Justia Criminal Law Opinion Summaries

A defendant was charged with multiple crimes and tried by jury in Washington County Circuit Court. After the jury was selected but before opening statements, the trial judge provided the jury with written instructions and read them aloud. These initial instructions covered issues such as the presumption of innocence, the state’s burden of proof, a defendant’s right not to testify, and other basic legal principles. The trial court informed the jury that these were “precautionary” instructions and that further instructions would be given after the close of evidence. When the evidence concluded, the court distributed a new set of written instructions but declined to reread several key instructions it had previously given orally at the outset of trial. The defendant objected, specifically requesting that the court reread instructions on the presumption of innocence, burden of proof, and right not to testify, but the court declined, leaving those instructions only in written form.The jury convicted the defendant on all counts. The defendant appealed to the Oregon Court of Appeals, arguing that the trial court’s failure to reread the key instructions at the end of the trial violated Oregon Rule of Civil Procedure (ORCP) 59 B, which requires the court to “state to the jury all matters of law necessary for its information in giving its verdict.” The state countered that the trial court had discretion regarding the timing of jury instructions under ORCP 58 and that any error was harmless because the instructions were provided in writing. The Court of Appeals ruled in favor of the defendant, holding that ORCP 59 B required the trial court to orally restate the necessary legal instructions at the close of trial and that the omission was not harmless.The Supreme Court of the State of Oregon affirmed the decision of the Court of Appeals, reversed the circuit court judgment, and remanded for further proceedings. The court held that ORCP 59 B requires the trial court to orally instruct the jury at the end of trial on all matters of law necessary for its verdict, and that this requirement is not satisfied by earlier oral instructions or written instructions alone. The error was not harmless. View "State v. Shine" on Justia Law

After a long-term romantic relationship began to deteriorate between Elijah Singleton and Ja’Keya Hampton, Singleton stole Hampton’s cellphone and refused to return it. The day before Hampton’s death, the two communicated via Facebook Messenger, arranging to meet so Singleton could return the phone. Hours later, Hampton was found dead in her car from a gunshot wound. Surveillance footage captured the shooting, with audio indicating Hampton called out to Singleton moments before being shot. After the incident, Singleton attempted to elude law enforcement and destroy evidence, but was arrested following a standoff. He was charged with capital murder and a firearm enhancement.During jury selection in the Crittenden County Circuit Court, a prospective juror who worked at the county jail expressed concerns about a conflict of interest in open court, prompting Singleton to move for a mistrial, which was denied. The State exercised peremptory strikes against four Black prospective jurors. Singleton raised a Batson challenge, arguing the strikes were racially motivated. The State provided race-neutral reasons, such as relationships with the victim’s family, perceived reluctance to serve, and inattentiveness. The circuit court credited the State’s reasons, found them race-neutral, and denied the Batson challenge. Singleton was convicted of first-degree murder and employing a firearm, and sentenced as a habitual offender.On appeal, the Supreme Court of Arkansas reviewed Singleton’s claims that the circuit court erred in denying his mistrial motion and his Batson challenge. The court held there was no abuse of discretion in denying the mistrial because the prospective juror’s statement did not prejudice the jury. It further held that the circuit court’s findings regarding the Batson challenge were not clearly against the preponderance of the evidence. The Supreme Court of Arkansas affirmed the convictions. View "SINGLETON v. STATE OF ARKANSAS" on Justia Law

