justin McKinney, and his girlfriend, Anna Franklin, as revenge for a drug-related incident involving one of the conspirators’ brothers. On the night of the crime, several of the group entered the victims’ home, where one participant shot and killed McKinney, and another shot and wounded Franklin. The group then fled, disposed of weapons, and made incriminating statements. Franklin survived and identified some of the assailants. Physical evidence, including firearms and shell casings, corroborated the events described by witnesses and participants.After the incident, several co-defendants pleaded guilty, while one was tried separately. The appellant, who was a juvenile at the time, was tried by a jury in the Superior Court of Fannin County and found guilty on all counts, including malice murder, attempted murder, and related offenses. He was sentenced to life in prison plus additional consecutive and concurrent terms. The trial court denied his motion for a new trial.The Supreme Court of Georgia reviewed the case. The appellant argued that his custodial statements should have been suppressed due to his age, learning disability, and other factors; that the trial court erred by modifying a pattern jury instruction to include “age” as a factor not to influence the jury; and that a post-incision autopsy photograph was improperly admitted. The Supreme Court of Georgia held that the trial court did not err in admitting the custodial statements, as the totality of the circumstances showed a knowing and voluntary waiver of rights. The Court also found no plain error in the jury instruction and no abuse of discretion in admitting the autopsy photograph. The convictions and sentences were affirmed. View "Hill v. State" on Justia Law

Two defendants were convicted by a jury of felony murder and related offenses after a fatal shooting outside a game room. The incident involved a physical altercation between the victim and the defendants, during which the victim was shot multiple times and his cell phone was taken. Eyewitnesses placed the defendants at the scene, described a fight immediately preceding the shooting, and identified one defendant as the shooter. DNA evidence linked one defendant to the victim, and both defendants gave inconsistent statements to investigators. The prosecution also introduced evidence of gang affiliation and suggested a motive related to the victim’s cooperation with law enforcement.The case was tried in the Superior Court of Emanuel County, where the jury found both defendants guilty on most counts. The trial court sentenced them to life imprisonment and denied their motions for new trial, except as to the gang-related charge, which the court found was not supported by sufficient evidence. The court’s rationale for reversing the gang conviction barred retrial on that count, and the State entered a nolle prosequi for it. The defendants appealed, challenging the sufficiency of the evidence, the admission of certain testimony, and the denial of their motions for directed verdict and new trial.The Supreme Court of Georgia reviewed the appeals. It held that the evidence, viewed in the light most favorable to the verdicts, was sufficient for a rational jury to find both defendants guilty beyond a reasonable doubt, including as parties to the crimes. The Court found no error in the admission of prior inconsistent statements or in the trial court’s handling of the gang evidence. The Court also determined that the trial court properly exercised its discretion in denying the motions for new trial on the general grounds. The convictions were affirmed, except for the gang-related count, which was not at issue on appeal. View "Bostic v. State" on Justia Law