After severely assaulting his mother in December 2017 and causing serious injuries, Akeel Bin-Bellah was charged by the State of Washington with first degree assault. In plea negotiations, the State agreed to reduce the original charge and, in a global agreement that also resolved an unrelated robbery case, Bin-Bellah pleaded guilty to one count of second degree assault and three counts of fourth degree assault, all relating to the same incident. As part of his plea, Bin-Bellah expressly stipulated that each count of assault represented a separate and distinct act, and acknowledged that his plea was knowing and voluntary. The plea arrangement substantially reduced his potential sentence compared to the original charges.Following sentencing in King County Superior Court, Bin-Bellah filed a motion for relief, contending that his multiple assault convictions violated double jeopardy because they all arose from a single criminal act. This motion was transferred to the Washington Court of Appeals, Division One, which granted his personal restraint petition. The Court of Appeals concluded that the record showed only one criminal act, found a double jeopardy violation, vacated the three fourth degree assault convictions, and remanded for resentencing on the remaining count.The Supreme Court of the State of Washington reviewed the case after granting discretionary review. The Supreme Court reversed the Court of Appeals. It held that under Washington’s flexible plea bargaining framework, a defendant may knowingly and voluntarily plead guilty to multiple lesser charges—even if they are legally or factually duplicative—so long as there is a factual basis for the original charge and the plea includes explicit factual stipulations to support the convictions. Because Bin-Bellah’s plea included such stipulations and was knowing and voluntary, his double jeopardy claim was foreclosed. The Supreme Court reinstated all his convictions and dismissed his personal restraint petition. View "In re Pers. Restraint of Bin-Bellah" on Justia Law

The case concerns a noncitizen, a native and citizen of Ecuador, who entered the United States without authorization around 1999. In 2009, he was convicted of reckless assault of a child and sentenced to three years in prison. During removal proceedings in 2010, the immigration judge advised him that his conviction made him ineligible for voluntary departure and offered removal instead. The noncitizen, after confirming his understanding of his rights and waiving his right to counsel and appeal, was removed to Ecuador in 2011. He later reentered the United States without permission and was arrested in 2021. In 2022, he was charged with aggravated illegal reentry.In the United States District Court for the Southern District of New York, the defendant moved to dismiss the criminal information, arguing that recent Supreme Court precedent established he had, in fact, been eligible for voluntary departure at his 2010 hearing, and that the immigration judge’s erroneous advice rendered the proceedings fundamentally unfair. The District Court, relying on prior Second Circuit precedent from United States v. Sosa, excused the defendant’s failure to exhaust administrative remedies and granted the motion to dismiss, finding his waiver of appeal was not knowing and intelligent due to the immigration judge’s mistake.The United States Court of Appeals for the Second Circuit reviewed the case. It held that the Supreme Court’s decision in United States v. Palomar-Santiago made clear that all three requirements of 8 U.S.C. § 1326(d)—exhaustion of administrative remedies, deprivation of opportunity for judicial review, and fundamental unfairness—are mandatory and cannot be excused by courts. Because the defendant failed to exhaust administrative remedies and was not deprived of the opportunity for judicial review, he was barred from collaterally attacking his removal order. The Second Circuit reversed the District Court’s dismissal and remanded the case for further proceedings. View "United States of America v. Mejia" on Justia Law

The case involves Richard Romanyshyn, who was subject to a disorderly conduct restraining order (DCRO) issued in Stark County, North Dakota, which included two minor children as protected parties. Romanyshyn was personally served with the DCRO and did not appeal it. Later, he allegedly violated the order by sending text messages to one or more protected parties. Subsequently, he was charged with violating the DCRO, a class A misdemeanor. Separately, a DCRO was issued against him in Hettinger County involving the same parties, but the North Dakota Supreme Court later reversed that order and remanded for an evidentiary hearing in Davis v. Romanyshyn, 2025 ND 18.After the Supreme Court’s reversal of the Hettinger County DCRO, Romanyshyn moved to dismiss the Stark County criminal charge, arguing that the DCRO in his case was invalid under the Davis precedent. The State responded that the Supreme Court’s decision in the Hettinger County matter did not affect the Stark County DCRO. The District Court of Stark County denied Romanyshyn’s motion to dismiss, finding that his challenge was a legal, not factual, one, and that no evidentiary hearing or factual findings were necessary.On appeal, the Supreme Court of North Dakota reviewed the district court’s denial of the motion to dismiss. The Court held that because Romanyshyn’s argument was purely legal and not dependent on disputed facts, the district court was not required to make factual findings. Further, the Supreme Court determined that the district court did not improperly take judicial notice of adjudicative facts. The Court declined to address the merits of the collateral attack argument because Romanyshyn did not brief the issue. The Supreme Court of North Dakota affirmed the amended criminal judgment. View "State v. Romanyshyn" on Justia Law

The defendant was charged with robbery and reckless endangerment in December 2024 while on parole for a prior conviction. He was arrested on December 18, 2024, did not post bond, and his parole was revoked during his pretrial custody. In June 2025, the robbery charge was amended to aggravated assault, and the defendant pled guilty to both aggravated assault and reckless endangerment. The district court sentenced him to five years for aggravated assault and two years for reckless endangerment, to run consecutively and consecutive to another sentence not at issue. The court did not give the defendant credit for time served in custody between his arrest and sentencing.The District Court of Burleigh County, South Central Judicial District, presided over sentencing. The defendant argued at sentencing that he should receive credit for time served from his arrest, claiming his custody was due to the new charges. The State contended the custody resulted from his parole revocation on a previous conviction. The defendant’s attorney acknowledged the parole was revoked five days after arrest but presented no evidence regarding the timing or application of credit. The district court found the time in custody was due to the parole violation, not the new charges, and denied credit for time served. The defendant appealed the sentence, claiming entitlement to credit and arguing the State bore the burden to prove facts supporting the denial.The Supreme Court of North Dakota reviewed the case. It held that under North Dakota law, the burden is on the defendant to show entitlement to credit for time served, and a defendant is not entitled to credit for time served on an unrelated prior conviction. The court found no abuse of discretion or illegality in the sentence, as it was within statutory limits and based on proper factors. The Supreme Court of North Dakota affirmed the criminal judgment. View "State v. Barse" on Justia Law

The case centers on the death of an individual, Adam, from a mixed-drug overdose. The defendant, a neighbor named Seymour, facilitated the purchase of heroin for Adam, who had a history of opioid addiction but had reportedly avoided heroin for years prior to the incident. On the day in question, Seymour drove Adam to buy heroin, which he consumed after returning home. He was found dead about an hour later. An autopsy revealed that his death was caused by the combined effects of heroin, mitragynine (kratom), methylphenidate, and diphenhydramine. Expert testimony indicated that while all four drugs had a synergistic effect, heroin was the most likely to result in overdose death among them.After a bench trial, Seymour was convicted of involuntary manslaughter, corrupting another with drugs, and heroin trafficking. She appealed only her convictions for involuntary manslaughter and corrupting another with drugs. The Tenth District Court of Appeals reversed those convictions, holding that the state had failed to provide sufficient evidence that the heroin Seymour provided was a but-for cause of Adam’s death, as no witness had testified that heroin alone caused the death.The Supreme Court of Ohio reviewed the sufficiency of the evidence under the correct standard, emphasizing the role of circumstantial as well as direct evidence. The court held that the but-for test for causation does not require proof that the defendant’s conduct alone caused the harm, only that the harm would not have occurred absent the defendant’s conduct. The presence of other contributing causes does not negate but-for causation. The Supreme Court of Ohio reversed the appellate court’s decision and reinstated the trial court’s judgment, finding sufficient evidence that the heroin Seymour provided was a but-for cause of Adam’s death. View "State v. Seymour" on Justia Law

The defendant was convicted of voting in more than one state during the 2016 general election. He maintained residences in both New Hampshire and Massachusetts and was alleged to have voted in Holderness, New Hampshire by absentee ballot and in Belmont, Massachusetts in person. The State introduced evidence of his voting history in both states from 1996 to 2018 and sought to exclude statements by an acquaintance, William Botelho, who had previously admitted to voting in the defendant's name in Massachusetts.The Grafton County Superior Court allowed the State to admit the defendant’s prior voting records under New Hampshire Rule of Evidence 404(b) and excluded Botelho’s statements as inadmissible propensity evidence, also denying the defendant’s request for a Richards hearing regarding Botelho’s potential testimony. After a jury found the defendant guilty, the Superior Court denied his post-trial motions for dismissal based on territorial jurisdiction, judgment notwithstanding the verdict, and to set aside the verdict.The Supreme Court of New Hampshire found that the Superior Court erred in admitting the defendant’s prior voting history because the danger of unfair prejudice substantially outweighed its probative value, especially since the prior alleged acts were nearly identical to the charged crime. The court also held that evidence of Botelho’s confession to voting in the defendant’s name in the 2016 election was not evidence of other bad acts under Rule 404(b) and should not have been categorically excluded. The Supreme Court further ruled that, if Botelho asserts his Fifth Amendment rights on remand, the trial court must hold a Richards hearing.The Supreme Court affirmed the lower court’s denial of the defendant’s motions regarding territorial jurisdiction, sufficiency, and weight of the evidence, but reversed the conviction due to the evidentiary errors and remanded for further proceedings. View "State v. Rosen" on Justia Law

The case concerns Cedric Lamont Berry, who was convicted for his role in the kidnapping and murder of Monique Baugh and the attempted murder of her boyfriend, J.M-M., on December 31, 2019. Berry and his accomplice were indicted on multiple charges, including first-degree premeditated murder, attempted murder, kidnapping, and felony murder. The prosecution presented extensive circumstantial evidence, including surveillance footage, cell-site location data, DNA, and physical evidence, linking Berry to the crimes. A jury found Berry guilty on all counts, and he was sentenced to life in prison without the possibility of release.Following the convictions, Berry appealed to the Minnesota Supreme Court, where his appellate counsel challenged the admissibility of cell-site location information and raised other procedural arguments. The Minnesota Supreme Court affirmed his convictions. Berry then filed a petition for postconviction relief in Hennepin County District Court, acting pro se. He argued that his appellate counsel was ineffective for not raising additional claims, including alleged procedural errors during his initial court appearances, insufficiency of evidence regarding his mental state as an aider and abettor, issues with jury instructions, and trial counsel’s handling of potentially prejudicial conduct by the prosecution.The Hennepin County District Court summarily denied Berry’s postconviction petition without an evidentiary hearing, concluding that even if Berry’s factual allegations were true, they did not entitle him to relief under the standard for ineffective assistance of counsel established in Strickland v. Washington. On appeal, the Minnesota Supreme Court reviewed the district court’s decision for abuse of discretion and the underlying ineffective assistance claims de novo. The Supreme Court held that the district court did not abuse its discretion and affirmed, finding that Berry’s petition did not allege facts that, if proven, would establish ineffective assistance of counsel as a matter of law. View "Berry vs. State of Minnesota" on Justia Law

The case concerns a man who was convicted of killing his girlfriend and her brother. The defendant and the girlfriend had lived together for years, and the girlfriend’s brother moved into their apartment. After neighbors heard shrieking and family received disturbing text messages from the defendant, the bodies of the girlfriend and her brother were discovered in the apartment, wrapped in rugs and placed near an air conditioner that had been set up to slow decomposition. Both victims had been stabbed multiple times. The defendant was later found in Mexico and extradited.At trial in the Superior Court of Los Angeles County, the prosecution charged the defendant with two counts of murder. A central issue was whether the defendant acted with premeditation or in the heat of passion. The defense sought to introduce a handwritten note found at the crime scene in which the defendant admitted to the killings and stated he was filled with rage after allegedly discovering the victims having sex. The trial court excluded the note during the prosecution’s case, ruling its probative value was outweighed by the risk of undue prejudice, but allowed the note when the defendant testified to introduce it himself. The jury convicted him of first degree murder for the girlfriend and second degree murder for the brother.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case. The court held that while there was sufficient evidence for the case to go to the jury, the trial court erred in excluding the note during the prosecution’s case, as the note was highly probative of the defendant’s state of mind and the theory of provocation. The appellate court found this error was prejudicial because it likely affected the verdict, especially regarding the degree of murder. The judgment was reversed, and the trial court was directed to vacate the convictions and set the matter for a new trial. View "People v. Tzul" on Justia Law